i

F I N A N C I A L T R E N D A N A L Y S I S

Fentanyl-Related Illicit Finance: 2024 Threat Pattern

& Trend Information

This Financial Trend Analysis (FTA) focuses on patterns and trends identified in Bank Secrecy Act
(BSA) data linked to fentanyl-related illicit finance. This report is issued pursuant to Section 6206 of
the Anti-Money Laundering Act of 2020, which requires the Financial Crimes Enforcement Network
(FinCEN) to periodically publish BSA-derived threat pattern and trend information.1 FinCEN issued
government-wide priorities for anti-money laundering and countering the financing of terrorism
(AML/CFT) on 30 June 2021, which included drug trafficking organization activity and transnational
criminal organization activity as government-wide priorities. In 2019 and 2024, FinCEN issued two
advisories that highlight financial typologies and red flag indicators associated with suspected fentanyl-
related activity.2,3 The information in this report is relevant to the public, including a wide range
of consumers, businesses, and industries and it highlights the value of BSA data filed by regulated
financial institutions.

Executive Summary: FinCEN analyzed 1,246 BSA reports that identified suspected fentanyl-
related activity. These reports were filed between January and December 2024 and identified
approximately $1.4 billion in suspicious transactions.4 The reported financial activity identified
various aspects of the illicit fentanyl supply chain—including precursor chemical procurement,
fentanyl trafficking, and fentanyl-linked money laundering—that have touchpoints across the U.S.
financial sector.

• Fentanyl Supply Chain Leverages U.S. Financial System: Depository institutions and money
services businesses (MSBs) in the United States accounted for 57 and 32 percent of fentanyl-
related BSA reports, respectively. These filings identified suspected illicit activities involving
elements of the fentanyl supply chain that often rely on the U.S. financial system to move
money globally.

• Fentanyl Trade Has Foreign Touchpoints: Mexico and the People’s Republic of China (PRC), the
top two foreign countries identified in subject address fields of BSA reports analyzed, play key
roles in the production of fentanyl and subsequent money laundering activity.

1. The Anti-Money Laundering Act of 2020 was enacted as Division F, §§ 6001-6511, of the William M. (Mac) Thornberry
National Defense Authorization Act for Fiscal Year 2021, Pub. L. 116-283 (2021).
2. See generally “FinCEN Advisory to Financial Institutions on Illicit Financial Schemes and Methods Related to the
Trafficking of Fentanyl and Other Synthetic Opioids,” FinCEN Advisory #FIN-2019-A006, 21 August 2019,
https://www.fincen.gov/resources/advisories/fincen-advisory-fin-2019-a006.
3. See generally “FinCEN Supplemental Advisory on the Procurement of Precursor Chemicals and Manufacturing
Equipment Used for the Synthesis of Illicit Fentanyl and Other Synthetic Opioids,” FinCEN Advisory
#FIN-2024-A002, 20 June 2024, https://www.fincen.gov/resources/advisories/fincen-advisory-fin-2024-a002.
4. The suspicious activity total may include BSA reports that describe continuing suspicious activity or amend earlier
reports, as well as reports that cover expanded networks involved in potential illicit activity.
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• Mexican Geographic Trends Highlight Cartels’ Financial Footprints and Procurement Methods: Sinaloa
and Jalisco, strongholds of the Sinaloa Cartel and the Cartel Jalisco Nueva Generacion (CJNG),
were the top two Mexican states identified in subject address fields of BSA reports related
to fentanyl.5 In addition, BSA reporting highlighted the role of Mexican chemical brokers
and the use of front companies, money mules, and U.S. intermediaries to procure fentanyl
precursor chemicals.

• E-Commerce Plays Key Role in Chinese Precursor Chemical Sales: PRC-based chemical suppliers
accept a wide range of payment methods and often leverage public advertisements, including
e-commerce platforms, to market fentanyl precursor chemicals. Reported activity suspected
of being potential precursor chemical sales primarily included bank wire transfers as well as
various MSB payment mechanisms, such as traditional funds transfers, electronic transfers via
online payment platforms, and transfers of convertible virtual currency (CVC).

• Other Foreign Touchpoints Reflected in Fentanyl Supply Chain: Subjects in other foreign countries—
including Canada, the Dominican Republic, and India—highlight the presence of alternative
suppliers of precursor chemicals and fentanyl, as well as the role of illegal online pharmacies.

• California, Florida, and New York Lead U.S. in BSA Reporting Subjects: Fentanyl-related financial
activity in the United States primarily involved subjects in populous states with large urban
areas that have established drug distribution networks and serve as collection points for illicit
proceeds. FinCEN analysis also noted a substantial number of subjects in southwest border
counties in California and Arizona.

• Fentanyl Traffickers in United States Primarily Deal in Cash and Peer-to-Peer Transfers: Domestic
sales of fentanyl appear to be conducted primarily in cash and peer-to-peer (P2P) transfers,
which were referenced in 54 and 51 percent of BSA reports, respectively. P2P transfers often
included payment memos containing drug-related euphemisms that enabled BSA filers to detect
suspicious activity. In addition, BSA reporting of CVC-related transactions primarily identified
bitcoin payments, including in suspected darknet marketplace drug sales.

