The recent Orders issued by the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on June 25, 2025, designating CIBanco, Intercam, and Vector as institutions of primary money laundering concern, serve as a critical alert for all Mexican entities with U.S. connections. Although the orders are effective September 4, 2025, the affected institutions are already experiencing exclusion from the U.S. financial system, significant client attrition, and threats to their long-term viability.
Entities doing business in Mexico—particularly those in the financial sector or engaged in U.S.-Mexico cross-border operations—are advised to take immediate and proactive measures to mitigate risk and avert similar regulatory actions.
Recommended strategies and measures include the following:
- Perform a comprehensive risk evaluation that identifies current exposure to indirectly or unwillingly aiding drug trafficking and advanced money laundering techniques.
- Enhance due diligence protocols, especially for counterparties in high-risk jurisdictions that include China (and Hong Kong), Germany, and India. Due diligence procedures for businesses operating or having customers in such jurisdictions should include comprehensive "know your customer" processes to include collecting ownership information and assessing the source of funds associated with these.
- Develop comprehensive customer and supplier risk profiles.
- Implement internal reporting and escalation procedures. Conduct internal investigations as necessary relating to any identified suspicious activity, red flags, or whistleblower complaints.
- Engage in transaction monitoring, particularly regarding banking transactions with high-risk clients or emanating from high-risk jurisdictions. This should include an audit to identify any suspicious activity, such as banking wires from multiple companies or institutions to a singular entity in a short period of time, or unusually large bulk transfers to entities in high-risk locations.
- Sever correspondent accounts or relationships with institutions or large clients/suppliers that are poorly regulated or do not have Anti-Money Laundering policies. Disengage from customers or partners that could be indirectly linked to front companies or any counterparties mentioned in FinCEN, OFAC, or DEA reports.
- Provide internal training specific to sanctions, narcotics trade risks, and suspicious activity recognition.
- Closely monitor and scrutinize cash-intensive transactions and sudden changes in financial behavior. Timely file Suspicious Activity Reports (SARs) as required by FinCEN regulations.
- Proactively engage with relevant U.S. regulators (FinCEN and others) on a non-attribution basis to develop an understanding of current enforcement priorities and due diligence and reporting expectations.
- Develop a long-term compliance practice that implements best practices and available guidance from regulators.
Foley´s Government Enforcement Defense & Investigations (GEDI) team has prepared a more in-depth analysis of FinCEN's orders that can be found here.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
