FinCEN Amends Special Measure on Certain Fund Transmittals Involving CIBanco

Adam Witmer
BSA, Regulatory Update

On April 16, 2026, FinCEN issued an order amending its June 2025 order finding that CIBanco S.A., Institución de Banca Multiple (CIBanco), is a financial institution operating outside of the United States that is of primary money laundering concern in connection with illicit opioid trafficking and imposing a special measure prohibiting certain transmittals of funds involving CIBanco. 

Effective April 16, 2026, the amendment allows for certain transmittals of funds provided that the Government of Mexico's appointed liquidator has determined that such transmittal of funds is necessary to liquidate CIBanco, and the transmittal of funds is not otherwise prohibited by law. All other provisions of the June 2025 Order remain unchanged.

The Amendment of Order can be found here.

Adam Witmer
BSA, Regulatory Update
Adam Witmer

Adam Witmer is a speaker, author, and founder of the Compliance Cohort. Adam has taught hundreds of seminars and training sessions to thousands of bankers throughout the United States and teaches on all areas of regulatory compliance. Adam has written five e-books that he never published, hit a grizzly bear while driving in a National Park, and is an award winning photographer and musician (though he no longer takes photos nor plays any instruments). In his spare time, Adam can be found kayaking on the lake, doing taekwondo with his kids, working on his (project) house, or spending time with his family.

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