• Money Laundering Schemes Range from Simple to Complex: Methods to launder suspected fentanyl
proceeds varied in sophistication. Simple schemes often included the direct repatriation of
illicit proceeds to Mexico through MSB funds transfers. BSA filers also identified complex
schemes including suspected professional money laundering organizations (PMLOs)—such
as Chinese money laundering organizations—potentially facilitating the movement of illicit
fentanyl proceeds on behalf of the cartels. BSA filers also reported potential trade-based
money laundering (TBML) activity involving electronics, such as cellular phones, and vaping/e-
cigarette devices.

5. See Drug Enforcement Administration, “National Drug Threat Assessment 2024,” May 2024, at pp. 4-8,
https://www.dea.gov/sites/default/files/2025-02/508_5.23.2024%20NDTA-updated.pdf.

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Scope and Methodology: FinCEN examined BSA reports containing keywords potentially
indicative of fentanyl-related financial activity, including the key terms highlighted in
FinCEN’s 2019 and 2024 fentanyl advisories, and reviewed each report to remove false
positives. The final dataset comprises 1,246 BSA reports filed between January and December
2024 (the review period), reporting approximately $1.4 billion in suspicious financial activity.
These reports may refer to financial activity that occurred prior to the review period.6

What is Fentanyl?
Fentanyl is a synthetic opioid, roughly 100 times more potent than morphine, traditionally used
for pain relief and anesthesia in medical care. However, illicit fentanyl—which is often produced
to mimic legitimate prescription drugs—is primarily synthesized, trafficked, and smuggled into
the United States by Mexican cartels.7 The Sinaloa Cartel and CJNG —which are Foreign Terrorist
Organizations, Specially Designated Global Terrorists, and Drug Trafficking Organizations—
largely control the fentanyl supply chain from Mexico and utilize precursor chemicals and
manufacturing equipment primarily sourced from the PRC to synthesize illicit fentanyl in
clandestine laboratories through a series of chemical reactions.8, 9, 10 The resulting fentanyl powder
is either pressed into pill form in Mexico or smuggled into the United States to be pressed
domestically for distribution. In 2024, the U.S. Drug Enforcement Administration (DEA) seized
over 55 million fentanyl pills and nearly eight thousand pounds of fentanyl powder.11

The fentanyl trade generates a significant amount of illicit profits for the cartels that are
exploiting the U.S. financial system in every step of the fentanyl supply chain. To help combat
the fentanyl threat, FinCEN personnel embedded at the DEA Special Operations Division
and the U.S. Department of Justice’s Joint Criminal Opioid Darknet Enforcement team are
providing BSA-driven financial intelligence support to law enforcement investigations
targeting precursor chemical sales, fentanyl trafficking, and related money laundering activity.

6. BSA filers often reported suspicious financial activity that may have occurred over a multi-year period that
began before 2024. This included instances in which filers identified derogatory information, such as arrests and
indictments, involving their customers.
7. See Drug Enforcement Administration, “National Drug Threat Assessment 2024,” May 2024, at pp. 4-8,
https://www.dea.gov/sites/default/files/2025-02/508_5.23.2024%20NDTA-updated.pdf.
8. Ibid.
9. See U.S. Department of State, “Designation of International Cartels,” 20 February 2025,
https://www.state.gov/designation-of-international-cartels/.
10. See U.S. Department of the Treasury, “OFAC Alert: International Cartels Designated as Foreign Terrorist
Organizations and Specially Designated Global Terrorists,” 18 March 2025, https://ofac.treasury.gov/media/934096/
download?inline.
11. See Drug Enforcement Administration, “DEA Fentanyl Seizures in 2024,” https://www.dea.gov/.

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Figure 1. Filers by Financial Institution Type

(Percentage of Total Fentanyl-Related BSA Reports, 2024)

Securities/Futures 1%
Casinos/Card Clubs 3%
Loan or Finance
Other Companies < 1%
7%

57%
32% Depository
Money Institutions
Services
Businesses
(MSB)

Banks and MSBs Filed Majority of BSA Reports, Primarily Identified

Funds Transfer Activity Across Fentanyl Supply Chain
Financial institutions filed 1,246 BSA reports between January and December 2024 identifying
transactions occurring across the fentanyl supply chain, including the procurement of precursor
chemicals, the trafficking of fentanyl, and the laundering of illicit proceeds. Depository institutions
filed 57 percent of fentanyl-related BSA reports in the dataset, and MSBs filed 32 percent of the
reports. Other types of financial institutions, including casinos and those dealing with securities
and futures, submitted roughly 11 percent of the BSA reports.

• FinCEN identified electronic funds transfers (EFTs), referenced in 80 percent of the BSA reports,
as the most common payment mechanism in fentanyl-related BSA reporting. Cross-border
EFTs, including wire transfers conducted by depository institutions and MSB funds transfers,
demonstrate the cartels’ reliance on the U.S. financial system to move funds internationally to
facilitate the fentanyl trade. P2P transfers were also identified as a common payment method
tied to suspected fentanyl sales occurring within the United States.

• Suspicious cash transactions potentially linked to fentanyl trafficking-related activities were

primarily reported by depository institutions, including instances of potential structuring.
Casino filers also reported cash activity that may have been tied to illicit drug activity based on
the filers’ identification of negative media associated with their patrons.

