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ARTICLE · 26 SEPTEMBER 2025

Ongoing Developments Related To FinCEN's CIBanco Order

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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...

United StatesFinance and Banking
Matthew Bisanz
Matthew Bisanz
Kiel Bowen
Kiel Bowen
Christopher Ellis
Christopher Ellis
Grace Kim
Grace Kim
Gina M. Parlovecchio
Gina M. Parlovecchio
Brad Resnikoff
Brad Resnikoff
Camille Doom
Camille Doom
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Executive Summary

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

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