On June 25, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued orders designating CIBanco, S.A., Institución de Banca Múltiple (“CIBanco”), Intercam Banco S.A., Institución de Banca Múltiple (“Intercam”), and Vector Casa de Bolsa, S.A. de C.V. (“Vector”) as foreign financial institutions of primary money laundering concern in connection with illicit opioid trafficking.

These are the first actions taken by FinCEN under the Fentanyl Sanctions Act, which grants the U.S. Department of Justice special powers to counter money laundering associated with the trafficking of fentanyl and other synthetic opioids. They represent a significant shift in the U.S. government’s efforts to dismantle the financial networks of drug trafficking organizations.

As described in the orders, FinCEN’s determinations are based on what it alleges to be each institution’s long-standing pattern of associations, transactions, and provision of financial services that facilitated illicit opioid trafficking by Mexico-based cartels. FinCEN also asserts that these institutions played a role in the procurement of precursor chemicals from China used in illicit fentanyl production.

FinCEN’s orders prohibit U.S. financial institutions from conducting any type of transmittals of funds—whether through bank accounts or cryptocurrencies—to or from the aforementioned Mexican entities. This prohibition will become effective 21 days after its publication in the U.S. Federal Register. U.S. banks, brokerage firms, and investment companies must take immediate action to ensure compliance, mitigate risk exposure, and terminate any operational relationships with CIBanco, Intercam, or Vector. The orders are expected to be published in the Federal Register in the coming days.

The public record supporting these orders references transactions dating back several years that facilitated the movement of funds tied to precursor chemicals and laundering operations on behalf of the Cartel Jalisco Nueva Generación (“CJNG”), Sinaloa, Gulf, and Beltrán-Leyva cartels, and in other instances, the coordination of money laundering schemes linked to China. FinCEN cited significant deficiencies in AML/CFT controls at each institution.

On June 25, 2025, the Ministry of Finance and Public Credit (Secretaría de Hacienda y Crédito Público, “SHCP”) issued a statement clarifying that, to date, no conclusive evidence has been found to confirm the involvement of the three designated institutions in criminal activities. The SHCP noted that it had requested additional information from the U.S. Department of the Treasury but received only general data regarding electronic transfers linked to legitimate Chinese commercial counterparties. It also emphasized that such transactions are consistent with the normal volume of trade between Mexico and China, which exceeded USD 139 million during the period under review.

Subsequently, and pursuant to the U.S. Department of the Treasury’s orders, on June 26, 2025, the Governing Board of the National Banking and Securities Commission (Comisión Nacional Bancaria y de Valores, “CNBV”) ordered the temporary managerial intervention of CIBanco and Intercam, in accordance with Article 129 of the Mexican Law on Credit Institutions (Ley de Instituciones de Crédito). This implies that the CNBV will appoint a provisional administrator to replace the CEO, the board of directors, and the shareholders’ meeting. Intervention is generally considered an event of default under agreements entered into with the banks. Therefore, we recommend reviewing such agreements to assess the possibility of exercising early termination rights.

In light of these unprecedented sanctions, financial institutions—particularly Mexican institutions—should immediately conduct targeted risk assessments focused on client relationships, transaction flows, and correspondent or fiduciary links to the designated institutions. These measures should be carried out under legal client- attorney privilege with both local and U.S. counsel. Now more than ever, institutions must ensure that their BSA/AML and anti-corruption compliance programs are robust, well-designed, and effectively implemented. This includes reviewing internal controls, onboarding and due diligence protocols, transaction monitoring systems, and third-party risk management frameworks—particularly as they relate to KYC (Know Your Customer) and KYCC (Know Your Customer’s Customer) obligations—in line with the U.S. Department of Justice and international expectations.

Beyond financial institutions, other market participants —including fiduciary/trustee services providers, trust beneficiaries, investment vehicles, and counterparties with ties to the designated entities—should urgently reassess their legal risk exposure. Clients operating fideicomisos or similar trust structures involving any of the sanctioned institutions should evaluate whether a restructuring is required to preserve asset access and ensure a compliance culture. Our team is currently analyzing various strategies to mitigate the impact of the foregoing and to maintain operational continuity within the legal framework. The legal implications of these sanctions extend far beyond regulatory matters and may affect the enforceability of contractual obligations, as well as access to cross-border services.

In cases where relationships exist with the designated institutions acting in their capacity as trustees, it is necessary to consider whether to transfer the administration of those trusts or asset-holding structures to non-designated entities, in order to avoid potential freezing of asset or breaches that may arise once the U.S. Department of the Treasury’s orders become effective.

In parallel, clients with exposure to the sanctioned institutions should commission an independent review of their shareholding structures and transaction histories. These proactive assessments can be instrumental in addressing future regulatory inquiries and in demonstrating a good-faith compliance culture. Likewise, any successor trustees or fiduciaries assuming asset management responsibilities of affected structures should reexamine their onboarding procedures, CDD/EDD frameworks, and overall governance to ensure alignment with heightened risk expectations.

Financial institutions and clients with exposure to the three designated entities should take immediate preventive and corrective measures. If you wish to assess the specific risks to your organization or explore legal and strategic options, our team is available to assist you. We work in collaboration with U.S. firms with extensive experience in regulatory matters and international sanctions, enabling us to provide comprehensive and effective legal advise.