On the highways south of the Rio Grande, armored trucks carry more than legitimate payrolls. In early 2025, FinCEN issued an alert warning that cartel-linked bulk cash smuggling networks are using Mexico-based shell companies and legitimate businesses as staging grounds. Once placed into accounts in Mexico, those same U.S. dollars are repatriated into the U.S. banking system under the cover of routine commerce.
This is not just a typology. It is a reminder that the same criminal organizations driving fentanyl into U.S. communities are equally adept at moving money back out. They are doing it quickly, at scale, and through regulated institutions that often do not realize they are part of the cycle.
FinCEN’s alert outlines a methodical laundering process. It begins with illicit proceeds from drug trafficking, human smuggling, and other high-revenue crimes. These funds are physically moved across the border into Mexico. The transport is often hidden in commercial shipments, personal vehicles, or small aircraft. Once in Mexico, the money is deposited into bank accounts controlled by Mexico-based companies.
Many of these companies operate in high-cash sectors such as retail, agriculture, and transport. Some are legitimate businesses with corrupt connections. Others are shell entities designed to exist only on paper. The deposits are masked as revenue from commercial sales, trade payments, or other business activity.
The next stage is repatriation. Armored car services play a central role, transporting bulk cash from Mexico to the United States for deposit into accounts at U.S. financial institutions. In certain cases, the armored carrier purchases the cash, credits the Mexico-based customer, and deposits the equivalent value into an affiliated U.S. account. From there, the funds may be wired back to Mexico, sent to related entities within the United States, or used to purchase goods that can be exported as part of a trade-based laundering cycle.
The cycle is designed to exploit jurisdictional and operational blind spots. Funds move between two financial systems with different regulatory structures, making it harder to identify the true source and purpose of the money. The involvement of armored car services adds another layer of complexity, particularly when those services may be subject to Bank Secrecy Act registration requirements as money transmitters.
FinCEN’s focus on this typology also aligns with increased executive authority to designate cartels as Foreign Terrorist Organizations (FTOs). For financial institutions, the risk is no longer limited to compliance failures. The consequences now extend to reputational damage, potential criminal liability, and association with entities subject to counterterrorism financing laws.
FinCEN’s alert provides specific indicators that should be built into monitoring systems and investigative procedures:
For banks and money services businesses
For armored car services
Institutions that treat this as a one-time compliance update risk missing its broader significance. This typology highlights the need for a holistic, cross-border view of customer activity.
From Sigma360’s perspective, the most effective response includes:
This scheme is not just about hiding illicit funds. It is about sustaining a criminal economy that destabilizes communities on both sides of the border. Every successful cycle strengthens the financial infrastructure of the cartels, allowing them to expand their reach and adapt to enforcement pressure.
Financial institutions hold a critical position in disrupting this process. By detecting patterns earlier, closing gaps in cross-border oversight, and responding decisively to suspicious activity, they can cut into the cash lifelines that cartels depend on.
FinCEN’s early 2025 alert is more than a regulatory reminder. It is a call for the industry to recognize how quickly illicit funds can cross borders, pass through legitimate channels, and re-enter the financial system dressed as lawful commerce. The institutions that adapt now will be better equipped to safeguard their customers, meet rising regulatory expectations, and reduce the reach of organized crime in the global economy.
The regulatory, reputational, and operational risks posed by Foreign Terrorist Organizations (FTOs) and cartel-linked entities have outpaced the capabilities of traditional screening solutions. Sigma360 was purpose-built for this challenge. Unlike legacy tools that rely on outdated watchlists or generic adverse media checks, our platform delivers a holistic, persistent view of FTO/DTO exposure at scale.
Our proprietary threat intelligence combines:
This intelligence is supported by an AI-driven engine that identifies and prioritizes risk based on behavioral patterns, not just entity names. Our platform is easy to deploy, with flexible delivery options that include API integration, batch screening, and advisory overlays.