Authors: Jeremy Clifton, CRCM, CAMS and Nick Milcarek, CAMS
On June 25, 2025, the Treasury issued special measures under section 2313a placing restrictions on three institutions in Mexico for facilitating the illegal drug trade on behalf of cartel organizations and being of primary money laundering concern. These institutions have been identified as CIBanco S.A., Institutión de Banca Multiple (CIBanco), Intercam Banco S.A., Institución de Banca Multiple (Intercam), and Vector Casa de Bolsa, S.A. de C.V. (Vector). While these orders are not OFAC sanctions, covered institutions will be required to restrict transmittals to and from these Mexican banks. The requirements only apply to these institutions’ Mexican operations and subsidiaries. This order will become effective September 4, 2025.
To comply with this order, financial institutions should ensure their systems in place are properly screening for these entities in all “transmittal of funds”. The FAQ notes “transmittal of funds” as the sending and receiving of funds from all payment methods and for all purposes including virtual currency. We see the most risk with foreign wires and IATs. A majority of AML systems and some core processors automatically update lists of restricted and sanctioned names usually the day after an update. However, FIs should verify with core providers, AML systems providers, wire correspondents and other parties that subject transactions will be effectively screened. Make sure to include any details or description fields on wires including intermediaries, FFTC, or FBO fields in the screening process. If service providers do not have a ready-made solution, you may be able to use the keyword function within some core system parameters to search for the restricted institutions.
If your FI finds a covered transaction the FI is not required to block or freeze the transaction or even report it to OFAC unless otherwise covered by another sanctions program. The FI simply cannot process or accept the transaction. However, any positive match would be a trigger for review for possible suspicious activity that could be SAR reportable. Please see FinCEN’s advisory (FIN-2024-A002) outlining various typologies associated with the procurement of fentanyl precursor chemicals and manufacturing equipment at the following link: https://www.fincen.gov/sites/default/files/advisory/2024-06-20/FinCENSupplemental-Advisory-on-Fentanyl-508C.pdf. FIs should consider a risk based approach to reviewing transactions for these covered institutions as soon as possible as bad actors may try to move funds before the effective date of September 4, 2025.
From a BSA/AML/CFT Program standpoint you should update your Special Measures sections of the Program to be inclusive of these new Special Measures and document written procedures within your Program.
Press releases and the FAQs can be found below:
Initial Treasury Press Release: https://home.treasury.gov/news/press-releases/sb0179
Effective Date Extension Press Release: https://www.fincen.gov/news/news-releases/treasury-extends-effective-dates-orders-issued-under-new-authority-counter
FAQs on the order: Final-FAQs.pdf
On June 25, 2025, the Treasury issued special measures under section 2313a placing restrictions on three institutions in Mexico for facilitating the illegal drug trade on behalf of cartel organizations and being of primary money laundering concern. These institutions have been identified as CIBanco S.A., Institutión de Banca Multiple (CIBanco), Intercam Banco S.A., Institución de Banca Multiple (Intercam), and Vector Casa de Bolsa, S.A. de C.V. (Vector). While these orders are not OFAC sanctions, covered institutions will be required to restrict transmittals to and from these Mexican banks. The requirements only apply to these institutions’ Mexican operations and subsidiaries. This order will become effective September 4, 2025.
To comply with this order, financial institutions should ensure their systems in place are properly screening for these entities in all “transmittal of funds”. The FAQ notes “transmittal of funds” as the sending and receiving of funds from all payment methods and for all purposes including virtual currency. We see the most risk with foreign wires and IATs. A majority of AML systems and some core processors automatically update lists of restricted and sanctioned names usually the day after an update. However, FIs should verify with core providers, AML systems providers, wire correspondents and other parties that subject transactions will be effectively screened. Make sure to include any details or description fields on wires including intermediaries, FFTC, or FBO fields in the screening process. If service providers do not have a ready-made solution, you may be able to use the keyword function within some core system parameters to search for the restricted institutions.
If your FI finds a covered transaction the FI is not required to block or freeze the transaction or even report it to OFAC unless otherwise covered by another sanctions program. The FI simply cannot process or accept the transaction. However, any positive match would be a trigger for review for possible suspicious activity that could be SAR reportable. Please see FinCEN’s advisory (FIN-2024-A002) outlining various typologies associated with the procurement of fentanyl precursor chemicals and manufacturing equipment at the following link: https://www.fincen.gov/sites/default/files/advisory/2024-06-20/FinCENSupplemental-Advisory-on-Fentanyl-508C.pdf. FIs should consider a risk based approach to reviewing transactions for these covered institutions as soon as possible as bad actors may try to move funds before the effective date of September 4, 2025.
From a BSA/AML/CFT Program standpoint you should update your Special Measures sections of the Program to be inclusive of these new Special Measures and document written procedures within your Program.
Press releases and the FAQs can be found below:
Initial Treasury Press Release: https://home.treasury.gov/news/press-releases/sb0179
Effective Date Extension Press Release: https://www.fincen.gov/news/news-releases/treasury-extends-effective-dates-orders-issued-under-new-authority-counter
FAQs on the order: Final-FAQs.pdf
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