On June 25, 2025, FinCEN issued orders against three Mexico-based financial institutions: CIBanco S.A., Institution de Banca Multiple (“CIBanco”); Intercam Banco S.A., Institución de Banca Multiple (“Intercam”); and Vector Casa de Bolsa, and S.A. de C.V. (“Vector”), all of which had a hand in laundering millions of dollars for Mexico-based cartels and illegal fentanyl production. These organizations are the first to be ordered by FinCEN under the Fentanyl Sanctions Act and the FEND Off Fentanyl Act.
FinCEN’s CIBanco Order stated that CIBanco facilitated transactions of precursor chemicals from China on behalf of cartel members.
The Intercam Order was based on the patronizing of illicit opioid trafficking by Mexico-based cartels with USD-denominated funds transfers. The Order also stated that Intercam executives met directly with suspected members of the cartel CJNG to discuss money laundering and transferring money for precursor chemicals necessary to make illicit substances from China. Intercam was found to have granted more than $1.5 million to Chinese-based companies for wrongful use of precursor chemicals between 2021 to 2024.
FinCEN’s Vector Order charges that the bank played a vital role in laundering $2 million from the US to Mexico and paid $1 million to Chinese-based companies that were explicitly tied to the shipment of precursor chemicals to Mexico for illicit purposes.
As a result of these Orders, covered financial institutions will be prohibited from any transactions with the three banks after 21 days, due to the new powers in the FEND Off Fentanyl Act.
The FEND Off Fentanyl Act provides FinCEN the authority to combat money-laundering connected to the trafficking of fentanyl, This includes the power to impose one or more of six special measures regulating record keeping, information collection, prohibiting transmittal of funds with targeted institutions, and reporting requirements of domestic financial institutions. These US financial institutions are then on a clock: they have exactly 21 days to comply with two critical components after the orders are announced.
Following an order against them, financial institutions must cease transmitting funds to or from banks, they then must be mindful of primary money laundering concerns in a sincere effort to abide by the Bank Secrecy Act. Should one or both of these requirements fail, the financial institutions could be subject to civil and criminal penalties.
These enforcements align with the current administration’s focus on fentanyl trafficking and targeting of cartels. A January 2025 Executive Order created a process to designate cartels as Foreign Terrorist Organizations. In the order, Trump calls for the “total elimination of these organizations’ presence in the United States and their ability to threaten the territory, safety, and security of the United States through their extraterritorial command-and-control structures.” In this vein he “declare[d] a national emergency, under IEEPA, to deal with those threats.” This aligns with new FCPA guidelines from the DOJ to, “Pursuing the eradication of Cartels and TCOs (Transnational Criminal Organizations).
