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pc nid 91987 Apr 15, 2026 pdonofrio@vixio.com US Track 2 Financial Crimes Enforcement Network horizon scanning
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United States Financial Crimes Enforcement Network Imposes Special Measure Restricting Fund Transmittals Involving CIBanco

On April 15, 2026, the Financial Crimes Enforcement Network (FinCEN) imposed a special measure prohibiting certain transmittals of funds involving CIBanco S.A., Institución de Banca Multiple, a Mexican financial institution. Special measures under the Bank Secrecy Act (BSA) represent enforcement actions taken by FinCEN to address money laundering and terrorist financing risks posed by specific financial institutions or jurisdictions. The imposition of restrictions on CIBanco indicates that FinCEN has identified significant compliance concerns or financial crime risks associated with the institution's operations. Such measures typically require U.S. financial institutions and money services businesses to implement enhanced due diligence procedures when processing transactions involving the designated entity, or in certain cases, to prohibit or restrict fund transfers entirely. The amendment to this special measure suggests modifications to the scope or terms of the original restriction. These adjustments may reflect evolving risk assessments, changes in the institution's compliance posture, or refinements to the enforcement action based on operational experience or additional information obtained by FinCEN. U.S. financial institutions and money services businesses subject to BSA requirements must comply with the terms of this special measure. Institutions should review the full details of the restriction to understand their specific obligations regarding transactions involving CIBanco and ensure appropriate systems and controls are implemented to achieve compliance. The measure remains in effect unless subsequently amended or rescinded by FinCEN. **Reference:** Financial Crimes Enforcement Network (FinCEN). Imposition of Special Measure Prohibiting Certain Transmittals of Funds Involving CIBanco S.A., Institución de Banca Multiple; Amendment. April 15, 2026. Available at: https://www.fincen.gov

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US Financial Crimes Enforcement Network Issues Order Restricting Transactions Involving CIBanco SA

On April 15, 2026, the US Financial Crimes Enforcement Network (FinCEN) issued an order — amending a previous June 2025 order — against CIBanco SA. FinCEN found that CIBanco SA violated federal anti-money laundering (AML) laws in connection with illicit opioid trafficking. The amended order stipulates that a covered financial institution is prohibited from engaging in any transmittal of funds from or to CIBanco SA. However, all transmittals of funds that are ordinarily incident and necessary for the government of Mexico to liquidate CIBanco SA, are authorized, provided that: The government of Mexico's appointed liquidator has determined that such transmittal of funds is necessary to liquidate CIBanco SA. The transmittal of funds is not otherwise prohibited by law.