On June 25, 2025, the Financial Crimes Enforcement Network (“FinCEN”) of the U.S. Department of the Treasury announced, via its official website, the imposition of regulatory sanctions on 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. (the “Sanctioned Institutions”), for being deemed of primary money laundering concerns in connection with certain criminal organizations involved in illicit opioid trafficking. The official publication can be found here.
- The effect of the sanctions is an express prohibition for U.S. financial institutions from sending or receiving funds to or from the Sanctioned Institutions.
- According to the sanction orders, these prohibitions will take effect 21 calendar days following their publication in the Federal Register, which is comparable to Mexico’s Diario Oficial de la Federación.
- These prohibitions will be indefinite, and FinCEN stated that the 21-day period is intended to allow the clients of the sanctioned entities, as well as U.S. financial institutions, to adjust their business and compliance models accordingly.
- In addition, the Governing Board of Mexico’s National Banking and Securities Commission (Comisión Nacional Bancaria y de Valores, “CNBV”) announced that it imposed a temporary managerial intervention on the sanctioned banks.
- Case Considerations.
According to investigations conducted by FinCEN, the Sanctioned Institutions consistently provided, over the years, financial services and instruments used to conceal the origin of funds related to opioid trafficking, as well as to purchase fentanyl chemical precursors from certain countries—most notably, according to FinCEN, from the People’s Republic of China.
These acts primarily served individuals and groups involved with certain criminal organizations previously designated as Drug Trafficking Organizations (“DTOs”), as well as Foreign Terrorist Organizations (“FTOs”) and Specially Designated Global Terrorists (“SDGTs”).
It is important to note that the sanctions imposed on the Sanctioned Institutions were applied pursuant to the FEND Off Fentanyl Act , which grants the Secretary of the Treasury the authority to designate: (i) foreign financial institutions, (ii) transactions, or (iii) types of accounts as of primary money laundering concerns related to illicit opioid trafficking, and to implement corresponding mitigation measures .
Accordingly, given FinCEN’s conclusion that the Sanctioned Institutions have consistently and significantly facilitated money laundering activities for DTOs in connection with illicit opioid trafficking, it determined that no measure short of a total and indefinite prohibition on the transfer of funds to and from these entities would adequately address the risk they pose to U.S. national security.
As such, the sanction (civil in nature, not criminal) results in a prohibition for U.S. financial institutions to engage in transactions with the Sanctioned Institutions, and it will take effect 21 days after publication in the Federal Register.
While the sanctions issued by FinCEN apply only to U.S. financial institutions, and according to the press release made by the Mexican Ministry of Finance and Public Credit (Secretaría de Hacienda y Crédito Público), the remainder of the Mexican financial system is not restricted from continuing to operate with these institutions.
It is worth noting that, given the potential implications of the sanctions imposed by the U.S. Department of the Treasury, on June 26, the CNBV’s Governing Board ordered the temporary managerial intervention of CI Banco, S.A., and Intercam Banco, S.A. The official press release can be found here.
However, it is important to highlight that this case demonstrates that U.S. authorities can and will apply similar measures to other Mexican financial institutions. Therefore, it is strongly recommended to reinforce anti-money laundering and counter-terrorism financing (“AML/CTF”) compliance programs, with particular emphasis on: (i) risk factors within institutional risk matrices; (ii) enhanced customer due diligence, especially for clients potentially involved in the production, commercialization, or transportation of fentanyl precursors or other opioids; and (iii) monitoring of international fund transfer networks, in order to avoid direct or indirect exposure to transactions that could jeopardize the international operations of Mexican financial institutions.
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This document does not constitute legal advice. If you have any questions regarding the scope or implementation of this note, please do not hesitate to contact us.
Bernardo Mendoza
Partner
bmendoza@k-g.com
Dorothy Lerch
Counsel
dlerch@k-g.com.mx
Gerardo H. Estrada
Attorney
gestrada@k-g.com.mx
[1] Title 21: Food and Drugs, U.S. Code, Section 2313a.
[2] Which are the same special measures for jurisdictions, financial institutions, international transactions, or types of account of primary money laundering concern pursuant to Title 31: Money and Finance, U.S. Code, Section 5318A. : Money and Finance , U.S. Code, Section 5318A.