Notices providing “red flags” to help financial institutions identify and report potential bulk cash smuggling across the U.S.-Mexico border and financing of ISIS were issued this week by the Financial Crimes Enforcement Network (FinCEN), Treasury’s financial crimes enforcement arm.
The two notices, FinCEN noted, are consistent with anti-money laundering and countering the financing of terrorism (AML/CFT) priorities established under the Bank Secrecy Act (BSA).
The ISIS financing “advisory” was issued Tuesday and shows a special focus on the funding of “homegrown violent extremist” (HVE) activity, such as the 2025 New Year’s day attack in New Orleans (a U.S. citizen from Texas drove a car bearing an ISIS flag into a crowd, then opened fire on law enforcement). The advisory provides a list of 11 “red flag” indicators financial institutions may use to identify potential efforts to fund such activity. (Don’t be fooled by the heading for that section, which reads “Red Flag Indicators Related to the Procurement of Fentanyl Precursor Chemicals and Manufacturing Equipment”).
FinCEN asks that institutions submitting suspicious activity reports (SARs) on monetary transactions potentially related to such activity reference Tuesday’s advisory by including the key term “ISIS-2025-A001” in SAR field 2 (Filing Institution Note to FinCEN) and the narrative and select SAR field 33(a) (Terrorist Financing-Known or suspected terrorist/terrorist organization) and include the term “ISIS” in the text box.
On Monday, FinCEN issued an “alert” focusing on bulk cash smuggling across the U.S.-Mexico border by Mexico-based transnational criminal organizations (TCOs). “In this particular typology, TCOs smuggle, launder, and repatriate bulk cash through a process involving Mexican businesses, usually with locations near the U.S. southwest border,” the alert notes. It details ways in which TCOs use 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. “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,” it notes.
Monday’s alert provides 10 “red flag” indicators of potential suspicious activity. In it, FinCEN asks that financial institutions submitting related SARs reference the alert in SAR field 2 (Filing Institution Note to FinCEN) and the narrative by including the key term “FIN-2025-BULKCASH” and select SAR field 36(z) (Money Laundering – Other) and include the term “BULKCASH” in the text box.
Leave a Reply