FinCEN’s Recent Actions: Existential Threat for Financial Institutions in Mexico

11/09/2025 31 min Episodio 81
FinCEN’s Recent Actions: Existential Threat for Financial Institutions in Mexico

Listen "FinCEN’s Recent Actions: Existential Threat for Financial Institutions in Mexico"

Episode Synopsis

Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group’s podcast, All Things Investigation. In this podcast, host Tom Fox welcomes back Jeremy Paner and Diego Durán de la Vega to discuss recent FinCEN enforcement actions targeting three Mexican financial institutions. The conversation explores the implications of these actions under the Fend Off Fentanyl Act, the evolving regulatory landscape, and the existential risks facing financial institutions operating in Mexico. The guests provide practical compliance guidance, lessons learned, and a forward-looking perspective on U.S. enforcement trends.

Highlights include:


Why These Enforcement Actions Matter

The Fend Off Fentanyl Act: A New Legal Tool

U.S. Government Focus on Mexico

Lessons from OFAC Enforcement

Compliance Implications for Financial Institutions

Responding to Enforcement: Practical Steps

Global Jurisdiction and the U.S. Financial System

Key Lessons for Compliance Officers

Looking Ahead: Future Enforcement Trends


Key Takeaways for Compliance Professionals:


The Fend Off Fentanyl Act introduces new, immediate risks for financial institutions, especially those with ties to Mexico.

U.S. enforcement actions can have global reach, severing access to the U.S. financial system.

Compliance programs must be robust, proactive, and responsive to regulatory advisories and negative media.

Effective communication between compliance and legal functions is crucial for mitigating risk.


Resources:

Hughes Hubbard & Reed website

Jeremy Paner

Diego Durán de la Vega

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