WASHINGTON, DC (December 2, 2025) |
Today, the Defense Credit Union Council, DCUC, sent a letter to the U.S. Treasury expressing concern over FinCEN’s November 28, 2025, alert on “Cross-Border Funds Transfers Involving Illegal Aliens.”
While DCUC supports efforts to combat illicit finance, DCUC President/CEO Anthony Hernandez cautioned that the alert, without clearer guidance, could unintentionally disrupt lawful transactions made by servicemembers, veterans, and their families, many of whom rely on cross-border transfers during deployments and relocations.
Hernandez warned that the alert’s broad scope and limited clarity may lead financial institutions to “over-comply” by flagging or blocking legitimate transfers, filing unnecessary Suspicious Activity Reports, or restricting routine remittances. These unintended consequences could delay or deny mission-critical financial support for military families, creating hardship and undermining financial readiness.
To prevent such disruptions, Hernandez urged the Treasury to adopt three key measures:
- Targeted Guidance: Clear instructions for military-serving banks and credit unions on how to comply without impeding lawful transactions, including risk indicators and reassurance that routine military-related remittances are not the alert’s focus.
- Clarification for Military Transfers: A formal statement that transfers involving U.S. servicemembers, veterans, or their lawful family members should not be treated as suspicious based solely on geography or immigration status.
- Regulatory Safe Harbor: Temporary protection for institutions acting in good faith while implementing the alert, helping them serve military families without fear of penalties.
In DCUC’s letter, Hernandez reminded of the unique impact credit unions have serving populations on or near military installations worldwide, noting that remittances (over $72 billion in 2024) are essential to many military households. Without refining, the alert risks harming the very individuals and members who defend our nation.
“DCUC stands ready to assist Treasury and FinCEN in clarifying the alert’s implementation to ensure national security goals are met without disrupting lawful financial support for servicemembers, veterans, and their families. We appreciate Treasury’s attention to this and urge swift action to protect and prioritize military financial readiness,” says Anthony Hernandez, DCUC President/CEO.