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"On June 30, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued an alert (the “Alert”), alongside a press release, outlining efforts to combat fiscal fuel theft (known in Mexico as “huachicol fiscal”) along the U.S.-Mexico border.  In simplest terms, fiscal fuel theft occurs when fuel is smuggled from the U.S. to Mexico to evade Mexico’s import tax."

"FinCEN’s action is part of U.S. law enforcement’s broader effort to curtail money laundering activities by Mexico-based cartels,” including the Jalisco New Generation Cartel (CJNG), the Sinaloa Cartel, and the Gulf Cartel— a subject we have previously covered. The Alert supplements FinCEN’s May 2025 alert on the topic and it provides updates in methodologies used in the operation and on new sanctions imposed by the Treasury’s Office of Foreign Assets Control (“OFAC”).  FinCEN’s alerts describe a scheme to bypass Mexican energy regulations, evade taxes, and undercut the fuel market, while relying on U.S. financial institutions to process transactions. In response, U.S. financial institutions operating in oil and gas markets along the southern border should remain vigilant in their due diligence and their reporting obligations."

"Background: How Cartels Smuggle and Commercialize U.S. Fuel in Mexico"

"Mexico’s regulatory and economic programs have led to an expensive and concentrated market for fuel products. Cartels are taking advantage of rising costs by smuggling fuel across the southern border to evade Mexican import taxes while using the excess profits to advance their enterprises."

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