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Geographic Trends in BSA Reporting Highlighted Precursor Chemical

Sales, Suspected International Money Laundering Involving Mexico
and the PRC
FinCEN analysis of BSA reporting identified Mexico and the PRC as the most frequently cited
locations of companies and individuals reported in fentanyl-related filings with a foreign nexus.
Illicit financial networks in these two countries underpin fentanyl production via the precursor
chemical trade while also enabling the laundering of illicit proceeds through complex money
laundering schemes and underground banking systems. BSA reports involving Mexico- and PRC-
based subjects primarily reported MSB funds transfers and wire transfers conducted via U.S.-
domiciled correspondent bank accounts held by Mexican and Chinese financial institutions.

BSA reporting also identified Hong Kong-based subjects potentially facilitating precursor
chemical sales and money laundering. Hong Kong-based companies were often reported in
conjunction with PRC-based subjects conducting similar financial activity or operating within
the same financial networks. In some instances, Hong Kong-based entities were identified as
branches or subsidiaries of PRC-based chemical companies suspected of supplying fentanyl
precursor chemicals.

Figure 2. Top 10 Countries Identified in BSA Reports, by Subject Address Field, 202412

Country BSA Report Count

United States 1,178
Mexico 101
PRC 71
Hong Kong 43
Canada 34
Dominican Republic 32
Colombia 26
United Kingdom 20
Spain 20
India 14

12. This table contains the number of BSA reports in which at least one subject was reported with a fixed field address in
the above countries. Based on a review of the BSA reports within the dataset, filers completed this field where subject
location could be identified. However, the subject may not be known or their information may not be available and/
or reported in all instances. In addition, the identification of the United States as the most common jurisdiction is
likely, in part, a reflection of the domestic nature of BSA reporting.

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Mexico-Related BSA Reports Most Frequently Cited Subjects in

Mexican States of Sinaloa and Jalisco
FinCEN analysis revealed nearly 32 percent of Mexico-based BSA report subjects in the dataset
were concentrated in the Mexican states of Sinaloa and Jalisco, strongholds of the Sinaloa Cartel
and CJNG.13 Additional clusters of addresses in Baja California, Sonora, and Chihuahua—border
states that play a key role in narcotics smuggling—were identified in 27 percent of Mexico-based
BSA report subjects.14 Subjects in Mexico City, the country’s main financial center, were reported in
roughly 10 percent of the fentanyl-related BSA filings.

Figure 3. BSA Report Subjects, by Mexican States, 2024

Sonora 40

Chihuahua 24

Nuevo León 12

Baja California 41

Sinaloa 81

México City 40

Nayarit 17

Jalisco 46

Number within parenthesis represents

total states in listed range
50 to 81 (1)
25 to 49 (4) Edo. de Mexico 17
11 to 24 (4)
0 to 10 (23)

13. See Drug Enforcement Administration, “National Drug Threat Assessment 2024,” May 2024, at pp. 4-8,
https://www.dea.gov/sites/default/files/2025-02/508_5.23.2024%20NDTA-updated.pdf.
14. Ibid.

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• Individuals in Sinaloa, Jalisco, and Mexico’s western border states were primarily identified as
beneficiaries of MSB funds transfers from U.S.-based senders suspected of repatriating drug
proceeds to Mexico and sourcing narcotics for distribution within the United States.

• BSA reporting identified Sinaloa- and Jalisco-based companies and individuals as the
predominate remitters of bank wire transfers to suspected PRC-based precursor chemical
suppliers. In one instance, a filer identified individuals with addresses in rural areas of
Sinaloa—including small towns and municipalities—sending wire transfers to PRC-based
chemical companies.

• In some instances, BSA filers identified subjects with addresses in key “plazas,” or towns, along
the U.S.-Mexico border in the states of Baja California, Sonora, and Chihuahua.15 The Mexican
cartels and associated criminal organizations often stage drug shipments, including fentanyl, in
these areas before smuggling them into the United States.16

Mexican Cartels and Chemical Brokers Leveraged Front Companies,

Money Mules, and U.S.-Based Intermediaries to Procure Fentanyl
Precursor Chemicals
BSA filers reported suspicious activity related to Mexico-based companies and individuals
remitting funds to PRC-based chemical manufacturers, or their associates, potentially for precursor
chemical procurement. While the exact chemicals exported from the PRC may have been unclear
to some BSA filers, the financial activity was often flagged due to the filers’ identification of risk
factors including the movement of funds between certain geographic corridors (e.g., Sinaloa,
Mexico to the PRC), anomalous transactional patterns, the involvement of Chinese chemical and
pharmaceutical entities, and opaque Mexico-based senders without an apparent connection to
the chemical industry or proper registration for importing chemical products.17 In addition, filers
identified open-source advertisements for known precursor chemicals and found connections to
entities previously charged in connection with or sanctioned for fentanyl-related activity.

15. A “plaza” is a specific territory controlled by a cartel in Mexico, located in a strategic geographic location, often
directly south of a U.S. border crossing. See U.S. Customs and Border Protection, “Operation Plaza Spike Fact Sheet,”
13 November 2024, https://www.cbp.gov/border-security/frontline-against-fentanyl/operation-plaza-spike-fact-
sheet#:~:text=What%20is%20a%20plaza%3F,27%20plazas%20operating%20in%20Mexico.
16. See Drug Enforcement Administration, “National Drug Threat Assessment 2024,” May 2024, p. 9,
https://www.dea.gov/sites/default/files/2025-02/508_5.23.2024%20NDTA-updated.pdf.
17. Mexican companies that import sector‐specific goods, including chemical products, are required to register with
Mexico’s Tax Administration Service. See International Trade Administration, Mexico – Country Commercial Guide,
“Import Requirements and Documentation,” 5 November 2023, https://www.trade.gov/country-commercial-guides/
mexico-import-requirements-and-documentation.

