The U.S. Financial Crimes Enforcement Network (FinCEN) issued an alert on payments directed by foreign agents through U.S. money services businesses (MSBs) and a notice on the exploitation of charities and nonprofit organizations (NPOs). Both publications provide indicators to help financial institutions detect and report terrorist financing, fraud and other illicit activity. Customer relationships should be assessed individually rather than treating either sector as uniformly high risk. The payments alert draws on financial institutions’ reports of more than USD 8 billion in potentially suspicious payments directed by foreign agents between 2021 and 2025. Such reporting does not establish illegality. Foreign agents may instruct U.S. MSBs to pay unrelated overseas recipients, leaving the MSBs and their banks with limited or contradictory information about beneficiaries and transaction purposes. Warning signs include unsupported payment instructions, transfers inconsistent with expected business activity and rapid movement of funds abroad after receipt. Principal MSBs should assess the purpose of these payment arrangements, the jurisdictions involved and the entities receiving funds as part of their oversight of foreign agents. The NPO notice distinguishes sham charities supporting illicit causes, fraud schemes diverting donations or government funding for personal enrichment, and insider embezzlement from otherwise legitimate organizations. Indicators include fundraising without apparent services, unusually large government reimbursements shortly after an organization begins operating, and unexplained payments to insiders or connected entities. No single indicator establishes suspicious activity, and institutions should consider the available facts and circumstances. For related suspicious activity reports, institutions are asked to include “FIN2026FOREIGNAGENT” or “FIN2026NPO,” as applicable, in field 2 and the narrative.
US FinCEN issues alert on over USD 8 billion in suspicious foreign agent payments and notice on charity abuse
The U.S. Financial Crimes Enforcement Network issued an alert on foreign agent payments through U.S. money services businesses and a notice on charity and nonprofit abuse. The alert draws on more than USD 8 billion in potentially suspicious payments reported between 2021 and 2025, highlighting opaque transfers to unrelated overseas recipients. The notice addresses sham charities, fraud and insider embezzlement, while both publications emphasize assessing individual customer risks rather than treating either sector as uniformly high risk.