- See 31 U.S.C. § 5312(a)(2); 31 CFR § 1010.100(t).
- On May 1, 2025, OFAC sanctioned three Mexican nationals and two Mexico-based entities that are linked, directly
or indirectly, to CJNG’s fuel theft and oil smuggling operations on the U.S. southwest border. See Treasury, “Treasury Targets Major Mexican Cartel Involved in Fentanyl Trafficking and Fuel Theft” (“OFAC May 2025 Designation”) (May 1, 2025).
- Pemex is Mexico’s national, state-owned oil and natural gas company. Its operations include: crude production (i.e.,
drilling crude oil from reservoirs); refining crude oil into gasoline, diesel, and other fuel; and the storage and distribution of fuel across Mexico. Historically, Pemex held a monopoly on the Mexican oil and natural gas industry. After reforms to the energy sector in 2013, the Government of Mexico ended Pemex’s monopoly and began allowing private sector investment and competition in the industry. However, Pemex continues to play a significant role in the Mexican oil and natural gas industry. See generally U.S. Department of Commerce, International Trade Administration, “Mexico Country Commercial Guide – Oil and Gas” (Nov. 5, 2023); Pemex, About Pemex.
- See DEA, “2024 National Drug Threat Assessment” (May 24, 2024), pp. 10 and 15.
FIN-2025-Alert002 May 1, 2025
FinCEN Alert on Oil Smuggling Schemes on the U.S.
Southwest Border Associated with Mexico-Based Cartels The U.S. Department of the Treasury’s (Treasury) Financial Crimes Enforcement Network (FinCEN), in coordination with Treasury’s Office of Foreign Assets Control (OFAC) and the U.S. Drug Enforcement Administration (DEA), Federal Bureau of Investigation (FBI), and Homeland Security Investigations (HSI), is issuing this Alert to urge financial institutions1 to be vigilant in detecting, identifying, and reporting suspicious activity connected to the smuggling of stolen crude oil from Mexico across the U.S. southwest border into the United States by the Jalisco New Generation Cartel (CJNG), Sinaloa Cartel, Gulf Cartel, and other Mexico-based transnational criminal organizations (TCOs) — frequently known as the “Cartels.” In recent years, fuel theft in Mexico, including crude oil smuggling, has become the most significant non-drug illicit revenue source for the Cartels and enables them to sustain their global criminal enterprises and drug trafficking operations into the United States. This Alert is being issued in coordination with an OFAC sanctions action.2 According to U.S. law enforcement authorities, the Cartels are using complicit Mexican brokers in the oil and natural gas industry to smuggle and sell crude oil stolen from Mexico’s state-owned energy company, Petróleos Mexicanos (Pemex),3 to complicit, small U.S.-based oil and natural gas companies (hereafter “U.S. importers”) operating near the U.S. southwest border. Through these schemes, the Cartels are stealing billions of dollars of crude oil from Pemex, fueling rampant violence and corruption across Mexico, and undercutting legitimate oil and natural gas companies in the United States.4