--- title: "Nepal (NP) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/nepal-np/ source_html: /jurisdictions/nepal/index.html description: "Financial integrity intelligence for Nepal (NP): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T19:35:25Z content_sha256: 9d92fc521e502f0bbcf05902c574e1bc8dea2f8c63c828280d7b6c185542da1f generator: "fe-fleet/md-twin@1.0" --- # Nepal (NP) — Financial-Integrity Intelligence · Sentinel Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved. Financial Integrity Monitor # Nepal NP Domains covered 8 of 8 Sources 110 Role actions 8 Horizon <90d 1 Jurisdiction profile FATF status: Grey-List Tier: B Risk direction: Stable Enablement vs enforcement: Mixed Nepal's AML/CFT regime rests on the Asset (Money) Laundering Prevention Act (ALPA, amended 2011-2019), the 2013 Proceeds and Instruments of Crime Act, and DMLI as sole ML/TF investigative authority under NRB supervision. More FATF grey-listed since February 2025; EU and UK both list Nepal as a high-risk third country. Major vulnerabilities persist in hundi/MVTS, cooperatives, casinos, real estate, beneficial ownership verification, and virtual-asset enforcement despite a formal VASP prohibition. Key deficiencies - Limited understanding of key ML/TF risks; 2020 NRA not updated despite a January 2025 target - Risk-based supervision of banks, cooperatives, casinos, DPMS and real estate remains underdeveloped; DNFBP supervision has not commenced - Illegal MVTS/hundi providers not being materially sanctioned - Weak capacity/coordination of competent authorities to investigate and prosecute money laundering - Beneficial ownership information not verified at the Company Registrar; fully reliant on self-declaration - Remaining technical compliance deficiencies in targeted financial sanctions regime for TF and PF Recent developments (18m) - FATF added Nepal to the Jurisdictions Under Increased Monitoring list on 21 February 2025 - EU Commission added Nepal to its high-risk third-country list via Delegated Regulation (EU) 2025/1184, effective June 2025 - UK HM Treasury lists Nepal as a High Risk Third Country under MLR Regulation 33, reaffirmed through the June 2026 advisory notice - 1st Follow-Up Report (Dec 2024) re-rated Nepal upward on Recommendations 2, 7, 10, 15, 19, 22 and 23 - September 2025 'Gen Z' protests toppled the Oli government, installing a reformist administration under PM Balendra Shah in March 2026 - Wave of high-profile DMLI/CIAA money-laundering and corruption prosecutions against former PMs, ministers and business figures in 2026 Brief ## Lead signal #### Lead Signal Nepal's financial-integrity position moved on two fronts this cycle, both tracing to the same underlying weakness: an identification gap between who nominally owns an entity or asset and who actually controls it. The Financial Action Task Force's June 2026 Plenary review retained Nepal on its list of jurisdictions under increased monitoring, with the Asia-Pacific Group on Money Laundering delegation concluding that Nepal has made only limited progress converting its action-plan commitments into operational outcomes. The retention is probable rather than confirmed on the strength of the evidence reaching this desk - it rests on press corroboration of the Plenary outcome rather than a directly retrieved FATF statement - but the direction is consistent: technical-compliance steps are understood to be in place, while prosecutions and asset recovery continue to lag. A September 2026 Asia-Pacific Group re-evaluation is the next scheduled checkpoint against which that gap will be tested. Read full brief #### Lead Signal Nepal's financial-integrity position moved on two fronts this cycle, both tracing to the same underlying weakness: an identification gap between who nominally owns an entity or asset and who actually controls it. The Financial Action Task Force's June 2026 Plenary review retained Nepal on its list of jurisdictions under increased monitoring, with the Asia-Pacific Group on Money Laundering delegation concluding that Nepal has made only limited progress converting its action-plan commitments into operational outcomes. The retention is probable rather than confirmed on the strength of the evidence reaching this desk - it rests on press corroboration of the Plenary outcome rather than a directly retrieved FATF statement - but the direction is consistent: technical-compliance steps are understood to be in place, while prosecutions and asset recovery continue to lag. A September 2026 Asia-Pacific Group re-evaluation is the next scheduled checkpoint against which that gap will be tested. Alongside the grey-list signal, a draft Company Act 2026 has surfaced provisions that would, for the first time, impose mandatory beneficial-ownership disclosure on public and large private companies within their annual financial statements. The drafting explicitly targets benami - proxy - shareholding structures that Nepal Rastra Bank investigations have previously documented, and it attaches real consequence to non-disclosure: fines of NPR 500,000 to 5,000,000 and up to three years' imprisonment for false disclosure. This is a structural proposal rather than an enacted rule, and its provision-level citation has not yet been confirmed, but it is the most concrete beneficial-ownership instrument to appear in the Nepal docket since the Financial Intelligence Unit's own 2026 Guidance Relating to Beneficial Ownership was issued under the Assets (Money) Laundering Prevention Act. #### Other Developments A beneficial-ownership guidance instrument is now confirmed in force. Financial Intelligence Unit Nepal has issued a Guidance Relating to Beneficial Ownership, 2026, under the Assets (Money) Laundering Prevention Act. This is the most solidly sourced development of the cycle, resting on a primary government document rather than secondary commentary, and it sits as the closest thing Nepal currently has to an operative beneficial-ownership standard pending the draft Company Act's passage. Crypto-linked suspicious-activity referrals continue to climb despite the blanket prohibition. The Financial Intelligence Unit's most recent disclosed figures show 321 crypto-linked suspicious-transaction cases forwarded to investigative authorities - 232 to Nepal Police, 115 to the Department of Revenue Investigation, and 6 to the Department of Money Laundering Investigation. Nepal Rastra Bank's own internal assessment, as reflected in that reporting, concludes that prohibition alone has not curbed underground crypto activity. The referral volume predates this cycle's window but remains the most recent standing disclosure available, and it reframes the prohibition less as a closed matter and more as a control that is visibly being tested in practice. The securities regulator's supervisory perimeter for investment companies has extended, on thinner sourcing. A Government of Nepal decision effective 2 January 2025 is understood to have made the Securities Board of Nepal the anti-money-laundering regulator for investment companies with paid-up capital of NPR 5 crore or annual transaction volume of NPR 10 crore, under section 7(2) of the Assets (Money) Laundering Prevention Act 2064. This rests on a single law-firm commentary source without a retrieved primary notice, so it is carried as an uncertain but structurally significant extension of supervisory reach into a previously under-supervised segment. #### Cross-Monitor Connections The beneficial-ownership thread connects directly to work tracking state capture and corporate-transparency architecture elsewhere in the fleet: a jurisdiction moving from guidance-only to statute-backed beneficial-ownership disclosure is a different risk profile for shell-company misuse than one relying solely on self-reported filings. The crypto referral volume is relevant to work tracking digital-asset infrastructure and information operations that obscure illicit flows, since a prohibition regime that pushes activity underground rather than eliminating it changes where and how those flows become visible to investigators. Readers following conflict-finance and extractive-industry integrity work should also note that weak asset-recovery effectiveness - the specific gap the Financial Action Task Force has flagged - is a generic enabler for layering proceeds regardless of predicate offence, not a Nepal-specific artefact. #### Outlook The next material checkpoint is the Asia-Pacific Group's re-evaluation, expected in the third quarter of 2026, which will test whether Nepal's technical-compliance steps have begun translating into prosecutions and recovered assets - the specific effectiveness gap the June 2026 review identified. On beneficial ownership, the draft Company Act's progress toward enactment, tentatively oriented toward the first quarter of 2027, is the structural item to watch; if passed as drafted, it would convert guidance-level expectation into statutory obligation with custodial penalties attached. Both tracks should be read together: a jurisdiction that pairs grey-list retention with a newly proposed beneficial-ownership statute is signalling an attempt to close the identification gap that enforcement effectiveness reviews keep surfacing, even where delivery has not yet caught up with intent. Earlier periodic briefs (7) 8 Nov 2026 · fim-2026-11-08 #### Lead Signal Nepal's financial-integrity position moved on two fronts, both tracing to the same underlying weakness: an identification gap between who nominally owns an entity or asset and who actually controls it. The Financial Action Task Force's June 2026 Plenary review retained Nepal on its list of jurisdictions under increased monitoring, with the Asia-Pacific Group on Money Laundering delegation concluding that Nepal has made only limited progress converting its action-plan commitments into operational outcomes. The retention is probable rather than confirmed on the strength of the evidence reaching this desk - it rests on press corroboration of the Plenary outcome rather than a directly retrieved FATF statement - but the direction is consistent: technical-compliance steps are understood to be in place, while prosecutions and asset recovery continue to lag. A September 2026 Asia-Pacific Group re-evaluation is the next scheduled checkpoint against which that gap will be tested. Alongside the grey-list signal, a draft Company Act 2026 has surfaced provisions that would, for the first time, impose mandatory beneficial-ownership disclosure on public and large private companies within their annual financial statements. The drafting explicitly targets benami - proxy - shareholding structures that Nepal Rastra Bank investigations have previously documented, and it attaches real consequence to non-disclosure: fines of NPR 500,000 to 5,000,000 and up to three years' imprisonment for false disclosure. This is a structural proposal rather than an enacted rule, and its provision-level citation has not yet been confirmed, but it is the most concrete beneficial-ownership instrument to appear in the Nepal docket since the Financial Intelligence Unit's own 2026 Guidance Relating to Beneficial Ownership was issued under the Assets (Money) Laundering Prevention Act. #### Other Developments A beneficial-ownership guidance instrument is now confirmed in force. Financial Intelligence Unit Nepal has issued a Guidance Relating to Beneficial Ownership, 2026, under the Assets (Money) Laundering Prevention Act. This is the most solidly sourced development of the cycle, resting on a primary government document rather than secondary commentary, and it sits as the closest thing Nepal currently has to an operative beneficial-ownership standard pending the draft Company Act's passage. Crypto-linked suspicious-activity referrals continue to climb despite the blanket prohibition. The Financial Intelligence Unit's most recent disclosed figures show 321 crypto-linked suspicious-transaction cases forwarded to investigative authorities - 232 to Nepal Police, 115 to the Department of Revenue Investigation, and 6 to the Department of Money Laundering Investigation. Nepal Rastra Bank's own internal assessment, as reflected