Industrial Policy & Trade Monitor· 2666 actions· ✨ 90 recent

FinCEN issued an amendment to its June 30, 2025 special-measure order (90 FR 27770) that had prohibited US covered financial institutions from transmitting funds to or from CIBanco S.A., a Mexican multiple-banking institution previously designated as of primary money-laundering concern in connection with illicit-opioid trafficking. Effective April 16, 2026, the amendment authorizes transmittals of funds ordinarily incident and necessary for the Government of Mexico to liquidate CIBanco. The carve-out is narrow: the broader §2313a prohibition on US-side correspondent activity with CIBanco remains in force outside the liquidation channel.

On 24 March 2026 Mexico's Supreme Court (SCJN), sitting in full Pleno session, unanimously upheld the constitutionality of the 2022 lithium nationalisation law (Decreto reforming the Mining Law and creating LitioMx) when resolving Acción de Inconstitucionalidad 78/2022 brought by a Senate minority (33 % of senators). The court affirmed Articles 1, 5 bis, and 10 of the Mining Law — which reserve all lithium exploration, exploitation, processing, and commercialisation exclusively to the State via the LitioMx decentralised public body and prohibit private concessions entirely — are constitutional, provided implementation follows established procedures requiring technical support and Mexican Geological Service validation. The ruling closes the last formal constitutional challenge to Mexico's state-monopoly lithium regime, confirming a permanent exclusion of private capital from the full lithium value chain.

FinCEN issued an expanded Geographic Targeting Order (GTO) requiring money services businesses (MSBs) located in designated counties and ZIP codes across Arizona, California, New Mexico, and Texas to file Currency Transaction Reports (CTRs) on cash transactions between $1,000 and $10,000 — well below the standard $10,000 CTR threshold. The order took effect March 7, 2026 and runs through September 2, 2026; the FR notice (FR Doc. 2026-04641) was published March 10, 2026. The expansion adds Bernalillo, Doña Ana, and San Juan Counties in New Mexico and Maricopa and Pima Counties in Arizona to the geography covered by the prior September 10, 2025 GTO. Compliance date for newly-covered MSBs is April 6, 2026; reports must be filed within 30 days (extended from the standard 15-day CTR deadline). The instrument is part of the post-2024 US enforcement architecture targeting fentanyl-related illicit-finance flows through the US-Mexico border MSB channel.

President Trump signed Executive Order "Ending Certain Tariff Actions" on 20 February 2026 (Federal Register doc 2026-03832, published 25 February 2026), terminating the additional ad-valorem duties imposed under nine prior IEEPA-based executive orders. The order followed within hours of the US Supreme Court's 6-3 decision the same day in Learning Resources, Inc. v. Trump, 607 U.S. ___ (2026), holding that the International Emergency Economic Powers Act does not authorize the President to impose tariffs and vacating the Trump 2.0 IEEPA tariff regime. The EO directs CBP to cease collection "as soon as practicable"; CSMS guidance set the collection-end date at 12:00 a.m. eastern on 24 February 2026. The order explicitly preserves all underlying national-emergency declarations and all non-IEEPA trade actions — Section 232 of the Trade Expansion Act, Section 301 of the Trade Act, Section 122 of the Trade Act, and Section 201 — so the Section 232 cascade and the paired Section 122 10% temporary surcharge (effective 24 Feb 2026) remain in force. This is the first SCOTUS-driven repeal of a presidential tariff regime in the modern era and recalibrates the entire post-2024 US tariff architecture by removing IEEPA as a legal pillar.

President Claudia Sheinbaum signed a comprehensive reform to Mexico's Customs Law (Ley Aduanera) published in the Diario Oficial de la Federación on 19 November 2025, entering into force 1 January 2026. The decree formally recognises the Agencia Nacional de Aduanas de México (ANAM) as the autonomous customs authority with expanded inspection and fiscalisation powers, creates a new inter-secretarial Consejo Aduanero with binding decisional authority over customs-agent licensing, and mandates real-time electronic traceability and video-surveillance at all recintos fiscales. The reform is Mexico's most comprehensive statutory overhaul of its customs-administration architecture in over a decade, directly conditioning USMCA-origin compliance infrastructure for approximately US$800 billion in annual MX-US trade and over 3,200 IMMEX-registered nearshoring operators.

