Criminal Law Library Blog
The Financial Crimes Enforcement Center (FinCEN)”is a bureau of the U.S. Department of the Treasury. The Director of FinCEN is appointed by the Secretary of the Treasury and reports to the Treasury Under Secretary for Terrorism and Financial Intelligence. FinCEN’s mission is to safeguard the financial system from illicit activity, counter money laundering and the financing of terrorism, and promote national security through strategic use of financial authorities and the collection, analysis, and dissemination of financial intelligence.”.
On June 25, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) imposed special measures under Section 9714 of the Fentanyl Sanctions Act and the FEND Off Fentanyl Act, designating three Mexico-based financial institutions, CIBanco, Intercam Banco, and Vector Casa de Bolsa , as primary money laundering concerns. The action prohibits US financial institutions from processing transmittals of funds to or from these entities, or to any account or digital asset address they administer. This marks the first use of these new authorities, aimed at disrupting financial infrastructure exploited by cartels for fentanyl trafficking and precursor procurement.
According to FinCEN’s findings, the designated institutions played a key role in laundering funds on behalf of major cartels including CJNG, the Gulf Cartel, the Beltran-Leyva Organization, and the Sinaloa Cartel. The institutions processed millions of dollars in payments to China-based suppliers of precursor chemicals used in fentanyl production. Examples include a 2023 incident in which a CIBanco employee knowingly created an account to launder USD 10 million for a Gulf Cartel member, and Intercam executives meeting with CJNG associates to design laundering schemes involving US dollar wire transfers to China. Vector was linked to over USD 2 million in laundered proceeds for the Sinaloa Cartel, and over USD 1 million in payments to Chinese chemical exporters from 2018 to 2023. From TRM Blog June 25, 2025.
On August 28, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) unveiled a critical advisory, FIN‑2025‑A003, highlighting the rising threat of Chinese Money Laundering Networks (CMLNs) utilized by Mexico-based transnational criminal organizations (TCOs), including the Jalisco New Generation Cartel, the Sinaloa Cartel, and the Gulf Cartel FinCEN.gov+1.
These CMLNs are sophisticated, decentralized professional money launderers operating across global corridors. Their efficiency, adaptability, and willingness to shoulder significant risk make them especially valuable to criminal enterprises. FinCEN underlines that CMLNs pose one of the most substantial money laundering threats to the integrity of the U.S. financial system FinCEN.gov+1.
The advisory not only provides a clear snapshot of how CMLNs are interwoven with cartel operations—facilitating the laundering of drug proceeds—but also offers key “red flag” indicators designed to help financial institutions identify and report suspicious activity. Moreover, it reminds institutions of their obligations under the Bank Secrecy Act (BSA), outlining how specific SAR (Suspicious Activity Report) fields should be used to reference this advisory (e.g., “CMLN‑2025‑A003” in field 2, and applicable checkboxes such as 38(n), 38(s), and 36(l)) FinCEN.gov+1.
FinCEN also released a parallel Financial Trend Analysis (FTA), on August 28 which deepens the understanding of the scale and complexity of CMLN-related activity in the U.S., drawing upon over 137,000 BSA filings—amounting to approximately $312 billion in suspicious transactions between 2020 and 2024 FinCEN.gov+3FinCEN.gov+3U.S. Department of the Treasury+3
CONCLUSION.
The recent actions by FinCEN underscore the U.S. government’s escalating efforts to combat the financial infrastructure enabling the fentanyl crisis and other transnational criminal activities. By designating key Mexico-based financial institutions and exposing the role of Chinese Money Laundering Networks, FinCEN is sending a clear signal that the U.S. financial system will not be a safe haven for illicit funds.
For financial institutions, the message is equally urgent: vigilance is no longer optional. The August 28, 2025 advisory, paired with the accompanying Financial Trend Analysis, highlights the scale, sophistication, and adaptability of these global laundering networks, amounting to more than $312 billion in suspicious transactions over four years. Institutions must leverage the “red flag” indicators, follow proper SAR reporting protocols, and strengthen anti money laundering compliance programs to protect both their operations and the integrity of the U.S. financial system.
FinCEN’s coordinated approach (combining enforcement actions, intelligence analysis, and clear guidance) reflects a broader strategy to disrupt the cartels’ global financial lifelines. While challenges remain, these developments represent a pivotal moment in the ongoing effort to safeguard national security and maintain trust in the financial sector.