On October 30, FinCEN issued an alert on suspicious cross-border payments through U.S.-based money services businesses (MSBs) and a notice on the illicit exploitation of charities and nonprofit organizations, as part of Treasury’s Minnesota fraud initiatives. Treasury announced the actions as part of the White House Task Force to Eliminate Fraud, citing what it called “rampant fraud” in the state (previously covered by InfoBytes here).

The alert addresses payments that U.S. principal MSBs make to third parties at the direction of foreign agents. FinCEN reported that its analysis of Bank Secrecy Act reporting identified more than $8 billion in suspicious foreign-agent-directed payments between 2021 and 2025, and that, in some instances, funds ultimately benefited entities with connections to terrorist financing. The alert lists red flags for principal MSBs and for banks that serve MSBs, including a foreign agent that: (i) regularly directs payments to third parties in jurisdictions such as China, the United Arab Emirates, Egypt, Kenya, Uganda, and Djibouti; (ii) provides non-descriptive payment reasons such as “settlement”; (iii) is missing or provides inconsistent invoices or contracts; and (iv) regularly directs payments in round-dollar amounts. FinCEN asked filers to include the key term “FIN2026FOREIGNAGENT” in suspicious activity reports and Form 8300 filings.

Separately, the notice describes three categories of schemes: (i) sham charities that purport to serve legitimate purposes but use funds for illicit activity, including terrorism; (ii) nonprofit fraud schemes, including the misappropriation of government funding, that enrich the people running them; and (iii) embezzlement by insiders at legitimate charity or non-profit organizations. FinCEN stated that the vast majority of U.S.-based nonprofits present a low risk of terrorist financing, and it encouraged institutions to evaluate each organization individually under a risk-based approach. The notice’s red flags include: (i) customers with a limited physical or online presence; (ii) customers with names resembling well-known organizations without any affiliation; (iii) newly established organizations that receive unusually large payments or government aid reimbursements soon after starting operations; and (iv) spending that does not match an organization’s financial profile. FinCEN requested that organizations filing reports of cash payments over $10,000 use the key term “FIN2026NPO” in the comments section of the report.