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Consumer Financial Protection Bureau (CFPB)
On Wednesday, April 9, 2025, the U.S. House of Representatives passed Senate Joint Resolution 18 to disapprove the CFPB’s “Overdraft Lending: Very Large Financial Institutions” rule. If signed by President Trump, the resolution would end the CFPB’s final rule which required financial institutions over $10 billion in assets to either cap overdraft fees at $5 or classify the programs as credit under Regulation Z.
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Federal Communications Commission (FCC)
The FCC revised a consent order to delay the effective date of the FCC’s rule that requires callers to treat a request to revoke consent made by a called party in response to one type of message as applicable to all future robocalls and robotexts from that caller on unrelated matter. The delay will change the effective date until April 11, 2026, to allow affected parties a reasonable opportunity to implement modifications to communications systems in a cost-effective manner to ensure that they can process revocation requests in accordance with this rule.
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Financial Crimes Enforcement Network (FinCEN)
FinCEN Issues Advisory on the Financing of ISIS
FinCEN released an advisory to assist financial institutions in identifying and reporting suspicious activity related to the financing of the Islamic State of Iraq and Syria (ISIS). The Advisory highlights how ISIS and its global affiliates fund themselves and receive financial support from sympathizers internationally and describes several typologies ISIS uses to transfer money between its affiliates. The Advisory also provides red flags that may assist financial institutions in identifying related suspicious activity.
The Advisory is a continuation of the sustained effort that Treasury has led for more than a decade, in coordination with the U.S. government interagency and foreign partners, to disrupt and eliminate ISIS’s revenue sources and financial networks. The Advisory is also consistent with the National Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Priorities, which include terrorist financing, as well as Treasury’s 2024 National Terrorist Financing Risk Assessment.
FinCEN Issues Alert on Bulk Cash Smuggling and Repatriation by Mexico-based Transnational Criminal Organizations
FinCEN released an alert on bulk cash smuggling and repatriation by Mexico-based Transnational Criminal Organizations (TCOs), urging financial institutions to be vigilant to such activity.
The Alert discusses transactions potentially related to the cross-border smuggling of bulk cash from the United States into Mexico and its repatriation into the United States and Mexican financial systems by Mexico-based TCOs. The Alert highlights one of several typologies that TCOs use to launder illicit proceeds generated in the United States through the cross-border movement of cash and how these operations enable the TCOs to place, layer, and integrate their illicit proceeds into the United States and Mexican financial systems where they can be accessed again to fund their criminal enterprises.
The Alert provides an overview of methodologies associated with these operations, highlights red flag indicators, and reminds financial institutions of their reporting requirements under the Bank Secrecy Act.
FinCEN Issues Analysis of Fentanyl-Related Threat Patterns and Trends in Bank Secrecy Act Reports
FinCEN issued a Financial Trend Analysis focused on patterns and trends identified in Bank Secrecy Act (BSA) data linked to fentanyl-related illicit finance. Between January and December 2024, financial institutions filed 1,246 BSA reports that identified suspected fentanyl-related activity amounting to approximately $1.4 billion in suspicious transactions. The reported financial activity highlighted various aspects of the illicit fentanyl supply chain—including precursor chemical procurement, fentanyl trafficking, and fentanyl-linked money laundering—that have touchpoints across the U.S. financial sector.
Illicit fentanyl is primarily synthesized, trafficked, and smuggled into the United States by Mexican cartels. The Sinaloa Cartel and the Cartel Jalisco Nueva Generacion—which are Foreign Terrorist Organizations, Specially Designated Global Terrorists, and Drug Trafficking Organizations—largely control the fentanyl supply chain from Mexico and use precursor chemicals and manufacturing equipment primarily sourced from the People’s Republic of China (PRC) to synthesize illicit fentanyl in clandestine laboratories. FinCEN analysis identified Mexico and the PRC as the top two foreign countries listed in subject address fields of fentanyl-related BSA reports filed in 2024.
Additional findings of FinCEN’s analysis include:
- The cartels and associated chemical brokers use front companies, money mules, and U.S.-based intermediaries to procure fentanyl precursor chemicals from PRC-based suppliers.
- PRC-based chemical suppliers accept a wide range of payment methods and often leverage public advertisements, including e-commerce platforms, to market fentanyl precursor chemicals.
- Fentanyl-related financial activity in the United States primarily involved subjects in populous states with large urban areas that have established drug distribution networks and serve as collection points for illicit proceeds, including a substantial number of subjects in southwest border counties in California and Arizona.
- Domestic sales of fentanyl appeared to be conducted primarily in cash and peer-to-peer transfers, which were referenced in 54 and 51 percent of BSA reports, respectively.
- Methods to launder suspected fentanyl proceeds varied in sophistication. BSA filers identified complex schemes, including the use of suspected Chinese money laundering organizations potentially facilitating the movement of illicit fentanyl proceeds on behalf of the cartels.
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