Quick Facts
Overview
The Financial Crimes Enforcement Network (FinCEN) imposed a $37 million civil money penalty on Brink’s Global Services USA, Inc. (Brink’s), a subsidiary of The Brink’s Company, for violations of the Bank Secrecy Act (BSA).
The action stems from Brink’s operating as an unregistered money services business (MSB) while transporting bulk currency shipments domestically and across borders, failing to implement an effective anti-money laundering (AML) program, and neglecting to file suspicious activity reports (SARs) on potentially illicit transactions.
Details of the Case
Brink’s, a provider of secure transportation for currency and valuables, conducted activities that qualified it as a money transmitter under BSA regulations, including cross-border and domestic shipments of U.S. dollars and other currencies.
These activities exceeded the narrow exemption for common carriers of currency, such as armored car services, which applies only to shipments from one person to the same person or their account at a financial institution, with no more than a custodial interest. Despite prior warnings from U.S. law enforcement between 2011 and 2017 about the need to register as an MSB, Brink’s continued operations without registering, implementing an AML program, or filing SARs.
This included facilitating approximately $800 million in bulk currency transactions involving Mexico, Spain, and the United States. Brink’s admitted to facts in a January 31, 2025, non-prosecution agreement with the Department of Justice but neither admitted nor denied other facts in the FinCEN consent order.
The violations exposed the financial system to risks of money laundering, as Brink’s failed to verify currency originators, consignees, or transaction purposes, potentially enabling illicit funds to move undetected.
WORKED EXAMPLES
Failure to Register Despite Warnings (October 2017)
In October 2017, Brink’s Inc. represented to U.S. law enforcement that the company was not registered with FinCEN, claiming none of its transactions required MSB registration. Law enforcement disagreed, advising review of FinCEN rulings, yet Brink’s continued unregistered operations.
- This followed at least seven engagements from June 2011 to October 2017 on Mexican criminal organisations exploiting armored car services for money laundering after U.S. dollar deposit restrictions in Mexico.
- Impact: Enabled ongoing unregistered activity, facilitating $800 million in bulk shipments without BSA compliance.
Cross-Border Currency Shipments Outside Exemption (2018–2020)
Brink’s transported bulk U.S. dollar shipments from Mexico to the United States via affiliate Servicio Pan Americano de Protección S.A. de C.V., then within the U.S., where originators and consignees were not the same party nor linked to the originator’s account.
- Involved shipments to third-party consignees, violating the 2014 FinCEN administrative ruling's conditions for exemption.
- Quantitative detail: Part of approximately $800 million in transactions, including those with Spain, exceeding the custodial-only requirement.
Domestic Shipments as Unregistered MSB (2018–2020)
Brink’s handled domestic bulk currency transports that did not meet exemption criteria, such as picking up from a financial institution and delivering to a currency originator, or vice versa, without third parties.
- Failed to obtain information on currency originators or confirm wholly domestic nature, as required for exceptive relief.
- Impact: Brink’s could not ascertain true sources or beneficiaries, leading to potential evasion of BSA reporting and risking money laundering facilitation.
Ignored Law Enforcement Outreach (June 2011–October 2017)
U.S. law enforcement conducted outreach with Brink’s on armored car exploitation by criminal groups, yet Brink’s did not adjust its model to comply with MSB requirements.
- No less than seven engagements highlighted risks post-Mexican U.S. dollar deposit restrictions.
- Result: Continued shipments without registration, AML program, or SAR filings during the relevant period.
Bulk Transaction Facilitation (2018–2020)
Brink’s shipped approximately $800 million in bulk currency as an unregistered MSB, enabling cross-border movements from Mexico and Spain to the U.S., and domestic transports.
- Activities included secure air, sea, and ground transport, often involving third parties not qualifying for exemption.
- Breakdown: Regularly failed to verify if services fell outside the limited armored car exception, exposing the firm to willful violation findings.
Fines and Penalties
Key Quotes
"Brink’s was aware that its business required registration with FinCEN and compliance with BSA regulations, but failed to comply or modify its business model to cease engaging in the money transmission activities giving rise to Brink’s obligation to register with FinCEN as an MSB." (From the FinCEN Consent Order)
"[W]hen operating outside of the strict scope of the common carrier exemption from money transmission, currency transporters may also be a money transmitter under FinCEN’s regulations." (From the 2014 FinCEN Administrative Ruling cited in the Consent Order)
"Throughout the Relevant Time Period, Brink’s facilitated the shipment of approximately $800 million of bulk currency transactions as an unregistered MSB (i) enabling cross-border currency shipments involving Mexico, Spain, and the United States, and (ii) facilitating domestic currency shipments." (From the FinCEN Consent Order)
Sources
