FinCEN Sanctions Drive MX$3.2 Trillion Asset Shift in Mexico

Mexico’s fiduciary market has undergone a MX$3.2 trillion reshuffle following capital migrations triggered by Financial Crimes Enforcement Network sanctions against CIBanco and Intercam. Banco Multiva absorbed MX$1.66 trillion in assets, underscoring growing concentration among a handful of institutions and its implications for competition and regulatory agility. The process culminated in CIBanco’s liquidation by the CNBV, reinforcing the critical importance of AML compliance and transparent governance across Mexico’s financial system.

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An estimated MX$3.2 trillion (US$183 billion) in fiduciary portfolios migrated across the Mexican financial system in the 12 months following sanctions imposed by the Financial Crimes Enforcement Network (FinCEN) on CIBanco and Intercam Banco, according to a new report by TMSourcing. The report, Mercado Fiduciario en México 2025–2026, states that the forced liquidation of these institutions triggered a significant structural reconfiguration of the trust market as assets were reassigned to alternative administrators.

The report identifies Banco Multiva as the primary recipient of these capital flows, absorbing more than MX$1.66 trillion (US$94.71 billion) in less than six months and emerging as the leading fiduciary administrator in the system. Secondary inflows were distributed among Actinver, Invex, and Grupo Financiero Inbursa, each receiving between MX$50 billion (US$2.85 billion) and MX$300 billion (US$17.11 billion). Kapital Bank also absorbed smaller portfolio volumes during the period.

This reconfiguration occurred within a banking trust segment that expanded 25% cumulatively between 2022 and 2026. Despite this growth, TMSourcing highlighted increasing concentration among a limited number of institutions.

“The current structure limits effective competition, reduces client options and weakens incentives for innovation and efficiency,” the report states. While the fiduciary model remains one of the most robust associative frameworks under Mexican law, the analysis argues that concentration is creating inefficiencies that constrain broader economic potential.

One key inefficiency cited is the imbalance in service provision for high-value assets. While a small group of banks administers most individual trusts, stock market and common representation mandates — representing the largest share of assets under management—are handled by a limited number of fiduciaries. The report also highlights regulatory asymmetries between unregulated multiple-purpose financial companies (Sofomes) and regulated financial intermediaries.

The study identifies several structural barriers, including a shortage of fiduciary institutions authorized by the National Banking and Securities Commission (CNBV). Disjointed fiscal criteria — particularly around obtaining a Taxpayer Identification Number (RFC) for trusts — continue to hinder market efficiency. Additional challenges include anti-money laundering compliance, judicial processes and the need for simplified trust structures.

“The evolution of the fiduciary framework represents a strategic opportunity to strengthen the Mexican financial system, expand access to specialized solutions and drive efficiency, innovation and competition,” TMSourcing said, emphasizing transparency as a key requirement for market development.

The CIBanco Case

In June 2025, FinCEN issued its first enforcement action under the Fentanyl Sanctions Act, alleging that CIBanco facilitated purchases of chemical precursors for drug cartels. The designation effectively cut the bank off from the US financial system, prompting immediate action by Mexican regulators. 

While President Claudia Sheinbaum and the Ministry of Finance initially questioned the lack of formal evidence, the CNBV invoked Article 129 of the Law of Credit Institutions to appoint provisional administrators from Alvarez & Marsal México to safeguard creditors and maintain stability.

Despite these measures, CIBanco experienced severe operational disruption. Visa terminated its relationship with the bank on June 30, 2025, affecting approximately 220,000 debit and prepaid cards. The bank also reported that more than US$38 million held in fiduciary accounts across US institutions became inaccessible due to the sanctions. Management warned that the measures threatened the institution’s viability and the jobs of more than 3,000 employees.

In an effort to challenge the sanctions, CIBanco filed a civil lawsuit in a US federal court against the United States Department of the Treasury in August 2025, arguing violations of due process. The case was later withdrawn after FinCEN extended the effective date of its prohibition order. 

The crisis culminated in October 2025, when the CNBV revoked CIBanco’s banking license. Its majority shareholder, Tenedora CI, said liquidation was necessary to protect the financial system amid severe liquidity constraints triggered by the US designation.

Following the revocation, the Institute for the Protection of Bank Savings initiated the liquidation and repayment process on October 13. Depositors were allowed to recover insured funds of up to 400,000 UDIs, equivalent to approximately MX$3.4 million (US$193,912) per person. IPAB clarified that while small depositors were protected, deposits held by board members and senior executives were not insured, although all credit obligations remained valid.

Tenedora CI maintained that independent reviews found no evidence of illicit activity, but acknowledged that the bank could not recover from the asset losses and reputational damage caused by the FinCEN designation.

Most recently, FinCEN amended its order, allowing Mexican authorities to proceed with the full liquidation of CIBanco’s assets. The US Treasury said the decision reflects “the shared commitment of the United States and Mexico to protect the financial systems of both countries from cartels and drug traffickers.”