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• BSA filers reported financial activity involving purported Mexican chemical brokers, individuals
that operate as intermediaries between chemical suppliers and the drug producers ultimately
synthesizing fentanyl.18 For instance, a BSA filer identified a network of front companies utilized
by a suspected chemical broker to obfuscate illicit payments to overseas chemical suppliers. In
another BSA report, a filer identified a purported Mexico-based chemical importation business—
established only one year prior and potentially operating as a shell company—transacting
exclusively with a single PRC-based chemical distributor. Suspected Mexico-based front
companies in BSA reporting ranged from seemingly legitimate chemical importers to firms
operating in disparate industries such as construction, marketing, and hardware.

• Mexico-based individuals, including individuals identified by filers as potential money

mules or prestanombres (loosely translated as “straw buyers”), conducted suspected precursor
chemical payments, according to BSA reporting. Filers often cited the use of generic payment
instructions (i.e., “goods” or “services”) and sporadic periods of account dormancy (i.e. limited
transactional activity beyond a one- to two-month window of conducting suspicious chemical-
related payments).19 BSA reporting also identified instances in which networks of Mexico-
based individuals concentrated in certain areas—such as Culiacan, Sinaloa—remitted bank wire
transfers to the same PRC-based chemical supplier, exhibiting a many-to-one typology.20

• FinCEN identified examples in BSA reporting where suspected Mexico-based chemical brokers
and their associated criminal networks shifted to using U.S. intermediaries to send payments
to precursor chemical suppliers in 2024. For instance, one filer identified a Mexico-based
company previously sending suspected precursor chemical payments directly to the PRC before
leveraging a U.S.-based company, owned by a Chinese national, as an apparent intermediary.
Another filer identified a suspected Mexican money laundering organization routing a portion
of its illicit proceeds to a U.S.-based front company potentially facilitating precursor payments
to PRC-based companies.

18. In July 2023, Mexican chemical broker Javier Algredo Vazquez was convicted of charges related to methamphetamine
importation and money laundering. Algredo Vazquez imported over 5 million kilograms of chemicals into Mexico
for the CJNG, including enough precursors to produce over 700 million doses of methamphetamine and over 2 billion
doses of fentanyl. Algredo Vazquez also transferred millions of dollars from the United States to chemical suppliers
in China and India to procure the chemicals. See U.S. Department of Justice, “Precursor Chemical Broker Sentenced
for Methamphetamine Importation and Money Laundering Conspiracies,” 23 February 2024, https://www.justice.gov/
archives/opa/pr/precursor-chemical-broker-sentenced-methamphetamine-importation-and-money-laundering.
19. Payments instructions, such as memos included with wire transfers, often reference purposes of payment and/or
invoice numbers for legitimate commercial activity.
20. A many-to-one typology describes instances in which suspicious payments are remitted from multiple originators to
a single beneficiary. This may be done to layer—or “break up”—the total volume of money being transferred in an
effort to avoid detection.

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PRC-Based Subjects Used E-Commerce to Market Fentanyl

Precursor Chemicals
BSA reporting underscored the PRC’s role as the primary source country for fentanyl precursor
chemicals and pill press machinery used to produce counterfeit, fentanyl-laced pills.21, 22 Filers
also identified PRC-based subjects in reported money laundering activity, including suspected
TBML schemes that leveraged the Chinese export sector. FinCEN analysis identified that nearly 50
percent of PRC-based subjects in the dataset were located in the provinces of Guangdong, Zhejiang,
and Hebei. In addition, the cities of Wuhan (Hubei province) and Shijiazhuang (Hebei province)
were tied for the most BSA report subjects by city.

Figure 4. BSA Report Subjects, by PRC Provinces and Municipalities, 2024

Hebei 24

Hubei 15

Shandong 17

Jiangsu 8

Anhui 7

Zhejiang 26

Number within parenthesis represents Fujian 8

total municipalities/provinces/regions
in the listed range
15 to 30 (5) Guangdong 30

7 to 14 (4)
1 to 6 (9)
0 (16) Hunan 9

21. In October 2023, eight PRC-based chemical companies and associated Chinese nationals were charged with crimes
relating to fentanyl and methamphetamine production, distribution of synthetic opioids, and sales resulting from
precursor chemicals. See U.S. Department of Justice, “Justice Department Announces Eight Indictments Against
China-Based Chemical Manufacturing Companies and Employees,” https://www.justice.gov/archives/opa/pr/justice-
department-announces-eight-indictments-against-china-based-chemical-manufacturing.
22. PRC-based companies also advertise pill binding agents and punch die molds which, in addition to pill press machines,
are purchased and utilized by Mexico- and U.S.-based fentanyl traffickers in the production of counterfeit pills.
See Drug Enforcement Administration, “Pill Press Photo Gallery,” https://www.dea.gov/pill-press-photo-gallery.

