FEND Off Fentanyl Act
In Re: CIBanco S.A. Institución De Banca Multiple
Intercam Banco S.A., Institución de Banca Multiple
Vector Casa de Bolsa, S.A. de C.V.
Date: June 25, 2025
Issue: The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued orders for the first time under the FEND Off Fentanyl Act (FOFA).
Case Summary: FinCEN issued orders designating CIBanco, Intercam and Vector (institutions) as primary money laundering concerns in connection with fentanyl trafficking under FOFA.
Section 311 of the USA PATRIOT Act authorizes the secretary of the Treasury to designate foreign financial institutions as “primary money laundering concerns” and to impose one or more “special measures” to protect the U.S. financial system.
Enacted in April 2024, FOFA targets money laundering specifically related to illicit opioid trafficking. Section 2313a authorizes the Treasury secretary to determine whether there are reasonable grounds to conclude that a foreign financial institution, class of transactions, or type of account is of primary money laundering concern in connection with illicit opioid trafficking. Upon making such a finding, the secretary is authorized to introduce a sixth special measure prohibiting or conditioning any “transmittal of funds” involving designated institutions.
According to FinCEN, the institutions each facilitated money laundering by Mexican drug cartels involved in opioid trafficking. FinCEN found that CIBanco, Mexico’s 20th largest financial institution, had a history of ties to international drug trafficking organizations (DTOs) and facilitating transactions on their behalf. According to FinCEN, CIBanco moved money on behalf of Mexico-based companies involved in the procurement of precursor chemicals for the production of fentanyl. The order also cites examples where CIBanco clients originated funds transfers to companies located in China that shipped precursor chemicals to Mexico.
FinCEN also found that Intercam, the 25th largest financial institution in Mexico, had processed funds transfers to China-based companies known to have shipped precursor chemicals to Mexico. According to the order, Intercam allowed a suspected “money mule,” who made 627 ATM deposits in the United States, to send approximately $1.9 million from the U.S.-based account into an Intercam account in Mexico, which FinCEN noted was meant to repatriate illicit funds to DTOs in Mexico. The order noted that Intercam had previously maintained accounts with several U.S.-based financial institutions, but these accounts were removed after the institutions became aware of Intercam’s compliance issues.
In addition, FinCEN found that Vector, the ninth-largest brokerage firm in Mexico, had played a role in remitting money through wire transfers from Mexican DTOs to China-based companies known to have shipped precursor chemicals to Mexico. According to the order, Vector remitted over $17 million to multiple China-based companies in early 2021 for a company tied to an international DTO. The order also noted the Sinaloa Cartel’s relationship to Vector, finding that the firm facilitated a $1.5 million transfer by a Sinaloa “money mule.”
FinCEN imposed the sixth special measure based on its assessment that the illicit actors using the services of the three Mexican banks pose an imminent threat to U.S. national security. As a result, FinCEN’s orders prohibit U.S. financial institutions from engaging in transmittals of funds with the Institutions. The sanctions apply only to branches, subsidiaries, and offices located in Mexico. Anyone who willfully violates these terms may face criminal fines or civil money penalties.
Bottom Line: In a historic first, FinCEN prohibited transactions with covered Mexico-based financial institutions. On July 9, 2025, FinCEN extended the effective date of the orders to Sept. 4, 2025.
Documents:
CI Banco Order
Intercam Order
Vector Order
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