FinCEN issues first AML orders under new authority to counter fentanyl

AML Compliance requires peak anti-money laundering by financial institutions. Mexican banks sanctioned by U.S. for alleged money laundering of cartel funds.

Last week, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued orders identifying 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, and prohibit, respectively, certain transmittals of funds involving CIBanco, Intercam, and Vector.  These orders are the first actions by FinCEN pursuant to the Fentanyl Sanctions Act and the FEND Off Fentanyl Act, which provide Treasury with additional authorities to target money laundering associated with the trafficking of fentanyl and other synthetic opioids, including by cartels.

FinCEN alleges that CIBanco and Intercam, commercial banks with over $7 and $4 billion in total assets, respectively, and Vector, a brokerage firm managing nearly $11 billion in assets, have collectively played a longstanding and vital role in laundering millions of dollars on behalf of Mexico-based cartels. The allegations assert that these institutions facilitate payments for the procurement of precursor chemicals needed to produce fentanyl.  

“Financial facilitators like CIBanco, Intercam, and Vector are enabling the poisoning of countless Americans by moving money on behalf of cartels, making them vital cogs in the fentanyl supply chain,” said Secretary of the Treasury Scott Bessent.  “Through the first use of this powerful authority, today’s actions affirm Treasury’s commitment to using all tools at our disposal to counter the threat posed by criminal and terrorist organizations trafficking fentanyl and other narcotics.”

According to the U.S. Treasury press release, these actions were taken within the broad context of the strong U.S.-Mexico inter-governmental relationship, the hallmarks of which include close collaboration and timely information exchange.  Both the United States and Mexico are committed to financial systems with strong anti-money laundering/countering the financing of terrorism (AML/CFT) controls that effectively protect their citizens from the transnational illicit finance threats of cartels trafficking fentanyl and other drugs, according to the Treasury statement. 

CIBanco allegations

As set out in the order, FinCEN determined that CIBanco, a foreign financial institution operating outside the United States, is of primary money laundering concern in connection with illicit opioid trafficking based on its long-standing pattern of associations, transactions, and provision of financial services that facilitate illicit opioid trafficking by Mexico-based cartels, including the Beltran-Leyva Cartel, Jalisco New Generation Cartel (CJNG), and Gulf Cartel.  CIBanco has also facilitated the procurement of precursor chemicals from China for illicit purposes.

For example, FinCEN asserts that a CIBanco employee in 2023 knowingly facilitated the creation of an account to purportedly launder $10 million on behalf of a Gulf Cartel member.  From 2021 through 2024, CIBanco processed over $2.1 million in payments on behalf of Mexico-based companies to China-based companies that shipped precursor chemicals to Mexico for illicit purposes. 

A copy of FinCEN’s CIBanco order is available here.

Intercam allegations

As set out in the order, FinCEN determined that Intercam, a financial institution operating outside the United States, is of primary money laundering concern in connection with illicit opioid trafficking as a result of its long-standing pattern of associations, transactions, and provision of financial services that facilitate illicit opioid trafficking by Mexico-based cartels, including CJNG.  Intercam has also processed USD-denominated funds transfers that finance the procurement of precursor chemicals from China on behalf of drug trafficking organizations for illicit purposes.

For example, FinCEN alleges that Intercam executives in late 2022 met directly with suspected CJNG members to discuss money laundering schemes, including transferring funds from China.  From 2021 through 2024, a China-based company associated with an individual shipping precursor chemicals from China to Mexico for illicit purposes received over $1.5 million from Mexico-based companies through Intercam.

A copy of FinCEN’s Intercam order is available here.

Vector allegations

As set out in the order, FinCEN determined that Vector, a financial institution operating outside of the United States, is of primary money laundering concern in connection with illicit opioid trafficking due to its facilitation of money laundering activities of Mexico-based cartels, including the Sinaloa Cartel and Gulf Cartel.  Vector has also facilitated the procurement of precursor chemicals from China for illicit purposes.

