FinCEN Alert on Risks Associated withForeign-Agent-Directed Transactions
October 30, 2026 / Source: FinCEN
The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) is issuing this Alert to urge financial institutions to be vigilant in detecting, identifying, and reporting suspicious activity arising from certain cross-border payments involving U.S.-based money services businesses (MSBs).
MSBs provide critically important services to underserved populations and offer a key means to transfer funds internationally. Treasury has consistently noted that financial institutions should assess all customers on a case-by-case basis and that no individual type of customer, including MSBs, should be considered uniformly high risk.
However, the cross-border relationships that MSBs often maintain to make overseas money transmission possible may give rise to potential risks to the U.S. financial system. Illicit actors may exploit these cross-border arrangements—particularly settlement arrangements subject to inadequate due diligence and transaction monitoring—to move funds through the U.S. financial system and obscure the ultimate beneficiaries and the underlying purpose of transactions.
In doing so, illicit actors may exploit MSBs’ cross-border relationships to further and conceal illicit activity; for example, FinCEN has identified instances where funds ultimately benefited entities with identified connections to terrorist financing. As described below, these risks may be particularly pronounced when U.S.-based MSBs implement transactions at the direction of foreign agents.
Through analysis of Bank Secrecy Act (BSA) reporting, FinCEN has identified more than $8 billion in suspicious foreign-agent-directed payments between 2021 and 2025.