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Home Compliance and Risk

FinCEN issues guidance on Mexico-based criminal organizations, ISIS

April 1, 2025
Reading Time: 1 min read
ABA urges FinCEN to reevaluate BOI collection burden on banks

The Financial Crimes Enforcement Network this week issued an alert for financial institutions on bulk cash smuggling and repatriation by Mexico-based transnational criminal organizations, or TCOs. It also issued an advisory on reporting suspicious activity related to the terrorist organization ISIS.

The alert discusses transactions potentially related to the cross-border smuggling of bulk cash from the U.S. into Mexico and its repatriation into U.S. and Mexican financial systems by Mexico-based TCOs, according to FinCEN. It provides an overview of methodologies associated with these operations, highlights red flag indicators, and reminds financial institutions of their reporting requirements under the Bank Secrecy Act.

The advisory is meant to help financial institutions in identifying and filing suspicious activity reports related to the ISIS financing. The document highlights how ISIS and its global affiliates fund themselves and receive financial support from sympathizers internationally and also describes several typologies ISIS uses to transfer money between its affiliates.

Tags: Anti-money launderingBank Secrecy ActFinCENSanctions
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