FinCEN Alert on Oil Smuggling Schemes

On May 1^st, 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