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FinCEN analysis indicated suspected PRC-based precursor chemical suppliers, including

individuals associated with these companies, accepted a wide range of payments. Bank wire
transfers were identified in 83 percent of filings involving PRC-based chemical suppliers, but
MSB payments comprised of traditional funds transfers, online payment platforms, and CVC
were also noted. In addition, BSA filers reported on the role of e-commerce in facilitating the
PRC’s precursor chemical trade. Filers’ identification of suspicious activity appeared to have been
aided by monitoring PRC-based chemical companies’ online activity, including advertisements
on e-commerce platforms, product listings on the companies’ websites, and pointed language
guaranteeing customs clearance.23

• BSA filers identified instances in which suspected payments for precursor chemicals were sent
to PRC-based individuals who were purportedly owners or employees of chemical companies.
Filers appeared to make these connections primarily based on phone numbers and e-mail
addresses, collected for due diligence purposes, that were matched with contact information
listed on chemical companies’ websites or advertisements on e-commerce platforms.

• Filers often noted the use of Chemical Abstracts Service (CAS) numbers associated with fentanyl
precursors in open-source advertisements. CAS numbers are unique numerical identifiers
assigned to chemical substances, but criminals may use them in an attempt to evade scrutiny
from authorities by omitting explicit references to fentanyl.24 In some instances, BSA filers
reported CAS numbers for fentanyl precursors referenced in payment instructions or in invoices
provided to filers by their clients.

Figure 5. Fentanyl Precursor Chemicals Referenced in BSA Reports, 2024

Chemical Name CAS Number

1-Boc-4-piperidone 79099-07-3
4-Anilinopiperidine 99918-43-1
4-Piperidone monohydrate hydrochloride 40064-34-4
1-Boc-4-(2-fluoro-phenylamino)-piperidine 887583-57-5
1-Benzyl-4-piperidone 3612-20-2
(2-chloroethyl)-benzene 622-24-2
(2-bromoethyl)-benzene 103-63-9

23. FinCEN, in support of U.S. law enforcement, has observed various methods utilized by precursor chemical suppliers
to successfully evade detection by customs authorities. For example, Chinese national Minsu Fang was charged
with selling more than 2,000 kilograms of fentanyl precursors in July 2024 after he and his co-conspirators evaded
law enforcement interdiction of the shipments by declaring them to have a de minimis value, less than $800, and
commingling the boxes containing the precursor chemicals with similarly low-value goods. See U.S. Department
of Justice, “Chinese National Indicted for Importation of Enough Chemicals to Make Millions of Fatal Doses of
Fentanyl,” 22 July 2024, https://www.justice.gov/archives/opa/pr/chinese-national-indicted-importation-enough-
chemicals-make-millions-fatal-doses-fentanyl.
24. See American Chemical Society, “CAS Registry,” https://www.cas.org/cas-data/cas-registry.

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Figure 6. Fentanyl Precursor Chemical Money Flows in BSA Reports, 2024

U.S.-Based U.S.-Based
Intermediaries U.S.-Based
Money Laundering Drug Trafficking
(Individuals or Organization
Companies) Organization
PRC-Based
Source of Supply
Chemi
sed ca
Ba NTAN

FE

YL
lB
o-
Mexic
Chemical

roker
Company

Company Coordinates Payments

Representative and Logistics
EMICA
CH

LS

Mexican Cartel
Mexico-Based
Financial Facilitators
$

Accept payments via bank wire NTAN

transfer, MSB funds transfer, Front/Shell Money Mules/ Chemical

FE

YL
online payment platforms, and Companies Straw Buyers Companies
CVC.
Online advertisements contain
phone numbers and e-mail
addresses.
EMICA
Advertise with CAS

CH

LS
numbers associated with fentanyl U.S.-Based Freight Forwarder/ Mexican
precursors. Customs Broker Airport/Port
Falsify/mislabel invoices and Clandestine
customs records. Lab in Mexico
LEGEND

Goods Money Relationships

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Other Foreign Touchpoints Highlighted Alternative Sources of

Precursor Chemicals and Fentanyl, Including Illicit Online Pharmacies
Canada-based subjects were primarily identified by BSA filers due to their suspected involvement
in drug trafficking organizations allegedly sourcing fentanyl and other drugs from traditional drug
source countries, such as Mexico.25 In addition, several BSA reports identified activity potentially
indicative of Canada-based individuals and companies purchasing precursor chemicals and
laboratory equipment that may be related to the synthesis of fentanyl in Canada. Canada-based
subjects were primarily reported with addresses in the provinces of British Columbia and Ontario.

Dominican Republic- and Colombia-based subjects were primarily listed in BSA reports that
identified MSB funds transfers linked to suspected drug trafficking organizations operating in the
United States. FinCEN analysis noted certain BSA filings by MSBs identified suspicious activity
involving U.S.-based subjects arrested for allegedly trafficking various types of narcotics including
fentanyl, methamphetamine, cocaine, and heroin. In addition, BSA reports with Dominican
Republic-based subjects referenced online pharmacies suspected of facilitating the sale of
counterfeit opioid pills often laced with fentanyl.26

BSA reporting also highlighted India’s role as a supplier of fentanyl precursor chemicals, though
its involvement is less extensive than that of the PRC, as observed in BSA reports.27, 28 Filers
identified suspicious activity involving purported India-based chemical and pharmaceutical
companies, and associated individuals, receiving bank wire transfers and MSB funds transfers
potentially linked to the sale of precursor chemicals. In some instances, India-based subjects
appeared to be associated with online pharmacies that also advertised counterfeit opioid
products potentially containing fentanyl.

