On February 6, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) imposed a $37 million civil money penalty against Brink’s Global Services USA, Inc. for anti-money laundering (“AML”) deficiencies that existed at the company from approximately October 7, 2018 to October 22, 2020 (“the Relevant Time Period”). This FinCEN’s first enforcement action against an armored car company.
According to FinCEN, during the relevant time period, Brink’s operated as a money transmitter helping high-risk entities move hundreds of millions of dollars in bulk currency across the Southwest Border of the United States without an adequate AML program in place – an act that exposed the U.S. financial system to potential money laundering activity, including narcotics trafficking. FinCEN accused Brink’s of willfully violating the Bank Secrecy Act (“BSA”) for failing to register as a money services business; failing to maintain an effective AML program; and failing to file suspicious activity reports (“SARs”). According to FinCEN, Brink’s ignored its obligation to register as a money transmitting business and allegedly failed to file any SARs during the relevant time period, despite the company’s repeated transport of bulk currency shipments from Mexican entities – shipments for which Brink’s purportedly made no effort to determine the source.
In addition to the payment of a civil money penalty to FinCEN, Brink’s must submit a plan to improve its AML program and, among other things, is subject to an AML program review by an independent consultant who must report on the adequacy of the program within a year of engagement.
On the same day, Brink’s reached a resolution with the Department of Justice to settle a parallel criminal action filed against the company for BSA violations. In its Non-Prosecution Agreement with the DOJ, Brink’s was ordered to forfeit more than $50 million for failing to register as a money transmitting business. After receiving credit for reaching a swift resolution and accepting responsibility for its actions, Brink’s will owe the DOJ approximately $20 million provided that the company implements a new compliance program. While FinCEN imposed a $37 million penalty on Brink’s, FinCEN agreed to credit the company for the $20 million it will pay to the DOJ, leaving the company with a payment of $17 million owed to the U.S. Treasury.
FinCEN Press Release | Consent Order | DOJ Press Release | Non-Prosecution Agreement