09.05.25
Continuing U.S. Enforcement Targeting of Cartels and Related Support
On August 28, 2025, the Financial Crimes Enforcement Network (FinCEN) issued Advisory FIN-2025-A003 and an accompanying Financial Trend Analysis to alert U.S. financial institutions of the significant and escalating threat posed by Chinese money laundering networks (CMLNs).
The first component, Advisory FIN-2025-A003, urges vigilance in detecting and reporting CMLN activity, outlines key typologies, and provides detailed red-flag indicators. The second, a Financial Trend Analysis, distills five years of Bank Secrecy Act data to illustrate the scope, channels, and sectors most vulnerable to CMLN exploitation.
Key Notes
- The U.S. government continues to enhance a multi-pronged enforcement approach targeting cartels and related money laundering.
- FinCEN is increasing its focus on money laundering networks involving Chinese companies supporting fentanyl production and drug cartels. Sanctions of foreign banks by FinCEN may increase.
- Companies should review international banking arrangements for risk that banks may be sanctioned by FinCEN.
- Companies should ensure that their third-party due diligence adequately addresses these money laundering and cartel risks.