FinCEN fines Brink’s $37 million for violating BSA/AML

Treasury’s financial crimes enforcement unit on Thursday said it has fined Brink’s Global Services USA Inc. $37 million over “willful violations” of the Bank Secrecy Act (BSA) and its implementing regulations in connection with its movement of funds across the Southwest border.

“As a result of Brink’s failures, hundreds of millions of dollars in bulk currency shipments were transmitted across the Southwest Border on behalf of high-risk entities – including a Mexican currency exchanger that later pleaded guilty to violating the BSA,” the Financial Crimes Enforcement Network (FinCEN) said.

In Thursday’s consent order, FinCEN said that Brink’s willfully violated the BSA by:

• failing to register with FinCEN as a money services business (MSB);
• failing to develop, implement, and maintain an effective AML program; and
• failing to file suspicious activity reports.

FinCEN said Brink’s will also be subject to an AML program review.

FinCEN said this was its first enforcement action against an armored company.

Thursday’s order points to a 2014 administrative ruling that provided certain exceptions from MSB registration requirements for armored car companies, but it said none of those applied to Brink’s. It also said Brink’s was aware of its obligation to register as an MSB.

FinCEN Announces $37,000,000 Civil Money Penalty Against Brink’s Global Services USA, Inc. for Violations of the Bank Secrecy Act