On June 25, 2025, the Financial Crimes Enforcement Network of the U.S. Department of the Treasury (“FinCEN”) issued three orders (the “FinCEN Orders”) targeting, and prohibiting certain U.S. persons from engaging in any transfer of funds involving, three Mexican financial institutions: CIBanco S.A., Institución de Banca Multiple (“CIBanco”), Intercam Banco S.A., Institución de Banca Multiple (“Intercam”) and Vector Casa de Bolsa, S.A. de C.V. (“Vector”). These actions mark the first exercise of a new authority set forth at 21 U.S.C. 2313a (“Section 2313a”), which was added to the U.S. Code in 2024 by the FEND Off Fentanyl Act. As a result of the FinCEN Orders, U.S. financial institutions will be broadly prohibited from engaging in transmittals of funds involving any of CIBanco, Intercam or Vector, resulting in the disconnection of these Mexican institutions from the U.S. financial institutions and additional market impacts.
