Mexico: Implications for Companies Following U.S. Actions and CNBV's Response Related to Alleged Fentanyl-Linked Money Laundering

On June 25, 2025, the U.S. Financial Crimes Enforcement Network (FinCEN) designated CIBanco, Intercam Banco, and Vector Casa de Bolsa as institutions of primary money laundering concern due to their alleged involvement in financing trafficking of fentanyl and other illicit substances.

This action—taken for the first time under the Fentanyl Sanctions Act and the FEND Off Fentanyl Act—prohibits U.S. financial institutions from executing fund transfers to or from the designated entities. Although the orders target three institutions, further designations cannot be ruled out.

In response, on June 27, the Mexican National Banking and Securities Commission (CNBV) implemented temporary managerial interventions in the three designated institutions. This measure aims to preserve financial system stability and protect users by replacing the institutions’ corporate governance bodies. The CNBV emphasized that this intervention does not constitute bankruptcy nor does it pose a systemic risk; rather, it is a preventive action carried out in accordance with the Law on Credit Institutions and the Securities Market Law.

Moreover, this sequence of measures sends a clear message: the United States is moving decisively in its strategy to combat Mexican cartels following their designation as Foreign Terrorist Organizations (FTOs). As a result, companies must adopt strategic measures for managing operational risks and reassess the risks associated with the financial services they use.