Mexican Transnational Criminal Organizations Targeted with New FinCEN Alert
With U.S. efforts to combat illicit fentanyl and drug smuggling at their southern border in full swing, yet another decisive blow was recently swung by a prominent American regulator to better protect the interests of the American public through improved financial awareness. Last week, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a rare “critical alert” addressing the pervasive issue of bulk cash smuggling and repatriation, particularly on behalf of Mexico-based Transnational Criminal Organizations (TCOs). This alert, titled FIN-2025-Alert001, urges financial institutions across the United States to elevate their vigilance against illicit activities of this variety which often fuel the operations of violent cartels and threaten national security.
FinCEN acts as the central financial intelligence agency of the United States, one tasked with collecting, analyzing, and disseminating financial information in furtherance of law enforcement investigations and prosecutions. Since the bureau’s inception in 1990, FinCEN has played a major role in the U.S. government’s efforts to combat transnational organized crime, doing so by providing investigative support to law enforcement, intelligence, and
regulatory agencies both domestically and abroad. Their latest alert zeroes in on a sophisticated laundering typology employed by TCOs: the smuggling of bulk cash – generally of the illicit variety – from the United States into Mexico. This practice is then followed by the reinvestment of these funds into the financial systems of both nations through a number of avenues, laundering the funds in the process while the identity of those behind these activities remains concealed. This process allows TCOs to “place, layer, and integrate” their illicit proceeds – generated primarily from drug trafficking and other criminal enterprises – back into legitimate financial channels. Once laundered, these funds become readily accessible to sustain and expand their operations, perpetuating a vicious cycle of crime and violence.
“Mexico-based TCOs generate vast sums of illicit proceeds that they launder through a number of schemes, such as bulk cash smuggling and repatriation operations highlighted in this Alert,” said FinCEN Director Andrea Gacki in a statement accompanying the release. She emphasized the Treasury’s unwavering stance: “The United States has zero tolerance for the TCOs’ activities,” underscoring FinCEN’s aggressive efforts to dismantle these networks. Gacki also highlighted the pivotal role of financial institutions as partners in this mission, calling on them to leverage the alert’s insights to detect and report suspicious activities.
The alert outlines specific methodologies used by TCOs, including the physical transportation of cash across borders and the use of intermediaries to deposit funds into U.S. and Mexican banks. The alert reads:
“The first step in the cycle of bulk cash smuggling involves moving illicit funds from the United States into Mexico. The smuggled illicit cash, which U.S. law enforcement estimates could average at least hundreds of thousands of USD daily, is usually packaged and concealed to avoid law enforcement scrutiny and to avoid U.S. currency
reporting requirements at the border. It is typically transported on an individual’s person, or in privately owned vehicles or commercial tractor-trailers by individuals complicit in Cartel operations. Individuals organizing the smuggling of cash may be cash couriers, financial supply chain specialists, or ‘currency handlers’ employed by
Cartels. Additionally, the use of private aircraft by TCOs to smuggle bulk cash is an increasing trend whereby TCOs establish shell companies to purchase and register aircraft to circumvent certain U.S. aviation regulations. Once smuggled, the cash is then delivered to complicit businesses located in Mexico near the southwest border of
the United States; these businesses may have active operations and activities or they may be shell companies with little to no commercial activity.”
From there, the bulk cash is repatriated from Mexico to the U.S. via both air and land-based transport. Cash has also been found to move from Mexico to Canada before entering the U.S., with Mexican businesses delivering the bulk cash to flights departing from Mexico to Canada. From here, Canada-based armored car services (ACS) retrieve the funds from the aircraft and transport them south across the U.S.-Canadian border, where they are transferred to a U.S. based ACS who may transport them further to be stored in a U.S.-based financial institution or to a secure storage facility for future disbursement. In many cases, these funds are moved through multiple armored car services to different locations across the U.S. to further obfuscate the paper trail before finally being deposited into U.S. banking accounts. FinCEN also adds that some ACSs even offer services where the value of the bulk cash is credited, rather than physically delivered, to a financial institution for deposit. In these instances, an ACS may “purchase” the bulk cash from the customer and credit the customer’s U.S. bank account for the value of the bulk cash.
The process is completed once the wire transfers or other funds transfers are made between the depository institution in the U.S. to its final resting location in a Mexican financial institution. These funds are often then used to purchase goods domestically or in other countries that can later be resold in Mexico or elsewhere as part of trade-based money laundering schemew to further launder the funds.
FinCEN’s alert provides a detailed list of red flag indicators – such as unusual cash deposits, rapid cross-border wire transfers, and transactions involving high-risk jurisdictions – to aid domestic financial service providers in identifying potential illicit activity of this variety. Under the U.S. Bank Secrecy Act (BSA), covered institutions are required to file Suspicious Activity Reports (SARs) when such patterns and red flags are identified, which bolsters FinCEN’s ability to track and disrupt these operations. The initiative against this form of illicit finance aligns with broader national priorities, supporting two of the eight Anti-Money Laundering and Countering the Financing of Terrorism goals set by the U.S. government. It also complements Executive Order 14157, signed to designate certain cartels as Foreign Terrorist Organizations and Specially Designated Global Terrorists, reflecting the administration’s commitment to safeguarding American communities and the stability of the global financial system.
FinCEN’s alert is the latest in a series of advisories aimed at curbing TCO revenue streams, a testament to its ongoing campaign against the financial infrastructure supporting organized criminal activity. Targeted financial institutions under this initiative include those operating in casino businesses, depository institutions, insurance companies, money services businesses, mortgage brokers, precious metals and jewelry dealers, and securities and futures firms. Covered entities are now urged to review and follow the reporting parameters highlighted within this memo. As TCOs continue to adapt their laundering tactics, this alert serves as both a warning and a call to action, reinforcing the critical partnership between the government and the private sector in the fight against transnational crime.
The latest FinCEN alert can be ready in its entirety here.
Citations
“FinCEN Alert on Bulk Cash Smuggling and Repatriation by Mexico-Based Transnational Criminal Organizations.” Financial Crimes Enforcement Network Alert, U.S. Department of the Treasury, 31 Mar.2025.