Podcast: Judgment in the …
News
UPDATE: Effective date regarding FinCEN’s new Section 2313a Orders against three Mexican financial institutions
30 June 2025
Key takeaways
U.S. based financial institutions that conduct funds transfers with the designated Mexican institutions have until 21 July to implement compliance procedures.
Transfers of funds involving these designated Mexican institutions are prohibited on or after July 21.
The orders, representing FinCEN’s first use of the new authorities, appeared in the 30 June Federal Register, establishing 21 July 2025 as the effective date.
As we reported here, the U.S. Department of the Treasury Financial Crimes Enforcement Network (FinCEN) 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 become effective 21 days after publication in the Federal Register. The orders were published here, here, and here, in the 30 June Federal Register, making the Effective Date Monday, 21 July 2025.
Authored by Gregory C.J. Lisa, Guillermo Larrea, Aleksandar Dukic, and Andrea Fraser-Reid.
Next steps
While slippage/delay of the effective date is possible, affected parties (including U.S. financial institutions) should not count on it. 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.
Articles you may be interested in
View more insights and analysis
