The 2026 World Cup—co-hosted by Mexico, the United States, and Canada—is projected to generate an economic impact for Mexico of approximately $3 billion [1]. This unprecedented event, spanning various stadiums across these three North American nations, will have a significant impact on national economies and, naturally, on transnational trade.
However, the surge in public procurement, international commercial transactions, goods and services, and the betting sector also brings a potential increase in money laundering risks and, in some cases, direct or indirect “terrorist financing.” This stems from transactions that could benefit members of Mexican cartels designated as terrorists by the United States government. The “World Cup fever” will heighten risks associated with money laundering through betting and casinos, as well as extraordinary movements within banking systems and other sectors of commerce, services, and consumption.
These challenges, coupled with the U.S. government’s recent and rigorous policy of investigation and sanctions, could result in severe consequences for both financial and non-financial sectors operating in Mexico. We are facing a completely new reality of scrutiny, accountability, and enforcement—consequences that may leave a lasting impact long after the World Cup trophy is awarded.
2025: A Paradigmatic Year
The year 2025 set a new precedent. In June, FinCEN announced sanctions against CIBanco, Intercam, and Vector[2] . These actions prohibited U.S. financial institutions from maintaining correspondent banking accounts with these Mexican entities due to their association with potential money laundering for criminal organizations. This move marked a milestone in investigative methodology and the triggers for such sanctions.
Two key lessons emerged:
- Extraterritorial Reach: Foreign banks (such as those in Mexico) do not need to have headquarters or be listed on U.S. stock exchanges to be subject to U.S. regulations. Merely maintaining correspondent banking relationships with U.S. banks is sufficient to make them liable for accountability and potential sanctions.
- Speed of Administrative Action: Administrative sanctions imposed by FinCEN—and even their mere announcement—can be faster and more lethal in practical terms than the initiation and prosecution of criminal or civil proceedings in the U.S.
Furthermore, at the close of 2025, the Treasury Department issued a powerful joint action between the Office of Foreign Assets Control (OFAC) and FinCEN. OFAC imposed economic sanctions on 27 entities and individuals operating in Mexico for their ties to the Hysa Organized Crime Group (HOCG). These subjects primarily operated gambling establishments and restaurants which, according to OFAC, were used to launder drug trafficking proceeds with the consent of the Sinaloa Cartel. According to the Treasury, the cartel maintains criminal control over much of the territory where this commercial group operated [3].
The consequences of these OFAC sanctions mean that all property and interests in property of the designated subjects located in the U.S., or in the possession or control of U.S. persons, are blocked and must be reported to OFAC. Additionally, any entity owned 50% or more, directly or indirectly, by one or more blocked persons is also blocked[3]. It is worth noting that individuals included in OFAC sanctions may undergo a “delisting” process before the Treasury Department, though this involves a series of complex actions and procedures.
Derived from the same coordinated action, FinCEN issued a measure restricting U.S. banks from opening or maintaining correspondent accounts for Mexican financial institutions that processed transactions with 10 specific casinos located in northern Mexico. By considering these casinos a potential money laundering risk linked to the Sinaloa Cartel, this “sanction”—even in its proposal phase—forces U.S. banks to require immediate compliance from their Mexican correspondents. In practice, this leaves the target establishments (the casinos) excluded from the U.S. financial system and, potentially, the Mexican one as well.
Crypto: A Priority
On February 5, 2026, A. Tysen Duva (Assistant Attorney General of the Criminal Division), one of the highest-ranking leaders within the U.S. Department of Justice (DOJ), stated in an interview that the Department will focus its efforts on investigating and prosecuting cases where Mexican cartel members use cryptocurrency to launder illicit funds[4].
This is already a reality. The DOJ has been especially emphatic in its policy of prioritizing cases involving potential money laundering schemes through the use of cryptocurrency wallets. The DOJ has secured guilty verdicts in criminal trials against individuals operating these wallets in countries like Colombia. The DOJ argued that these wallets should have been properly registered and licensed as “money transmitters” under the U.S. Bank Secrecy Act, as the scheme utilized U.S. accounts to convert funds into dollars—a case involving the laundering of over $300 million [5].
The Whistleblower Factor
These risks are further amplified considering that the SEC, FinCEN, and the DOJ possess powerful reward mechanisms for informants, known as Whistleblowers. These programs can offer rewards between 10% and 30% of the amount recovered by the U.S. government, provided the recovery exceeds $1 million. Crucially, whistleblowers do not need to be U.S. citizens or be based in the U.S. to access these programs; most agencies provide online platforms for reporting.
What does this mean for companies and financial institutions in Mexico? Regardless of confidentiality agreements or clauses with employees and contractors, any individual can report potential violations of these norms. If successful, they may receive rewards that, in some cases, have reached $279 million, alongside a guarantee of anonymity[6].
Conclusion: Preventing “Own Goals”
The World Cup fever visible across Mexico and the continent will bring a massive influx of people, capital, and contracts. While this is a major opportunity for the economy, it also entails significant risks that must be identified to prevent “own goals” with disastrous results. Within this framework of heightened risk, the following are fundamental:
- Reinforce Risk Identification and Mitigation: Companies and financial institutions must strengthen their frameworks to identify latent risk points that will increase during the World Cup, establishing solid mitigation strategies with special emphasis on links to FTOs (Foreign Terrorist Organizations).
- Prepare for Litigation: The corporate indictments of 2025 demonstrate that the DOJ is willing to litigate. Compliance programs cannot be “paper-only”; they must be effective enough to withstand a potential criminal trial.
- Listen to Whistleblowers: Ensure that internal reporting channels are reliable and responsive. If an employee feels ignored, they may turn to government channels—and they now have significant financial incentives to do so.
[1]Mundial 2026 dejaría hasta 3,000 mdd en México: así busca el país capitalizar el turismo deportivo, available at https://www.eleconomista.com.mx/politica/mundial-2026-dejaria-3-000-mdd-mexico-asi-busca-pais-capitalizar-turismo-deportivo-20251115-786758.html
[2] Treasury Issues Unprecedented Orders under Powerful New Authority to Counter Fentanyl, available at https://www.fincen.gov/news/news-releases/treasury-issues-unprecedented-orders-under-powerful-new-authority-counter
[3] 3Treasury and Government of Mexico Partners Target Transnational Criminal Organization, available at https://home.treasury.gov/news/press-releases/sb0315
[4] Justice Department steps up pressure on cartels’ financial networks as launderers turn to crypto, available at https://apnews.com/article/justice-department-cartels-money-laundering-cryptocurrency-4f64f93f0a4e7135bbba184f2832a041
[5] Florida Man Convicted of Leading $300 Million Money Laundering Operation for Transnational Criminal Organization, available athttps://www.justice.gov/usao-edny/pr/florida-man-convicted-leading-300-million-money-laundering-operation-transnational
[6] SEC Issues Largest-Ever Whistleblower Award https://www.sec.gov/newsroom/press-releases/2023-89#:~:text=The%20Securities%20and%20Exchange%20Commission,ill%2Dgotten%20gains%20and%20interest
