On January 20, 2025, Inauguration Day, the Trump administration issued Executive Order 14157 promising to implement policies designed to achieve the“ total elimination” of certain drug cartels and transnational criminal organizations’( TCOs) presence in the U. S. to combat the illicit and deadly fentanyl trade.
In support of this policy initiative, the administration has deployed an“ all available tools” and whole-of-government approach, including:
▪ On February 5, 2025, the U. S. Department of Justice( DOJ) issued a memorandum,“ Total Elimination of Cartels and Transnational Criminal Organizations,” outlining four main areas of action,( a) charging priorities,( b) removing bureaucratic impediments to aggressive prosecutions,( c) creation or reengagement of joint task forces and( d) pursuing legislative changes designed to broaden statutes to prohibit manufacturing and other conduct related to fentanyl, serialize pill press machines to facilitate tracking by law enforcement and permanently place fentanyl-related substances on Schedule I of the Controlled Substances Act. 1
▪ On February 20, 2025, the U. S. Department of State in consultation with the U. S. Department of the Treasury( Treasury Department), respectively, designated eight Latin American drug cartels as foreign terrorist organizations( FTOs) and specially designated global terrorists( SDGTs). 2
▪ On March 11, 2025, the Financial Crimes Enforcement Network( FinCEN) issued a Geographic Targeting Order significantly increasing reporting obligations and significantly lowering the reporting threshold for money services businesses located in 30 U. S. zip codes along the southwest border with Mexico for 180 days. 3
▪ On April 11, 2025, FinCEN published a Financial Trend Analysis( FTA):“ Fentanyl-Related Illicit Finance: 2024 Threat Pattern and Trend Analysis” that found, among other things, the U. S., Mexican, Chinese and other foreign financial sectors serve as a potent and pervasive medium for the fentanyl supply chain. 4
▪ On May 1, 2025, FinCEN, in coordination with other U. S. enforcement agencies issued an alert warning U. S. financial institutions( FIs) that Mexico-based cartels and other TCOs are stealing billions of dollars of crude oil from Mexico’ s state-owned oil conglomerate, Petróleos Mexicanos( Pemex) and smuggling it across the U. S. Southwest border and into the U. S. 5 According to the Treasury Department, this activity is the cartels’ second-largest revenue generator following illicit drug trafficking. On the same day, OFAC announced the designations of three Mexican nationals and two Mexican-based entities targeting the Cartel Jalisco Nueva Generacion( CJNG), one of the cartels designated in February 2025. 6
On June 25, 2025, FinCEN took an“ unprecedented” step by issuing an order under section 2313 of the FEND Off Fentanyl Act that identified three large Mexican FIs ― CIBanco( Mexico’ s 20th largest bank), Intercam Banco( Mexico’ s 25th largest bank) and Vector Casa de Bolsa( Mexico’ s ninth-largest brokerage firm)― as being of“ primary money laundering concern” in connection with illicit opioid trafficking. 7 The orders mark the first time FinCEN has employed Section 2313a to sanction foreign FIs for opioid trafficking-related money laundering. For example, the orders found, among other things:
▪ CIBanco had a“ history of ties to international [ drug trafficking organizations ],” 8 including two organizations that the Trump administration designated as FTOs and SDGTs in February 2025, the Gulf Cartel and CJNG, through over 20 Chinabased companies known to have shipped precursor chemicals to Mexico for illicit purposes.
▪ Intercam processed funds transfers to China-based companies known to have shipped precursor chemicals to Mexico.
▪ Vector sent more than $ 17 million to several China-based companies for a company tied to an international drug trafficking organization and“ engaged in several transactions over several years” that the Treasury Department determined“ involved proceeds of bribes paid by the Sinaloa Cartel to Mexico’ s‘ top law enforcement official.’” 9
These enforcement actions prohibit U. S. FIs from transmitting any funds to and from these entities, effectively cutting them off from the U. S. financial system and stand to have profound implications for companies doing business in Mexico.
The Treasury Department took these landmark actions notwithstanding its acknowledgement that each of these FI intermediaries engaged in significant legitimate business activities. Within 48 hours, these orders ― the first of their kind issued under U. S. legislation enacted last year( the Fentanyl Sanctions Act and the FEND Off
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