in that reporting, concludes that prohibition alone has not curbed underground crypto activity. The referral volume predates the window but remains the most recent standing disclosure available, and it reframes the prohibition less as a closed matter and more as a control that is visibly being tested in practice. The securities regulator's supervisory perimeter for investment companies has extended, on thinner sourcing. A Government of Nepal decision effective 2 January 2025 is understood to have made the Securities Board of Nepal the anti-money-laundering regulator for investment companies with paid-up capital of NPR 5 crore or annual transaction volume of NPR 10 crore, under section 7(2) of the Assets (Money) Laundering Prevention Act 2064. This rests on a single law-firm commentary source without a retrieved primary notice, so it is carried as an uncertain but structurally significant extension of supervisory reach into a previously under-supervised segment. #### Cross-Monitor Connections The beneficial-ownership thread connects directly to work tracking state capture and corporate-transparency architecture elsewhere in the fleet: a jurisdiction moving from guidance-only to statute-backed beneficial-ownership disclosure is a different risk profile for shell-company misuse than one relying solely on self-reported filings. The crypto referral volume is relevant to work tracking digital-asset infrastructure and information operations that obscure illicit flows, since a prohibition regime that pushes activity underground rather than eliminating it changes where and how those flows become visible to investigators. Readers following conflict-finance and extractive-industry integrity work should also note that weak asset-recovery effectiveness - the specific gap the Financial Action Task Force has flagged - is a generic enabler for layering proceeds regardless of predicate offence, not a Nepal-specific artefact. #### Outlook The next material checkpoint is the Asia-Pacific Group's re-evaluation, expected in the third quarter of 2026, which will test whether Nepal's technical-compliance steps have begun translating into prosecutions and recovered assets - the specific effectiveness gap the June 2026 review identified. On beneficial ownership, the draft Company Act's progress toward enactment, tentatively oriented toward the first quarter of 2027, is the structural item to watch; if passed as drafted, it would convert guidance-level expectation into statutory obligation with custodial penalties attached. Both tracks should be read together: a jurisdiction that pairs grey-list retention with a newly proposed beneficial-ownership statute is signalling an attempt to close the identification gap that enforcement effectiveness reviews keep surfacing, even where delivery has not yet caught up with intent. 3 Nov 2026 · fim-2026-11-01 #### Lead Signal Nepal was retained on the Financial Action Task Force's increased-monitoring (grey) list at the Plenary that concluded on 30 October 2026. A pre-Plenary progress review found only two of the fifteen prescribed action-plan points fully completed as of September 2026, with three largely completed, six partially addressed and three left unaddressed. The exit deadline has moved to January 2027. Other jurisdictions were removed from the list at the same Plenary, but none were added, and Nepal was not among those released from monitoring. Alongside the standing-architecture signal, Nepal's Department of Money Laundering Investigation published the country's second National Risk Assessment in September 2026, following an earlier assessment in 2020. The new assessment rates national money-laundering threat as High, vulnerability as Medium, and combined risk as Medium-High, with real estate, precious metals, cooperatives and virtual assets flagged among the highest-risk sectors. The virtual-asset flag is notable given that Nepal maintains a blanket prohibition on cryptocurrency activity, which frames enforcement in this space as criminal-law matters rather than licensed-sector supervision. #### Other Developments Crypto-linked enforcement under the existing prohibition. The Kathmandu Valley Crime Investigation Office arrested a 28-year-old resident of Dhanusha for routing funds equivalent to approximately 26.99 million US dollars through a Binance account, in connection with facilitating online betting. The case was brought under provisions addressing unlicensed virtual-currency activity together with gambling-prohibition provisions. Because Nepal treats virtual-currency transactions as a prohibited activity rather than a regulated one, this arrest functions as a enforcement data point against the blanket ban rather than as a licensing or supervisory action, and it sits squarely within the categories the new National Risk Assessment flagged as elevated risk. Action-plan composition remains uneven. The technical detail behind Nepal's grey-list status points to continuing deficiencies in the targeted financial sanctions regime for terrorist financing and proliferation financing, among the compliance gaps still outstanding against the fifteen-point plan. The shift of the completion deadline to January 2027 gives Nepal a defined but short runway to demonstrate measurable enforcement results, including prosecutions and asset freezing or confiscation, rather than further policy or institutional reform alone. #### Cross-Monitor Connections The National Risk Assessment's flagging of cooperatives, real estate and precious metals alongside virtual assets suggests a layering pattern of interest to conflict-finance and state-capture-oriented monitoring elsewhere in the analytical fleet, though no cross-border conflict-finance nexus has been evidenced for Nepal. The crypto-linked betting enforcement action also has a natural read-across to monitoring of informal value-transfer and hundi-style networks, which the action-plan language references directly, though that connection is noted here only as a structural observation rather than an evidenced finding. #### Outlook The January 2027 deadline is the single clearest marker ahead. Nepal's grey-list exit now depends on demonstrating enforcement results, not merely legislative or institutional architecture, over roughly two months as scheduled. Continued arrests under the existing crypto prohibition, of the kind seen in the Dhanusha case, may be presented domestically as enforcement progress, but the action-plan scoring suggests the gap lies more in sanctions-regime technical compliance than in street-level enforcement volume. Whether Nepal is removed from, or remains on, the grey list at the first Plenary after the deadline will be the next material test of this trajectory. 25 Oct 2026 · fim-2026-10-25 #### Lead Signal Nepal enters this cycle with its grey-list status structurally unresolved even as self-reported progress accumulates. At an October 2026 parliamentary committee briefing, a Ministry of Finance Joint Secretary stated that Nepal has fully addressed four of eleven FATF Immediate Outcomes and expects higher ratings in two more, a claim that sits alongside the harder fact that the June 2026 Paris plenary retained Nepal on the grey list after finding meaningful progress on only nine of fifteen action-plan items, with the remaining six only partially implemented. The gap between the ministerial framing and the plenary record is itself the signal: an APG follow-up report, a Tier 1 FATF-linked source, confirms the follow-up process analysing technical compliance deficiencies identified in Nepal mutual evaluation is ongoing, but no independent FATF or APG publication yet corroborates the specific four-of-eleven claim. Confidence on the self-reported progress is accordingly held at the probable tier, not higher, pending plenary confirmation. This AML/CTF regime signal does not sit in isolation. It is compounded by a persistent enabler-jurisdiction problem in the casino and DNFBP sector, where supervisory gaps in beneficial ownership transparency, investigations, and targeted financial sanctions remain acute, and by commercial activity that tests how far domestic payment rails can be drawn into activity the state otherwise prohibits. #### Other Developments Casino-sector AML provisions remain at the proposal stage. Amendments to the pending Tourism Bill would introduce mandatory know-your-customer systems, real-time financial intelligence unit monitoring, suspicious transaction reporting, and a dedicated anti-money-laundering compliance officer at each casino, alongside a beneficial-ownership disclosure threshold for casino licensees stricter than the general company-law standard. None of this is yet enacted; the Bill remains at House committee stage, and the casino sector continues to operate under administrative directive rather than binding statutory AML duty in the interim. An offshore casino platform settled through domestic payment rails. NPL11, a Curacao-licensed online casino and sports-betting platform, launched in July 2026 serving Nepali users with deposit and payout options through eSewa and Khalti, Nepal's two dominant domestic payment service providers. The arrangement sits awkwardly against Nepal's blanket prohibition on online gambling, and raises a question about the AML exposure of the domestic PSPs involved in settling funds for a product the state does not permit domestically licensed operators to offer. A new formal remittance corridor reduces reliance on informal channels. The Nepal Clearing House Limited and the National Payments Corporation of India launched a real-time digital remittance service in June 2026 linking Nepal's National Payments Interface with India's Unified Payments Interface. This formalises what has historically been a large, cash- and hundi-dominated corridor, with structural implications for the visibility of cross-border flows between the two countries. The payment-systems regulatory directive was expanded. Nepal Rastra Bank has heavily amended and expanded its Integrated Directive on Payment Systems, the instrument most directly relevant to the AML/CFT compliance infrastructure payment institutions and banks are required to maintain. Enforcement against crypto activity continues under the comprehensive prohibition. Nepal Police reported 42 cryptocurrency-related arrests in fiscal year 2025/26, including 7 foreign nationals and 35 Nepali citizens. This development pre-dates the current window but is noted for enforcement-posture continuity: Nepal's prohibition on crypto assets remains unchanged and actively policed. Foreign-exchange limits were liberalised. Nepal Rastra Bank revised its foreign exchange regulations under an amendment to the Unified Circular 2082, increasing the limits available for foreign-currency payments and exchange services to businesses and individuals, a development with cross-border payment and trade-finance relevance beyond its immediate commercial-activity framing. #### Cross-Monitor Connections The NPL11 settlement arrangement and the NCHL-NPCI remittance linkage both carry a payments-architecture dimension that intersects directly with WPM reporting, since the AML exposure of a domestic PSP settling funds for a prohibited offshore product is a function of how that PSP's compliance architecture and payment-rail access are structured, not solely a financial-crime typology question. The casino-sector developments also carry a conflict-finance and enabler-jurisdiction angle worth routing to commodity- and state-capture-focused monitors to the extent future Tourism Bill enactment affects the supervisory perimeter for an entire sector FATF and APG have repeatedly flagged. #### Outlook The near-term marker to watch is whether an independent FATF or APG publication confirms the Ministry of Finance's four-of-eleven Immediate Outcome claim; absent that, the self-reported progress should be read as a government relations position rather than a plenary finding. The Tourism Bill's casino AML provisions remain the single most consequential pending instrument for Nepal's enabler-jurisdiction exposure, and their enactment status should be tracked through subsequent committee stages. The NPL11 arrangement raises a payment-rail compliance question that may surface in future cycles as either enforcement action against the PSPs involved or a legal clarification of the prohibition's scope. 