Treasury Department’s Crime Unit Announces Crackdown on Cross-Border Transfers of “Funds Derived from Unlawful Employment” Sent by Illegal Aliens

There has been a flurry of announcements from the Trump administration in recent days regarding its battle against illegal immigration and how to address the tens of millions of people in the U.S. illegally. Amidst the talk of benefits being cut off and visas being suspended, there was another monumental move that was just announced.

Specifically, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) just sent an advisory to money services businesses (“MSBs”) which handle international wires stating that the requirement for preparing and submitting a Suspicious Activity Report (“SAR”) for “cross-border funds transfers” also applies to “funds derived from unlawful employment” in the United States. In more simple language, this means money earned by someone who may not legally work in this country is prohibited from being wired out of this country. This is a huge development.

The threshold for the SAR reporting requirement is $2,000 in aggregate, which means that “structuring” a series of smaller wires is also prohibited if the total exceeds $2,000. The regulation related to structuring states that “a series or pattern of such transfers that collectively suggest an intent to evade the SAR threshold must be reported.” In other words, the total amount of all wires must be reported. In addition, attempting to structure wires is itself a suspicious activity that must be reported.

As noted by FinCEN, these international wires frequently include payments to the smugglers who brought the “migrants” across the border, which effectively rolls to the drug cartels and crime syndicates. FinCEN calls these syndicates “Mexico based transnational criminal organizations.”

The press release from FinCEN and the Treasury Department is at this link. A few quotes from it are below the link.

“FinCEN Issues Alert on Cross-Border Funds Transfers Involving Illegal Aliens” [Treasury Department FinCEN Press Release – 11/28/2025]

Today, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) is issuing an Alert as part of Treasury’s effort to prevent the exploitation of the U.S. financial system by illegal aliens in the United States seeking to move illicitly obtained funds. Annually over the past several years, the United States has witnessed a significant volume of cross-border funds transfers, including remittances from individuals located in the United States, and has taken multiple steps this year to highlight risks presented by cross-border financial activity.

“Money services businesses should be vigilant in identifying suspicious financial activity involving illegal aliens who present significant threats to national security and public safety,” said Under Secretary for Terrorism and Financial Intelligence John K. Hurley.

This Alert is consistent with Executive Order 14159, Protecting the American People Against Invasion. Money services businesses (MSBs) are generally required to file a suspicious activity report for a transaction that involves at least $2,000 and that the MSBs know, suspect, or have reason to suspect is relevant to a possible violation of law or regulation. This includes the cross-border transfer of funds derived from unlawful employment or otherwise derived from funds the MSB knows, suspects, or has reason to suspect were illicitly obtained in the United States.

The full report issued by FinCEN to money services businesses is at this link, including this explanation for their action, “FinCEN has taken multiple steps this year to highlight the risks involved with cross-border financial activity, particularly transactions that benefit Mexico-based cartels, several of which have been designated as Foreign Terrorist Organizations.”

Freightwaves and its CEO Craig Fuller have done a great job covering the many problems related to the explosive growth of illegal, foreign truck drivers that are behind the wheel on American roads. In a piece over the weekend, Mr. Fuller discusses the impact of this new regulation on the trucking industry and beyond, since much of the unlawful earnings of those foreign truck drivers are wired back to their home countries.

“The Feds drop the hammer on illegal immigration” [Freightwaves – 11/29/2025]

Of the estimated 11–14 million undocumented immigrants in the U.S., roughly 60% to 70% regularly send remittances, totaling approximately $160 billion annually—an amount exceeding the GDP of many countries. Mexico, Guatemala, Honduras, and El Salvador alone receive over $100 billion combined.

By explicitly criminalizing funds derived from unlawful employment, the Administration aims to choke off this massive financial flow. When these flows are severely restricted, the financial incentive to remain in the U.S. shadow economy evaporates, resulting in a collapse of the economic model of illegal immigration.

But what if the employees of companies that do international wires simply turn a blind eye and do not complete the Suspicious Activity Reports required by the Treasury Department? That would be a bad decision. Wires leave an easily traceable trail under Treasury’s purview, and there could be harsh penalties for those who don’t comply. More specifically, the executives of companies who don’t comply could go to jail. As reported by Freightwaves:

FinCEN’s far-reaching powers include the ability to:

• Compel any financial institution to hand over records without a warrant (via National Security Letters).
• Unilaterally freeze assets.
• Impose civil penalties of $250,000 per transaction.
• Criminally prosecute executives for “willful blindness.”

Conservatives seeking to de-incentivize illegal immigration have long advocated for the imposition of severe remittance taxes on foreign wires sent by illegal aliens. This Treasury Department action prohibiting the international wiring of “proceeds from unlawful employment” will have much the same impact.

[buck.throckmorton at protonmail dot com]

posted by Buck Throckmorton at 11:00 AM

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