25. See U.S. Department of State, “International Narcotics Control Strategy Report,” March 2024, p. 253, https://www.
state.gov/wp-content/uploads/2025/01/2024-INCSR-Vol-1-Drug-and-Chemical-Control-Accessible-Version.pdf.
26. Although the majority of illicit fentanyl is produced by Mexican cartels to be smuggled in bulk into the United States,
DEA has also noted an increase in illegal online pharmacies selling and shipping counterfeit pills made with fentanyl
to unsuspecting customers in the United States who believe they are purchasing real pharmaceutical drugs. See Drug
Enforcement Administration, “DEA Issues Warning About Illegal Online Pharmacies,” 4 October 2024,
https://www.dea.gov/alert/dea-issues-warning-about-illegal-online-pharmacies.
27. See Drug Enforcement Administration, “National Drug Threat Assessment 2024,” May 2024, p. 7,
https://www.dea.gov/sites/default/files/2025-02/508_5.23.2024%20NDTA-updated.pdf.
28. In January 2025, an Indian national and two India-based companies, Raxuter Chemicals and Athos Chemicals, were
charged with criminal conspiracies to distribute and import fentanyl precursor chemicals to the United States. See
U.S. Department of Justice, “Two Indian Chemical Companies and a Senior Executive Indicted for Distributing
Fentanyl Precursor Chemicals,” 6 January 2025, https://www.justice.gov/usao-edny/pr/two-indian-chemical-
companies-and-senior-executive-indicted-distributing-fentanyl.

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BSA Reporting Identified Fentanyl-Related Financial Trends in the

United States
Figure 7. BSA Filing Subjects, by U.S. States, 2024

VT
WA 20 ME
188 39
MT ND
18 11
MN NH
OR 53 NY 27
57 WI 514
ID SD 64 MA
33 6 MI 281
WY 95 CT RI
PA 89 21
11 138
IA
15 OH NJ
NE 200
14 IL IN 131
NV 46 DE
51 141
UT WV VA 22
42 CO 50 112
68 KS MO KY MD
CA 33 54 119
15 NC
845
145 DC
TN 27
87
OK SC
AZ 55 AR 93
160 NM 35
36 GA
AL 206
MS 55
35
TX LA
375 64

FL
698
HI
12

Number within parenthesis represents

AK
total states in listed range 17
100 to 845 (15)
50 to 99 (14)
25 to 49 (10)
0 to 24 (12)

California, Florida, and New York Most Frequently Reported Locations in

Fentanyl-Related BSA Reports
Financial institutions reported fentanyl-related financial activity or BSA report subjects linked to
every U.S. state and Washington, D.C. FinCEN analysis of BSA reporting in the dataset identified
subjects primarily with addresses in California, Florida, and New York. In addition, other states
with large urban areas that have established drug distribution networks and can serve as collection
points for the laundering of illicit proceeds —such as Texas, Massachusetts, Georgia, Washington,
and Illinois—also prominently featured BSA report subjects.

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 F I N A N C I A L T R E N D A N A L Y S I S

• Counties in California (i.e., Los Angeles, Orange, Riverside, San Bernandino, and San Diego)
and Arizona (i.e., Maricopa and Pima) near the southwest border were listed in the address
fields for over 20 different subjects identified in the BSA reports related to fentanyl during the
review period.

• BSA report subjects in Florida were primarily concentrated in the Miami metropolitan area,
including Broward, Miami-Dade and Palm Beach counties. Hillsborough, Orange, and Polk
counties also had at least 20 subjects.

• Bronx, Kings, and Queens counties in New York each had over 50 BSA report subjects in the
dataset. In addition, New York, Suffolk, and Westchester counties each had at least 20 subjects.

• Cook County in Illinois, which includes Chicago, was home to the third most BSA report subject
addresses in the dataset (after Los Angeles and Miami-Dade counties, respectively).

Figure 8. BSA Report Subjects, by U.S. Counties, 2024

Number within parenthesis represents

total states in listed range
20 to 110 (40)
10 to 19 (72)
5 to 9 (98)
0 to 4 (3,009)

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 F I N A N C I A L T R E N D A N A L Y S I S

Suspected U.S.-Based Fentanyl Traffickers Primarily Transacted in Cash and

P2P Transfers
FinCEN analysis of BSA reports involving domestic suspected fentanyl trafficking identified
that cash and P2P transfers were the most commonly referenced financial mechanisms. Cash
activity was referenced in 54 percent of such BSA filings involving suspected U.S.-based fentanyl
traffickers, while P2P transfers were noted in 51 percent.29 Filers often cited prior drug-related
criminal records and recent criminal charges involving their customer(s) to connect the reported
financial transactions to potential fentanyl-related activity.

• BSA filers reported suspected cash deposit structuring activity in nearly 20 percent of cash-
related filings.30 This included BSA report subjects splitting deposits between multiple bank
branch locations, as well as conducting deposits via Automated Teller Machines. In some
instances, filers suspected the comingling of licit and illicit funds in business checking accounts
potentially linked to fentanyl trafficking and money laundering. For example, FinCEN analysis
noted at least 30 references to trucking and transportation companies—many of which were
reported for suspicious cash transactions—amongst BSA reports in the dataset.

