FinCEN amends CIBanco special measure to allow transmittals needed for Mexico's liquidation of CIBanco

Applies to: Covered financial institutions engaging in transmittals of funds involving CIBanco; the order is outside residential mortgage underwriting and servicing.

Effective

Apr 16, 2026

Applicability confidence

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What to review: First, note that this amendment is optional and relaxes the CIBanco order. From April 16, 2026, transmittals of funds that are ordinarily incident and necessary for Mexico's liquidation of CIBanco are authorized. This applies only if the appointed liquidator has determined they are necessary and they are not otherwise prohibited by law. The record places the order outside residential mortgage underwriting and servicing.

QC implications

• If compliance relies on this authorization for a CIBanco-related transmittal, QC may check that the file shows the Government of Mexico's appointed liquidator determined the transmittal was necessary to liquidate CIBanco.
• QC may check that any transmittal handled under this authorization was ordinarily incident and necessary for the liquidation and was not otherwise prohibited by law.
• QC may check that the authorization was applied only to transmittals on or after April 16, 2026.