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.
Financial infrastructure and the fentanyl trade: crypto’s role
According to TRM Labs, drug trafficking organizations — including the Sinaloa Cartel and CJNG — have significantly scaled their use of cryptocurrency in the fentanyl supply chain, particularly to facilitate cross-border payments for precursor chemicals sourced from China. In many cases, these transactions are made in tether (USDT) or bitcoin and processed through loosely regulated over-the-counter (OTC) brokers or P2P platforms with minimal AML oversight. Blockchain analysis reveals that precursor chemical suppliers advertise directly on darknet markets and messaging apps, accepting digital assets in exchange for chemicals shipped to Mexico. Once paid, crypto funds are laundered through complex transaction patterns including peel chains, layering, and cross-chain swaps, and often cashed out through Chinese exchanges or international mules.
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TRM traced specific cases where chemical shipments ordered by Mexico-based actors were paid in crypto and shipped from warehouses in Wuhan, China. Wallets tied to these actors were later linked to known laundering nodes servicing cartels. One 2025 investigation detailed how over USD 150 million in stablecoin payments flowed through a mix of exchanges and mule accounts tied to synthetic opioid trafficking networks.
Stablecoins are attractive for illicit actors, such as drugs cartels and money laundering networks, due to their speed, liquidity, and perceived stability. As outlined in TRM’s blog about the Guiding and Establishing National Innovation for US Stablecoins (GENIUS) Act on June 17, 2025, in Q1 2025, stablecoins accounted for 60% of illicit transaction volume across the crypto ecosystem.
TRM’s data also show that while traditional banks remain essential to cartel money movement, digital assets are increasingly used at the procurement layer — allowing buyers and suppliers to transact with speed and perceived anonymity. These patterns underscore the dual use of crypto alongside fiat systems in the fentanyl economy and reveal critical vulnerabilities that FinCEN and law enforcement are beginning to confront.
National security implications and enforcement outlook
The FinCEN designations come in the context of heightened US counter-narcotics efforts. In January 2025, the Trump administration issued an Executive Order directing the Treasury and State Departments to designate Mexican cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs). By February, six major cartels — including CJNG, Sinaloa, and the Gulf Cartel — had received these designations. FinCEN’s latest orders are intended to sever these groups from the global financial system, including the US dollar and increasingly, digital asset rails.
While the FinCEN orders did not explicitly reference virtual currencies, they prohibit US financial institutions from transmitting funds to any convertible virtual currency addresses controlled by the three designated entities. This underscores the growing recognition of cryptocurrency’s role in transnational drug finance and Treasury’s efforts to bring these vectors under existing AML/CFT oversight.
TRM Labs continues to support federal agencies by tracing the crypto components of fentanyl and precursor trafficking networks. The ongoing convergence of crypto and cartel finance — through both traditional and digital platforms — suggests that future designations may incorporate blockchain-based payment infrastructure directly. As Treasury officials have emphasized, the US government is committed to using all available authorities to disrupt the financial lifelines of transnational criminal organizations.
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