Section 2313a: What Financial Institutions Need to Know and How to Prepare

A New Era of Targeted Financial Controls 

In June 2025, FinCEN exercised its new authority under Section 2313a of Title 21, created by the FEND Off Fentanyl Act. This provision empowers FinCEN to identify foreign entities, accounts, or transaction types that pose a primary concern for money laundering related to illicit opioids. 

For the first time, FinCEN imposed prohibitions on U.S. financial institutions, effectively cutting off funds transfers to three Mexico-based institutions tied to fentanyl trafficking. The orders take effect on October 20th, 2025. 

This marks a major shift. Instead of solely relying on Section 311 of the Patriot Act, FinCEN now has a faster, more targeted tool to disrupt drug cartel financing. 

What Section 2313a Means for Financial Institutions 

Financial institutions must act quickly to comply with these orders. The key obligations include: 

• Screening and blocking: Prevent prohibited transmittals involving designated entities such as CIBanco, Intercam Banco, and Vector Casa de Bolsa.
• Enhanced due diligence: Review cross-border transactions and correspondent relationships for potential exposure.
• Policy and controls updates: Incorporate compliance with Section 2313a into BSA/AML procedures.
• Penalties for non-compliance: Civil fines of at least twice the amount of the transaction (up to about $1.78M), and possible criminal fines up to $1M for willful violations. 

Unlike typical sanctions programs, these measures are not OFAC-driven but are direct FinCEN orders. That distinction means institutions must update monitoring systems and workflows rapidly to avoid gaps. 

The Compliance Challenge 

Traditional monitoring systems often lag in adapting to new regulatory authorities. The unique structure of Section 2313a outside of OFAC but equally enforceable creates several challenges. 

Legacy systems are not configured to capture 2313a-specific identifiers. Real-time blocking requires data sharing across counterparties. Analysts must also distinguish between OFAC sanctions alerts and 2313a prohibitions, avoiding both over-blocking and missed transactions. 

How FiVerity Can Help 

FiVerity’s real-time collaboration and intelligence platform is designed for scenarios where speed, clarity, and coordinated defense matter most. 

FiVerity supports Section 2313a compliance in several ways: 

• Shared intelligence: Timely updates on FinCEN-designated entities and transactions, beyond static lists.
• Real-time alerting: Prohibited transactions flagged instantly, before funds leave your institution.
• Joint investigation tools: Secure collaboration with peer institutions to verify exposure to designated entities under Section 2313a.
• Customizable risk models: Distinguish between OFAC-driven sanctions and Section 2313a prohibitions within a single workflow. 

This gives your team the ability to not only comply, but also to stay ahead, building resilience against the evolving financial tactics of fentanyl traffickers. 

Final Thoughts 

Section 2313a represents a powerful new regulatory tool in the fight against illicit opioid financing. For compliance teams, it also brings new complexity orders that resemble sanctions but function differently, with steep penalties for missteps. 

Financial institutions that adapt quickly will not only protect themselves from regulatory risk but also contribute to cutting off the financial pipelines fueling the opioid crisis. 

FiVerity helps institutions comply with confidence while strengthening defenses against the latest threats. To learn how your institution can prepare for Section 2313a and future FinCEN actions, schedule a demo with FiVerity today.