FinCEN Regulatory Alert: $37 Million Civil Penalty Against Brink's Global Services USA, Inc.

Written By Justin Muscolino
 
 

Summary: The Financial Crimes Enforcement Network (FinCEN) has issued a $37 million civil money penalty against Brink’s Global Services USA, Inc. (Brink’s) for willful violations of the Bank Secrecy Act (BSA). This enforcement action marks FinCEN’s first-ever penalty against an armored car company, highlighting serious AML lapses that exposed the U.S. financial system to significant money laundering risks.

Impacted Parties / Organizations

  • Armored Car & Cash Transport Services – Must ensure full compliance with BSA and AML regulations.
  • Financial Institutions & MSBs – Should reassess partnerships with cash transport providers for regulatory adherence.
  • Compliance & Risk Management Teams – Must strengthen oversight of high-risk currency transactions.
  • Legal & Regulatory Professionals – Need to evaluate exposure to enforcement risks and review AML programs.

Key Violations & Findings

  • Failure to Register as a Money Services Business (MSB): Brink’s operated without proper FinCEN registration, evading regulatory scrutiny.
  • Deficient AML Program: The company failed to develop, implement, and maintain an effective AML program, leaving bulk currency shipments vulnerable to abuse.
  • Lack of Suspicious Activity Reporting: Brink’s neglected to file required
  • Suspicious Activity Reports (SARs) despite handling high-risk transactions.
  • Southwest Border Money Laundering Risks: Hundreds of millions of dollars in bulk currency shipments facilitated potential illicit financial activity, including transactions for a Mexican currency exchanger later convicted of BSA violations.

Regulatory & Enforcement Implications

  • Stronger AML Oversight on Cash Transport Services: FinCEN’s action signals increased scrutiny of companies handling bulk cash transactions.
    Heightened Compliance Expectations: Financial institutions working with armored car services must verify AML controls and reporting obligations.
    Mandatory AML Program Review: Brink’s is now subject to a comprehensive AML program assessment as part of FinCEN’s resolution.

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Justin Muscolino https://highriskeducation.com
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