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This is the second amendment to FinCEN's first-ever Section 2313a orders (the special-measure authority enacted under the FY2024 NDAA, 21 USC §2313a, which lets Treasury order covered US financial institutions to prohibit certain transmittals of funds to or from foreign financial institutions found to be of primary money-laundering concern in connection with illicit-opioid trafficking — a more surgical instrument than full OFAC SDN designation).
Sequence:
and Vector, published in the Federal Register on June 30, 2025 (FR docs 2025-11991, 2025-11992, 2025-11993; 90 FR 27770 et seq.). Original effective date: 21 days after publication, i.e. July 21, 2025.
90 FR 30826) extended the effective date to September 4, 2025, in response to industry comment on operational-readiness gaps.
90 FR 40974) extends the effective date a second time, from September 4 to October 20, 2025.
The August 22 amendment leaves the substantive prohibition unchanged: on the new effective date, US covered financial institutions are barred from transmitting funds from or to any account held at, or otherwise involving, the three named institutions, and must apply special due diligence to detect and reject covered transmittals. The amendment is a pure timing adjustment — no scope, no severity, no covered-institution list change.
The reason given by FinCEN is that additional time is needed for covered US institutions to operationalise the prohibition (correspondent de-risking, customer notification, counterparty reroute) without disrupting legitimate US-Mexico cross-border payment flows. The FinCEN press release emphasised that the underlying determinations of primary money-laundering concern remain intact and are not being reconsidered.
Banco Santander US) get an extra ~46 days to complete de-risking and reroute legitimate Mexico-side flows away from the three named institutions.
Vector face an extended uncertainty window — the prohibition is still coming, just six weeks later than previously scheduled.
Section 2313a implementation: the authority is sufficiently novel that FinCEN appears willing to use sequential amendments to calibrate the operational ramp.
filed: 2026-04-16-us-fincen-cibanco-mexico-liquidation-amendment.md) which addresses the cross-border bank-resolution plumbing problem that the October 20, 2025 effective date created once IPAB began CIBanco's wind-down.
filed in the IPTM register? At time of filing, only the April 2026 liquidation-carve-out amendment exists. The originals and the July 11, 2025 first extension (FR doc 2025-12973) are still in the filing queue and should be backfilled by future wakes; once they are, this action's responds_to: should be updated to point to them.
extension issued? Public reporting through the April 2026 liquidation amendment suggests the prohibition did take effect on October 20, 2025, with bank-resolution amendments rather than further timing extensions following.