Alert: Treasury Names Three Mexico-Based Financial Institutions as a Primary Money Laundering Concern

The Special Investigations Unit (SIU) within FINRA’s National Cause and Financial Crimes Detection program issued this alert to highlight the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) orders under new authority to counter illicit opioid trafficking. The alert further reminds firms of their requirements under FINRA Rule 3310 (Anti-Money Laundering Compliance Program).

Summary

On June 25, 2025, FinCEN issued orders identifying 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, S.A. de C.V. (Vector)—to be of primary money laundering concern in connection with over $100 million in illicit opioid trafficking for Mexico-based cartels, primarily through the procurement of precursor chemicals from China. These orders prohibit covered financial institutions¹ from engaging in any and all transmittals of funds to or from CIBanco, Intercam and Vector. The orders define transmittals of funds as the sending and receiving of funds, including convertible virtual currency. To ensure orderly implementation, FinCEN delayed the effective date for 21 days after the orders are published in the Federal Register² (Effective Date).

As noted in the related frequently asked questions (FAQs) published by FinCEN:

• FinCEN expects covered financial institutions to:
  • implement procedures to ensure compliance with the terms of the orders; and
  • exercise reasonable due diligence to prevent engaging in transmittals of funds involving CIBanco, Intercam or Vector.
• By the Effective Date, covered financial institutions should:
  • cease any and all transmittals of funds to or from CIBanco, Intercam or Vector, as defined in the orders; and
  • consider the finding of primary money laundering concern regarding CIBanco, Intercam and Vector when complying with the firms’ Bank Secrecy Act obligations, including any appliable obligations to establish and maintain anti-money laundering and countering the financing of terrorism compliance programs.
• The orders do not apply to historical transactions and covered financial institutions do not need to “reject” funds received before the Effective Date. Covered financial institutions are only responsible for applying the orders to transactions that occur after the orders are effective. FinCEN will delay the effective dates of these orders for 21 days from their publication in the Federal Register to allow time to adapt business practices to respond and comply.
• The orders do not impose a new Suspicious Activity Report (SAR) reporting obligation or change existing SAR reporting obligations. If a SAR is filed on CIBanco, Intercam or Vector 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. Further, transactional information, including the customer information related to the transaction(s) involving CIBanco, Intercam or Vector such as name(s), identification number(s), phone number(s), physical address(es) and any other activity identified with that customer, would be useful in a SAR.

Reminders

FINRA Rule 3310(a) requires members to “[e]stablish and implement policies and procedures that can be reasonably expected to detect and cause the reporting of transactions required under [the BSA] and the implementing regulations thereunder;” the BSA and its implementing regulations require financial institutions to report suspicious transactions to FinCEN using SARs.³ In addition, FINRA Rule 3310(f)(ii) and 31 C.F.R. § 1023.210(b)(5) require that a member’s AML program include appropriate risk-based procedures for conducting ongoing customer due diligence, including procedures for conducting ongoing monitoring to identify and report suspicious transactions.

FINRA encourages members to continue to monitor the FinCEN website for relevant information such as publication of the order in the Federal Register and updates to the FAQs. FinCEN has stated that questions regarding these orders can be directed to www.fincen.gov/contact.

If you have general questions about this alert, please contact FINRA’s Special Investigations Unit (SIU).