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The US Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued a new alert warning financial institutions about bulk cash smuggling and repatriation operations conducted by Mexico-based Transnational Criminal Organizations (TCOs). 

The advisory  how these cartels launder illicit proceeds through cross-border cash payments and urges financial institutions including banks and payments firms to strengthen their compliance efforts.

“Mexico-based TCOs generate vast sums of illicit proceeds that they launder through a number of schemes, such as bulk cash smuggling and repatriation operations highlighted in this Alert,” said FinCEN Director Andrea Gacki in a media statement. 

“The United States has zero tolerance for the TCOs’ activities and Treasury, to include FinCEN, is working aggressively to counter these violent organizations. This Alert supports Treasury’s continuing mission to counter TCOs and their illicit activities, and financial institutions are a critical partner in that effort.”

The alert is part of the US government’s broader strategy under , which formally designates certain cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs). 

The threat from cash smuggling

FinCEN’s move reflects growing concerns over the influence of criminal networks that pose significant threats to US national security.

According to the regulator, bad actors are leveraging money service businesses (MSBs) to transmit funds under the guise of legitimate transactions.

“TCOs utilize the cover of Mexico-based businesses to repatriate formerly smuggled bulk cash into the United States via foreign and domestic armored car services (ACSs) and air transport,” the alert says. 

“This bulk cash is then delivered by an ACS to a U.S. financial institution, typically a depository institution or money services business (MSB), and either deposited into accounts that are owned by the Mexico-based businesses or transmitted by the MSBs on behalf of the Mexico-based businesses.”

The alert reminds banks, credit unions and MSBs of compliance requirements under the Bank Secrecy Act (BSA) that obligate them to report suspicious activity. 

FinCEN advises institutions to flag transactions associated with these schemes using the key term “FIN-2025-BULKCASH” in their suspicious activity reports (SARs).

The advisory also lists red flags for financial institutions, such as large cash deposits from businesses linked to Mexico without clear justification, the rapid movement of funds between US and Mexican accounts, and Mexico-based businesses that use ACSs or international wire transfers to move large sums.

The FinCEN alert is part of a broader enforcement push, following recent penalties against financial service providers facilitating these operations. 

For example, in February 2025,  imposed a civil money penalty against Brink’s Global Services USA, Inc. for its role in transporting millions in cartel-linked cash.