FinCEN Alert on Cross-Border Funds Transfers Involving Illegal Aliens (FIN-2025-Alert003)

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1. 31 C.F.R. § 1010.100(ff).
2. See 31 C.F.R. § 1010.100(w).
3. As used in this Alert, “illegal aliens” does not include: (1) U.S. citizens or nationals; (2) lawful permanent residents of
   the United States; (3) aliens whose presence in the United States is authorized by a visa or other permission to legally enter and remain in the United States and have not exceeded their authorization to remain in the United States; or (4) aliens whose employment in the United States is authorized by statute or regulation or who are otherwise specifically authorized to be employed in the United States.
4. Executive Order 14159, Protecting the American People Against Invasion, 90 FR 8443 (issued Jan. 20, 2025; published Jan.
   29, 2025).
5. Executive Order 14157, Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially
   Designated Global Terrorists, 90 FR 8439 (issued Jan. 20, 2025; published Jan. 29, 2025); Department of State, Foreign Terrorist Organization Designations of Tren de Aragua, Mara Salvatrucha, Cartel de Sinaloa, Cartel de Jalisco Nueva Generacion, Carteles Unidos, Cartel del Noreste, Cartel del Golfo, and La Nueva Familia Michoacana, 90 FR 10030 (Feb. 20, 2025).
6. FinCEN, Issuance of a Geographic Targeting Order Imposing Additional Recordkeeping and Reporting Requirements on Certain
   Money Services Businesses Along the Southwest Border, 90 FR 12106 (Mar. 14, 2025); FinCEN, Geographic Targeting Order Imposing Recordkeeping and Reporting Requirements on Certain Money Services Businesses Along the Southwest Border, 90 FR 43557 (Sept. 10, 2025). In accord with applicable court orders, MSBs under the jurisdiction of the U.S. District Court for the Southern District of California as well as certain Texas-based MSBs have not been, and are not currently, required to submit information to FinCEN pursuant to these Geographic Targeting Orders. FIN-2025-Alert003 November 28, 2025 FinCEN Alert on Cross-Border Funds Transfers Involving Illegal Aliens The U.S. Department of the Treasury’s (Treasury) Financial Crimes Enforcement Network (FinCEN) is issuing this Alert to urge money services businesses (MSBs)1 to be vigilant in detecting, identifying, and reporting suspicious activity connected to cross-border funds transfers2 involving illegal aliens, i.e., individuals without legal status in the United States.3 FinCEN is issuing this Alert as part of the U.S. Department of the Treasury’s effort to prevent the exploitation of the U.S. financial system by illegal aliens seeking to move illicitly obtained funds, including by moving those funds across the border. This Alert is also consistent with Executive Order 14159, Protecting the American People Against Invasion, which notes that illegal aliens “present significant threats to national security and public safety” and highlights the need to “dismantle cross-border human smuggling and trafficking networks.”4 FinCEN has taken multiple steps this year to highlight the risks involved with cross-border financial activity, particularly transactions that benefit Mexico-based cartels, several of which have been designated as Foreign Terrorist Organizations.5 Earlier this year, FinCEN issued Geographic Targeting Orders requiring MSBs located in certain counties and ZIP codes along the southwest border in Arizona, California, and Texas to file Currency Transaction Reports (CTRs) with FinCEN at a lower-dollar threshold than standard CTR reporting requirements.6 Additionally, FinCEN Suspicious Activity Report (SAR) Filing Request:
   FinCEN requests that MSBs reference this Alert by including the key term “FIN-2025-Alert003” in SAR field 2 (Filing Institution Note to FinCEN) and the narrative.