On November 13, 2025, the U.S. Department of the Treasury’s (“Treasury’s”) Financial Crimes Enforcement Network (“FinCEN”) issued a finding (“Finding”) and related notice of proposed rulemaking (“Proposed Rule”) pursuant to Section 311 of the USA PATRIOT Act (“Section 311”), targeting ten Mexico-based gambling establishments (“Gambling Establishments”). FinCEN found transactions involving the Gambling Establishments to constitute a “class of transactions” of “primary money-laundering concern” for purposes of Section 311. In particular, FinCEN found that the Gambling Establishments ultimately were controlled by a criminal group that used the establishments to facilitate money laundering for the Sinaloa Cartel.
