On November 13, 2025, FinCEN issued a finding and notice of proposed rulemaking that identifies transactions involving ten identified Mexico-based gambling establishments as a class of transactions to be of primary money laundering concern. FinCEN proposes to limit these gambling establishments' access to the U.S. financial system by prohibiting covered financial institutions from opening accounts for foreign banks that process transactions for these ten gambling establishments.
The ten gambling establishments identified as major money laundering risks, which all operate in Mexico and offer gambling services, include the following:
Emine Casino (San Luis Rio Colorado, Sonora)
Casino Mirage (Culiacan, Sinaloa)
Midas Casino (Agua Prieta, Sonora)
Midas Casino (Guamúchil, Sinaloa)
Midas Casino (Los Mochis, Sinaloa)
Midas Casino (Mazatlan, Sinaloa)
Midas Casino (Rosarito, Baja California)
Palermo Casino (Nogales, Sonora)
Skampa Casino (Ensenada, Baja California)
Skampa Casino (Villahermosa, Tabasco)
FinCEN believes that Gambling Establishments are ultimately controlled by the Sinaloa Cartel, facilitating money laundering through complex international financial networks. For over six years, the senior leadership of these establishments has conducted transactions that benefit the cartel under the direction of its members and affiliates. FinCEN, therefore, proposes to impose a special measure to prohibit U.S. financial institutions from opening or maintaining a correspondent account for any foreign banking institution if such account is used to process transactions involving any of the gambling establishments; and require U.S. financial institutions to apply special due diligence to their correspondent accounts that is reasonably designed to guard against the use of such accounts to process transactions involving any of the gambling establishments.
The NPRM does not propose a new or amended SAR reporting obligation. However, consistent with their existing SAR reporting obligations, covered financial institutions may consider, as warranted and appropriate, FinCEN’s finding that transactions involving the gambling establishments targeted today are a class of transactions of primary money laundering concern.
Written comments on the notice of proposed rulemaking will be accepted until December 17, 2025.
Read FinCEN’s press release here.
The full NPRM can be found here.