FinCEN Alert on Oil Smuggling Schemes

On May 1st, FinCEN issued an Alert (FIN-2025-Alert002) urging …financial institutions 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…Fuel theft in Mexico has become …the most significant non-drug illicit revenue source for the Cartels…, as it helps sustain their global criminal enterprises and drug trafficking operations.

The Alert provides some red flags for small U.S.-based oil and natural gas companies which could indicate involvement in an oil smuggling scheme. A few of these include:

  • A customer is a small U.S.-based oil and natural gas company, importing company, or freight company operating in states on the U.S. southwest border with transactional activity and profit margins that exceed the typical business profile of similar companies in their industries.
  • A customer is a small U.S.-based oil and natural gas company that is receiving domestic and international wire transfers for invoices related to the sale of crude oil but sending wire transfers to Mexican or U.S. companies for invoices for the purchase of waste oil or other hazardous materials.
  • A customer is a U.S. company that is the ultimate consignee of purchases of waste oil or other hazardous materials but is registered to a residential address.

FinCEN requests that financial institutions reference this Alert by including the key term “FIN-2025-OILSMUGGLING” in SAR field 2 (Filing Institution Note to FinCEN) and the narrative.

We will be discussing this Alert in more depth during our AML/CFT Membership Group meeting. Be sure to join us!

Published
2025/05/15

Emily Riley

Emily joined Banker’s Compliance Consulting with past roles that include Compliance Officer, CRA Officer, Flood Specialist and head of the Mortgage Department at a community Bank. Though some may find it a bit mundane, Emily enjoys reading regulations – often in the middle of the night when the insomnia kicks in. Emily has a heart for compliance and loves to see others succeed. Emily and her husband have two children, two dogs, and two birds. Though Emily has numerous hobbies (some of which include motorcycles (Harley Davidson), piecing quilts, and reading) her favorite thing is to spend time with her husband, children, and family.

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