FinCEN Targets Mexico Casinos Tied to Sinaloa Cartel Money Laundering

The US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has taken decisive action to disrupt the financial flows supporting the Sinaloa Cartel by identifying transactions involving ten Mexico-based gambling establishments as being of primary money laundering concern. Published on 13 November 2025, the finding and accompanying Notice of Proposed Rulemaking (NPRM) represents a significant escalation in efforts to sever criminal organisations’ access to the US financial system.

In collaboration with the Government of Mexico, FinCEN proposes to prohibit covered financial institutions from opening or maintaining correspondent banking accounts if those accounts are used to process transactions connected to the named establishments. These include casinos operating in Sonora, Sinaloa, Baja California and Tabasco, all of which are assessed as being ultimately controlled by a criminal group with deep operational links to the Sinaloa Cartel. By restricting correspondent banking channels, FinCEN aims to choke off the ability of these venues to move funds into, through or out of the United States.

According to FinCEN, senior leadership within these casinos have, for years, facilitated the layering and integration of illicit proceeds for the cartel. Activities included sending payments to senior cartel figures and following detailed instructions designed to bypass anti money laundering controls within financial institutions. The move leverages the authority of section 311 of the USA PATRIOT Act, which enables Treasury to impose special measures when classes of foreign transactions are deemed to pose a primary money laundering threat.

This action forms part of a coordinated strategy, launched in parallel with sanctions imposed by the Office of Foreign Assets Control against individuals responsible for laundering narcotics proceeds on behalf of the cartel. Together, these measures underscore a broader push to increase pressure on transnational criminal organisations exploiting international financial channels.

Implications for financial institutions

FinCEN’s NPRM does not introduce any new Suspicious Activity Report (SAR) obligations. However, institutions are encouraged to consider the heightened money laundering risk associated with transactions involving the identified gambling establishments. Where SARs are filed, FinCEN requests that firms reference “FIN-311-Gambling-Establishments” in both Field 2 and within the narrative. This will support more effective targeting and trend analysis across the sector.

The announcement also highlights the continued relevance of FinCEN’s whistleblower incentive programme, which rewards individuals who provide actionable information leading to enforcement actions resulting in monetary penalties exceeding 1,000,000 dollars. This includes potential future cases arising from violations of the proposed special measures, once a final rule is issued.

A decisive move in the fight against money laundering

For financial crime and compliance professionals, this development reinforces the critical importance of transactional monitoring, correspondent banking oversight and the identification of high-risk jurisdictions and business models. Casinos, particularly those operating in regions dominated by organised crime, remain attractive channels for the concealment and movement of illicit proceeds.

FinCEN’s intervention sends a clear message that gambling establishments linked to cartel activity will be aggressively targeted. By tightening the perimeter around the US financial system, Treasury aims to reduce the ability of the Sinaloa Cartel to exploit legitimate banking infrastructure to sustain its operations. For banks and other covered institutions, this is another reminder of the essential role they play in protecting financial stability and national security.

Read the press release here.