Any U.S. person who initiates or processes transactions involving these institutions risks violating FinCEN’s orders, leading to potential civil or criminal penalties under the Bank Secrecy Act and related statutes.
On June 25, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued orders designating three Mexico-based financial institutions—CIBanco S.A., Institución de Banca Múltiple; Intercam Banco S.A., Institución de Banca Múltiple; and Vector Casa de Bolsa S.A. de C.V.—as being of primary money laundering concern in connection with illicit opioid trafficking. These designations, made under the Fentanyl Sanctions Act and the FEND Off Fentanyl Act, prohibit certain transmittals of funds to or from the named entities and become effective 21 days after publication in the Federal Register.
Provided below is a summary of key developments, highlighting the consequences for any U.S. person dealing with these designated financial institutions.
Overview of the FinCEN Orders
Primary Money Laundering Concern
FinCEN determined that CIBanco, Intercam and Vector each facilitated money laundering for major Mexico-based cartels, including the Jalisco New Generation Cartel, the Gulf Cartel and the Sinaloa Cartel.
Prohibited Transmittals of Funds
Covered U.S. financial institutions (as defined in the Bank Secrecy Act regulations) are prohibited from processing any transmittals of funds either “from or to” CIBanco, Intercam or Vector, or to any account or convertible virtual currency address administered by or on behalf of these entities.
Effective Date
The prohibitions take effect 21 days after publication in the Federal Register.
Consequences for U.S. Persons
Prohibition on Financial Dealings
Any U.S. person who initiates or processes transactions involving these institutions risks violating FinCEN’s orders, leading to potential civil or criminal penalties under the Bank Secrecy Act and related statutes.
Criminal and Civil Penalties
Violations of FinCEN orders can result in significant monetary fines and, in severe cases, criminal liability. U.S. persons who fail to comply may also face sanctions-related measures or additional enforcement actions.
Heightened Compliance Obligations
U.S. businesses must ensure that their compliance programs—including know your customer, anti-money laundering (AML) and countering the financing of terrorism (CFT) protocols—are updated to detect and block any attempted transactions with these entities.
Reputational Risk
In addition to legal ramifications, industry participants dealing with designated financial institutions can suffer reputational damage if perceived to be facilitating financing for cartels or the opioid trade.
Why Is This Important?
U.S. persons may inadvertently engage with these designated institutions if, for instance, they enter into contracts with vendors or suppliers who designate any of the newly prohibited Mexican banks as the recipient for payment.
A U.S. company might arrange to pay its vendor in Mexico without realizing that the vendor’s chosen bank account belongs to one of these financial institutions, which FinCEN has specifically identified as being of primary money laundering concern in connection with illicit opioid trafficking. Once the prohibitions become effective—21 days after publication in the Federal Register—any transmittal of funds “from or to” these institutions or accounts under their control is disallowed for U.S. persons and covered U.S. financial institutions.
Because many cross-border commercial arrangements involve wire transfers or other conventional payment methods, unsuspecting parties may discover too late that a supplier has designated a CIBanco, Intercam or Vector account for accepting funds. Even routine property-related payments (e.g., rent, contract fulfilment or vendor services) risk noncompliance if the designated receiving account is held at one of these institutions. Such inadvertent dealing could draw regulatory scrutiny or penalties, given FinCEN’s blanket prohibition on any transmittal to or from these entities.
Moreover, as the FinCEN orders describe, the prohibition extends to convertible virtual currency addresses administered by or on behalf of these institutions, not just wire transfers or other more traditional payment channels. Consequently, a U.S. importer paying a Mexican supplier that routinely uses one of these banks—or a U.S. tenant paying rent into an account based in one of these banks—would be at risk of violating the order unless they halt or reroute these payments. To avoid potential liability, U.S. persons and entities should carefully vet the financial institutions named in any requests for payment and conduct thorough due diligence on counterparties’ banking arrangements.
What U.S. Entities Need to Do Next
To ensure compliance with the new designations and prohibitions, it is advisable to screen current and prospective counterparties by updating all payment and client screening processes so that any direct or indirect transactions involving CIBanco, Intercam or Vector are promptly identified. Dealings with these designated institutions should be halted or reassessed immediately to avert potential violations. It is equally important to strengthen AML/CFT controls by adopting enhanced due diligence measures, especially with respect to Mexico-based counterparties and cross-border or multijurisdictional transactions, and to provide staff with updated training on the FinCEN designations and prohibited transactions under the new orders. Finally, regulatory developments should be tracked by closely monitoring further announcements or clarifications from FinCEN and the U.S. Department of the Treasury, as well as by reviewing the Federal Register for any publications or amendments to these initial orders.
Conclusion
FinCEN’s designations of CIBanco, Intercam and Vector under the Fentanyl Sanctions Act and FEND Off Fentanyl Act illustrate the U.S. government’s intensified efforts to disrupt illicit opioid trafficking and the associated money laundering. U.S. persons, including financial institutions and businesses, should promptly review and, if necessary, modify their operations to ensure full compliance, thereby reducing the likelihood of significant penalties and reputational harm.
About Duane Morris
Attorneys in Duane Morris’ Mexico Business Group and International Practice Group have considerable subject matter experience involving operations in Mexico and international trade issues. Such work includes setting up companies in Mexico, purchasing land for manufacturing facilities, monitoring the constantly evolving enforcement changes to merchandise classification, advising clients on pertinent duty mitigating strategies, performing risk assessments and assisting clients in developing and implementing cost-effective compliance policies and taking remedial actions when necessary.
For More Information
If you have any questions about this Alert, please contact Eduardo Ramos-Gómez, Geoffrey M. Goodale, Raul Rangel Miguel, any of the attorneys in our Mexico Business Group, any of the attorneys in our International Practice Group or the attorney in the firm with whom you are regularly in contact.
Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.