While other agencies have seemed to slow down a bit, FinCEN has not. On March 31st, it issued an Alert (FIN-2025-Alert001) on “Bulk Cash Smuggling and Repatriation by Mexico-Based Transnational Criminal Organizations”.
The Alert discusses transactions potentially related to the cross-border smuggling of bulk cash from the United States into Mexico and its repatriation into the United States and Mexican financial systems by Mexico-based TCOs. 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.
On April 1st, it also issued an Advisory (FIN-2025-A001) on “Financing of the Islamic State of Iraq and Syria (ISIS) and its Global Affiliates”.
…to assist financial institutions in identifying and reporting suspicious activity related to the financing of the Islamic State of Iraq and Syria (ISIS). The Advisory highlights how ISIS and its global affiliates fund themselves and receive financial support from sympathizers internationally and describes several typologies ISIS uses to transfer money between its affiliates. The Advisory also provides red flags that may assist financial institutions in identifying related suspicious activity.
If you are a member of our AML/CFT Membership Group, we will be discussing these alerts. They also relate directly to some things we covered in the March and February meetings. Here’s a sample along with information on a recent OFAC Alert (“International Cartels Designated as Foreign Terrorist Organizations…”).
If you are not a member of the AML/CFT group, you are missing out and we hope you join us soon!
Published
2025/04/16