On September 10, 2025 FinCEN issued a Geographic Targeting Order (GTO) under 31 USC 5326 requiring money services businesses (MSBs) in designated southwest-border counties and ZIP codes across California, Texas, and (newly added) Arizona to file Currency Transaction Reports (CTRs) on cash transactions between $1,000 and $10,000 — well below the BSA's standard $10,000 CTR threshold. The order ran through March 6, 2026 (180 days, the GTO statutory maximum) and was subsequently extended via the March 10, 2026 expanded GTO (FR Doc. 2026-04641) which retained the $1,000 floor and added inland transit hubs (Bernalillo, Doña Ana, San Juan in NM; Maricopa, Pima in AZ). The September 2025 order modified an earlier March 14, 2025 GTO that had used a $200 threshold and covered a narrower TX/CA strip; the September 2025 modification raised the threshold to $1,000 in response to MSB-industry feedback on operational burden, while extending the geography to include Arizona. Filing deadline is extended from the standard 15 days to 30 days.

FinCEN published an order amending the three June 25, 2025 special-measure orders (as previously amended by the July 11, 2025 order, FR doc 2025-12973) prohibiting US covered financial institutions from transmitting funds to or from CIBanco S.A., Intercam Banco S.A., and Vector Casa de Bolsa, S.A. de C.V. — three Mexican institutions designated of primary money-laundering concern in connection with illicit-opioid trafficking under Section 2313a of the Fiscal Year 2024 NDAA. The amendment extends the effective date of all three prohibitions from September 4, 2025 to October 20, 2025, granting US covered institutions an additional ~46 days to wind down correspondent exposures. The underlying primary-money-laundering-concern findings remain intact — only the implementation deadline shifts.

FinCEN published an order amending the three June 25, 2025 special-measure orders (FR docs 2025-11991, 2025-11993, 2025-11990; 90 FR 27770 et seq.) prohibiting US covered financial institutions from transmitting funds to or from CIBanco S.A., Intercam Banco S.A., and Vector Casa de Bolsa, S.A. de C.V. — three Mexican institutions designated of primary money-laundering concern in connection with illicit-opioid trafficking under Section 2313a of the Fiscal Year 2024 NDAA. This first extension shifts the effective date of all three prohibitions from July 21, 2025 to September 4, 2025 (a 45-day delay), giving US covered institutions additional time to wind down correspondent exposures. The underlying primary-money-laundering- concern findings remain unchanged — only the implementation deadline shifts.

On 26 June 2025, the Governing Board of Mexico's National Banking and Securities Commission (CNBV), invoking Article 129 of the Ley de Instituciones de Crédito, decreed the temporary managerial intervention of CI Banco, S.A. and Intercam Banco, S.A., replacing their administrative bodies and legal representatives. The measure came one day after the US Treasury's FinCEN designated both institutions (along with Vector Casa de Bolsa) as foreign financial institutions of primary money-laundering concern tied to opioid-trafficking networks, and prohibited certain US fund transmittals to them. CNBV/SHCP framed the intervention as a depositor- and creditor-protection measure to safeguard the two banks' operations against the fallout of the US action; Vector Casa de Bolsa was not included in the CNBV intervention.

On March 11, 2025 FinCEN issued a Geographic Targeting Order (GTO) under 31 USC 5326 — published in the Federal Register on March 14, 2025 (FR Doc. 2025-04099) and effective April 14, 2025 — requiring every money services business (MSB) located in 30 designated ZIP codes across seven counties in California (Imperial, San Diego) and Texas (Cameron, El Paso, Hidalgo, Maverick, Webb) to file a Currency Transaction Report (CTR) on cash transactions of more than $200 but not more than $10,000, far below the Bank Secrecy Act's standard $10,000 CTR floor. The order also imposed customer-identification recordkeeping and, per the FinCEN order text, gave covered MSBs thirty (30) days to file CTRs (vs. the standard fifteen). It was framed by Treasury as part of the post-January-2025 cartel-targeting policy stack (Trump Executive Order 14157 designating Mexican drug cartels as Foreign Terrorist Organizations / SDGTs) and was intended to surface low-value cash flows used by Mexico-based cartels and related criminal actors. The GTO was a 180-day order set to expire September 9, 2025; it was subsequently superseded on September 10, 2025 by a modified GTO that raised the threshold to $1,000 in response to MSB-industry feedback on burden, expanded geography to Arizona, and was itself replaced/expanded again on March 10, 2026.

The U.S. Department of Commerce, through the International Trade Administration's Enforcement and Compliance unit, published a technical correction to its 31 January 2024 final rule ("Procedures and Rules for Article 10.12 of the United States-Mexico-Canada Agreement", 89 FR 6011) that established the binational-panel and extraordinary-challenge-committee procedures replacing the legacy NAFTA Article 1904 framework. The correction removes erroneously duplicated regulatory text in 19 CFR § 356.8(b)(2) — language that had been inadvertently copied from § 356.8(b)(1) in the prior rulemaking — and is effective on publication. The fix is non-substantive and does not alter any rights, obligations, or procedural requirements for parties to USMCA Chapter 10 binational-panel reviews of US antidumping and countervailing duty determinations involving Canadian or Mexican merchandise.