Ceasing Transactions per FinCEN Section 2313a

We are aware of FinCEN’s Section 2313a order to cease any and all transmittals of funds to/from CIBanco, Intercam Banco, and Vector Casa de Bolsa financial institutions starting October 20, 2025.

While CBX has several block list functions available, we do not have adequate data to automatically scan for and block transactions to/from these institutions through all channels.

Although most credit unions will not be affected, it is important to follow the FinCEN guidelines should a member be identified as receiving or sending funds to any of these three institutions.

Through conversations with several credit unions, we’ve compiled some tips we’d like to share with the network as they may help you comply with the order. You may elect to:

  • Convert ACH reports to PDF and use the Find feature within your PDF viewer to search for the bank names.
  • Work with Asterisk Intelligence to generate reports that search ACH addenda records for evidence of these institutions’ names.
    • Note: These reports are a best effort, and there is no guarantee they will catch all related ACH items. Items will be caught assuming the spelling is exactly the same as the query search criteria.
  • Educate staff who post wires/create checks to check outgoing wires/checks for these institutions.
  • Flag members that are known to have transactions with these institutions for review.
  • Utilize current block list functionality such as Country Code, Wires incoming/outgoing, payee name, etc. Learn more about fraud block lists.

Please review the FinCEN FAQs for more information.