WASHINGTON–The Financial Crimes Enforcement Network (FinCEN) is reporting that “red flag” notices designed 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.
Agency spokesperson Ary Paglairizes said the two notices are consistent with anti-money laundering and countering the financing of terrorism (AML/CFT) priorities established under the Bank Secrecy Act (BSA).
According to FinCEN, the ISIS financing “advisory” 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 agency noted).
The advisory provides a list of 11 “red flag” indicators financial institutions may use to identify potential efforts to fund such activity.
Reference Requested
FinCEN said FI submitting suspicious activity reports (SARs) on monetary transactions potentially related to such activity should reference the 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.
Bulk Cash Smuggling
Separately, 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,” FinCEN said in the alert.
The alert also includes details around how 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,” the alert states.
More Red Flags
The alert on Bulk Cash also provides 10 “red flag” indicators of potential suspicious activity, and FinCEN is asking FIs filing related SARs to 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.