18 Oct 2026 · fim-2026-10-18 #### Lead Signal Nepal enters this cycle with its grey-list status structurally unresolved even as self-reported progress accumulates. At an October 2026 parliamentary committee briefing, a Ministry of Finance Joint Secretary stated that Nepal has fully addressed four of eleven FATF Immediate Outcomes and expects higher ratings in two more, a claim that sits alongside the harder fact that the June 2026 Paris plenary retained Nepal on the grey list after finding meaningful progress on only nine of fifteen action-plan items, with the remaining six only partially implemented. The gap between the ministerial framing and the plenary record is itself the signal: an APG follow-up report, a Tier 1 FATF-linked source, confirms the follow-up process analysing technical compliance deficiencies identified in Nepal mutual evaluation is ongoing, but no independent FATF or APG publication yet corroborates the specific four-of-eleven claim. Confidence on the self-reported progress is accordingly held at the probable tier, not higher, pending plenary confirmation. This AML/CTF regime signal does not sit in isolation. It is compounded by a persistent enabler-jurisdiction problem in the casino and DNFBP sector, where supervisory gaps in beneficial ownership transparency, investigations, and targeted financial sanctions remain acute, and by commercial activity this cycle that tests how far domestic payment rails can be drawn into activity the state otherwise prohibits. #### Other Developments Casino-sector AML provisions remain at the proposal stage. Amendments to the pending Tourism Bill would introduce mandatory know-your-customer systems, real-time financial intelligence unit monitoring, suspicious transaction reporting, and a dedicated anti-money-laundering compliance officer at each casino, alongside a beneficial-ownership disclosure threshold for casino licensees stricter than the general company-law standard. None of this is yet enacted; the Bill remains at House committee stage, and the casino sector continues to operate under administrative directive rather than binding statutory AML duty in the interim. An offshore casino platform settled through domestic payment rails. NPL11, a Curacao-licensed online casino and sports-betting platform, launched in July 2026 serving Nepali users with deposit and payout options through eSewa and Khalti, Nepal's two dominant domestic payment service providers. The arrangement sits awkwardly against Nepal's blanket prohibition on online gambling, and raises a question about the AML exposure of the domestic PSPs involved in settling funds for a product the state does not permit domestically licensed operators to offer. A new formal remittance corridor reduces reliance on informal channels. The Nepal Clearing House Limited and the National Payments Corporation of India launched a real-time digital remittance service in June 2026 linking Nepal's National Payments Interface with India's Unified Payments Interface. This formalises what has historically been a large, cash- and hundi-dominated corridor, with structural implications for the visibility of cross-border flows between the two countries. The payment-systems regulatory directive was expanded. Nepal Rastra Bank has heavily amended and expanded its Integrated Directive on Payment Systems, the instrument most directly relevant to the AML/CFT compliance infrastructure payment institutions and banks are required to maintain. Enforcement against crypto activity continues under the comprehensive prohibition. Nepal Police reported 42 cryptocurrency-related arrests in fiscal year 2025/26, including 7 foreign nationals and 35 Nepali citizens. This development pre-dates the current window but is noted for enforcement-posture continuity: Nepal's prohibition on crypto assets remains unchanged and actively policed. Foreign-exchange limits were liberalised. Nepal Rastra Bank revised its foreign exchange regulations under an amendment to the Unified Circular 2082, increasing the limits available for foreign-currency payments and exchange services to businesses and individuals, a development with cross-border payment and trade-finance relevance beyond its immediate commercial-activity framing. #### Cross-Monitor Connections The NPL11 settlement arrangement and the NCHL-NPCI remittance linkage both carry a payments-architecture dimension that intersects directly with WPM reporting, since the AML exposure of a domestic PSP settling funds for a prohibited offshore product is a function of how that PSP's compliance architecture and payment-rail access are structured, not solely a financial-crime typology question. The casino-sector developments also carry a conflict-finance and enabler-jurisdiction angle worth routing to commodity- and state-capture-focused monitors to the extent future Tourism Bill enactment affects the supervisory perimeter for an entire sector FATF and APG have repeatedly flagged. #### Outlook The near-term marker to watch is whether an independent FATF or APG publication confirms the Ministry of Finance's four-of-eleven Immediate Outcome claim; absent that, the self-reported progress should be read as a government relations position rather than a plenary finding. The Tourism Bill's casino AML provisions remain the single most consequential pending instrument for Nepal's enabler-jurisdiction exposure, and their enactment status should be tracked through subsequent committee stages. The NPL11 arrangement raises a payment-rail compliance question that may surface in future cycles as either enforcement action against the PSPs involved or a legal clarification of the prohibition's scope. 28 Sep 2026 · fim-2026-09-28 #### Lead Signal Nepal was kept on the FATF grey list at the June 2026 Paris Plenary, with the APG crediting technical-compliance progress on targeted financial sanctions while assessing overall effectiveness as weak, particularly around investigation, prosecution and asset confiscation in the banking and financial sector. A September 2026 APG follow-up review sits as a decisive checkpoint for Nepal, one that could either move the jurisdiction toward eventual grey-list exit or, if progress is judged insufficient, raise the prospect of escalation. This is not an isolated compliance-technicality story: Nepal's own 2026 National Risk Assessment, prepared by the Department of Money Laundering Investigation, rates the money-laundering threat as High, vulnerability as Medium, and overall risk as Medium-High, while placing terrorist-financing risk at medium-low and proliferation-financing risk at low. Architecturally, the persistence of grey-list status despite technical progress illustrates a familiar pattern in enabler-adjacent jurisdictions: rules can be strengthened on paper faster than institutions can be resourced to apply them. #### Other Developments A draft Company Act 2026 would introduce Nepal's first general statutory beneficial-ownership disclosure requirement, mandating control-chain documentation and BO disclosure for public and large private companies, with penalties reaching NPR 5 million for companies and one to three years' imprisonment for officers who make false declarations. This responds directly to a documented gap: reporting on the draft Act describes extensive use of benamed, or proxy, shareholding as a mechanism enabling money laundering and illicit-asset concealment under the current regime. Separately, and confirmed via a government-hosted primary document, an official Guidance on Beneficial Ownership, 2026 has been published, explicitly tying BO transparency to FATF Recommendation 24 and situating it within Nepal's 2025 ICRG Detailed Action Plan. Read together, these two developments, one a proposed statute and one a published guidance document, indicate that Nepal's beneficial-ownership gap is moving from an acknowledged weakness toward an active area of institutional response, even though no centralised public UBO registry has yet been confirmed operational. Nepal's own National Risk Assessment for 2026 identifies its enabler-sector exposure with unusual specificity. Real estate and precious-metals dealing are rated as the highest-risk laundering channels, but the single largest concentration of laundered value by sector is attributed to cooperatives. This is a structurally significant finding: Nepal's Asset (Money) Laundering Prevention Act already designates real-estate agents, precious-metals dealers, lawyers, notaries, accountants and other professional facilitators as reporting entities, yet the NRA's own assessment implies that formal DNFBP designation has not translated into effective coverage of the cooperative sector specifically, which is treated in the evidence as a persistent enforcement gap rather than a newly emerging one. #### Cross-Monitor Connections The cooperative and DNFBP enabler-sector findings surfaced here connect to enforcement patterns that other Asym Intel monitors track independently: sustained weakness in prosecuting and confiscating assets from cooperative-sector laundering is a structural theme that a state-capture or governance-focused monitor would read as a capacity question rather than a rules question, since Nepal's statutory designation of these sectors as reporting entities is not itself in doubt. Nepal's blanket criminal prohibition on cryptocurrency, enforced via internet-service-provider-level exchange blocking and Cyber Bureau prosecutions, is a standing feature not revisited this period but worth noting as context for any cross-border digital-asset flow analysis touching Nepal. #### Outlook The September 2026 APG follow-up review is the single most consequential near-term event for Nepal's financial-integrity trajectory: its outcome will determine whether the jurisdiction is credited with sufficient progress to begin an exit pathway from the grey list, or whether continued weak effectiveness in investigation, prosecution and asset confiscation triggers warnings of further escalation. In parallel, the draft Company Act 2026 remains a proposed instrument with no confirmed enactment date, presently estimated toward the first quarter of 2027 on a year-wide uncertainty band; its passage would represent Nepal's most significant beneficial-ownership reform to date, but until enacted, the benami-shareholding gap it targets remains open. Illustrative note: any near-term scenario in which grey-list pressure and BO-reform momentum reinforce each other, or conversely diverge, is offered below as analytical orientation only, not as a forecast. 