• FinCEN analysis of BSA reporting indicates that U.S.-based fentanyl traffickers potentially
utilized electronic payment methods, including P2P platforms, as a potential placement point
for illicit fentanyl proceeds into the U.S. financial system. Based on the range of reported
amounts in BSA reports, utilization of these platforms for suspected fentanyl trafficking
purposes potentially varies from street level dealers to small distributors.

• In certain BSA reports, filers reported P2P transfers that contained payment memos such
as “blues” and “ills” which, in addition to blue dot emojis, are common euphemisms for
counterfeit opioid pills that contain fentanyl.31, 32 Some suspected traffickers also overtly
mentioned fentanyl and other illicit drugs in chats or messages on platforms that support both
communication and financial transactions.

29. Some BSA reports identified subjects conducting both cash and P2P activity.
30. Regulations implementing the BSA require financial institutions to file Currency Transaction Reports (CTRs) for
cash transactions in excess of $10,000 by, through, or to such financial institutions. Structuring occurs when cash
transactions are broken up for the purpose of evading the CTR requirement.
31. FinCEN analysis of BSA reporting identified other potential fentanyl-related references in financial transactions
including blue robot and alien emojis, as well as gas pump and package emojis potentially in reference to the
delivery or shipping of illicit drugs. Terms like “lows,” “shoes,” and “dirty” or “dirty 30s” (potentially an allusion to
counterfeit M30 tablets containing fentanyl) were also noted.
32. See Drug Enforcement Administration, “Emoji Drug Code Decoded,” December 2021,
https://www.dea.gov/sites/default/files/2021-12/Emoji%20Decoded.pdf.

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CVC and Darknet Marketplace-Related Filings Primarily Referenced Bitcoin

FinCEN analysis of BSA reporting identified a potential nexus to CVC in nearly 10 percent of filings
within the dataset, which primarily reported activity involving bitcoin. At least one type of CVC
was mentioned in 85 percent of CVC-related BSA filings. The remaining 15 percent of CVC-related
reports typically identified transfers of potentially illicit funds from traditional bank accounts to
virtual asset service providers (VASPs). In addition, roughly 15 percent of the CVC-related reports
noted activity involving darknet marketplaces suspected of facilitating fentanyl sales.

• FinCEN analysis identified references to bitcoin in 86 percent of BSA reports that referenced at
least one type of CVC. In addition, other CVCs such as Ethereum and Litecoin were noted in 38
and 12 percent of CVC-related reports, respectively.

• Twenty different darknet marketplaces potentially facilitating the sale of fentanyl and other
illicit drugs were referenced in BSA filings. Darknet marketplaces operate on the dark web
and allow users to buy and sell illicit goods using CVCs and anonymizing technologies.33 BSA
filers identifying this activity were primarily VASPs that observed their clients, many of which
had prior drug-related criminal records, transacting with CVC wallets tied to known darknet
marketplaces.

Fentanyl-Linked Money Laundering Schemes Ranged from Simple

to Complex
FinCEN analysis of BSA reporting found that methods to launder suspected fentanyl proceeds
varied in sophistication. Simple schemes—which may have been facilitated by drug trafficking
organizations themselves—included repatriation of suspected fentanyl proceeds through MSB
funds transfers. BSA reports often identified instances of customers sending similar dollar amount
transactions within a short time frame, often on the same days and minutes apart, to the same
counterparties in Mexico. In one BSA report, a filer identified suspicious activity involving an MSB
agent that conducted cash deposits funding outbound funds transfers to Mexico and Guatemala
that were inconsistent with seasonal patterns the filer typically observed.

Complex money laundering schemes tied to suspected fentanyl proceeds were identified in reports
with some of the largest reported amounts in the dataset. In these schemes, fentanyl traffickers
appeared to outsource the laundering process to third-parties or PMLOs that leveraged TBML
techniques to ultimately return value to the cartels.

33. See Federal Bureau of Investigation, “A Primer on Darknet Marketplaces,” 1 November 2016,
https://www.fbi.gov/news/stories/a-primer-on-darknet-marketplaces.

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 F I N A N C I A L T R E N D A N A L Y S I S

Professional Money Laundering Organizations Played Key Role in Moving

Suspected Fentanyl Proceeds
BSA reporting identified suspected PMLOs—including networks comprised of Chinese and
Mexican nationals operating as money couriers—potentially facilitating the laundering of fentanyl
proceeds. PMLOs are typically operated by money brokers that facilitate money laundering on
behalf of clients, such as the cartels, that pay a fee for these services. Chinese money laundering
organizations (CMLOs), a type of PMLO, operate within Chinese underground banking systems
that enable Chinese nationals to acquire U.S. dollars (USD) in the United States while evading
foreign exchange regulations in the PRC.34 CMLOs often use mirror transfers, which involve the
movement of renminbi (RMB) held in Chinese bank accounts by individuals purchasing USD in the
United States. Funds transferred within the PRC can be used to pay for goods exported to Mexico
for the benefit of the cartels and their business partners.35

• BSA reporting identified networks of suspected CMLO money couriers, primarily individuals
with Chinese passports, conducting suspicious financial transactions. The reported activity
included large cash deposits into personal and business checking accounts, including accounts
purportedly associated with legitimate businesses, such as restaurants and salons. Filers often
noted these suspected couriers purchased cashier’s checks with cash as a means of moving
funds between bank accounts. In some instances, these CMLO networks were identified
receiving large volumes of P2P payments from numerous third-party individuals and suspected
shell or front companies for potential laundering purposes.

