FinCEN Deputizes Financial Institutions in Hunt for Environmental Crimes

The Financial Crimes Enforcement Network (“FinCEN”) unit of the U.S. Department of the Treasury called this week for the nation’s financial institutions to be on the lookout for money flows indicative of environmental crimes. The Notice links environmental crimes to FinCEN’s traditional missions of combatting corruption and international terrorism and money-laundering, but also expressly recites a new ESG mission due to “environmental crimes’ contribution to the climate crisis, including threatening ecosystems, decreasing biodiversity, and increasing carbon dioxide in the atmosphere.”

The Notice cites statistics ranking environmental crimes as the third largest illicit activity world-wide, behind only trafficking in drugs and counterfeit goods, and the leading source of illicit income in conflict zones.

The Notice provides financial institutions with specific instructions for filing environmental-crime suspicious activity reports and describes various categories of suspicious activities.

Earlier in the week, FinCEN convened a virtual exchange on the issue.

FinCEN Notice FIN-2021-NTC4 (Nov. 18, 2021) can be found here.

Thomas K. Potter, III ( is a partner in the Securities Litigation Practice Group at Burr & Forman LLP. Tom is licensed in Tennessee, Texas, and Louisiana. He has over 35 years of experience representing financial institutions in litigation, regulatory, and compliance matters. 

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