5 Sep 2026 · fim-2026-08-21 #### Lead Signal Nepal remains under FATF increased monitoring following the 19 June 2026 Paris Plenary, with the Asia/Pacific Group on Money Laundering assessing meaningful progress on only nine of the fifteen action-plan items reviewed. FATF's own listing (a Tier-1 primary source) confirms the retention, and Kathmandu Post reporting corroborates the APG's finding that enforcement, investigation and prosecution outcomes remain inadequate. FATF Recommendation 24, governing beneficial ownership and transparency of legal persons, is one of the specific standards against which Nepal's action-plan performance is assessed, and the APG review records an uncovered control-gap signal on this item specifically. A September 2026 checkpoint has been flagged as critical, and continued shortfall on prosecutorial follow-through raises the risk of escalation rather than exit from increased monitoring. The Government of Nepal has moved to address part of this gap through the Money Laundering Prevention (Third Amendment) Ordinance, 2083, which expands the Department of Money Laundering Investigation's jurisdiction to tax offences, smuggling, insider trading and banking and foreign-exchange crimes, and enables joint prosecution of predicate and money-laundering offences in the Special Court — but the APG has separately questioned the legitimacy of introducing this expansion by ordinance rather than through parliamentary process. #### Other Developments Casino beneficial-ownership proposal. The Tourism Bill 2081 casino-sector amendments, still under committee-stage scrutiny, would introduce Nepal's first sector-specific beneficial-ownership disclosure requirement, applying to any stake of ten percent or more in a licensed casino, alongside mandatory know-your-customer procedures, real-time Financial Intelligence Unit monitoring, suspicious transaction reporting and a dedicated anti-money-laundering compliance officer per casino. This is a direct legislative response to persistent APG criticism of weak casino-sector oversight, though it remains at the proposal stage and carries the same ordinance-route execution risk visible elsewhere in Nepal's AML architecture. Enabler-sector gaps and regional contrast. The APG's assessment continues to flag cooperatives, casinos, real estate and hundi or informal value-transfer networks as persistent supervisory gaps for Nepal. A regional contrast is instructive here: Cambodia's central bank governor has publicly warned that Cambodia risks a third FATF grey-list placement absent sustained enforcement against scam-linked online-gambling laundering, a self-reported enforcement-pressure signal that stands in some contrast to Nepal's pattern of legislative output without matching prosecutorial results. Cambodia was not itself listed on the 19 June 2026 FATF register. #### Cross-Monitor Connections The Tourism Bill 2081's beneficial-ownership and casino-compliance-officer proposals sit directly on the boundary with the world-payments and advennt monitors' coverage of Nepal's gambling sector, where the same bill and the same enforcement escalation against online betting are tracked from licensing and payment-corridor perspectives respectively. The nationwide enforcement campaign against unlicensed online betting, which world-payments and advennt track as a distribution-and-payments story, is read here as an AML/CFT enforcement-capacity signal: it demonstrates enforcement reach against unlicensed platforms even as APG separately assesses Nepal's formal prosecutorial follow-through as inadequate — an enablement-versus-enforcement tension worth watching across monitors. #### Outlook The September 2026 FATF/APG checkpoint is the pivotal near-term event: continued shortfall on the six action-plan items not yet showing meaningful progress raises material risk of escalation, while a credible showing of enforcement outcomes could support eventual grey-list exit. The Tourism Bill's beneficial-ownership provisions, if enacted, would close a specific and long-flagged casino-sector gap, but their execution risk is compounded by the same ordinance-route legitimacy question APG has already raised regarding the Third Amendment Ordinance. Watch for whether the Casino Regulatory Unit proposal advances alongside the BO-disclosure threshold, and whether enforcement statistics — not just legislative output — begin to feature in Nepal's next APG progress report. 11 Aug 2026 · fim-2026-08-05 #### Lead Signal Nepal's retention on the FATF grey list at the 19 June 2026 plenary, confirmed against the FATF's own list page, is best read alongside concrete domestic tightening rather than in isolation. The Asia/Pacific Group's own assessment credits Nepal with meaningful progress on 9 of the 15 action-plan items, with 6 still only partially implemented — a picture of genuine but incomplete delivery. Set against that backdrop, Nepal Rastra Bank amended its Integrated Directive on Payment Systems, 2082 this cycle to require national ID verification for wallet creation and updates, retroactive beneficial-ownership and insider screening of existing shareholders, directors and senior management at licensed payment institutions, and to encourage — though not yet mandate — AI/ML integration into fraud-risk management. Read architecture-over-incident, this is a capacity-deficit signal rather than a permissiveness signal: a jurisdiction visibly building out its domestic AML/CFT plumbing in parallel with an incomplete international action-plan record indicates a state genuinely working the problem rather than one declining to engage with it. The FATF Grey List itself moved elsewhere this cycle too, with Kuwait and Papua New Guinea added in February 2026 and Algeria and Namibia removed, underscoring that grey-list status is not a static designation but an actively managed and contested one. #### Other Developments Russia's shadow fleet has nearly tripled to an estimated 1,900 vessels even as enforcement activity against it intensified. A fifth French Navy interception of 2026 and a new EU sanctions package adding 30 additional shadow-fleet vessels, together with provisions specifically targeting crypto and energy-sector financing channels, have not yet arrested the fleet's underlying growth, suggesting that current interdiction capacity is being outpaced by fleet-reclassification economics rather than by any reduction in the underlying evasion architecture. AMLA finalised its Implementing Technical Standard on cooperation within the AML/CFT supervisory system for direct-supervision purposes on 21 July 2026, reaffirming both the 40-firm direct-supervision perimeter and the January 2028 supervision start date, alongside the 10 July 2027 application date for the single AML rulebook. This is a concrete operational step toward EU-level direct supervision, though the great majority of EU obliged entities remain under national supervision until the direct-supervision cohort's 2028 start. Cambodia's central bank governor publicly warned of a third FATF grey-listing risk tied to casino- and scam-centre-linked laundering amid an intensified domestic anti-gambling crackdown, notable as a rare public self-disclosure of relisting risk from within government rather than from external assessors. Laos's Golden Triangle Special Economic Zone, centred on the Kings Romans concession, continues to function as a quasi-extraterritorial laundering, forced-labour and drug-trafficking hub in which Lao state authority is effectively displaced, with UN-linked reporting flagging displacement risk toward Laos as Cambodia's own crackdown intensifies. FinCEN issued a supplemental alert alongside OFAC's designation of two Mexican nationals and nine entities tied to the Cartel de Jalisco Nueva Generacion's fuel-smuggling and customs-mislabeling schemes, confirming fuel theft as one of the cartel's largest non-drug illicit revenue streams and evidencing a durable, primary-sourced trade-based money-laundering corridor along the US-Mexico border. #### Cross-Monitor Connections The Laos Golden Triangle SEZ finding sits squarely at the intersection of financial-integrity and state-capture analysis: a concession zone in which the host state's own authority is displaced by a private operator is as much a governance-architecture question as a laundering-typology one, and connects to conflict-finance and forced-labour reporting channels tracked elsewhere. The CJNG fuel-theft corridor is a conflict-finance-adjacent signal in its own right, functioning as war-economy-style financing infrastructure even absent a formal armed-conflict designation, and links to commodity-flow monitoring of fuel and customs documentation. The Russia shadow-fleet escalation continues to connect financial-integrity sanctions-evasion tracking to broader information-operations and commodity-flow monitoring of the tankers' cargo and flagging practices. #### Outlook Nepal's near-term picture depends heavily on whether the Tourism Bill 2081's proposed AML provisions — a per-casino compliance officer, real-time FIU monitoring, and mandatory STRs — are enacted alongside the NRB payment-directive tightening already in force; enactment would represent a further concrete step against the outstanding FATF action-plan items. On the sanctions-evasion side, the shadow fleet's continued growth despite intensified EU/French interdiction suggests the next material signal to watch is whether the EU's new crypto-and-energy-focused sanctions provisions begin to visibly constrain fleet financing, or whether reclassification economics continue to outpace enforcement. AMLA's 2028 direct-supervision start date remains the structural marker against which incremental EU supervisory-architecture progress should be measured going forward. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion Nepal has been reviewed or deferred at every FATF plenary since its listing on 21 February 2025, retained through the June 2026 plenary as a Jurisdiction Under Increased Monitoring with five of seven action-plan items still outstanding; the only area of confirmed progress is targeted-financial-sanctions technical compliance relating to terrorist and proliferation financing. This anniversary-length persistence is itself an architecture-level signal: it demonstrates that grey-list status, once assigned, tends to function as a durable classification rather than a transitional one, particularly for jurisdictions facing capacity rather than willingness constraints. Continue reading Layered onto the FATF designation is a structurally uneven international response that constitutes the more analytically significant finding this cycle. The European Union classifies Nepal as a high-risk third country through Commission Delegated Regulation (EU) 2025/1184, effective 10 June 2025 and retained through the December 2025 update, a formal delegated-act mechanism requiring an affirmative EU-level legislative step. The United Kingdom achieves the equivalent designation automatically under Money Laundering Regulation 33, a mechanism that incorporates the FATF list without a discrete UK legislative act, most recently reaffirmed in a 19 June 2026 advisory notice continuous since February 2025. The United States, by contrast, has issued only a non-binding FinCEN advisory (26 February 2025, citing 31 CFR 1010.610) that recommends but does not mandate enhanced due diligence for Nepal-linked business, and maintains no standalone codified high-risk-third-country list at all. The result is three distinct compliance obligations attaching to the same underlying jurisdiction risk: mandatory EDD under EU delegated authority, mandatory EDD under UK automatic incorporation, and discretionary EDD under US advisory guidance. The divergence carries direct operational consequences for the correspondent-banking relationships through which Nepal-linked payment flows are typically routed. Both the EU and UK designations attach, in the structured evidence base, to correspondent-bank customer-typology exposure, meaning banks and payment companies maintaining correspondent relationships touching Nepal face mandatory enhanced due diligence in two of three major regulatory blocs and only recommended due diligence in the third. Cross-sector obliged entities more broadly, not only banks, fall within the affected-firm-type scope of both the EU and UK designations, widening the population of institutions required to apply differentiated controls depending on which regulatory perimeter governs a given relationship. For globally active institutions operating across all three jurisdictions, this is not a gap in any single regime but a structural feature of how the sanctions and high-risk-country architecture is currently built, an arbitrage surface in miniature, even absent any confirmed exploitation this cycle. A third strand concerns terrorist-financing and sanctions-evasion vulnerability rather than confirmed evasion activity. Nepal's porous, high-volume land border with India, combined with entrenched hawala/hundi settlement infrastructure, is consistent with FATF's generic hawala typology for currency-control, tax, and sanctions evasion. Nepal's own Mutual Evaluation Report finds no material domestic terrorist-financing risk, and no confirmed incident evidence links this corridor to sanctions circumvention this cycle; the finding is carried at Possible confidence and should be read as a standing structural vulnerability rather than an active scheme, distinguishing it clearly from the higher-confidence grey-list and HRTC-divergence findings