On March 31, 2025, FinCEN issued an Alert on bulk cash smuggling and repatriation by Mexico-based Transnational Criminal Organizations (TCOs). The Treasury, alongside FinCEN, is urging financial institutions to be vigilant in identifying and reporting transactions potentially related to the cross-border smuggling of bulk cash from the United States into Mexico and the repatriation of bulk cash into the U.S. and Mexican financial systems by these Mexico-based criminal organizations.
The Alert highlights one of several typologies that TCOs use to launder illicit proceeds generated in the United States through the cross-border movement of cash and how these operations enable the TCOs to place, layer, and integrate their illicit proceeds into the United States and Mexican financial systems where they can be accessed again to fund their criminal enterprises.
The Alert also provides red flag indicators for Depository Institutions to help detect, prevent, and report suspicious activity connected to the cross-border bulk cash movements, as follows:
A large volume of cash is delivered to a U.S.-based financial institution via an ACS on behalf of a customer who operates a Mexico-based business, a business located near the U.S. southwest border, or a U.S.-based company with an affiliated Mexico-based business. Following the delivery, the customer then rapidly moves the funds to a financial institution based in Mexico, makes transfers to another business in the United States they own and operate, or purchases a large volume of goods.
Large volumes of cash are transported by an ACS or passenger vehicles to an U.S.-based MSB located along the southwest border and rapidly transferred to Mexico.
A customer that owns a Mexico-based business, or a customer with an affiliated Mexico-based business, receives a large credit from a U.S.-based ACS into their account at a U.S.-based financial institution.
A customer that owns a Mexico-based business receives a large credit into their account at a U.S.-based financial institution after depositing bulk cash into the U.S.-based financial institution’s vault at a U.S.-based ACS secure storage facility.
A customer that owns a Mexico-based business receives a large cross-border wire transfer to their account at a U.S.-based financial institution from a Canada-based financial institution.
Read FinCEN’s news release here.
The full Alert can be found here.