All in Regulatory Update

On July 14, 2025, the OCC, the Federal Reserve Board, and the FDIC issued a joint statement in their continued efforts to provide clarity on banks’ engagement in crypto-asset-related activities. The joint statement, which focuses on safekeeping crypto-assets, discusses how existing laws, regulations, and risk-management principles apply to the activity and does not create any new supervisory expectations.

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.