The U.S. Treasury Department has escalated its financial surveillance efforts by issuing a comprehensive advisory targeting cross-border money transfers linked to individuals without legal immigration status. This directive represents a significant shift in federal oversight of remittance services and money transfer businesses. The Financial Crimes Enforcement Network’s latest alert signals heightened scrutiny of international financial flows amid growing concerns about illicit fund movements across American borders.
Money service businesses see increased reporting obligations
FinCEN has released a warning with recommendations that money service businesses be extra cautious with cross-border cash transfers that relate to persons lacking any kind of immigration status in the United States. This is in addition to the targeting of cross-border payments that the MSB knows, suspects, or has a reasonable ground to believe relate to proceeds of illegal work or other illegal activity. Businesses will now be required to report any unusual activity that relates to cross-border payments of more than $2,000.
The warning stresses that money service businesses must be extra vigilant for activity that indicates they aim to facilitate the transportation of funds that have been gained unscrupulously, as well as other cross-border movements. Treasury Department officers explain that some persons may seek to use the financial system for their own gain, moving unscrupulously gained assets through cross-border channels that would allow them to evade detection by law enforcement.
This Treasury Department rule is specifically compliant with Executive Order 14159, entitled “Protecting the American People Against Invasion,” which considers persons lacking immigration status “as posing a significant threat to national security, public safety, or the integrity of any essential resource, infrastructure, or economic interest of the United States” as well as “as threatening national security, public safety, or such a resource, infrastructure, or interest through their use of cross-border human smuggling or human trafficking, or their exploitation of American financial systems.”
Remittance across national borders touches record heights
According to the BEA, the value of personal remittances that immigrants in the United States sent back to foreign residents exceeded $72 billion in 2024. Although Treasury Department authorities admit that most cross-border payments of this kind are legitimate and play a crucial role in providing economic support to loved ones abroad, they remain concerned that some individuals may seek to exploit this system.
An alert issued by the agency is in line with the policy changes that were announced by President Trump. Trump announced that there will be a “permanent pause on immigration from ‘Third World Countries’” and that benefits will stop for non-citizens. In addition, Trump announced that people will be “removed if they do not embody the greater good for America or if they do not embody America’s interests.”
“Money services businesses must remain alert for suspicious financial activity associated with illegal aliens who pose substantial threats to national security and public safety,” warned Under Secretary for Terrorism and Financial Intelligence John K. Hurley.
Policy considerations: Going beyond financial regulation
FinCEN alert reflects the broader efforts of the Treasury Department designed to stem the use of the U.S. financial system as a tool of illegal proceeds launderers. Coming in the wake of a series of measures implemented this year in response to mounting concern over cross-border financial activity generated by criminals, as well as other individuals that do not qualify, FinCEN’s move will see the administration conduct a review of all asylum admissions as well as every Green Card awarded within the last two presidential administrations to the nationals of 19 different countries.
With regard to immigration, the most recent guidance offered by the Treasury signals a paradigm shift in its proactive oversight of cross-border financial activity, particularly as it relates to unauthorized individuals. Such a regulatory paradigm represents a pivotal aspect of immigration control measures. However, this move raises debated ideals, such as the relationship between national security interests and banking services for immigrants.
