FinCEN Exchange on Cartel Financing: UK Compliance Implications

On 10 August 2026, the US Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) convened law enforcement agencies and financial institutions in San Francisco for an information-sharing engagement on cartel activity. The session was led by Gene Lange, performing the duties of the Under Secretary for Terrorism and Financial Intelligence, alongside FinCEN Deputy Director Jimmy Kirby, and covered case studies, typologies and suspicious activity associated with cartel networks. It was the third event in the Combating and Obstructing Money Movements Associated with Narcotics and Drug Trafficking Organizations (COMMAND) series, which sits under the FinCEN Exchange programme — a statutorily authorised voluntary public-private partnership established in 2017 and codified within the Anti-Money Laundering Act of 2020.

The COMMAND series supports Executive Order 14157, which provides for the designation of cartels and other organisations as foreign terrorist organisations (FTOs) and specially designated global terrorists (SDGTs). Eight groups were designated on that basis, including Tren de Aragua, Mara Salvatrucha (MS-13), the Cártel de Sinaloa, and the Cártel de Jalisco Nueva Generación (CJNG), with the Cartel de los Soles subsequently designated as an SDGT in July 2025.

For UK-regulated firms, the immediate point of divergence is legal rather than operational. None of these organisations is proscribed under Schedule 2 to the Terrorism Act 2000, and the proscribed list as at December 2025 comprised 84 international groups, with the most recent additions being Palestine Action, Maniacs Murder Cult and the Russian Imperial Movement. UK institutions therefore do not engage the fundraising, use and possession, funding arrangements, money laundering or disclosure offences at sections 15 to 19 of the Act in respect of cartel-linked funds. Exposure instead runs through the Proceeds of Crime Act 2002 and the Money Laundering Regulations 2017, supplemented by indirect US risk where there is a dollar-clearing, correspondent or US-branch nexus — OFAC has itself flagged the enhanced sanctions and criminal exposure attaching to material support for the designated cartels.

That asymmetry has practical consequences for list management. Firms screening against the UK Sanctions List will not see the FTO or SDGT status reflected, and reliance on a UK-only screening posture will not surface counterparties whose exposure sits entirely on the US side. Where a group entity, payment corridor or client relationship touches US jurisdiction, the FTO overlay materially changes the risk calculus for relationships that would otherwise be assessed as ordinary predicate-offence risk.

The engagement model itself is also worth noting. The FinCEN Exchange rests on a statutory footing that permits structured typology exchange between agencies and industry; the UK equivalent is the Joint Money Laundering Intelligence Taskforce (JMLIT), hosted by the National Crime Agency (NCA), operating alongside the direct information-sharing gateways introduced by the Economic Crime and Corporate Transparency Act 2023. Firms with transatlantic operations should ensure typologies surfaced through one channel are being fed into financial crime risk assessments on both sides.

FinCEN has directed institutions to its published alerts, advisories and financial trend analyses for current cartel-related indicators. These remain a useful calibration input for UK typology work, notwithstanding the absence of a corresponding UK designation.