Sam Cooper

The U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) has identified $1.4 billion in fentanyl-linked suspicious transactions, naming China, Mexico, Canada, and India as key foreign touchpoints in the global production and laundering network. The analysis, based on 1,246 Bank Secrecy Act filings submitted in 2024, tracks financial activity spanning chemical purchases, trafficking logistics, and international money laundering operations.

The data reveals that Mexico and the People’s Republic of China were the two most frequently named foreign jurisdictions in financial intelligence gathered by FinCEN. Most of the flagged transactions originated in U.S. cities, the report notes, due to the “domestic nature” of Bank Secrecy Act data collection. Among foreign jurisdictions, Mexico, China, Hong Kong, and Canada were cited most often in fentanyl-related financial activity.

The FinCEN report points to Mexico as the epicenter of illicit fentanyl production, with Mexican cartels importing precursor chemicals from China and laundering proceeds through complex financial routes involving U.S., Canadian, and Hong Kong-based actors.

The findings also align with testimony from U.S. and Canadian law enforcement veterans who have told The Bureau that Chinese state-linked actors sit atop a decentralized but industrialized global fentanyl economy—supplying precursors, pill presses, and financing tools that rely on trade-based money laundering and professional money brokers operating across North America.

“Filers also identified PRC-based subjects in reported money laundering activity, including suspected trade-based money laundering schemes that leveraged the Chinese export sector,” the report says.

A point emphasized by Canadian and U.S. experts—including former U.S. State Department investigator Dr. David Asher—that professional Chinese money laundering networks operating in North America are significantly commanded by Chinese Communist Party–linked Triad bosses based in Ontario and British Columbia—is not explored in detail in this particular FinCEN report.¹

Chinese chemical manufacturers—primarily based in Guangdong, Zhejiang, and Hebei provinces—were repeatedly cited for selling fentanyl precursors via wire transfers and money service businesses. These sales were often facilitated through e-commerce platforms, suggesting that China’s global retail footprint conceals a lethal underground market—one that ultimately fuels a North American public health crisis. In many cases, the logistics were sophisticated: some Chinese companies even offered delivery guarantees and customs clearance for precursor shipments, raising red flags for enforcement officials.

While China’s industrial base dominates the global fentanyl supply chain, Mexican cartels are the next most prominent state-like actors in the ecosystem—but the report emphasizes that Canada and India are rising contributors.

“Subjects in other foreign countries—including Canada, the Dominican Republic, and India—highlight the presence of alternative suppliers of precursor chemicals and fentanyl,” the report says.

“Canada-based subjects were primarily identified by Bank Secrecy Act filers due to their suspected involvement in drug trafficking organizations allegedly sourcing fentanyl and other drugs from traditional drug source countries, such as Mexico,” it explains, adding that banking intelligence “identified activity indicative of Canada-based individuals and companies purchasing precursor chemicals and laboratory equipment that may be related to the synthesis of fentanyl in Canada. Canada-based subjects were primarily reported with addresses in the provinces of British Columbia and Ontario.”

FinCEN also flagged activity from Hong Kong-based shell companies—often subsidiaries or intermediaries for Chinese chemical exporters. These entities were used to obscure the PRC’s role in transactions and to move funds through U.S.-linked bank corridors.

Breaking down the fascinating and deadly world of Chinese underground banking used to move fentanyl profits from American cities back to producers, the report explains how Chinese nationals in North America are quietly enlisted to move large volumes of cash across borders—without ever triggering traditional wire transfers.

These networks, formally known as Chinese Money Laundering Organizations (CMLOs), operate within a global underground banking system that uses “mirror transfers.” In this system, a Chinese citizen with renminbi in China pays a local broker, while the U.S. dollar equivalent is handed over—often in cash—to a recipient in cities like Los Angeles or New York who may have no connection to the original Chinese depositor aside from their role in the laundering network. The renminbi, meanwhile, is used inside China to purchase goods such as electronics, which are then exported to Mexico and delivered to cartel-linked recipients.

FinCEN reports that US-based money couriers—often Chinese visa holders—were observed depositing large amounts of cash into bank accounts linked to everyday storefront businesses, including nail salons and restaurants. Some of the cash was then used to purchase cashier’s checks, a common method used to obscure the origin and destination of the funds. To banks, the activity might initially appear consistent with a legitimate business. However, modern AI-powered transaction monitoring systems are increasingly capable of flagging unusual patterns—such as small businesses conducting large or repetitive transfers that appear disproportionate to their stated operations.

On the Mexican side, nearly one-third of reports named subjects located in Sinaloa and Jalisco, regions long controlled by the Sinaloa Cartel and Cartel Jalisco Nueva Generación. Individuals in these states were often cited as recipients of wire transfers from U.S.-based senders suspected of repatriating drug proceeds. Others were flagged as originators of payments to Chinese chemical suppliers, raising alarms about front companies and brokers operating under false pretenses.

The report outlines multiple cases where Mexican chemical brokers used generic payment descriptions such as “goods” or “services” to mask wire transfers to China. Some of these transactions passed through U.S.-based intermediaries, including firms owned by Chinese nationals. These shell companies were often registered in unrelated sectors—like marketing, construction, or hardware—and exhibited red flags such as long dormancy followed by sudden spikes in large transactions.

Within the United States, California, Florida, and New York were most commonly identified in fentanyl-related financial filings. These locations serve as key hubs for distribution and as collection points for laundering proceeds. Cash deposits and peer-to-peer payment platforms were the most cited methods for fentanyl-linked transactions, appearing in 54 percent and 51 percent of filings, respectively.

A significant number of flagged transactions included slang terms and emojis—such as “blues,” “ills,” or blue dots—in memo fields. Structured cash deposits were commonly made across multiple branches or ATMs, often linked to otherwise legitimate businesses such as restaurants, salons, and trucking firms.

FinCEN also tracked a growing number of trade-based laundering schemes, in which proceeds from fentanyl sales were used to buy electronics and vaping devices. In one case, U.S.-based companies owned by Chinese nationals made outbound payments to Chinese manufacturers, using funds pooled from retail accounts and shell companies. These goods were then shipped to Mexico, closing the laundering loop.

Another key laundering method involved cryptocurrency. Nearly 10 percent of all fentanyl-related reports involved virtual currency, with Bitcoin the most commonly cited, followed by Ethereum and Litecoin. FinCEN flagged twenty darknet marketplaces as suspected hubs for fentanyl distribution and cited failures by some digital asset platforms to catch red-flag activity.

Overall, FinCEN warns that fentanyl-linked funds continue to enter the U.S. financial system through loosely regulated or poorly monitored channels, even as law enforcement ramps up enforcement. The Drug Enforcement Administration reported seizures of over 55 million counterfeit fentanyl pills in 2024 alone.

The broader pattern is unmistakable: precursor chemicals flow from China, manufacturing occurs in Mexico, Canada plays an increasing role in chemical acquisition and potential synthesis, and drugs and proceeds flood into the United States, supported by global financial tools and trade structures. The same infrastructure that enables lawful commerce is being manipulated to sustain the deadliest synthetic drug crisis in modern history.