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Treasury Secretary Scott Bessent announced new fraud prevention measures in Minnesota on October 30, under the White House Task Force to Eliminate Fraud. FinCEN issued two documents the same day. The first is an Alert on Risks Associated with Foreign-Agent-Directed Transactions. The second is a Notice on the Use of Charities and Non-Profit Organizations for Illicit Activity.
Treasury’s release puts a figure on the problem. From 2021 to 2025, financial institutions reported more than $8 billion in potentially suspicious wire payments sent through U.S. money services businesses at the direction of foreign agents. The alert asks institutions to watch cross-border payments that may hide the real beneficiary or fund illicit activity, including terrorism. “When greed meets negligence, the American people suffer,” Bessent said.
Three charity schemes
| Scheme | How it works |
|---|---|
| Sham charity | Claims a legitimate purpose and funds illicit activity |
| False cause | Solicits donations to fund the fraudsters’ lifestyles |
| Insider embezzlement | Insiders steal from a legitimate charity |
Treasury also said it has stopped nearly $190 million in funds tied to overseas fraud and returned more than $100 million to U.S. victims. The release points to the Feeding Our Future case, in which $49 million was taken from a federal child nutrition program.
The FATF grey list shrinks
The same day, FinCEN relayed the outcome of the October FATF plenary. Bulgaria, Côte d’Ivoire, the Democratic Republic of the Congo and Monaco left the list of jurisdictions under increased monitoring, and none were added. The high-risk list of Iran, North Korea and Burma is unchanged. FinCEN reminded institutions that due diligence “should not be used as the basis to engage in wholesale or indiscriminate de-risking.”
If your bank banks an MSB with foreign corridors or a local nonprofit, this alert is about your customers.
- Pull your MSB customers with cross-border wire activity and review them against the alert’s red flags this month.
- Review nonprofit accounts for the three schemes in the notice, especially new charities with fast-growing inflows.
- Update your country risk ratings for the four jurisdictions that left the grey list, and record the reason for each change.
Zovos logs each fraud case with a two-person decision on whether to file a SAR. A new FinCEN alert then has a place to land in your case review.
This is for information only and is not legal advice. Read the alert and notice in full and confirm your SAR obligations with counsel.