All in BSA

On August 19, 2025, FinCEN extended the effective dates for orders issued on June 25, 2025, prohibiting certain transmittal of funds involving three Mexico-based financial institutions. Covered financial institutions will now have until October 20, 2025, to implement the orders prohibiting certain transmittal of funds involving CIBanco S.A., Institución de Banca Multiple (CIBanco), Intercam Banco S.A., Institución de Banca Multiple (Intercam), and Vector Casa de Bolsa, S.A. de C.V. (Vector).

On August 6, 2025, FinCEN published a Readout regarding its latest FinCEN Exchange held on July 15 where it convened Treasury components, law enforcement agencies, financial institutions, regulatory technology companies, and trade groups to share insights on driving innovation in the digital assets ecosystem while protecting consumers from emerging fraud and scam threats. The FinCEN Exchange event, titled “Advancing Digital Assets Innovation While Safeguarding Consumers Against Fraud and Scam Risks,” focused on industry trends, fraud prevention, law enforcement's role in combating financial crimes related to digital assets, and compliance best practices.

On July 21, 2025, FinCEN announced it intention to postpone the effective date of the final rule establishing Anti-Money Laundering/Countering the Financing of Terrorism Program and Suspicious Activity Report Filing Requirements for Registered Investment Advisers and Exempt Reporting Advisers (IA AML Rule). The action, according to FinCEN, is to ensure efficient regulation that appropriately balances costs and benefits.

On  July 9, 2025, FinCEN extended the effective dates for orders issued on June 25, 2025, prohibiting certain transmittal of funds involving three Mexico-based financial institutions. Covered financial institutions will now have an additional 45 days or until September 4, 2025 to implement the orders prohibiting certain transmittal of funds involving CIBanco S.A., Institution de Banca Multiple (CIBanco), Intercam Banco S.A., Institución de Banca Multiple (Intercam), and Vector Casa de Bolsa, S.A. de C.V. (Vector).

On June 27, 2025, FinCEN issued an order permitting banks to collect Tax Identification Number (TIN) information from a third party rather than from the bank’s customer. FinCEN said that this action is aimed at providing banks with greater flexibility in fulfilling compliance obligation without presenting a heightened risk of money laundering, terrorist financing, or other illicit finance activity.

On June 25, 2025, FinCEN issued unprecedented orders identifying three Mexico-based financial institutions as being of primary money laundering concern in connection with illicit opioid trafficking, and prohibit, respectively, certain transmittals of funds involving the institutions. The named instituiosn include 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.