For example, FinCEN alleges that, from 2013 through 2021, a Sinaloa Cartel money mule employed various methods to launder $2 million from the United States to Mexico through Vector.  Additionally, the order describes how from 2018 through 2023, Vector was found to have completed over $1 million in payments on behalf of Mexico-based companies to China-based companies known to have shipped precursor chemicals to Mexico for illicit purposes.  These payments illustrate significant failings in Vector’s AML/CFT controls, according to FinCEN. 

A copy of FinCEN’s Vector order is available here

U.S. tries new tools in fight against drug trafficking

Combating drug cartels and stopping the flow of deadly drugs into the United States is one of the Trump Administration’s highest priorities, according to the U.S. Treasury.  In January 2025, President Trump issued an executive order creating a process by which certain cartels and other organizations would be designated as Foreign Terrorist Organizations (FTOs) and/or Specially Designated Global Terrorists (SDGTs). 

Accordingly, in February, the U.S. Departments of the Treasury and State designated eight organizations, including six major Mexico-based drug cartels, as FTOs and SDGTs, including the CJNG, Gulf Cartel, and Sinaloa Cartel.  The FinCEN orders are intended to complement these designations as a further step to deny individuals and entities associated with cartels access to the U.S. financial system.  

As described in FinCEN’s orders, covered financial institutions are prohibited from engaging in transmittals of funds from or to CIBanco, Intercam, or Vector, or from or to any account or convertible virtual currency address administered by or on behalf of CIBanco, Intercam, or Vector. These prohibitions become effective 21 days after publication in the Federal Register.

Initial response from Mexico president, regulators

The LA Times reported soon after the announcement of the orders that Mexico’s president Claudia Sheinbaum pushed back against the accusations of money laundering and asked for hard proof that supports the accusations. Sheinbaum said she had not yet seen seen evidence indicating money laundering, and she would withhold judgment until she saw proof of the money laundering accusations alleged by the U.S.

This U.S. action against Mexican financial institutions–even though their assets in the Mexican banking sector are small–has some financial analysts in Mexico on edge over the larger impact to the country’s financial system and to what may happen in the future.

Upon the U.S. announcement of the FinCEN orders, Mexico’s National Banking and Securities Commission responded within hours. It seized control of the identified banks and broker-dealer to stabilize operations and safeguard depositors.

AML expectations for institutions of all sizes, types

The institutions named by the U.S. were not large multinational banks. They were mid-sized firms serving Mexican and cross-border clients—regional players that may once have considered themselves outside the spotlight of global regulators. But in today’s AML environment, smaller-sized institutions are not free from scrutiny.

With cross-border money laundering fueling fentanyl trafficking, human smuggling, and cartel violence, regulators are increasingly linking financial crime to national security. And the tools they wield—like OFAC sanctions and FinCEN’s enforcement actions—can deliver near-instant consequences. One day a bank is operational; the next, it is under federal control and cut off from international clearing systems.

Compliance programs must be ready for anything

For compliance professionals, the lessons are clear: Inadequate AML controls are no longer just a regulatory risk—they’re an existential one. Banks that lack effective screening, monitoring, and due diligence expose themselves to massive reputational and operational fallout.

To meet these challenges, institutions must adopt compliance systems that go beyond the basics. Static rules and siloed tools can’t keep pace with the risk landscape. What’s needed are dynamic, integrated platforms that orchestrate the full compliance lifecycle—from perpetual KYC to sanctions screening, transaction monitoring, and case management.

The RegTechONE advantage

This is exactly the kind of challenge that RegTechONE was built to meet.

The RegTechONE platform empowers financial institutions with:

In the face of intensifying scrutiny and evolving threats, the institutions that will thrive are those that invest in compliance agility and orchestration. RegTechONE helps you meet those expectations—and stay ahead of the enforcement curve.

A final takeaway

The FinCEN actions against CIBanco, Intercam, and Vector Casa de Bolsa underscore a truth every compliance professional knows: When AML fails, the consequences can be immediate and far-reaching. But with the right strategy, tools, and partners, AML Compliance and smart Risk Management can become competitive strengths.


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