Banking and Finance Law Daily Wrap Up, BANK SECRECY ACT—FinCEN bars MEXC Global fund transfers starting December 10, (Nov 9, 2026)

By Charles A. Menke, J.D.

The order covers convertible virtual currency (CVC) and has no cessation date; existing suspicious-activity reporting and sanctions obligations remain unchanged for covered institutions.

The Financial Crimes Enforcement Network (FinCEN) has issued an order that will prohibit covered domestic financial institutions from sending or receiving funds to or from defined foreign MEXC Global operations. Treasury announced the action as part of Operation Economic Outcast after finding reasonable grounds to conclude that MEXC Global, a CVC exchanger founded in 2018 and incorporated in the Seychelles, is of primary money laundering concern in connection with Russian illicit finance. The order takes effect Dec. 10, 2026.

FinCEN determined that MEXC Global facilitated at least $16.7 billion in likely illicit activity since May 2021. From May 2021 through May 2026, FinCEN reported $16.7 billion in funds connected to Russian illicit finance and other illicit activities, including sanctions evasion and cybercrime. The agency’s finding cites transfers involving Russia-affiliated illicit actors, sanctions evasion, and Russian darknet-market activity.

Although FinCEN acknowledged it lacked full insight into MEXC Global’s legitimate activities and assumed some of its business is legitimate, it nevertheless concluded that the risks from the likely illicit activity and the need to protect the U.S. financial sector outweighed that legitimate business. FinCEN said additional recordkeeping or reporting would let risky transfers continue. It also concluded that correspondent- or payable-through-account restrictions would not adequately reach transfers outside those relationships, including potential indirect U.S.-dollar access through other foreign institutions.

Scope and compliance. The order identifies covered actors as domestic financial institutions and domestic financial agencies and its transfer prohibition reaches the sending and receiving funds, including convertible virtual currency. MEXC Global’s defined scope includes branches, subsidiaries, and offices operating as financial institutions outside the U.S., along with successor entities. U.S.-located branches, subsidiaries, and offices are expressly excluded; the order’s explanatory discussion also excludes U.S. affiliates.

FinCEN reserved the authority to impose conditions on certain transfers and grant appropriate exemptions. The order leaves covered institutions’ existing Bank Secrecy Act obligations, including Suspicious Activity Report filing, unchanged. It also preserves obligations under other applicable laws and regulations, including sanctions administered and enforced by Treasury’s Office of Foreign Assets Control. Covered institutions and their officers, directors, employees, and agents are subject to civil or criminal penalties for willfully violating the order.

Companies: MEXC Global

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