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UPDATE #2: Effective date of FinCEN’s Section 2313a orders against three Mexican financial institutions delayed until September 4
10 July 2025
Key takeaways
U.S. financial institutions that conduct funds transfers with the designated Mexican institutions have until 4 September to implement compliance procedures.
Transfers of funds involving these designated Mexican institutions are prohibited on or after 4 September.
The orders, representing FinCEN's first use of the new authorities, appeared in the 30 June Federal Register, initially establishing 21 July 2025 as the effective date.
As we reported here, the Financial Crimes Enforcement Network (FinCEN), a component of the U.S. Department of the Treasury, issued 2313a orders designating three Mexican financial institutions - CIBanco, S.A.; Intercam Banco, S.A.; and Vector Casa di Bolsa, S.A. de C.V. (collectively “Affected Mexican Institutions”) - as “primary money laundering concerns,” and prohibiting U.S. financial institutions from engaging in funds transfers to or from these designated institutions. The orders were to become effective 21 days after publication in the Federal Register.
We reported here that the orders were published in the 30 June Federal Register, making the effective date Monday, 21 July 2025. In that alert, we noted the possibility that FinCEN might extend the deadline.
On 9 July, FinCEN announced that it was extending the effective date by 45 days to give covered financial institutions additional time to implement the orders. The orders, prohibiting certain transmittal of funds involving CIBanco S.A., Institution de Banca Multiple, Intercam Banco S.A., Institución de Banca Multiple, and Vector Casa de Bolsa, S.A. de C.V., now go into effect 4 September 2025.
FinCEN also provided updated FAQs in its July 9 announcement, issuing further compliance guidance. We are reviewing the updated FAQs and will provide further analysis.
Authored by Gregory C.J. Lisa and Andrea Fraser-Reid.
Next steps
While the order announced on 9 July represents compliance deadline slippage, affected parties (including U.S. financial institutions) should not assume further extensions of the effective date of the 2313a orders will be forthcoming. Take steps to prepare.
If you have any questions regarding FinCEN's Section 2313a orders, require assistance preparing for the effective date, or if you have other compliance concerns, please reach out to any Hogan Lovells contacts.
Contacts
Washington, D.C.
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