Cartel Crackdown Begins: FinCEN’s 2313a Orders Signal a New AML Enforcement Era

On June 25, 2025, FinCEN exercised a new and aggressive authority under Section 2313a of the FEND Off Fentanyl Act, designating three Mexican financial institutions—CIBanco, Intercam, and Vector Casa de Bolsa—as entities of “primary money laundering concern” in connection with illicit opioid trafficking. These designations are not symbolic. They come with hard consequences: all covered U.S. financial institutions are now prohibited from conducting any transmittals of funds to or from these entities, effective within 21 days.

What is Section 2313a and Why It Matters

Section 2313a is a legislative response to the fentanyl crisis that empowers Treasury to shut down financial nodes of the drug trade without going through the typical rulemaking process, and this is the first time FinCEN has ever used this authority. Unlike Section 311 of the USA PATRIOT Act, which requires proposals and public comment, Section 2313a allows FinCEN to issue immediate civil orders to prohibit fund flows. In this case, the orders were based on findings that the named institutions played a direct role in laundering proceeds related to the procurement of precursor chemicals used by fentanyl-producing cartels, some of which are now designated as Foreign Terrorist Organizations.

Banks and AML professionals should treat this as a turning point. This signals a further expansion of AML enforcement into the realm of national security. Compliance officers are no longer dealing solely with abstract regulatory expectations. These are live, time-sensitive directives targeting specific entities linked to narcotics trafficking and terrorism. The lines between financial crime, national defense, and foreign policy are being erased.

What This Means for U.S. Financial Institutions

Every bank, broker-dealer, money services business, and other covered institution under 31 CFR 1010.100(t) is now expected to take concrete action. Not next quarter. Not pending clarification. Now.

By the effective date, institutions must:

1. Cease all transmittals of funds to or from CIBanco, Intercam, and Vector (limited to their Mexico-based operations).

2. Incorporate these designations into their AML/CFT risk assessments and control frameworks.

3. Ensure transaction screening and payment systems block relevant transactions.

4. Identify existing or historical relationships that could be affected, particularly correspondent relationships, trade finance, securities transactions, and cross-border wire corridors.

5. Train relevant personnel on how to identify attempts to circumvent the restrictions.

   
   

Failing to comply can result in civil penalties of up to two times the value of the prohibited transaction or $1.77 million, whichever is greater. Willful violations could carry criminal penalties, including fines up to $1 million.

What Makes This Different

First, the velocity. FinCEN acted without issuing a notice of proposed rulemaking. The justification was the urgency of the fentanyl threat and the critical role these institutions play in cartel financing networks. That rationale should serve as a warning. There will be more of these. And they will not be preceded by months of stakeholder input.

Second, the specificity. These orders name names. This is not a vague advisory about typologies or emerging threats. It is a formal designation of three financial institutions by name, and it comes with legal obligations. That is a far cry from the more academic advisories that AML teams are used to parsing.

Third, the link to foreign policy and national security. Treasury is aligning AML enforcement with geopolitical priorities. That’s not speculation—that’s embedded in the language of the FEND Off Fentanyl Act. Compliance professionals must begin to think in those terms. Traditional risk models built around customer demographics and transaction volumes are insufficient. The question going forward is: are your clients connected to global supply chains of illicit finance, chemical procurement, or sanctioned actors?

How Banks Should Respond Strategically

The tactical checklist is important, but it won’t be enough. These orders require a structural response. AML programs must become more agile, more threat-informed, and more integrated with the institution’s broader risk posture.

If your current sanctions or screening platforms cannot reliably detect affiliates or counterparties tied to the named institutions, you are exposed. If your compliance staff is unaware of how fentanyl trafficking networks operate financially, you are behind. And if your institution is still treating AML as a regulatory box-checking exercise rather than a frontline defense tool, you are out of alignment with Treasury’s expectations.

This is the time to reassess risk matrices, update typologies to include procurement of precursor chemicals, review exposure to Mexican financial intermediaries, and evaluate how geopolitical designations impact your customer base. You should also be reviewing FinCEN’s fentanyl typology advisories, cross-referencing with current client activity, and documenting every aspect of your institution’s response to this order.

For Financial Institutions With Significant Cross-Border Activity Involving China or Mexico: Take a Proactive Approach

If your institution has had any historical dealings with CIBanco, Intercam, or Vector — especially involving cross-border transactions to or from Mexico — now is the time for a proactive internal review. Don’t wait for your next exam to raise questions about missed transactions. Do a lookback now.

If anything questionable comes up, even if the transaction technically occurred before the order takes effect, you should seriously consider filing a SAR. Being proactive here isn’t just good compliance, it’s basic risk management. FinCEN is not likely to look favorably on firms that sat on potentially suspicious activity and waited to be asked about it.

File SARs Appropriately

If you do detect activity involving these institutions, and a SAR is warranted under existing guidance, FinCEN has asked that you include the following tags in Field 2 (Filing Institution Note to FinCEN):

• “CIBanco2313a FIN-2025”

• “Intercam2313a FIN-2025”

• “Vector2313a FIN-2025”

  
  

Based on recent conversations with law enforcement, these tags are crucial, as this activity can be missed by review teams unless explicitly included. Be thorough. Include as much transactional context and customer detail as possible, including names, account numbers, addresses, phone numbers, and a narrative of any concerning behavior or links to broader fentanyl-related typologies.

The Bottom Line

These 2313a orders are not business as usual. They are a shift toward a faster, more targeted, and more consequence-driven AML enforcement regime. Compliance is no longer just a matter of good governance. It is now an extension of U.S. foreign and national security policy.

Banks and financial institutions that fail to internalize this shift are at risk. Those that move quickly, think strategically, and build adaptable compliance frameworks will be better positioned not only to meet regulatory requirements but to safeguard the financial system in an increasingly complex threat environment. The era of reactive compliance is over. This is a time for decisiveness.

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Meet The Author

John Calderon is the Founder and Chair of the Coalition Against Financial Crime (CAFC), a national organization dedicated to advancing collaboration, innovation, and knowledge-sharing across the anti-financial crime community. A three-time BSA Officer with over a decade of frontline experience, John has led high-risk institutions through complex regulatory challenges, including consent orders, remediation projects, and full-scale program overhauls. He is also the President and CEO of ClearPath Compliance, a boutique consulting firm delivering tailored BSA/AML and financial crime solutions to small and often-overlooked financial institutions.

Follow John on LinkedIn: https://www.linkedin.com/in/financialcrimefighter/