Brink’s Global Services Faces Penalties for Bank Secrecy Act Violations & Unlicensed Money Transmitting

Key Takeaways

• Brink’s Faces Major Penalties: Brink’s Global Services USA has agreed to a $37 million civil penalty and a $50 million forfeiture due to multiple violations of the Bank Secrecy Act (BSA), marking the first such case involving an armored car company.
• Failure to Implement AML Controls: Brink’s engaged in willful violations by transporting large sums of money without the necessary anti-money laundering (AML) controls, exposing the U.S. financial system to significant risks, including money laundering and narcotics trafficking.
• Illegal Transactions and Noncompliance: Brink’s illegally transmitted funds both domestically and internationally without verifying the legitimacy of recipients, including cross-border currency transport between the U.S. and Mexico, failing to adhere to BSA regulations.
• Collaborative Investigation: The investigation was a coordinated effort between the U.S. Attorney’s Office, Homeland Security Investigations, and U.S. Customs and Border Protection, highlighting the importance of inter-agency cooperation in tackling financial crimes.

Deep Dive

Brink’s Global Services USA, Inc. (BGS), a well-known name in currency transport, is paying the price for serious compliance failures. The company has agreed to millions in penalties following multiple violations of the Bank Secrecy Act (BSA), a key piece of U.S. anti-money laundering (AML) law. This settlement includes a $37 million civil penalty levied by the Financial Crimes Enforcement Network (FinCEN) and a $50 million forfeiture linked to criminal charges for operating as an unlicensed money transmitter.

This is a case—the first of its kind involving an armored car company—and it’s sending a message to organizations that noncompliance with the BSA can result in substantial financial and reputational damage.

A Breakdown of the Violations

So, what happened? According to FinCEN, Brink’s engaged in a pattern of willful violations, moving large sums of money across U.S. borders without the necessary AML controls in place. This exposed the U.S. financial system to significant risks, including money laundering, narcotics trafficking, and other illicit activities.

For example, Brink’s transported hundreds of millions of dollars in bulk currency across the U.S.-Mexico border for high-risk entities, including a Mexican currency exchange that later pleaded guilty to violating the BSA. In doing so, Brink’s failed to register with FinCEN as a money services business, didn't implement an effective AML program, and neglected to file suspicious activity reports.

In short, Brink’s failed to follow the rules designed to monitor illicit financial flows, leaving a glaring hole in the regulatory framework.

A Series of Inadequate Transactions

The violations didn’t stop at border crossings. Brink’s also admitted to illegally transmitting funds domestically and internationally without the proper safeguards. One example: Brink’s moved over $15 million from a money service business in San Diego to another in Florida across 12 transactions—but failed to verify the legitimacy of the final recipients. This is a basic requirement under the law, and it was ignored.

Additionally, Brink’s was involved in importing more than $35 million in currency from Mexico into the U.S. The company worked with other transporters to facilitate these cross-border transactions, but none of them ensured compliance with BSA regulations. The result? A series of illegal money transmissions that bypassed U.S. law.

Holding Brink’s Responsible

The Department of Justice’s U.S. Attorney’s Office for the Southern District of California was instrumental in bringing Brink’s to account. First Assistant U.S. Attorney Andrew Haden made it clear that this case "closes a back door where cash covertly entered the global financial system." It’s a reminder that businesses like Brink’s must adhere to BSA reporting requirements to prevent illegal activity and maintain the integrity of the financial system.

Shawn Gibson, Special Agent in Charge of Homeland Security Investigations (HSI) San Diego, emphasized the collaborative nature of this investigation. It wasn’t just one agency—it was a team effort to expose these violations. Sidney Aki, Director of Field Operations for U.S. Customs and Border Protection (CBP) San Diego, noted how these cross-border financial crimes were disrupted thanks to the partnerships between various law enforcement agencies.

As Brink’s settles the case without admitting criminal guilt, it faces the financial consequences of its actions. But this settlement serves as yet another reminder to other businesses in the financial and currency transport industries that noncompliance with regulatory frameworks like the BSA can be incredibly costly.

For Brink’s, this resolution is just the beginning of dealing with the long-term impact of its violations. As the financial sector faces a growing wave of regulatory enforcement, companies must be proactive in tightening their compliance controls to avoid becoming the next target.

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