Overview

• FinCEN issued an Advisory and a Financial Trend Analysis on August 28 instructing banks, brokers and other firms to intensify monitoring for Chinese money laundering networks used by Mexico-based drug cartels.
• Analyzing 137,153 Bank Secrecy Act reports from 2020 to 2024, the agency identified roughly $312 billion in suspicious activity linked to suspected CMLN operations.
• Guidance highlights red flags such as accounts opened by people listing occupations like student, housewife, retiree or laborer that show large unexplained volumes, as well as possible use of counterfeit PRC passports and complicit bank insiders.
• FinCEN reported significant exposure in real estate with $53.7 billion flagged across 17,389 reports and cited 83 adult and senior day care centers in New York associated with $766 million in suspicious flows.
• Treasury described a cartel–CMLN exchange driven by Mexican dollar restrictions and Chinese capital controls, and coverage contrasted these fiat-based volumes with far smaller illicit crypto estimates.