FinCEN Issues Warning on High-Risk Cross-Border Migrant Transfers

FinCEN has issued a new alert highlighting the growing financial crime risks associated with cross-border funds transfers conducted by illegal migrants within the United States. The alert, published on 28 November 2025, urges money services businesses to strengthen controls and heighten vigilance around remittances that may involve illicitly obtained funds, particularly where indicators point to unlawful employment or other criminal activity.

The Treasury emphasises that MSBs have a legal duty to submit suspicious activity reports for transactions of 2,000 dollars or more where there is knowledge or reasonable suspicion of criminal conduct. This includes cross-border transfers financed through illicit earnings made inside the United States. The alert aligns with Executive Order 14159, Protecting the American People Against Invasion, reinforcing the government’s focus on safeguarding the financial system from misuse by individuals who may also pose broader security risks.

For compliance teams, the announcement underscores the importance of robust customer due diligence, enhanced monitoring of high-risk remittance corridors, and the proactive identification of suspicious behavioural patterns. As financial crime typologies evolve, MSBs must ensure their controls are sufficiently agile to detect and report transfers linked to illegal migrant activity, preventing the flow of criminal proceeds across borders.

Read the press release here.