above. #### Outlook The FATF's October 2026 plenary is the next material inflection point for Nepal's sanctions-architecture posture: whether TFS technical-compliance progress and nascent hundi-sector enforcement steps are judged sufficient to advance Nepal toward eventual delisting, against a baseline where five of seven action-plan items remain outstanding. Grey-list exit before that review is assessed as unlikely. Separately, the United Kingdom's Money Laundering and Terrorist Financing (Amendment) Regulations 2026, expected to commence in the third quarter of 2026, will revise, without altering the underlying automatic-incorporation logic, how UK regulated firms apply Regulation 33 enhanced due diligence to Nepal-linked relationships. Absent a coordinated EU-UK-US convergence effort, which no source this cycle indicates is under consideration, the tripartite divergence in designation mechanics is likely to persist as a standing feature of Nepal's sanctions-architecture profile through at least the next plenary cycle. #### Beneficial Ownership and Corporate Transparency Since Nepal is not an EU or EEA Member State, the European Union's AML Package is not the primary lens through which Nepal's beneficial-ownership exposure should be read; rather, Nepal's most directly relevant developments this cycle are domestic: a politically-transition-driven wave of prosecutions set against an unreformed corporate-registry verification gap. Following the September 2025 Gen Z protests and the March 2026 installation of a reformist government under Prime Minister Balendra Shah, Nepal's Department of Money Laundering Investigation and Commission for the Investigation of Abuse of Authority have detained or charged a five-time former Finance Minister (court-approved emergency arrest and seven-day remand extension, 20 June 2026, the most senior figure detained to date), a former Energy Minister (detained 29 March 2026), a former Parliament Speaker charged over a gold-smuggling and laundering scheme, and an alleged power broker under investigation for a $25.6 million secondary-market share-purchase scheme. Continue reading Beneath this enforcement intensity, the structural deficiency that makes such schemes possible remains unresolved: the Office of the Company Registrar's beneficial-ownership data is fully reliant on customer self-declaration with no proactive verification mechanism, a deficiency the 2023 Mutual Evaluation Report rated non-compliant or a major shortcoming under Recommendations 24 and 25, with no reported reform through the June 2026 follow-up cycle. The Mahara case illustrates the gap in practice: approximately $527,000 in gold-smuggling proceeds were layered through land purchases and bank accounts of associates and shell travel and tour companies, structures that an unverified registry cannot flag at onboarding. A parallel scheme, the Gorkha Media Network/Galaxy 4K TV savings-cooperative scandal implicating former Home Minister Rabi Lamichhane, shows the same weak-supervision dynamic operating through cooperative rather than corporate vehicles. The credibility of the current enforcement wave is itself qualified by a demonstrated political-cycle vulnerability. The Attorney General's withdrawal of organised-crime and money-laundering charges against Lamichhane shortly before elections, now under Supreme Court show-cause review, with petitioners describing the withdrawal as unconstitutional and politically timed, shows that prosecutorial discretion over money-laundering cases in Nepal remains exposed to political timing. Read together, the 2026 wave should be assessed as genuine political-transition-driven prosecutorial momentum that nonetheless remains structurally reversible, rather than as evidence of durable institutional reform. Globally, the EU AML Package sets the structural direction for beneficial-ownership regulation: the AML Regulation (Reg (EU) 2024/1624, the AMLR) applies directly across Member States, the sixth AML Directive (6AMLD) is transposed nationally, and the AMLA Regulation (Reg (EU) 2024/1620) establishes the Anti-Money Laundering Authority with a direct- and indirect-supervision perimeter that shifts obliged-entity oversight from purely national authorities toward a hybrid EU-level regime. Nepal sits outside this perimeter entirely; its EU nexus runs instead through the pre-AMLA Article 9 AMLD high-risk-third-country delegated-act mechanism, which the European Commission is expected to migrate into the AMLR/AMLA supervisory architecture as AMLA's direct-supervision remit builds out through 2026-2028. This is durable structural backdrop against which Nepal's own beneficial-ownership verification gap should be read, not a substitute for it: the AMLA transition affects how EU-based obliged entities treat Nepal-linked exposure, but it does not itself reform the Company Registrar. #### Outlook No legislative reform of the Company Registrar's verification mechanism has been signalled this cycle, and the overdue completion of Nepal's third National Risk Assessment update, which would be a natural vehicle for such reform, remains pending with no confirmed start date beyond a missed January 2025 target. The Supreme Court's pending show-cause ruling on the Lamichhane charge withdrawal is the most concrete near-term test of whether the current enforcement wave can withstand political-cycle pressure; its outcome will materially inform whether the 2026 prosecutions are read as durable or episodic. Institutions maintaining correspondent or direct exposure to Nepali politically-exposed persons, high-net-worth clients, or corporate structures should treat the current absence of independent beneficial-ownership verification as a standing control gap rather than a condition likely to be resolved in the near term. #### Enabler Jurisdictions and Professional Facilitators Nepal's casino and wider DNFBP sector remains the central enabler-jurisdiction exposure this cycle. A sector-level gap assessment from a Nepali professional body identifies persistent weaknesses in supervision, preventive measures, beneficial ownership transparency, investigations, prosecutions, and targeted financial sanctions, concentrated in exactly the high-risk sectors FATF and APG assessments have repeatedly flagged: cooperatives, designated non-financial businesses and professions, informal remittance systems, and non-profit organisations. This is a structural finding, not an episodic one: the gaps describe an architecture of under-supervision rather than a single enforcement failure. Continue reading The legislative response under consideration is the Tourism Bill, which has attracted 263 amendments, the largest cluster targeting casino regulation specifically. The proposed provisions would require mandatory know-your-customer systems, real-time financial intelligence unit monitoring, suspicious transaction reporting, and a dedicated anti-money-laundering compliance officer at each casino. A companion amendment would set a beneficial-ownership disclosure threshold for casino licensees below the general fifteen percent standard set by the Anti-Money Laundering, Asset Confiscation and Related Matters Act section 35A, which would convert what is currently an administrative directive regime into binding statutory law specific to the sector. The significance of this pending legislation is architectural. Casinos sit in the category of designated non-financial businesses and professions that FATF Recommendation 22 and Recommendation 28 require be brought within customer due diligence and supervisory perimeters comparable to financial institutions, and Nepal's current reliance on administrative direction rather than statute is precisely the kind of technical compliance deficiency that mutual evaluation and follow-up processes are designed to surface. Enacting the Tourism Bill provisions would narrow that deficiency; leaving the Bill at committee stage preserves it. Either outcome is itself a durable fact about the jurisdiction's enabler profile, independent of any single enforcement action. This enabler-jurisdiction exposure also intersects with the commercial reality that offshore gambling platforms are already able to reach Nepali users through domestic payment rails notwithstanding the domestic prohibition on online gambling, which is addressed separately under commercial activity but which underscores that the supervisory gap identified here is not merely theoretical: it has a live commercial manifestation. #### Outlook The Tourism Bill's progress through House committee is the single most consequential near-term marker for this domain. If enacted with the casino AML provisions intact, Nepal would move from an administrative to a statutory basis for DNFBP supervision in its highest-risk gambling sector, directly responsive to the FATF Recommendation 22 and Recommendation 28 gaps identified in the current assessment. Absent enactment, the structural gaps in supervision, beneficial ownership transparency, and targeted financial sanctions enforcement identified this cycle should be expected to persist into subsequent mutual evaluation follow-up cycles. #### Conflict Finance and Extractive-Industry Integrity No Nepal-specific conflict-finance or extractive-industry-integrity findings were identified in this cycle's evidence bundle. This domain is carried forward in accordance with the fixed six-domain analytical set rather than populated with findings not supported by this cycle's research: Nepal's evidence base this cycle concerns FATF grey-list dynamics, beneficial-ownership opacity, enabler-sector channels, virtual-asset policy, and compliance-technology capacity, none of which extend into confirmed armed-conflict financing or extractive-industry-integrity territory for Nepal specifically. The nearest adjacent signal, the hawala/hundi-adjacent terrorist-financing and sanctions/currency-control-evasion vulnerability at the Nepal-India border, carried under D1 and cross-referenced to SCEM for regional conflict-finance monitoring, is a structural vulnerability rather than a confirmed conflict-finance flow, and Nepal's own Mutual Evaluation Report finds no material domestic terrorist-financing risk. No extractive-industry sector (mining, timber, or other resource-trade corridor) findings specific to Nepal appear in this cycle's structured claims at all. Continue reading #### Outlook This domain is flagged as limited signal for the current cycle and should be read as a placeholder for continuity rather than a substantive assessment. Any future extractive-industry or conflict-finance signal specific to Nepal, for example developments touching cross-border resource-trade corridors or documented armed-group financing routed through Nepali intermediaries, would warrant reactivation of this domain with dedicated findings rather than continued placeholder treatment. No such signal is anticipated in the near term based on this cycle's research coverage. #### Crypto / Digital Assets / Financial Innovation Nepal maintains a blanket legal prohibition on virtual currency use, yet enforcement activity this period demonstrates that the prohibition has not eliminated the movement of substantial value through crypto channels. The Kathmandu Valley Crime Investigation Office arrested an individual in Dhanusha accused of transacting an amount equivalent to approximately USD 26.99 million through a Binance account, in connection with an unlicensed online betting operation. The individual faces charges under the National Penal Code provision prohibiting virtual currency transactions as well as a separate gambling-prohibition provision. The scale of the figure involved, over two and a half billion Nepali rupees by one conversion, is the analytically significant element: it indicates that a prohibition regime without extensive technical capacity for blocking or monitoring offshore exchange access can still see large volumes of value move through nominally banned instruments, with enforcement arriving only after the fact and only when a case is flagged through other activity, in this instance an online betting investigation. The case did not originate from targeted