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Fentanyl special measures: What compliance teams need to know

Terri Luttrell, CAMS-Audit, CFCS
July 3, 2025
Read Time: 0 min

Fentanyl special measures: What compliance teams need to know

The Financial Crimes Enforcement Network (FinCEN) has invoked new authorities under the FEND Off Fentanyl Act (the Act) to target key financial facilitators of synthetic opioid trafficking. On June 25, 2025, FinCEN designated three financial institutions in Mexico as primary money laundering concerns. The agency also issued orders that prohibit any transmittal of funds involving these organizations.

These actions represent a significant expansion of regulatory expectations for financial institutions in the United States. They also signal a shift in how banks and credit unions are expected to detect and disrupt fentanyl-related financial activity.

The ongoing toll of fentanyl in the U.S.

While the new FinCEN orders mark a shift in regulatory strategy, the urgency behind them is rooted in the human cost of fentanyl trafficking. Synthetic opioids, particularly illicitly manufactured fentanyl, remain the leading cause of drug overdose deaths in the United States.

According to provisional 2024 data from the Centers for Disease Control and Prevention (CDC):

  • More than 70,000 overdose deaths in 2024 involved synthetic opioids, primarily fentanyl. This figure accounts for the majority of all overdose fatalities.
  • Fentanyl was detected in approximately seven out of every ten overdose deaths, highlighting how deeply it has permeated the illicit drug market.
  • Adults aged 18 to 45 continue to be the most affected, with fentanyl remaining the leading cause of death in this age group.
  • A growing number of cases involve polysubstance use, where fentanyl is mixed with other drugs like cocaine, methamphetamine, or xylazine, increasing overdose risk and complicating emergency response.
  • Although total opioid deaths have declined slightly since 2023, fentanyl-related fatalities remain persistently high, especially in rural areas and regions across the South and Midwest.

These statistics underscore why financial institutions are being asked to take a more active role in disrupting the financial infrastructure behind fentanyl trafficking. The fentanyl special measures are not only about regulatory compliance; they are part of a broader national effort to save lives.

 

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Understanding the reach of Special Measure Six

The fentanyl special measures were issued under Special Measure Six, a provision of the Act that empowers FinCEN to prohibit the transmission of funds involving institutions connected to opioid trafficking. This authority goes beyond traditional Section 311 actions, applying to any fund transfers, including those involving crypto wallets and online payments.

The institutions named in the orders include:

  • CIBanco S.A. and its subsidiaries Finanmadrid Mexico and CI Fondos
  • Intercam Banco S.A.
  • Vector Casa de Bolsa, S.A. de C.V.

FinCEN found that each of these institutions facilitated payments that supported the trafficking of fentanyl and its chemical precursors. These orders take effect 21 days after publication in the Federal Register and apply to any accounts or fund transfers, whether through traditional or digital channels.

Recognizing red flags tied to fentanyl trafficking

In connection with the fentanyl special measures, FinCEN has reaffirmed the importance of identifying behavioral and transactional red flags. These red flags were initially outlined in FinCEN advisories, including 2024-A002 and 2019-A006, and are critical for strengthening anti-money laundering programs.

Red flags based on customer or counterparty behavior:

  • Individuals or entities with a history of drug-related convictions or links to chemical laboratories
  • Businesses based in China or Hong Kong that have no physical location or maintain a residential mailing address
  • Customers who have no business relationship with China but use Chinese phone numbers or IP addresses
  • Mexican importers of chemical products or lab equipment who lack valid business licenses or show little online presence
  • Groups of seemingly unrelated importers in Mexico that share contact details or interact with the same foreign suppliers

Red flags in transactional activity:

  • Repeated low-dollar payments, typically under $1,000, to companies in China or Hong Kong
  • Use of money services businesses or online payment platforms to send funds in patterns that appear designed to avoid reporting requirements
  • Beneficiaries in Mexico receiving funds from multiple unrelated U.S. senders
  • Wire transfers from businesses without an apparent commercial reason to interact with chemical suppliers
  • Use of cryptocurrencies such as Bitcoin or Monero for overseas payments, particularly when involving unregulated platforms
  • Attempts to avoid cash reporting thresholds through structuring or by canceling transactions after initiating them

Financial institutions should integrate these indicators into onboarding processes, transaction monitoring, and investigative protocols.

Steps financial institutions should take

The fentanyl special measures require immediate attention from compliance teams. Because these orders prohibit transmittals of funds, including those that may not involve direct relationships with the named institutions, institutions need to assess risk across all lines of business.

Key actions include:

  1. Review past transactions to identify any activity tied to the named institutions or their subsidiaries. Screening wire activity from the past 60 to 90 days can help gauge potential exposure. Employ temporary resources if needed for this lookback.
  2. Block payment activity using affected Bank Identification Numbers (BINs) or routing numbers, particularly if operations include card, MSB, or crypto sectors.
  3. Ensure processors and fintech partners are applying restrictions, especially for BaaS providers or acquiring institutions.
  4. Escalate potential matches and file SARs when warranted. While the new orders do not mandate SARs, FinCEN’s language suggests that institutions should treat any connection as a due diligence red flag.
  5. Update internal controls and training to reflect these restrictions. Incorporate keywords and entity names into monitoring systems to ensure alerts are captured and addressed quickly.

A broader risk: Trade-based money laundering and fentanyl financing

The fentanyl special measures also spotlight the growing use of trade-based money laundering to mask illicit proceeds. Criminal networks often use commercial transactions to legitimize payments, such as purchasing goods with drug proceeds and exporting them to cartel-linked businesses.

Common methods include:

  • Purchasing goods such as electronics or industrial equipment with drug proceeds, then shipping them to Mexico
  • Mispricing shipments to transfer value without moving cash
  • Structuring deposits into funnel accounts to hide the origin of funds

These strategies complicate the detection of trafficking-related activity. Financial institutions with customers involved in international trade should consider applying enhanced due diligence and reviewing trade finance transactions more closely.

 

A call to act

The fentanyl crisis continues to cause widespread harm, and financial institutions are positioned to support law enforcement by disrupting the financial infrastructure that traffickers rely on. The fentanyl special measures are more than a regulatory requirement; they are an opportunity for institutions to play a direct role in protecting their communities. A proactive, well-coordinated AML/CFT response not only meets FinCEN’s expectations but also strengthens the institution’s risk position. As synthetic opioids continue to evolve, so must the strategies used to detect and report the movement of illicit funds.

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About the Author

Terri Luttrell, CAMS-Audit, CFCS

Compliance and Engagement Director
Terri Luttrell is a seasoned AML professional and former director and AML/OFAC officer with over 20 years in the banking industry, working both in medium and large community and commercial banks ranging from $2 billion to $330 billion in asset size.

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About Abrigo

Abrigo enables U.S. financial institutions to support their communities through technology that fights financial crime, grows loans and deposits, and optimizes risk. Abrigo's platform centralizes the institution's data, creates a digital user experience, ensures compliance, and delivers efficiency for scale and profitable growth.

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