Overview

• FinCEN issued an advisory and a Financial Trend Analysis directing U.S. financial institutions to identify and report Chinese money laundering networks used by Mexico-based drug cartels, including activity linked to fentanyl proceeds.
• From January 2020 through December 2024, banks filed 137,153 BSA reports associated with suspected CMLN activity totaling roughly $312 billion.
• Treasury outlined red flags for customer profiles, urging banks to scrutinize accounts with unexplained wealth or refusals to provide source-of-funds information, including those listing occupations such as student, housewife or retiree.
• Investigators detailed laundering methods that include trade-based schemes, mirror transactions and money mules, along with recruiting complicit bank employees and using counterfeit Chinese passports to open accounts.
• Sector risks flagged in the analysis include more than $53.7 billion in suspicious real-estate activity and about $766 million tied to 83 adult and senior day care centers in New York, with links also noted to fraud, human trafficking and human smuggling.