All in Regulatory Update

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.

On June 23, 2025, FinCEN issued a press release to inform U.S. financial institutions that the Financial Action Task Force (FATF), an intergovernmental body that establishes international standards to combat money laundering, counter the financing of terrorism, and combat weapons of mass destruction proliferation financing (AML/CFT/CPF), has issued public statements updating its lists of jurisdictions with strategic AML/CFT/CPF deficiencies following its plenary meeting last month. U.S. financial institutions should consider the FATF’s stance toward these jurisdictions when reviewing their obligations and risk-based policies, procedures, and practices.