On April 9, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a 21-page Financial Trend Analysis titled Fentanyl-Related Illicit Finance: 2024 Threat Pattern & Trend Information. FinCEN reviewed 1,246 Bank Secrecy Act (BSA) reports targeting fentanyl-related activity. The reports involved $1.4 billion in suspicious activity, with Mexico and China being the top two foreign countries identified in the subject address fields.

The Financial Trend Analysis highlighted several activities and patterns helpful to financial institutions in detecting and reporting suspicious activity related to fentanyl:

• Other countries besides Mexico and China identified in the subject address fields include Canada, the Dominican Republic and India.
• BSA reports highlighted the role of Mexican chemical brokers and the use of front companies, money mules and U.S. intermediaries to procure fentanyl precursor chemicals.
• States with the most fentanyl-related BSA reports are California, Florida and New York.
• There are a substantial number of fentanyl-related BSA reports in southwest border counties in California and Arizona.
• Electronic funds transfers (EFTs), referenced in 80% of the BSA reports, are the most common payment mechanism in fentanyl-related BSA reporting.

There’s no better time than now to ensure your institution is BSA compliant. Our compliance pros stand ready to help. Rely on Doeren Mayhew to validate compliance and help mitigate risks.