In 2024, financial institutions (FIs) submitted over 1,200 Bank Secrecy Act (BSA) reports, identifying approximately $1.4 billion in suspicious transactions related to suspected fentanyl activity. Recent actions by the Financial Crimes Enforcement Network (FinCEN) and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) signal probable growth in these report submissions:
- The first actions by FinCEN under the Fentanyl Eradication and Narcotics Deterrence (FEND) Off Fentanyl Act identified three Mexico-based FIs as being of primary money laundering concern in connection with illicit opioid trafficking. Covered financial institutions are prohibited from engaging in transmittals of funds from or to these institutions.
- OFAC recently sanctioned Mexican individuals and companies involved in supplying illicit fentanyl precursor chemicals to the Sinaloa Cartel. FIs, among others, risk exposure to sanctions for engaging in certain transactions involving these entities.
Regulatory expectations for FIs to guard against fentanyl trafficking are growing, requiring these institutions to ensure they’re not participating in the fentanyl supply chain.
>> Get techniques for mapping cartel-linked shell companies and tracing precursor chemicals <<
Identifying red flags in an evolving illicit supply chain
After the PRC government scheduled all fentanyl-related substances as a class in May 2019, purchase and shipment of illicit fentanyl and other synthetic opioids from the PRC declined. Mexico-based transnational criminal organizations (TCOs) filled this void to become the predominant traffickers of these drugs into the U.S. These TCOs purchase fentanyl precursor chemicals and manufacturing equipment primarily from PRC-based suppliers and then synthesize the opioids in Mexican labs.
FIs must be on the hunt for red flags, including trade typologies, that may signal illicit drug trafficking.
Some trade typologies — import and export of DEA List 1 chemicals or a high proportion (or certain combinations) of known essential chemical imports — are fairly obvious red flag indicators of increased risk for precursor chemical diversion.
Other red flags are more challenging to detect.
Case study: Identifying anomalous shipments of precursors
In a 2024 advisory, FinCEN identified this red flag:
“A customer is a Mexican company that does not appear to be involved in the chemical manufacturing and pharmaceutical industries despite transactional activity indicating the procurement of fentanyl precursor chemicals and associated manufacturing equipment.”
Detecting this red flag requires the ability to identify anomalous shipments, which in turn requires comprehensive insight into an entity’s trade history.
In 2022, a Mexican news outlet reported an investigation into three companies, including Corporativo Y Enlance Ram, for supplying precursor chemicals to cartels. Investigating Corporativo Y Enlance Ram in Sayari Graph, the company at first appears to be a benign trading firm dealing in consumer goods like toys and sports equipment, a deeper look at its trade history reveals unusual chemical shipments.
Corporativo Y Enlance Ram imported at least five shipments of sodium borohydride, a chemical added to the DEA’s Special Surveillance List in 2023 due to its use in fentanyl production, from a Chinese supplier between May 2024 and January 2025. Further investigation uncovered significant volumes of methylformamide and tartaric acid imports from the same supplier. These chemical shipments are anomalous given the company’s primary business, raising serious questions about the ultimate use of these chemicals, although trade data alone cannot confirm diversion for illicit drug production.
To meet regulatory expectations, FIs must cast a wider investigative net beyond a single, perhaps innocuous, transaction to include an entity’s trade history.
How Sayari helps FIs screen for fentanyl precursors
FIs must monitor entities and transactions for many red flags. Searching across multiple databases to uncover these red flags is time- and resource-intensive.
Effective disruption of the fentanyl supply chain requires a single comprehensive view of the actors, infrastructure, and trade flows involved. Platforms like Sayari Graph make this possible by integrating commercial, corporate, and trade data into a unified investigative environment, illuminating the networks behind today’s illicit drug supply chains.
Sayari solutions help FIs conduct proactive screening to identify red flags indicative of illicit drug activity and remain on top of regulatory actions. To turn findings into enforcement, Sayari also helps FIs deliver actionable intelligence in their Suspicious Activity Reports (SARs) by integrating corporate and trade data to produce evidence-backed narratives that empower government agencies to act decisively.
To learn how Sayari can help your institution detect and comprehensively report on illicit drug activity, request a personalized demo.
