FinCEN Exposes Organised Crime Cash Loop: Banks Urged to Act

The United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued a powerful new alert highlighting how Mexico-based organised crime or Transnational Criminal Organisations (TCOs) are exploiting bulk cash smuggling and repatriation schemes to launder illicit proceeds. This alert, issued in support of Executive Order 14157, underscores a coordinated crackdown on organised crime and international cartels that threaten public safety, national security, and the stability of the Western Hemisphere.

These TCOs generate vast sums of illicit revenue in the United States, primarily through drug trafficking and other organised criminal activities. The proceeds are smuggled in bulk cash across the border into Mexico and then reintroduced into both Mexican and US financial systems using a complex mix of seemingly legitimate businesses, armoured transport services, and air cargo. These activities form part of a wider money laundering typology that enables cartels to place, layer, and integrate dirty money, making it appear legitimate and accessible for reinvestment into criminal operations.

FinCEN Director Andrea Gacki emphasised the urgency:

"The United States has zero tolerance for the TCOs’ activities, and Treasury, including FinCEN, is working aggressively to counter these violent organisations. Financial institutions are a critical partner in that effort."

The alert provides detailed methodologies used by cartels, highlights red flag indicators of suspicious activity, and reinforces financial institutions’ obligations under the Bank Secrecy Act. Key indicators include unusually high cash deposits near the US–Mexico border, inconsistent business activity patterns, and unexplained use of armoured transport or air freight.

This latest advisory complements previous FinCEN products aimed at countering TCO-related revenue streams and aligns with two of the eight national Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) priorities. In parallel, the Treasury’s Office of Foreign Assets Control (OFAC) designated six individuals and seven entities tied to a Sinaloa Cartel-linked money laundering network, reaffirming the strategic focus on dismantling financial enablers of organised crime.

Financial institutions now face a clear directive: move beyond passive compliance to active disruption. Proactive monitoring, enhanced due diligence, and robust reporting are essential to identifying and dismantling these illicit financial flows. In today’s global financial landscape, complacency is not an option.

Read the press release here. The full alert is available online at FIN-2025-Alert001