Jack Harrington Quoted in ACAMS moneylaundering.com on Preparing for FinCEN’s New Tool Against Fentanyl Trafficking

Bradley attorney Jack Harrington was quoted in a moneylaundering.com article about the tension between heavy-duty enforcement and banks’ desire for regulatory stability following FinCEN’s new tool targeting financial channels tied to the fentanyl supply chain. Banks around the world are bracing for heightened risk and scrutiny.

“In light of this, banks in Mexico and the wider Latin American region, if they’re smart, are going to do a lookback analysis for cartel-related entities, such as logistics, energy and shipping, particularly along the U.S.-Mexico border,” said Harrington, a former federal prosecutor in who oversaw investigations into fraud, money laundering and other complex crimes.

The scope of the lookback banks should conduct to identify any links, however indirect, to illicit opioid traffickers and their finances in light of FinCEN’s efforts to tackle both will vary based on their respective sizes, risk profiles and tolerances, explained Harrington.

CIBanco, a commercial lender in Mexico City, began liquidating last month after Mexico’s National Banking and Securities Commission, or CNBV, revoked its license and the Institute for the Protection of Bank Savings, or IPAB, put plans in motion to repay depositors. The second target, Intercam Banco, has sold an undisclosed amount of assets to Kapital Bank, while the third, Vector Casa de Bolsa, a brokerage in Mexico City that FinCEN linked to the Sinaloa and Gulf cartels, has transferred thousands of accounts to a former competitor, Finamex Casa de Bolsa, reportedly after losing hundreds of millions of dollars in revenue.

“I would suggest they start by determining whether any of their customers conducted any transactions with one of those three companies in the preceding two years, then subject those customers to enhanced due-diligence to include a deeper understanding of why those wires were sent, their counterparts, etc.,” Harrington said.

“It’s too early to say if anything will change in terms of how U.S. banks approach relationships with foreign financial institutions, whether or not they’re designated [pursuant to] 2313a or [solely] under section 311,” Harrington added. “The key difference isn’t the outcome, but the process of getting there, and that concerns a lot of institutions.”

The full article, “FinCEN’s New Tool Against Fentanyl Trafficking Gives Banks Pause,” was published by ACAMS moneylaundering.com on Nov. 11, 2025. (login required)