The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a multi-tiered operation targeting more than 100 U.S. money services businesses (MSBs) operating along the southwest border for potential non-compliance with Bank Secrecy Act (BSA) requirements intended to detect money laundering and combat illicit finance. The operation has already produced six notices of investigation, dozens of examination referrals to the Internal Revenue Service (IRS), and more than 50 compliance outreach letters. The effort is based on analysis of over one million Currency Transaction Reports and 87,000 Suspicious Activity Reports, and is focused on money laundering vulnerabilities where MSBs appear to be non-compliant with the BSA. FinCEN is coordinating with the Homeland Security Task Force, the IRS, and state and federal law enforcement and regulatory partners, and reminded MSBs of core obligations including maintaining risk-based AML/CFT programs, customer identification as needed to meet BSA reporting requirements, monitoring and timely filing of Suspicious Activity Reports, timely Currency Transaction Reports above thresholds, and oversight of agents, branches, and third-party service providers where applicable. FinCEN described the initiative as ongoing and said it may lead to civil money penalties, civil injunctive actions, warning letters, and referrals to criminal authorities for willful BSA violations.