FinCEN amends CIBanco special measure to permit Government-of-Mexico liquidation transmittals

Mechanism

This is a Section 2313a special-measure amendment, not a tariff or sanctions action. The June 30, 2025 order (90 FR 27770), as amended by 90 FR 30826 (July 11, 2025) and 90 FR 40974 (August 22, 2025), prohibited US covered financial institutions from engaging in transmittals of funds from or to CIBanco. The April 16, 2026 amendment carves out one narrow channel: payments necessary for the Government of Mexico to wind down and liquidate CIBanco — a recognition that Mexico's bank-resolution authority (IPAB / Banxico) needs USD-clearing access to actually distribute depositor funds and satisfy CIBanco's correspondent-side liabilities during the resolution.

The amendment leaves the underlying primary-money-laundering-concern finding intact. CIBanco itself remains barred from US correspondent relationships as a going concern. The carve-out applies only to "transmittals... ordinarily incident and necessary" to the liquidation procedure — meaning US covered institutions may now process these payments without falling foul of the §2313a prohibition, but the burden is on the institution to demonstrate the transmittal is in fact incident-and-necessary to the liquidation.

Downstream implications

• Mexican bank-resolution channel restored for one specific case;

precedent for future §2313a designations facing the same practical-resolution problem.

• IPAB-led wind-down can now access USD-rail clearing, reducing risk

of disorderly default on cross-border counterparty obligations.

• US covered institutions still must perform diligence — the carve-out

is permissive, not blanket; transmittals outside the liquidation scope remain prohibited.

• Signals continued willingness by Treasury/FinCEN to tune §2313a

orders mid-stream where bilateral resolution authorities need workable plumbing — distinct from OFAC SDN treatment.

Open questions

• Does Intercam Banco S.A. and Vector Casa de Bolsa S.A. de C.V.

(the two other June 2025 §2313a targets) get parallel liquidation-carve-out amendments? If yes, the amendment template generalises into a US-MX bank-resolution coordination pattern.

• How will US correspondent banks operationalise the

"incident-and-necessary" diligence test? Wells Fargo / Citi compliance memos will define the practical perimeter.

• Once liquidation is complete, is the underlying §2313a order

rescinded or does the determination persist as a deterrent signal?

• Note: predecessor June 30, 2025 order (FR doc 2025-11993) and the

two prior amendments (2025-12973 of July 11, 2025; 2025-16080 of August 22, 2025) are not yet filed in the IPTM register at the time this amendment is filed; responds_to: should be backfilled once the parent action is filed by a future wake.