FinCEN Issues Alert on Foreign-Agent-Directed Payments and Notice on Charity Abuse

FinCEN issued Alert FIN-2026-Alert009 on suspicious cross-border payments involving U.S.-based money services businesses and Notice FIN-2026-NTC2 on the exploitation of charities and non-profit organizations for terrorist financing, fraud and other illicit activity. The documents identify risks and request that relevant suspicious activity reports include FIN2026FOREIGNAGENT or FIN2026NPO, respectively, in SAR field 2 and the narrative. FinCEN emphasizes individual, risk-based assessments: neither money services businesses nor the non-profit sector should be treated as uniformly high risk.