>>189731, >>189732, >>189733, >>189734, >>189735, >>189736, >>189737, >>189738, >>189739, >>189740, >>189741, >>189742, >>189743, >>189744, >>189745
First used June 25, 2025. Three Mexican financial institutions designated on a single day CIBanco, Intercam, and Vector Casa de Bolsa. One of them wasn't even a bank. It was a brokerage.
The weapon had expanded beyond banking entirely.
Three versions of the same weapon in twenty-four years.
2001: we can kill your bank account.
2023: we can kill your ability to send or receive money at all.
2025: we can do it specifically because you're washing fentanyl proceeds through a brokerage in Mexico City.
The money left the banks. The law followed it to crypto. The money moved to fentanyl brokerages. The law followed it there.
And then there was the loophole.
When Huione Group got designated last October $4 billion in laundered funds, pig butchering scams, North Korean cyber heists it did what designated entities have always done.
It changed its name.
Huione Pay became H-Pay Service PLC. Same logo. Same services. Same parent company. New name.
The old designation was written against "Huione Group." Not "H-Pay."
Here's the part that will bother you.
Treasury knew about this trick in 2004.
A Belarusian bank called Infobank was designated under Section 311. It renamed itself Trustbank. The designation didn't automatically disappear but it took a decade to fully resolve, and the rename created legal ambiguity that the designated entity exploited.
Twenty-two years later, in June 2026, FinCEN proposed amending the Huione rule to cover "any successor entity."