crypto-market surveillance; it surfaced as a secondary consequence of investigating illegal betting, which itself points to a gap in dedicated monitoring capacity for virtual-currency flows outside of incidental discovery. This pattern, a strict legal bar paired with limited technical detection capacity, is a structural condition rather than an isolated incident, and it bears directly on how Nepal's broader financial-integrity posture should be read: the formal prohibition provides a basis for prosecution after the fact, but it does not by itself constitute an active-defence capability against misuse of the instrument. Continue reading The case also illustrates a specific enforcement seam: virtual-currency use intersecting with other prohibited conduct, here online betting, rather than virtual-currency use prosecuted purely on its own terms. Where enforcement against crypto-related conduct arrives bundled with enforcement against an unrelated predicate offence, the resulting caseload may understate the true scale of virtual-currency activity happening independently of any other criminal nexus, since purely crypto-denominated activity without an accompanying predicate offence may not surface through the same investigative channels. #### Outlook Whether this arrest represents an isolated case or the first of a cluster will depend on whether authorities treat the scale of the sum involved as justification for broader proactive monitoring of exchange-linked flows, rather than continuing to rely on incidental discovery through unrelated investigations. Any move toward building dedicated monitoring capacity for virtual-currency flows would mark a shift from the current posture, in which the prohibition itself functions as the primary control and detection remains largely reactive. #### Compliance Technology and Active Defence Nepal's compliance-technology posture this cycle is characterised by a persistent, foundational capacity gap rather than by any active-defence or RegTech adoption signal. Multiple AML-relevant Nepali agencies, cooperatives regulators, real estate registries, revenue and tax authorities, customs and import-export bodies, and precious-metals-trade oversight, still lack electronic record-keeping, forcing manual file retrieval for any investigation touching those sectors. This is not a discrete technology gap confined to one agency; it spans the institutional map of bodies whose data the Department of Money Laundering Investigation and Nepal Rastra Bank would need to draw upon to move from case-by-case manual investigation toward automated transaction-monitoring or analytics-driven supervision. Continue reading The practical consequence connects directly to this cycle's other domain findings. The beneficial-ownership verification gap at the Company Registrar, the entrenched but unmapped hundi/MVTS network, and the underground virtual-asset activity operating outside any monitoring framework all describe risks that a digitised, cross-agency data environment would make substantially more detectable. Their persistence as structural rather than resolving issues is, in part, a downstream consequence of this capacity gap: without electronic records at the cooperative, real estate, revenue, and customs level, Nepali authorities cannot deploy the kind of automated red-flag detection that would allow beneficial-ownership opacity or trade-based laundering patterns to surface outside of politically-driven, case-specific investigations such as the current anti-corruption wave. This positions Nepal's compliance-technology profile as a watch-status structural constraint rather than an active or evolving finding this cycle: no new RegTech investment, supervisory-technology procurement, or digitisation initiative was identified in the evidence base, and none of the gaps identified, including the absence of a DNFBP supervisory technology framework, show signs of near-term resolution. #### Outlook Meaningful improvement in Nepal's compliance-technology posture would most plausibly emerge as a byproduct of the overdue third National Risk Assessment update, if that update is paired with a digitisation or supervisory-technology component, though no source this cycle confirms such a component is planned. Absent a dedicated RegTech or SupTech investment programme, Nepal's reliance on slow, manual, case-by-case investigation is assessed as likely to persist through at least the next assessment cycle, continuing to constrain the analytical reach of the Department of Money Laundering Investigation and Nepal Rastra Bank even as case-specific enforcement activity, as seen in the 2026 anti-corruption wave, continues under the current manual model. #### AML/CTF Regime Nepal's grey-list status with the FATF was retained at the Plenary that concluded on 30 October 2026, with the broader reporting on FATF's global list activity indicating no countries were newly added to the grey list at that same Plenary. The retention decision rests on a record in which only two of the fifteen prescribed action-plan items had been fully completed as of September 2026, and the completion deadline for the remaining items has now moved to January 2027. This is the second time in the recent cycle that the deadline has been extended rather than resulting in escalation, which is itself a notable data point: FATF has continued to extend the runway for demonstrated progress rather than moving Nepal toward a call-for-action designation, suggesting the body currently assesses the trajectory as one of partial but insufficient progress rather than stalled or regressive progress. Continue reading Nepal's own institutional response includes the completion of a second comprehensive national risk assessment in 2026, following an earlier assessment in 2020. The existence of two assessments six years apart indicates a degree of institutional continuity in risk-mapping work, though the persistence of only two of fifteen action points being fully completed as of September 2026 suggests that risk assessment and risk mitigation have proceeded on different timelines, with the assessment function outpacing the implementation and enforcement function. This is a familiar pattern across grey-listed jurisdictions generally: the analytical and policy architecture for identifying money-laundering and terrorist-financing risk develops ahead of the operational capacity, legal authority, or institutional will to act on those findings through prosecutions, asset freezing, or confiscation. The gap most frequently cited in assessments of Nepal's position concerns targeted financial sanctions for terrorist financing and proliferation financing, where technical-compliance deficiencies remain outstanding as part of the action plan. This is a structural finding rather than an incident: it concerns the architecture of the sanctions-implementation mechanism itself, not a single enforcement failure, and it is the kind of deficiency that typically requires legislative or regulatory instrument change rather than administrative action alone to resolve. #### Outlook The January 2027 deadline is the operative date against which Nepal's progress will next be measured, and the outcome at that point, full completion, continued partial completion, or escalation, will shape correspondent banking and cross-border payment friction for Nepali institutions independent of whatever the FATF plenary formally decides. Historically, jurisdictions in prolonged grey-list status face de facto costs through correspondent de-risking that persist even where no additional formal measures are applied, and Nepal's extended timeline on sanctions-implementation technical compliance in particular leaves that specific deficiency as the most likely candidate for continued scrutiny beyond January 2027 if other action points are resolved first. #### Commercial Activity Two commercial developments define this cycle for Nepal, and both carry financial-integrity implications that extend beyond their surface framing as payments or product news. The first is the launch of a real-time digital remittance service linking Nepal's National Payments Interface with India's Unified Payments Interface, a partnership between the Nepal Clearing House Limited and the National Payments Corporation of India that went live in June 2026. This formalises what has historically been Nepal's single largest and lowest-earning remittance corridor, a corridor long characterised by heavy reliance on cash and informal hundi-style transfer networks. Bringing this flow onto a formal, traceable rail is a structurally positive development for transaction visibility and, by extension, for the kind of cross-border financial intelligence that underpins AML/CTF assessment, even though no deal value or transaction-volume figures have been publicly disclosed for the launch itself. Continue reading The second development sits in sharper tension with Nepal's regulatory posture. NPL11, a Curacao-licensed online casino and sports-betting platform, launched in July 2026 marketing directly to Nepali users and settling deposits and payouts through eSewa and Khalti, the country's two dominant domestic payment service providers. Nepal maintains a blanket prohibition on online gambling, and the use of licensed domestic payment rails to settle funds for an offshore product outside that licensing perimeter raises a direct question about the AML and counterparty-risk exposure the two payment service providers have taken on, whether knowingly or through insufficient merchant-category screening. No public information confirms whether eSewa or Khalti have taken, or been required to take, any remedial action regarding this integration, and confidence in how this arrangement will be treated going forward is accordingly held at the uncertain tier. These two developments should be read together rather than separately: one formalises a legitimate cross-border flow into a supervised rail, while the other channels a prohibited activity through supervised rails without apparent additional control. Both illustrate the same underlying point about Nepal's payments architecture, namely that the country's domestic payment service providers are becoming a more consequential node in cross-border financial flows generally, which raises the stakes on whatever KYC and merchant-screening controls those providers apply to the counterparties they onboard. #### Outlook The remittance corridor formalisation should be expected to generate further commercial and infrastructure news as transaction volumes migrate from informal to formal channels. The NPL11 arrangement is the more consequential marker for financial integrity specifically, and the question of whether Nepali regulators or the payment service providers themselves take any action regarding the offshore-gambling settlement arrangement is the most direct test of how seriously the domestic payments sector treats its own AML exposure to prohibited-activity counterparties. Regulatory horizon In Force Pending 2026-Q4 · ±quarter ### September 2026 APG mutual-evaluation follow-up review September 2026 review outcome will determine whether Nepal remains grey-listed, is warned of blacklist escalation, or shows sufficient progress toward exit. [Asia/Pacific Group on Money Laundering (APG) / FATF Source](https://www.zigram.tech/article/nepal-fatf-blacklisting-warning-aml/) Proposed 2027-Q1 · ±year ### Draft Company Act 2026 - mandatory beneficial-ownership disclosure Companies would face new mandatory beneficial-ownership disclosure in annual filings, with fines (NPR 500,000-5,000,000) and up to 3 years' imprisonment for false disclosure. [Source](https://english.nepalnews.com/s/explainers/everything-businesses-need-to-know-about-nepals-new-company-act-draft/) Proposed 2027-Q1 · ±year ### Company Act 2026 (draft, beneficial-ownership disclosure) Mandatory beneficial-owner identification at incorporation and annual disclosure for public/large private companies, with criminal penalties for false declarations. [Government of Nepal Source](https://english.nepalnews.com/s/explainers/everything-businesses-need-to-know-about-nepals-new-company-act-draft/) In Force Pending 2027-Q1 · ±quarter ### FATF Action Plan completion deadline Nepal has until January 2027 to demonstrate measurable enforcement results or risk further FATF action. source not collected 4 dated · 1 pending date · baseline financial-integrity-2026-07-05 Role action cards MLRO ### Nepal remains under increased international monitoring while a new corporate beneficial-ownership disclosure duty is proposed. Continued grey-list status signals that suspicious-activity reporting and investigative follow-through remain the specific area assessors are watching; the draft Company Act's disclosure duty would add a new documentary source against which existing beneficial-ownership self-reporting could eventually be checked. 