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UPDATE #3: Effective date of FinCEN’s Section 2313a orders against three Mexican financial institutions delayed again
20 August 2025
Key takeaways
U.S. financial institutions that conduct funds transfers with the institutions subject to FinCEN’s Section 2313a orders now have until 20 October 2025 to implement compliance procedures and to stop funds transfers.
The 19 August announcement is the second extension of the effective date applicable to FinCEN's first use of the new authorities.
On 19 August 2025, FinCEN issued an order extending the effective date of the three June 2025 orders prohibiting certain transmittals of funds involving CIBanco S.A., Institución de Banca Multiple, Intercam Banco S.A., Institución de Banca Multiple, and Vector Casa de Bolsa, S.A. de C.V. As we reported here, the June 2025 orders designated the three Mexico-based financial institutions as “financial institutions of money laundering concern” and prohibited U.S. financial institutions from conducting funds transfers with them. The effective date, initially 21 July, was delayed until 4 September. U.S. financial institutions that conduct funds transfers with the designated Mexican institutions now have until 20 October 2025 to implement compliance procedures. Transfers of funds (either sending or receiving, and including transfers of digital assets) involving the designated Mexican institutions are prohibited on or after 20 October.
Authored by Gregory C.J. Lisa and Andrea Fraser-Reid.
Next steps
Affected parties, especially U.S. financial institutions, should leverage the additional time to ensure robust compliance procedures are in place by the effective date. If you have any questions regarding FinCEN's Section 2313a orders or any other compliance concerns, please reach out to any Hogan Lovells contact.
Contacts
Washington, D.C.
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