On June 25, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued its first orders (“Orders”) pursuant to the 2024 FEND Off Fentanyl Act (21 U.S.C. § 2313a) (the “FEND Act”), designating 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”), as being of “primary money laundering concern” in connection with illicit opioid trafficking. The Orders were originally published in the Federal Register on June 30, 2025, with an initial effective date of July 21, 2025.¹

On July 9, 2025, FinCEN extended the initial effective date by 45 days to September 4.² Most recently, on August 19, FinCEN further extended the effective date for the Orders to October 20, 2025.² The multiple extensions from the initial effective date reflect significant steps taken by the Mexican government to address FinCEN’s concerns,² including placing administrative and legal representatives in key managerial roles of the affected institutions to promote regulatory compliance and the prevention of illicit finance. The new effective date of October 20, 2025, allows for continued bank operations without endangering client resources and protects the savings and assets of depositors and investors. According to FinCEN, these steps, along with parallel review of the anti-money laundering/countering the financing of terrorism (“AML/CFT”) certification of the compliance officers in all three institutions, reflect a commitment to addressing financial integrity risks. FinCEN continues to monitor and work closely with Mexican authorities to ensure sustained progress.³

In response to FinCEN’s order, CIBanco filed a complaint in US District Court for the District of Columbia on August 17, 2025, seeking to enjoin the initial order.^4 5 CiBanco voluntarily dismissed its lawsuit based on FinCEN’s latest extension.

These...