FinCEN has cut MEXC Global off from the US financial system. In an order issued on 6 November 2026 under section 9714 of the Combating Russian Money Laundering Act, FinCEN found that MEXC Global is a financial institution of primary money laundering concern in connection with Russian illicit finance and prohibited every covered financial institution from engaging in any transmittal of funds from or to it. The order takes effect 30 days after it is published in the Federal Register. Money transmitters, banks and crypto firms have that window to find their exposure and block it.
What the order says
The order rests on section 9714(a), as amended in 2022, which lets the Treasury impose special measures on a foreign financial institution linked to Russian illicit finance. FinCEN chose the strongest of them: a prohibition on transmittals of funds, rather than extra recordkeeping or limits on correspondent accounts.
| Item | Position |
|---|---|
| Legal basis | Section 9714(a) of the Combating Russian Money Laundering Act, as amended by section 6106(b) of the NDAA for FY2022 |
| Finding | MEXC Global is of primary money laundering concern in connection with Russian illicit finance |
| Measure | Covered financial institutions may not engage in any transmittal of funds from or to MEXC Global |
| Who is covered | Any "financial institution" as defined in 31 CFR 1010.100(t) |
| Transmittal of funds | Sending and receiving of funds, including convertible virtual currency (CVC) |
| Effective | 30 days after Federal Register publication, with no cessation date |
| Penalties | Civil and criminal penalties under 31 U.S.C. 5321 and 5322 for wilful violation |
FinCEN describes MEXC Global as a CVC exchanger founded in 2018, incorporated in the Seychelles without a virtual asset licence, operating in more than 170 countries and processing more than USD 1 billion a day as of June 2026. It found that MEXC facilitated USD 16.7 billion in funds connected to Russian illicit finance and other illicit activity between May 2021 and May 2026, including transactions with the sanctioned exchanges Garantex and Grinex and the A7 network, and billions of dollars of transactions benefitting Iran, North Korean facilitators and cybercrime actors.
Who is covered
The order uses the Bank Secrecy Act definition of "financial institution" in 31 CFR 1010.100(t). That definition is broad. It includes banks, savings associations and credit unions, broker-dealers, futures commission merchants, casinos, card clubs and money services businesses. Every US-registered crypto exchange, crypto kiosk operator, stablecoin payment firm and money transmitter registered with FinCEN as an MSB is therefore in scope, whether or not it ever had a direct relationship with MEXC.
"MEXC Global" means MEXC and any subsidiary, branch or office operating outside the United States, and any successor entity. FinCEN names MEXC Global Ltd and MX Global Ltd in the Seychelles, MEXC Estonia OÜ, GIDA Technology AG in Switzerland and MXC Global Ltd in the UK, and former Singapore entities. A successor means anyone that takes over MEXC's assets or carries on its affairs under a new name. Any MEXC branch or affiliate in the United States is expressly excluded.
When it applies
FinCEN released the order on 6 November 2026 and sent it to the Federal Register. On 9 November 2026 it had not yet appeared there. The prohibition takes effect 30 days after publication, so the likely date is early to mid December 2026. Firms should watch the Federal Register and set their go-live date from the publication date, not from the press release.
There is no end date. FinCEN reserves the right to impose conditions instead of a full prohibition and to grant exemptions, but none were granted in the order.
What firms must do before the effective date
The practical work is the same for a bank, a remittance company and a crypto exchange: find the exposure, stop it, and document what was done.
| Step | What it involves |
|---|---|
| Find direct exposure | Accounts, wallets, deposit addresses or counterparty records belonging to any MEXC entity or successor |
| Find indirect exposure | Customers who send to or receive from MEXC deposit addresses or MEXC-controlled wallets, identified through blockchain analytics |
| Update screening | Add MEXC entities and known addresses to counterparty and wallet screening, and to correspondent and nested account reviews |
| Block outgoing transfers | Stop customer withdrawals and payments to MEXC addresses or accounts from the effective date |
| Plan for incoming CVC | Decide how to treat crypto received from MEXC (see below) and write it into procedures |
| Tell customers | Update terms and in-app messages for customers who use MEXC, so withdrawals are not attempted and then stopped |
| Train and test | Brief operations, payments and compliance teams; test the controls before the effective date |
| Record decisions | Keep the risk assessment, screening changes and any exposure review on file for examiners |
Banks should look one layer further. FinCEN said a measure limited to correspondent accounts would not stop MEXC reaching dollars through indirect relationships via other foreign institutions. A bank serving foreign MSBs, payment processors or exchanges should ask those customers how they will stop MEXC flows, and review any customer with material MEXC exposure in its blockchain or payment data.