• One filer identified a network of suspected CMLO money couriers based on travel-related
expenditures potentially indicative of conducting money pickups across the United States,
including booking unusual multi-leg trips to and from various major metropolitan areas. The
filer noted large purchases with airlines, hotels, travel agency websites, tolls and parking
meters, food delivery services, gas stations, and restaurants across the country.

• BSA reports also identified a suspected Mexican money laundering organization that leveraged
a network of Mexican nationals to conduct money pickups throughout the United States. A
filer indicated this organization appeared to use counterfeit Mexican passports to establish
fictitious businesses and bank accounts that were ultimately used to receive suspicious cash
deposits. The funds were subsequently remitted via bank wire transfers to several Mexico-
based companies, including a purported financial technology firm.

34. PRC foreign exchange rules cap the maximum amount of RMB individuals are allowed to convert into other
currencies at approximately $50,000 per year. Chinese citizens are also restricted from directly transferring RMB
abroad without prior approval from PRC’s State Administration of Foreign Exchange (SAFE). See U.S. Department
of State, “2024 Investment Climate Statements: PRC,” 2024, https://www.state.gov/reports/2024-investment-climate-
statements/PRC/.
35. FinCEN has previously detailed typologies related to TBML/Black Market Peso Exchange schemes involving Mexican
criminal organizations. See “FinCEN Advisory to Financial Institutions on Illicit Financial Schemes and Methods
Related to the Trafficking of Fentanyl and Other Synthetic Opioids,” FinCEN Advisory #FIN-2019-A006, 21 August
2019, https://www.fincen.gov/resources/advisories/fincen-advisory-fin-2019-a006.

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Suspected Trade-Based Money Laundering Schemes Leveraged Electronics

and Vapes
BSA filers identified suspected cartel-linked TBML schemes that appeared to leverage strong
consumer demand for electronics, including cellular phones, and vaping/e-cigarette devices.36
Black Market Peso Exchange (BMPE)-related activity was also suspected by several filers that
identified goods being shipped to drug-source countries, such as Mexico. Despite suspected
TBML/BMPE only being referenced by BSA filers in 2 percent of the reports within the dataset,
these reports accounted for nearly 42 percent of the aggregate reported amount.

• BSA reporting identified a suspected TBML/BMPE scheme involving a network of Colombia-,

Mexico-, and U.S.-based companies purportedly involved in the wholesale acquisition of
electronics and vaping/e-cigarette devices from a PRC-based supplier. The reported financial
activity, which occurred between 2022 and 2024, identified U.S.-domiciled accounts receiving
cash and checks deposits, automated clearing house (ACH), wire, and P2P transfers from
numerous third parties that ultimately funded outgoing wire transfers to a PRC-based
company. The filer noted the U.S.-based companies, owned by Chinese nationals, appeared
to be linked via online banking logins conducted through a shared device, despite these
companies being incorporated by seemingly unrelated individuals in different states.

• Another network of U.S.-based, wholesale electronics companies sharing common ownership

was reported under the BSA for suspected TBML/BMPE activity in 2024. The involved bank
accounts were primarily funded by large cash deposits and incoming ACH and wire transfers—
often containing invoice numbers and references to “mobile phones”—from foreign companies
located in Hong Kong, the United Arab Emirates, and Mexico (specifically Culiacan, Sinaloa).
The filer further noted a pattern in which the reported BSA subjects had previously received
round dollar wire transfers from other Mexico-based companies for a period of roughly two
months before transactions with those counterparties ceased.

36. Media reporting suggests the cartels maintain significant interest in Mexico’s vape/e-cigarette market amid the
Mexican government’s push to ban the importation and sale of such devices. See “Sinaloa Cartel Turf War Between
Chapitos and Mayiza Expands to Mexico’s Contested Vape Market,” The Latin Times, 21 December 2024, https://www.
latintimes.com/chapitos-mayiza-turf-war-expands-mexicos-soon-illegal-e-cigarette-market-570005.

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Figure 9. Composite PMLO/TBML Money Flows in Fentanyl-Related BSA Filings, 2024

Mexico-Based
Importer
Mexico-Based
Money Broker
Mexican Cartel Mexico-Domiciled
Bank Accounts

NTAN Front/Shell Financial

U.S.-Based Companies Technology Firm

FE

YL
Cell Phones
Money Broker U.S.-Based Vapes/E-Cigarettes
Drug Trafficking
Organization
Leader / Coordinates
Money Pick-ups
U.S.-Domiciled
Bank Accounts Account
Outflow

Cashier’s Checks
U.S.-Based and Foreign
U.S.-Based Businesses Wholesalers
Money Couriers
Peer-to-Peer
Transfers
Personal Accounts

Wire Transfers
Various
Individuals
Shell Companies
These transactions may be repeated
several times over to layer the activity Real Automobiles
Estate

PRC-Based PRC-Domiciled Payments (within Chinese

Exporter Bank Accounts LEGEND Financial System) Casino
Tuition Gaming
Goods Money Relationships

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The information in this report is based on fentanyl-related information obtained from analysis
of BSA data, and open-source publications, as well as insights from law enforcement and other
partners. FinCEN welcomes feedback on this report, particularly from financial institutions.
Please submit feedback to the FinCEN Regulatory Support Section at www.fincen.gov/contact.

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