On November 28, 2025, FinCEN issued a significant alert (FIN-2025-Alert003) urging financial institutions, particularly Money Services Businesses (MSBs) to sharpen their monitoring of cross-border transfers potentially linked to individuals without lawful U.S. status. The alert points to a typology where illicit proceeds, such as those derived from unauthorized employment, are funneled abroad through seemingly low-risk channels. While such transfers are often low in value and high in volume, FinCEN warns they may form part of broader illicit financial activity, including human smuggling, drug trafficking, or terrorist financing networks.
This alert represents a strategic evolution in regulatory expectations, shifting attention from high-value transfers to low-dollar transactions that may have outsized risk implications. In practice, FinCEN is calling on MSBs and related financial entities to strengthen customer due diligence, refine monitoring rules to flag activity around the $2,000 SAR threshold, and ensure proper filing procedures are in place, including the use of “FIN-2025-Alert003” in SARs. Importantly, FinCEN underscores that lawful remittances should not be disrupted; the focus is on detecting and reporting activity with clear red flags or patterns suggestive of illicit behavior.
AFC Group recommends that financial institutions undertake a prompt and targeted review of their cross-border activity, with particular attention to customer segments and jurisdictions that may intersect with elevated risk profiles. Institutions should prioritize reassessing relevant corridors, ensuring alignment between risk exposure and current control frameworks. It is essential that compliance teams are adequately trained to recognize the specific red flags outlined in the FinCEN alert, including transaction structuring, discrepancies in employment data, and remittances directed to high-risk jurisdictions. Equally important is the capability of existing monitoring systems to escalate and document transactions that, while falling below traditional thresholds, may present material compliance concerns due to contextual risk factors.
Read the FinCEN Alert here: FIN-2025-Alert003