It just got much riskier to do business in Mexico. On June 25, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a novel set of orders finding three financial institutions in Mexico — CIBanco S.A., Institución de Banca Multiple (CIBanco), Intercam Banco S.A., Institución de Banca Multiple (Intercam) and Vector Casa de Bolsa, S.A. de C.V. (Vector) — laundered drug proceeds for illicit opioid traffickers, including two Mexican cartels. And because the Trump administration has designated some cartels as foreign terrorist organizations, the gravity of the June 25 Orders only increases. The June 25 Orders prohibit covered financial institutions, such as US banks, from engaging in any transmittal of funds from or to CIBanco, Intercam, or Vector. Financial institutions that engage in such prohibited transactions may face civil or criminal penalties under 31 U.S.C. 5321, 5322 of up to two times the amount of the transaction.

FinCEN’s Statutory Authority Under a Set of New Laws

Passed in 2024, the Fentanyl Sanctions Act and FEND Off Fentanyl Act granted the Treasury Department the authority to target money laundering associated with the trafficking of fentanyl and other synthetic opioids. Pursuant to 21 U.S.C. 2313a, the Secretary of the Treasury has the authority to find that any of the following are “of primary money laundering concern,” i.e., pose a money laundering threat to the US financial system, “in connection with illicit opioid trafficking”:

• One or more financial institutions operating outside of the United States;
• One or more classes of transactions within, or involving, a jurisdiction outside of the United States or
• One or more types of accounts within, or involving, a jurisdiction outside of the United States.

After making such a finding, the Treasury Department may impose certain “special measures” to defend the US financial system from money laundering risks connected to illicit opioid trafficking.[1] There are six special measures that FinCEN may administer, including: imposing additional recordkeeping, information collection, or reporting requirements set forth in 31 U.S.C. 5318A(b)(1)-(4); prohibiting and/or placing conditions upon the opening or maintaining in the United States of correspondent or payable-through accounts for or on behalf of the financial institution, as set forth in 31 U.S.C. 5318A(b)(5); and finally, prohibiting or imposing conditions upon certain transmittals of funds by any covered financial institution, as set forth in 21 U.S.C. 2313a(a)(2). 

FinCEN has the authority to impose any of the foregoing special measures it deems appropriate. In determining which special measures are appropriate, FinCEN considers the factors set forth in 31 U.S.C. 5318A(a)(4)(B), including: whether the special measure would address the money laundering concern in a manner consistent with US national security and foreign policy interests; whether the measure would create a significant competitive disadvantage, including through imposing undue burdens on legitimate activities of the financial institution; and whether any other reasonable alternatives or special measures would adequately address the money laundering concern.

FinCEN’s Findings: CIBanco, Intercam and Vector Are Laundering Money in Connection With Illicit Opioid Trafficking, Including by Cartels

The June 25 Orders constitute FinCEN’s first exercise of its authority under the Fentanyl Sanctions and FEND Off Fentanyl Acts. The orders announce FinCEN’s determination that the three financial institutions “played vital roles in facilitating money laundering activities of Mexico-based cartels engaging in illicit opioid trafficking, including facilitating payments for the procurement of precursor chemicals essential for the production of illicit opioids by drug trafficking organizations (DTOs), some of which were also designated this February as Foreign Terrorist Organizations (FTOs).”[2] Specifically, the June 25 Orders describe FinCEN’s findings that, among other things:

• CIBanco provides financial services that benefit drug-trafficking organizations, including the Gulf Cartel, the Beltran-Leyva Organization (BLO) and the Jalisco Generation New Cartel (CJNG).
• Intercam provides financial services that benefit CJNG.
• Vector provides financial services that benefit the Sinaloa Cartel and the Gulf Cartel.

Treasury Secretary Scott Bessent said that these institutions “are enabling the poisoning of countless Americans by moving money on behalf of cartels, making them vital cogs in the fentanyl supply chain.”[3] He emphasized the Treasury Department’s “commitment to using all tools at our disposal to counter the threat posed by criminal and terrorist organizations trafficking fentanyl and other narcotics.”[4] Indeed, after determining that no other special measures would adequately address the money laundering concern, the Treasury is imposing the most severe tool at its disposal: a complete prohibition on the transmittal of all funds to or from the named financial institutions.

Willful violations of the June 25 Orders can carry significant fines, with civil and criminal penalties up to two times the amount of the transaction, capped at $1,776,364 (as of July 9, 2025) and $1 million per violation respectively.

What to Do Now and What to Expect in the Future

The June 25 Orders originally became effective on July 21, but that was recently extended to September 4, 2025. The orders apply to all covered financial institutions, including US banks, securities brokers and dealers, money service businesses, telegraph companies, casinos, card clubs, any person subject to supervision by a bank supervisory authority, future commissions merchants, introducing brokers in commodities and mutual funds. By that date, covered financial institutions must cease any and all transmittals of funds (including convertible virtual currency) from or to CIBanco, Intercam or Vector, this includes direct and indirect transactions, even via intermediaries.

FinCEN also recommends that covered financial institutions:

• Consider the finding of primary money laundering concern regarding CIBanco, Intercam and Vector when complying with their other Bank Secrecy Act obligations, including any applicable obligations to establish and maintain anti-money laundering and countering the financing of terrorism (AML/CFT) compliance programs;
• 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
• Report transactions by filing Suspicious Activity Reports if the covered financial institution uncovers concerning links to the designated banks.

FinCEN’s targeting these financial institutions for providing services to cartels is consistent with the Trump administration’s focus on the “total elimination” of cartels. And while the Treasury Department’s authority in this realm covers financial institutions, accounts and transactions, the Justice Department can bring enforcement actions against any company or individual who knowingly provides material support (property or services, including currency, financial services, lodging, personnel and transportation) to a foreign terrorist organization. Any business transaction, therefore, with one of the cartels that has been designated as a foreign terrorist organization, could result in liability under 18 U.S.C. 2339B for providing material support to a terrorist. These June 25 Orders are part of a sea change when it comes to the risk of doing business in Mexico. Not only can a financial institution face civil and criminal fines for violations of the June 25 Orders, but it’s in danger of facing a criminal allegation that it’s supporting terrorists. 

[1] See 21 U.S.C. 2313a(a).

[2] See FinCEN’s Frequently Asked Questions originally issued on June 25, 2025 and updated on July 9, 2025, re: Update to Section 2313ª Orders Prohibiting Certain Transmittals of Funds Involving CIBano, Intercam, and Vector (citing Department of State, Foreign Terrorist Organization Designations of Tren de Aragua, Mara Salvatrucha, Cartel de Sinaloa, Cartel de Jalisco Nueva Generación, Carteles Unidos, Cartel del Noreste, Cartel del Golfo, and La Nueva Familia Michoacana, 90 FR 10030 (Feb. 20, 2025), https://www.federalregister.gov/d/2025-02873; See 8 U.S.C. 1189(a)(1)).

[3] Press Release, U.S. Dep’t of Treasury, Treasury Issues Historic Orders under Powerful New Authority to Counter Fentanyl (June 25, 2025).

[4] Id.