Treasury Eyes Ban on Transactions with Shady Mexican Casinos
Published Date: 11/17/2025
Proposed Rule
Summary
FinCEN is proposing new rules to stop money laundering linked to ten gambling spots in Mexico. U.S. banks won’t be allowed to open or keep accounts that help these places move money, and they’ll need to watch their accounts extra carefully. Comments on this plan are open until December 17, 2025, so everyone has a chance to weigh in!
Analyzed Economic Effects
3 provisions identified: 0 benefits, 3 costs, 0 mixed.
Ban on Correspondent Accounts
Under the proposal, U.S. financial institutions would be prohibited from opening or maintaining any correspondent account for a foreign banking institution if that account is used to process a transaction involving any of ten named Mexico-based gambling establishments. The prohibition is proposed under section 311 (special measure five) and would apply to transactions involving those ten gambling establishments identified in the rule.
Required Special Due Diligence
The proposal would require U.S. financial institutions to apply special due diligence to their correspondent accounts that is reasonably designed to guard against use of those accounts to process transactions involving any of the ten Mexico-based gambling establishments. Banks would need to add and maintain enhanced monitoring and controls on correspondent accounts to detect and block such transactions.
Treating Casinos as Foreign Financial Institutions
FinCEN proposes to define the ten named Mexico-based gambling establishments as 'financial institutions operating outside of the United States' for purposes of section 311. That definitional change would allow FinCEN to apply section 311 special measures (including the correspondent-account prohibition and due diligence requirements) to transactions involving those establishments.
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Key Dates
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