On February 6, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced 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 main U.S. anti-money laundering (AML) law that protects the financial system from illegal behavior.

Due to Brink’s failure, high-risk entities sent hundreds of millions of dollars in bulk currency shipments across the Southwest Border. This included a Mexican currency exchanger that later pleaded guilty to violating the BSA.

FinCEN’s Director Andrea Gacki said: “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. 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.”

Marlene Koury, partner at Constantine Cannon said: “This news is particularly notable because it is FinCEN’s first enforcement action against an armored car company. This is the kind of complex case involving BSA violations we typically handle at our firm.”

The Consent Order between FinCEN and Brink’s outlined the following:

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. Additionally, Brink’s will be subject to an AML program review.

If you decide to blow the whistle, you could be eligible for rewards associated with reporting violations of AML laws and regulations. If you believe you have information on AML violations or want to learn more about what it means to be a whistleblower, please contact us. We will connect you with an experienced member of the Constantine Cannon whistleblower team for a free and confidential consult.

Read FinCEN Announces $37M Civil Money Penalty Against Brink’s Global Services USA, Inc. for Violating the Bank Secrecy Act at constantinecannon.com