Immediate Release
February 06, 2025
The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) assessed a $37,000,000 civil money penalty against Brink’s Global Services USA, Inc. (Brink’s) for willful violations of the Bank Secrecy Act (BSA), the primary U.S. anti-money laundering (AML) law that safeguards the financial system from illicit use, and its implementing regulations. As a result of Brink’s failures, hundreds of millions of dollars in bulk currency shipments were transmitted across the Southwest Border on behalf of high-risk entities—including a Mexican currency exchanger that later pleaded guilty to violating the BSA. This is FinCEN’s first enforcement action against an armored car company.
“For years, Brink’s moved large sums domestically and across the Southwest Border without required AML controls, exposing the U.S. financial system to a heightened risk of money laundering, including from narcotics trafficking and other illicit activity,” said FinCEN’s Director Andrea Gacki. “This enforcement action is an important reminder that FinCEN will take action against those who fail to do their part to safeguard our nation’s financial system.”
As set forth in its resolution with FinCEN, Brink’s willfully violated the BSA, including failing to: (i) register with FinCEN as a money services business; (ii) develop, implement, and maintain an effective AML program; and (iii) file suspicious activity reports. In addition to the civil money penalty, Brink’s will also be subject to an AML program review.
FinCEN appreciates the close collaboration with its partners from the U.S. Attorney’s Office for the Southern District of California on this matter.
FinCEN’s Enforcement and Compliance Division is responsible for investigating serious violations of the BSA. For additional information regarding the facts and circumstances associated with this enforcement action, including the specific BSA violations and their underlying causes, please see the Consent Order between FinCEN and Brink’s.
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Purpose:
The purpose of this update is to inform stakeholders that FinCEN has assessed a $37 million civil money penalty against Brink’s Global Services USA, Inc. for willful violations of the Bank Secrecy Act and its implementing regulations.
The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) took action against Brink’s due to their failure to implement effective anti-money laundering (AML) controls, which exposed the U.S. financial system to a heightened risk of money laundering from narcotics trafficking and other illicit activities.
This update serves as an important reminder that FinCEN will take enforcement actions against entities that fail to safeguard the nation’s financial system.
Effects on Industry:
The assessment of a $37 million civil money penalty by FinCEN is expected to have significant effects on the industry. Brink’s failure to implement AML controls and register with FinCEN as a money services business has compromised the integrity of the U.S. financial system, making it vulnerable to money laundering.
This enforcement action is likely to increase awareness among armored car companies and other entities that handle large sums of cash about the importance of implementing effective AML programs and registering with FinCEN.
Furthermore, this update may lead to increased scrutiny from regulatory bodies and law enforcement agencies on entities that fail to comply with AML regulations, potentially resulting in more severe penalties for non-compliance.
Relevant Stakeholders:
The following stakeholders are affected by this update:
- Brink’s Global Services USA, Inc.
- Armored car companies
- Money services businesses
- Financial institutions
- Law enforcement agencies and regulatory bodies
These entities must take note of the importance of implementing effective AML programs and registering with FinCEN to avoid similar penalties.
Next Steps:
To comply with this update, Brink’s Global Services USA, Inc. has agreed to:
- Pay a $37 million civil money penalty
- Implement an AML program review
Other entities in the industry must also take steps to ensure they are complying with AML regulations and registering with FinCEN as required.
Any Other Relevant Information:
This update is part of FinCEN’s ongoing efforts to safeguard the nation’s financial system from illicit activities.
The assessment of this civil money penalty serves as a reminder that FinCEN will take enforcement actions against entities that fail to comply with AML regulations.
In addition, the close collaboration between FinCEN and its partners from the U.S. Attorney’s Office for the Southern District of California highlights the importance of cooperation in combating illicit financial activities.
