In a dynamic environment of regulations, financial institutions (FIs) must always be on their toes, wary and ready for something unexpected to come out of the blue and leave them scrambling for a solution. As compliance requirements changes are becoming more frequent, being agile and flexible is no longer an option for financial institutions – it’s mandatory.
Recent case in point: The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued the FinCEN Section 2313a orders, which prohibits transmittals of funds involving the following Mexico-based financial institutions: 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) identified as primary money laundering concern in connection with illicit opioid trafficking, and prohibit, respectively, certain transmittals of funds involving CIBanco, Intercam, and Vector.
As part of the USA’s ongoing fight against money laundering associated with the trafficking of fentanyl and other synthetic opioids, order 2313a empowers FinCEN to impose a broader set of “special measures,” including outright prohibitions on transmittals of funds, and to do so via order rather than the slower, more cumbersome rulemaking process.
What this means for financial institutions:
The effective date of these FinCEN orders is October 20, 2025. According to FinCEN, these entities will not be added to the OFAC SDN or Non-SDN lists in connection with these orders.
FIs must update their AML and sanctions screening policies, procedures & screening lists and treat the new 2313a orders like other special measures.
FIs must make sure they are able to identify and prevent funds transfers (wires, ACH, instant payment, SWIFT) that involve the ordered entities.
How Fincom enables its customers to accommodate the new orders:
This order exemplifies the dynamic nature of AML regulation; banks must move quickly to update policies, lists, and transaction-level screening to remain compliant. Because things can change suddenly and announcements can be decided overnight, FI’s must have agility and the flexibility to adapt quickly. And for that, a robust sanctions screening system should be in place.
To help its customers across the U.S. brace for the new regulations, FINCOM has created a new sanctions screening list named Fentanyl sanction Act, that will include these ordered entities, and future additional ones, which will no doubt be added as the list grows. This new list is now included in the set of sanctions and watchlists available to all Fincom customers. Thanks to its agile system architecture that is capable of rapidly accommodating the addition of new sanctions lists and its proactive approach, Fincom’s customers are assured that they meet the new regulation.
Order 2313a emphasizes regulators’ expectations from FIs to rapidly accommodate new AML regulations and the need for agile screening systems such as Fincom that can operationalize new restrictions across ACH, wires, and instant payments at very short time.
FinCEN’s recent actions made it clear: For Financial institutions, Agility and flexibility aren’t options – they’re mandatory.
