The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued a new alert urging money services businesses (MSBs) to heighten scrutiny of cross-border funds transfers that may be linked to individuals without legal status in the United States. The move forms part of a broader federal effort to prevent the misuse of the U.S. financial system for money laundering, terrorist financing, and other illicit activities connected to cross-border crime.
In the alert, FinCEN calls on MSBs to be vigilant in detecting, identifying, and reporting suspicious transactions involving the movement of funds across U.S. borders, particularly where such transfers may involve illegally obtained income or unlawful employment by illegal aliens. Treasury officials said the guidance is aimed at disrupting financial flows that may be exploited by criminal networks, including human smuggling and trafficking organizations operating across borders.
The alert aligns with Executive Order 14159, Protecting the American People Against Invasion, issued earlier this year, which describes illegal immigration as posing “significant threats to national security and public safety.” The executive order underscores the government’s priority to dismantle cross-border human smuggling and trafficking networks, many of which rely on informal or low-value financial transfers to move proceeds discreetly.
FinCEN’s action also builds on a series of measures taken in 2025 to address risks associated with cross-border financial activity, particularly transactions that benefit Mexico-based transnational criminal organizations (TCOs). Several of these groups have recently been designated as Foreign Terrorist Organizations, intensifying regulatory and enforcement focus on their financial lifelines.
Earlier this year, FinCEN issued Geographic Targeting Orders (GTOs) requiring MSBs in specific counties and ZIP codes along the U.S. southwest border—covering parts of Arizona, California, and Texas—to file Currency Transaction Reports at thresholds lower than standard requirements. These orders were designed to capture patterns of suspicious cash activity near border regions known to be vulnerable to smuggling and cartel-related operations. FinCEN noted, however, that certain MSBs under the jurisdiction of federal courts in California and Texas are currently exempt from these requirements due to court orders.
The agency has also released multiple alerts and advisories highlighting related threats, including bulk cash smuggling and repatriation schemes, oil smuggling operations tied to Mexican cartels, and the growing use of Chinese money laundering networks to move and clean illicit proceeds for TCOs.
Against this backdrop, the scale of legitimate cross-border transfers remains substantial. According to the Bureau of Economic Analysis, personal remittances sent by U.S. resident immigrants to recipients abroad exceeded $72 billion in 2024. While FinCEN emphasized that the vast majority of these transfers are lawful and provide essential financial support to families overseas, it warned that similar low-dollar, high-volume transactions have historically been exploited by malign actors to finance terrorism, drug trafficking, and other criminal activity.
Under existing regulations, MSBs are generally required to file a Suspicious Activity Report (SAR) for transactions of $2,000 or more when they know, suspect, or have reason to suspect that the funds are linked to a possible violation of law or regulation. This includes cross-border transfers involving funds derived from unlawful employment or other illicit sources connected to illegal aliens.
To support enforcement and data analysis, FinCEN has instructed financial institutions to include the SAR key term “FIN-2025-Alert003” in both the filing institution note and the narrative section of any SAR related to this alert.
Treasury officials said the guidance is intended not to impede legitimate remittances, but to ensure that MSBs play a critical role in safeguarding the financial system from abuse. As cross-border criminal networks grow increasingly sophisticated, regulators say effective monitoring and timely reporting by frontline financial institutions remain essential to protecting U.S. national security and financial integrity.
For more details, refer to the attached PDF.
By FCCT Editorial Team