3 evidence refs Compliance ### A new beneficial-ownership disclosure regime and an extended securities-sector AML perimeter are both at the proposal or early-implementation stage. The draft Company Act and the 2026 beneficial-ownership guidance together indicate a tightening documentary standard for corporate ownership, while the Securities Board of Nepal's AML designation for investment companies above stated thresholds extends the population of entities subject to direct AML supervision. 3 evidence refs Legal ### The draft Company Act attaches custodial penalties to false beneficial-ownership disclosure, a new liability exposure once enacted. Up to three years' imprisonment and fines of NPR 500,000 to 5,000,000 for false disclosure represent a materially higher liability bar than current self-reported filings carry; the provision is not yet enacted and its pinpoint citation is unconfirmed. 1 evidence refs Board ### Grey-list retention continues alongside a structural beneficial-ownership reform proposal, both relevant to reputational and market-access exposure. Continued increased-monitoring status can affect correspondent-banking and cross-border relationships; the beneficial-ownership reform, if enacted, would be a structural step toward addressing the effectiveness gap international assessors have identified. 2 evidence refs CTO ### Underground crypto activity continues at scale despite the blanket prohibition remaining in force. 321 crypto-linked suspicious-activity referrals indicate that the prohibition has not eliminated crypto-denominated activity touching Nepal, with implications for how transaction-monitoring and screening systems should treat flows connected to the jurisdiction. 1 evidence refs Risk ### Two structural risk vectors are active: an unresolved effectiveness gap in AML enforcement, and persistent underground crypto activity despite prohibition. Both signals point to a gap between formal control architecture and actual outcomes, a pattern risk functions should weight more heavily than the absence of enforcement headlines might suggest. 3 evidence refs Operations ### A new investment-company AML supervisory threshold and continued elevated crypto-linked referral volumes are both relevant to screening and monitoring calibration. The Securities Board of Nepal's AML designation for investment companies above stated thresholds may create new reporting touchpoints, and the sustained crypto referral volume suggests monitoring thresholds should not assume the prohibition has suppressed actual activity. 2 evidence refs Audit ### Key AML findings this cycle rest on secondary or single-source evidence rather than directly retrieved primary documents. The grey-list retention finding and the Securities Board designation both rest on secondary or single-source commentary rather than a retrieved primary notice, a documentation gap worth noting for audit-trail adequacy on these specific findings. 2 evidence refs Scenario sketches ### Illustrative layering through undisclosed proxy shareholding ahead of Company Act enactment In an illustrative scenario, a corporate group anticipating the draft Company Act's beneficial-ownership disclosure requirement could seek to restructure proxy shareholding arrangements before any enactment date, transferring nominal ownership through intermediate holding entities in less-supervised sectors so that the eventual disclosure obligation captures a simplified ownership picture rather than the underlying control structure. This is an illustration of how a transition period between a proposal and its enactment could be used, not an observed instance. Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact. Standing trackers (T1–T6) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture no_change No material change identified in UN Panel / OFAC / OFSI evasion channels relevant to Nepal this cycle. T2 · EU AML Package / AMLA no_change Not applicable to Nepal (non-EEA); no AMLR/6AMLD/AMLA movement bears on this jurisdiction. T3 · FATF Grey List watch Nepal remains on the FATF grey list following the June 2026 Plenary review; a September 2026 APG re-evaluation is the next scheduled checkpoint per analyst commentary. T4 · Beneficial-Ownership Register Status watch A draft Company Act 2026 would add mandatory beneficial-ownership disclosure for public/large private companies, and a 2026 FIU Guidance on Beneficial Ownership has been issued; no live centralised public BO registry confirmed operational yet. T5 · Crypto / VASP Regulatory Framework no_change Nepal's blanket crypto prohibition under the Foreign Exchange (Regulation) Act and NRB Act remains in force with no signalled relaxation as of this cycle; FIU reporting shows continued underground growth. T6 · Sanctions Regime Divergence no_change No Nepal-specific sanctions-divergence signal identified this cycle. Registers ### Enforcement actions - 1 Apr 2026 - 1 Dec 2025 - 1 Oct 2025 - 29 Mar 2026 - 20 Jun 2026 - 30 Oct 2026 - 30 Oct 2026 - Nepalese police arrested businessman and alleged power broker Deepak Bhatta on money-laundering charges in Kathmandu after DMLI opened an investigation into his 3.81 billion rupee ($25.6m) purchase of secondary-market shares in Nepal Reinsurance Co. and other entities, alleging misappropriated funds were used for personal stock purchases. 1 Apr 2026 - Nepal's anti-graft body filed corruption charges against 55 officials and a Chinese state-linked contractor alleging embezzlement, inflated costs and procurement-law breaches during construction of Pokhara International Airport, a Belt and Road Initiative project. 1 Dec 2025 - CIAA charged the former Speaker and his son, along with senior customs officials, over a scheme that smuggled more than 8.4 kilograms of gold into Nepal concealed in electronic cigarettes, generating roughly $527,000 in proceeds subsequently laundered through land and bank-account layering. 1 Oct 2025 - Former Energy Minister Deepak Khadka was detained as part of a money-laundering probe amid a wider wave of arrests of senior political figures following the March 2026 change of government. 29 Mar 2026 - DMLI investigators obtained a court-approved emergency arrest and seven-day remand extension of a former five-time finance minister over alleged involvement in an illicit asset-laundering case, arresting him at a hotel during an internal party event. 20 Jun 2026 ### Sanctions changes - 10 Jun 2025 - 19 Jun 2026 - 30 Jun 2026 - 1 Apr 2026 - The European Commission added Nepal to the EU list of high-risk third countries with AML/CFT strategic deficiencies via Commission Delegated Regulation (EU) 2025/1184 (10 June 2025), amending Delegated Regulation (EU) 2016/1675, following FATF's grey-listing of Nepal. The listing was retained through the December 2025 update (Delegated Regulations (EU) 2026/46 and 2026/83). 10 Jun 2025 - HM Treasury lists Nepal as a High Risk Third Country (HRTC) under Regulation 33 of the Money Laundering Regulations, automatically incorporating FATF's Jurisdictions Under Increased Monitoring list; Nepal has appeared on every HRTC advisory notice update since February 2025, most recently the 13 February 2026 and 19 June 2026 notices, triggering mandatory enhanced due diligence for the UK regulated sector. 19 Jun 2026 - FinCEN issued a public advisory informing U.S. financial institutions that FATF added Nepal (and Laos) to the Jurisdictions Under Increased Monitoring list on 21 February 2025, instructing firms to factor this into risk-based due diligence under 31 CFR 1010.610, but without imposing a formal OFAC blocking or licensing regime specific to Nepal. 26 Feb 2025 ### Regulatory horizon (register) - APG/FATF Mutual Evaluation on-site review (follow-up) - FATF/APG Nepal September 2026 checkpoint - Draft Company Act 2026 beneficial-ownership disclosure - APG/FATF Mutual Evaluation on-site review (follow-up) - Company Act 2026 (draft, beneficial-ownership disclosure) - September 2026 APG mutual-evaluation follow-up review - FATF Action Plan completion deadline - FATF Action Plan completion deadline (grey-list exit) - Draft Company Act 2026 — mandatory beneficial-ownership disclosure - September 2026 APG/FATF re-evaluation of Nepal's grey-list action plan - FATF plenary review of Nepal's grey-list action plan progress - Overdue completion of Nepal's third National Risk Assessment (NRA) update - UK Money Laundering and Terrorist Financing (Amendment) Regulations 2026 commencement ### Active schemes - [HIGH] Hundi/MVTS informal value transfer network - Cross-border casino laundering along Nepal's borders - [HIGH] Savings-cooperative fraud and diversion scheme - [HIGH] PEP asset-layering via land and nominee bank accounts - Underground virtual-asset use despite blanket VASP prohibition - Hawala-adjacent TF/sanctions-evasion vulnerability at border Sources - [https://www.fatf-gafi.org/en/countries/detail/Nepal.html](https://www.fatf-gafi.org/en/countries/detail/Nepal.html) - [https://kathmandupost.com/money/2026/06/20/nepal-still-on-grey-list-as-fatf-shares-its-review-report](https://kathmandupost.com/money/2026/06/20/nepal-still-on-grey-list-as-fatf-shares-its-review-report) - [https://kathmandupost.com/national/2026/05/20/apg-warns-nepal-over-weak-anti-money-laundering-progress-flags-risk-of-further-downgrade-from-grey-list](https://kathmandupost.com/national/2026/05/20/apg-warns-nepal-over-weak-anti-money-laundering-progress-flags-risk-of-further-downgrade-from-grey-list) - [https://www.lightspark.com/knowledge/is-crypto-legal-in-nepal](https://www.lightspark.com/knowledge/is-crypto-legal-in-nepal) - [https://focusgn.com/asia-pacific/nepal-lawmakers-propose-dedicated-casino-regulator-in-tourism-bill-overhaul](https://focusgn.com/asia-pacific/nepal-lawmakers-propose-dedicated-casino-regulator-in-tourism-bill-overhaul) - [https://www.casinoguardian.co.uk/2026/01/27/cambodia-intensifies-crackdown-on-illegal-online-gambling-amid-fatf-scrutiny/](https://www.casinoguardian.co.uk/2026/01/27/cambodia-intensifies-crackdown-on-illegal-online-gambling-amid-fatf-scrutiny/) - [https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) - [https://english.nepalnews.com/s/long-reads/206401/](https://english.nepalnews.com/s/long-reads/206401/) - [https://english.nepalnews.com/s/explainers/the-vanishing-33-kg-gold-a-scandal-of-gold-smuggling-murder-and-high-level-cover-ups/](https://english.nepalnews.com/s/explainers/the-vanishing-33-kg-gold-a-scandal-of-gold-smuggling-murder-and-high-level-cover-ups/) - [https://english.nepalnews.com/s/explainers/everything-businesses-need-to-know-about-nepals-new-company-act-draft/](https://english.nepalnews.com/s/explainers/everything-businesses-need-to-know-about-nepals-new-company-act-draft/) - [https://www.nrb.org.np/departments/fiu/](https://www.nrb.org.np/departments/fiu/) - [https://kathmandupost.com/national/2025/02/22/it-s-official-nepal-falls-back-into-fatf-grey-list](https://kathmandupost.com/national/2025/02/22/it-s-official-nepal-falls-back-into-fatf-grey-list) - [https://english.nepalnews.com/s/long-reads/facing-the-fatf-abyss-will-nepal-act-on-its-own-money-laundering-confession/](https://english.nepalnews.com/s/long-reads/facing-the-fatf-abyss-will-nepal-act-on-its-own-money-laundering-confession/) - [https://myrepublica.nagariknetwork.com/news/weak-law-enforcement-puts-nepals-anti-money-laundering-at-reasonable-risks--30-99.html](https://myrepublica.nagariknetwork.com/news/weak-law