FinCEN Names Mexican Casinos Operating on Behalf of Sinaloa Cartel As Primary Money Laundering Concern
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) – the bureau tasked with collecting and analyzing financial information to combat domestic and international money laundering and terror financing activity – recently took decisive action against Mexico’s notorious Sinaloa Cartel, designating various transactions involving 10 Mexico-based gambling establishments tied to the group as a class of transaction of “primary money laundering concern” under Section 311 of the USA PATRIOT Act. FinCEN issued a finding and notice of proposed rulemaking (NPRM) announced on November 14, 2025 which aims to sever the access of these establishments to the U.S. financial system by prohibiting American banks from processing any and all transactions linked to them. The measure will also require U.S. financial institutions to apply special due diligence to their correspondent banking accounts to better defend against the misuse of such accounts to process transactions involving any of the identified enterprises.
Over recent years, the U.S. federal government has targeted an increasingly significant network of criminal activity linking Chinese criminal organizations and Mexico-based drug cartels, with this relationship ultimately facilitating the laundering of ill-gotten proceeds from drug trafficking, human trafficking, fraud, and other criminal activities. The illicit returns from this alliance have been staggering, with analysts estimating that the proceeds from the activity bred from this relationship have topped $300 billion between January 2020 and December 2024 alone. Utilizing precursor materials created by and smuggled in from China and other countries and later distributing the drugs in the form of pills often disguised as prescription opioid medications such as Xanax, Oxycodone or Percocet, Mexican agents operating on behalf of the Sinaloa Cartel have been able to infiltrate the United States defenses to sell these narcotics. In return for their services and providing these precursor materials for synthesis, Chinese entities receive significant amounts of money previously laundered by Mexican shell companies, or they receive the dirty cash itself which they ultimately clean through the international financial system. To avoid detection throughout this process, the vehicles of choice for exchanging funds by Mexican and Chinese criminal networks have grown to include a number of outlets, most notably cryptocurrencies and casinos.
As such, both the U.S. and Mexican government have honed in on the latter in their latest efforts to thwart financial crime. The targeted gaming establishments identified in FinCEN’s notice include Emine Casino in San Luis Río Colorado, Casino Mirage in Culiacán, five Midas Casino locations across Sonora, Sinaloa, and Baja California, Palermo Casino in Nogales, and two Skampa Casinos in Ensenada and Villahermosa.1 Each of these respective entities are accused of being controlled by a sprawling criminal network that launders drug proceeds for the Sinaloa Cartel, one of the world’s most powerful drug trafficking organizations. The Sinaloa Cartel, responsible for trafficking massive quantities of fentanyl, cocaine, and methamphetamine into the U.S., has long exploited legitimate businesses to clean the illicit proceeds of their destabilizing activities. Given their high cash volumes and cross-border clientele, casinos have proven ideal vehicles to facilitate such schemes.
Since taking office, President Trump has taken the offensive against narco-cartels fueling the opioid crisis seen across America and significantly contributing to the growth of cross-border crime. In February, the Trump Administration levied unprecedented designations against eight of Latin and Central America’s most prominent cartels and transnational criminal organizations, naming the Sinaloa Cartel amongst its other counterparts as foreign terror organizations (FTO’s). The Administration has also begun to carry out highly-controversial targeted airstrikes against vessels transporting illicit narcotics throughout Latin America. The latest move, while more conservative, is expected to help constrict the various financial channels that serve as a lifeline for more widely-recognized cartels to continue their illicit activity. With respect to the new actions, evidence collected by the federal government shows senior casino leadership at the aforementioned establishments received explicit instructions from cartel operatives on evading anti-money laundering (AML) detection systems, while also actively making illicit payments to high-ranking cartel members.
The NPRM itself follows years of bilateral U.S.-Mexico coordination to facilitate the identification of the involved parties, this in spite of elevated tensions found between the leadership of the two countries since the start of 2025. Mexican authorities have intensified their own respective operations in this regard of late, seizing cartel assets and arresting key facilitators over recent months. FinCEN Director Andrea Gacki emphasized the partnership: “Treasury and the Government of Mexico have been coordinating to safeguard our financial institutions from the Sinaloa Cartel and its illicit financial activities”1, adding that the Treasury will continue to target the financing of transnational criminal organizations to protect the integrity of the U.S. financial system. Concurrently, the Treasury’s Office of Foreign Assets Control (OFAC), targeting the Hysa Organized Crime Group and numerous Mexico-based gambling establishments involved in cartel-related money laundering and a slew of other criminal activities across Mexico and Europe, sanctioned a total of 27 individuals and entities related to these investigations.
Under the new measure, domestic financial institutions are not required to file new Suspicious Activity Reports (SARs), but are encouraged to flag relevant transactions using the code “FIN-311-Gambling-Establishments.” The proposed rule, open for public comment for 30 days after Federal Register publication, represents the fifth special measure under Section 311 – the most severe available to FinCEN. If finalized, the rule would force foreign banks to choose between servicing these casinos or maintaining U.S. correspondent accounts – effectively isolating the establishments from dollar-based transactions.
As the opioid crisis claims hundreds of thousands of American lives annually – largely driven by cartel-supplied fentanyl – the financial chokehold slowly being established underscores a critical front in the broader fight against global narco-trafficking.
Citations
- “FinCEN Combats Financial Support to the Sinaloa Cartel by Finding Transactions Involving 10 Mexico-Based Gambling Establishments to Be of Primary Money Laundering Concern.” Financial Crimes Enforcement Network, U.S. Department of the Treasury, 14 Nov. 2025.