Pursuant to the FEND Off Fentanyl Act, FinCEN identified three Mexico-based financial institutions as being of primary money laundering concern, specifically in relation to illicit opioid trafficking. As a result, it issued orders
on June 25th prohibiting certain funds transmittals to or from CIBanco, Intercam or Vector.
Since the initial order was issued, the effective date was delayed until September 4, 2025. By the amended effective date, FinCEN expects covered financial institutions to: (1) implement procedures to ensure compliance with the terms of the orders; and (2) exercise reasonable due diligence to prevent engaging in transmittals of funds involving CIBanco, Intercam, or Vector…
FinCEN recommends that covered financial institutions continue to implement appropriate AML/CFT procedures and systems, including conducting compliance screening to identify customers and determine their involvement in a transmittal of funds involving CIBanco, Intercam, or Vector and reporting transactions as might be required under any applicable suspicious activity reporting requirements. If a SAR is filed on CIBanco, Intercam, or Vector’s transactional activity, in Field 2 (Filing Institution Note to FinCEN) of the SAR format, FinCEN requests that covered financial institutions enter “CIBanco2313a FIN-2025”, “Intercam2313a FIN-2025”, and “Vector2313a FIN-2025”, as appropriate.
The FEND Off Fentanyl Act added Section 2313a to Title 21 of the United States Code. Section 2313a allows the Treasury to issue special measures to be imposed upon financial institutions, transactions or accounts found to be of primary money laundering concern, specifically in relation to illicit opioid trafficking. These orders are the first time FinCEN has implemented such special measures under the Fentanyl Act.