FinCEN issued Alert FIN-2026-Alert005 on 3 September 2026 on money laundering tied to digital asset investment scam centres, and two of its red-flag indicators turn on physical metal. One covers a customer who says a purported law enforcement or government representative told them to pay in digital assets, wire money abroad, or buy precious metals or gift cards. The second covers a customer who takes funds out of a retirement or investment account to buy gold from a precious metals dealer and says they have been instructed to hand it to a courier. FinCEN records that law enforcement has seen scammers direct victims to buy gold coins or bars, which couriers working for the operators then collect and move.
Both indicators sit at intake and at the release instruction rather than on the payment leg: what is checkable is the account the money came from and who takes physical possession of the bars. A courier handoff separates the buyer of record from whoever leaves with the metal, so the identity the transaction file carries and the identity holding the bars are not the same. FinCEN keys the reporting to two forms — SAR field 2 and the narrative carry the term FIN-2026-SCAMCENTERS, with “Fraud-Other” under field 34(z) described as Scam Centers; Form 8300, filed on cash over $10,000 received in a trade or business, takes the suspicious-transaction box and the same term in the comments. Section 314(b) of the USA PATRIOT Act carries a safe harbour for sharing customer information between institutions, which is how one buyer moving across several dealers becomes visible to any of them. A filed SAR and its supporting documentation are kept for five years, so the intake file is what has to carry the funding account, the release instruction and the identity of the collector.
The alert is guidance. Who counts as a financial institution, and what each of them must file, rests with FinCEN under the Bank Secrecy Act.