Crypto received from MEXC
FinCEN accepts that a crypto firm often cannot reject an incoming transfer before it arrives, because CVC systems let the sender push funds to any address. The order therefore gives covered institutions discretion over how to handle CVC that originated at MEXC, based on the facts of each transaction. FinCEN gives two examples where returning funds may not be possible or sensible: where the CVC sat in an unhosted wallet for a long period after leaving MEXC, and where a firm's own risk procedures stop it returning funds to MEXC.
A sound procedure covers three points. First, how the firm detects MEXC-origin funds, including the look-back it applies through intermediate wallets. Second, what it does with them: return to the originating address where that is possible and permitted, or hold and escalate. Third, how it records and reports the event, including whether a suspicious activity report is needed.
SARs, OFAC and the rest of the programme
The order does not change other obligations. FinCEN states that SAR filing and OFAC sanctions duties continue in full. MEXC's own customers include persons on US, EU and UK sanctions lists, so exposure found during the review can raise both a SAR question and a sanctions question at the same time.
The order also fits a pattern. FinCEN has used section 9714 against Bitzlato in 2023 and PM2BTC in 2024, and in October 2026 proposed a similar prohibition on transactions with the A7 network's sub-agents. A compliance programme that treats each order as a one-off project will keep repeating the same work. A standing procedure for special measures, with owners, screening steps and a template exposure review, makes the next one quicker. Our list of FinCEN special measures in force tracks each order.
What the order does not do
The order is a special measure, not a sanctions designation, and the difference affects how firms respond.
| Question | Position under the order |
|---|---|
| Does it freeze MEXC assets held by US firms? | No. It prohibits transmittals of funds. Blocking and freezing are OFAC sanctions tools, which apply separately if a party is designated |
| Does it cover MEXC entities in the US? | No. US branches, subsidiaries and offices are expressly excluded |
| Does it stop customers holding tokens bought on MEXC? | No. It prohibits transmittals from or to MEXC Global, not holding assets that once passed through it |
| Does it apply to foreign firms? | It binds US covered financial institutions. Foreign banks and exchanges that rely on US correspondents should expect those correspondents to ask how they keep MEXC flows out |
| Is there a transition after the effective date? | No. The prohibition applies in full from the effective date |
Firms with group companies outside the US should decide whether to apply the same block group-wide. Doing so keeps one standard across the group and avoids MEXC flows reaching the US entity through an affiliate.
What examiners and auditors will ask
State examiners, independent AML testers and bank partners will look for evidence that the order was handled as part of the programme rather than by email.
- When did the firm learn of the order, and who owned the response?
- What exposure review was run, over what period, using which data and tools?
- When were screening lists and blockchain analytics rules updated, and were they tested?
- How are incoming crypto transfers from MEXC handled, and is that written down?
- Were SAR decisions made on any exposure found, and documented?
- Were agents, partners and customers told where relevant?
A short memo answering these questions, signed off by the BSA officer and noted at the next board or senior management meeting, is usually enough.
How this fits a money transmitter's compliance programme
For licensed money transmitters, the MEXC review is also state exam evidence. State examiners test whether the BSA programme responds to new FinCEN actions and whether screening lists are updated promptly. Recording the review in the risk assessment and the board or senior management minutes shows that the programme works. Our guide to money transmitter compliance requirements sets out the full programme, and our money transmitter compliance calendar for 2027 lists the recurring dates.
Crypto firms that hold state licences, or that are still assessing whether they need them, should also check that MEXC flows have not been routed through their own platforms by customers using the firm as an on-ramp. Our guide to state licensing for crypto money transmission covers the licensing side.