Key takeaways
U.S. based financial institutions that conduct funds transfers with the designated Mexican institutions have until 21 July to implement compliance procedures.
Transfers of funds involving these designated Mexican institutions are prohibited on or after July 21.
The orders, representing FinCEN’s first use of the new authorities, appeared in the 30 June Federal Register, establishing 21 July 2025 as the effective date.
As we reported here, the U.S. Department of the Treasury Financial Crimes Enforcement Network (FinCEN) issued 2313a orders designating three Mexican financial institutions - CIBanco, S.A.; Intercam Banco, S.A.; and Vector Casa di Bolsa, S.A. de C.V. (collectively “Affected Mexican Institutions”) - as “primary money laundering concerns,” and prohibiting U.S. financial institutions from engaging in funds transfers to or from these designated institutions. The orders become effective 21 days after publication in the Federal Register. The orders were published here, here, and here, in the 30 June Federal Register, making the Effective Date Monday, 21 July 2025.
Next steps
While slippage/delay of the effective date is possible, affected parties (including U.S. financial institutions) should not count on it. Take steps to prepare.
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