-enforcement-puts-nepals-anti-money-laundering-at-reasonable-risks--30-99.html) - [https://www.castellum.ai/global-sanctions-guide/apac/nepal-sanctions-guide](https://www.castellum.ai/global-sanctions-guide/apac/nepal-sanctions-guide) - [https://www.openownership.org/en/map/country/nepal/](https://www.openownership.org/en/map/country/nepal/) - [https://giwmscdnone.gov.np/media/pdf_upload/Guidance%20on%20Beneficial%20Ownership,%202026%20English_quanikx.pdf](https://giwmscdnone.gov.np/media/pdf_upload/Guidance%20on%20Beneficial%20Ownership,%202026%20English_quanikx.pdf) - [https://attorneynepal.com/blog/Anti-Money-Laundering-Act-Nepal](https://attorneynepal.com/blog/Anti-Money-Laundering-Act-Nepal) - [https://taxconsultantnepal.com/compliance-with-anti-money-laundering-aml-tax-reporting-in-nepal/](https://taxconsultantnepal.com/compliance-with-anti-money-laundering-aml-tax-reporting-in-nepal/) - [https://english.biznessnews.com/posts/nepal-moves-closer-to-exiting-fatf-grey-list-despite-latest-setback-](https://english.biznessnews.com/posts/nepal-moves-closer-to-exiting-fatf-grey-list-despite-latest-setback-) - [https://kathmandupost.com/national/2026/06/20/nepal-still-on-grey-list-as-fatf-shares-its-review-report](https://kathmandupost.com/national/2026/06/20/nepal-still-on-grey-list-as-fatf-shares-its-review-report) - [https://www.fatf-gafi.org/en/countries/global-network/asia-pacific-group-on-money-laundering--apg-.html](https://www.fatf-gafi.org/en/countries/global-network/asia-pacific-group-on-money-laundering--apg-.html) - [https://en.ican.org.np/site/view/nepal-grey-list](https://en.ican.org.np/site/view/nepal-grey-list) - [https://www.ggrasia.com/nepal-lawmakers-seek-dedicated-casino-regulator-in-proposed-tourism-law-overhaul](https://www.ggrasia.com/nepal-lawmakers-seek-dedicated-casino-regulator-in-proposed-tourism-law-overhaul) - [https://www.globenewswire.com/news-release/2026/09/17/3363930/0/en/npl11-launched-as-licensed-online-casino-in-nepal-on-july-19-2026-with-deposits-and-payouts-via-esewa-and-khalti.html](https://www.globenewswire.com/news-release/2026/09/17/3363930/0/en/npl11-launched-as-licensed-online-casino-in-nepal-on-july-19-2026-with-deposits-and-payouts-via-esewa-and-khalti.html) - [https://borgenproject.org/remittance-to-nepal/](https://borgenproject.org/remittance-to-nepal/) - [https://ictframe.com/nrb-payment-systems-directive-rules/](https://ictframe.com/nrb-payment-systems-directive-rules/) - [https://bankingnews.com.np/2026/08/6067/](https://bankingnews.com.np/2026/08/6067/) - [https://english.nepalnews.com/s/business/nepal-rastra-bank-increases-foreign-exchange-and-payment-limits/](https://english.nepalnews.com/s/business/nepal-rastra-bank-increases-foreign-exchange-and-payment-limits/) - [KathmanduPati](https://english.kathmandupati.com/2026/10/nepal-must-accelerate-reforms-to-exit-fatf-grey-list/) - [Nepal News (English)](https://english.nepalnews.com/s/explainers/nepal-remains-stuck-on-fatf-grey-list-what-it-means-and-why-exit-looks-elusive/) - [The Kathmandu Post](https://kathmandupost.com/money/2026/06/20/nepal-still-on-grey-list-as-fatf-shares-its-review-report) - [Law Alpine](https://lawalpine.com/blog/cryptocurrency-and-bitcoin-law-in-nepal) - [AML UAE](https://amluae.com/fatf-grey-list-update-october-2026/) - [Nepal News](https://english.nepalnews.com/s/long-reads/facing-the-fatf-abyss-will-nepal-act-on-its-own-money-laundering-confession/) - [Ratopati](https://english.ratopati.com/story/85005/police-arrest-28-year-old-youth-from-dhanusha-for-crypto-transaction-of-over-rs-2-billion) - [https://english.kathmandupati.com/2026/10/nepal-must-accelerate-reforms-to-exit-fatf-grey-list/](https://english.kathmandupati.com/2026/10/nepal-must-accelerate-reforms-to-exit-fatf-grey-list/) - [https://amluae.com/fatf-grey-list-update-october-2026/](https://amluae.com/fatf-grey-list-update-october-2026/) - [https://english.ratopati.com/story/85005/police-arrest-28-year-old-youth-from-dhanusha-for-crypto-transaction-of-over-rs-2-billion](https://english.ratopati.com/story/85005/police-arrest-28-year-old-youth-from-dhanusha-for-crypto-transaction-of-over-rs-2-billion) - [https://www.nrb.org.np/contents/uploads/2026/01/Information-Booklet_AML-CFT_FIU-Nepal.pdf](https://www.nrb.org.np/contents/uploads/2026/01/Information-Booklet_AML-CFT_FIU-Nepal.pdf) - [https://nitipartners.com/investment-company-registration-nepal/](https://nitipartners.com/investment-company-registration-nepal/) - [https://english.clickmandu.com/2026/01/5529/](https://english.clickmandu.com/2026/01/5529/) - [Jurisdictions under Increased Monitoring - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) - [Jurisdictions under Increased Monitoring - 19 June 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [Nepal](https://www.fatf-gafi.org/en/countries/detail/Nepal.html) - ["Black and grey" lists](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [Mutual Evaluation of Nepal](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofnepal.html) - [Jurisdictions under Increased Monitoring - 21 February 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2025.html) - [Jurisdictions under Increased Monitoring - 13 June 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2025.html) - [Countries / Jurisdictions](https://www.fatf-gafi.org/countries/) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions.html) - [Nepal's Anti-Corruption Crackdown: New Era or False Dawn? | OCCRP](https://www.occrp.org/en/feature/nepals-anti-corruption-crackdown-new-era-or-false-dawn) - [Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov](https://www.fincen.gov/news/news-releases/financial-action-task-force-identifies-jurisdictions-anti-money-laundering-2) - [Nepal's measures to combat money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Nepal-mer-2023.html) - [Nepal's progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Nepal-APG-FUR-2024.html) - [Anti-money laundering and counter-terrorist financing measures Nepal](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/Nepal-APG-MER-2023.pdf.coredownload.inline.pdf) - [Jurisdictions under Increased Monitoring - 21 February 2025](https://www.fatf-gafi.org/content/fatf-gafi/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2025.html) - [Jurisdictions under Increased Monitoring - 24 October 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2025.html) - [After NepaLeaks sparks anti-corruption reform, 'weak' data transparency still a hurdle for reporters - ICIJ](https://www.icij.org/inside-icij/2021/06/after-nepaleaks-sparks-anti-corruption-reform-weak-data-transparency-still-a-hurdle-for-reporters/) - [The Asia/Pacific Group on Money Laundering Financial Action Task Force](https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/Vulnerabilities%20of%20Casinos%20and%20Gaming%20Sector.pdf.coredownload.pdf) - [fatf REPORT THE ROLE OF HAWALA AND OTHER SIMILAR SERVICE PROVIDERS](https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/Role-of-hawala-and-similar-in-ml-tf.pdf.coredownload.pdf) - [Mutual Evaluation of Nepal 1st Follow-Up Report June 2024](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/Nepal-FUR-APG-June-2024.pdf.coredownload.inline.pdf) - [Anti-money laundering and countering the financing of terrorism at international level - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en) - [Jurisdictions under Increased Monitoring - 13 February 2026](https://www.fatf-gafi.org/content/fatf-gafi/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) - [The FATF Recommendations](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html) - [Anti-Money Laundering and Terrorist Financing Directive 4 - Finance](https://finance.ec.europa.eu/regulation-and-supervision/financial-services-legislation/implementing-and-delegated-acts/anti-money-laundering-and-terrorist-financing-directive-4_en) - [Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/commission-updates-list-high-risk-countries-strengthen-international-fight-against-financial-crime-2025-06-10_en) - [European Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/european-commission-updates-list-high-risk-countries-strengthen-international-fight-against-2025-12-04_en) - [EU methodology for the identification of high-risk third countries - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level/eu-methodology-identification-high-risk-third-countries_en) - [High risk third countries and the international context content of anti-money laundering and countering the financing of terrorism - European Commission](https://finance.ec.europa.eu/financial-crime/high-risk-third-countries-and-international-context-content-anti-money-laundering-and-countering_en) - [UAE Off EU Watchlist, Critics Say Reforms Fall Short | OCCRP](https://www.occrp.org/en/news/uae-off-eu-watchlist-critics-say-reforms-fall-short) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/topics/high-risk-and-other-monitored-jurisdictions.html) - [From trading bans to total embrace, a global guide to crypto regulation](https://www.icij.org/investigations/coin-laundry/cryptocurrency-regulations-global-explainer/) - [2025 Crypto Adoption and Stablecoin Usage Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/2025-crypto-adoption-and-stablecoin-usage-report) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [Global crypto regulation review 2025](https://www.elliptic.co/resources/global-crypto-regulation-review-2025) - [Elliptic's 2026 regulatory and policy outlook: 5 crypto trends to expect in 2026](https://www.elliptic.co/blog/regulatory-and-policy-crypto-trends-to-except-in-2026) - [How crypto regulation changed in 2025: a global review](https://www.elliptic.co/blog/how-crypto-regulation-changed-in-2025) - [Five steps to effective cryptocurrency sanctions compliance in 2026](https://www.elliptic.co/blog/five-steps-to-effective-cryptocurrency-sanctions-compliance-in-2026) - [2026 Crypto Crime Report Introduction - Chainalysis](https://www.chainalysis.com/blog/2026-crypto-crime-report-introduction/) - [Elliptic's 2026 regulatory and policy outlook: US sets the pace](https://www.elliptic.co/blog/elliptics-2026-regulatory-and-policy-outlook-us-sets-the-pace) - [The challenges of crypto regulation in Laos](https://www.elliptic.co/blog/the-challenges-of-crypto-regulation-in-laos) - [Money Laundering Advisory Notice: High Risk Third Countries - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2) - [Money Laundering Advisory Notice: June 2026 - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/money-laundering-advisory-notice-high-risk-third-countries--2) - [Changes to the FATF's Public Lists The Money Laundering, ...](https://assets.publishing.service.gov.uk/media/69988878b33a4db7ff889ef3/Annex_C_-_Advisory_Notice_-_February_2026.pdf) - [High-risk third countries](https://www.gamblingcommission.gov.uk/licensees-and-businesses/notice/high-risk-third-countries) - [HM Treasury publish updated list of high risk third jurisdictions](https://www.gamblingcommission.gov.uk/licensees-and-businesses/notice/hm-treasury-publish-updated-list-of-high-risk-third-jurisdictions) - [Nepal Charges Ex-Printing Chief With Money Laundering | OCCRP](https://www.occrp.org/en/news/nepal-charges-ex-printing-chief-with-money-laundering) - [Nepal Arrests Alleged Power Broker Deepak Bhatta in Money Laundering Probe | OCCRP](https://www.occrp.org/en/news/nepal-arrests-alleged-power-broker-deepak-bhatta-in-money-laundering-probe) - [Nepal's Top Court Keeps Ex-PM Oli in Custody Amid Protest Probe | OCCRP](https://www.occrp.org/en/news/nepal-supreme-court-upholds-arrests-of-former-top-ministers) - [Nepal Files Corruption Charges Against 55 Officials, Chinese Contractor Over Pokhara Airport | OCCRP](https://www.occrp.org/en/news/nepal-files-corruption-charges-against-55-officials-chinese-contractor-over-pokhara-airport) - [Nepal Court Seeks Explanation for Dropping Money Laundering Case Against Ex-Home Minister | OCCRP](https://www.occrp.org/en/news/nepal-court-seeks-explanation-for-dropping-money-laundering-case-against-ex-home-minister) - [Nepal Court Orders Detention for Finance Minister Paudel in Money Laundering Probe | OCCRP](https://www.occrp.org/en/news/nepal-court-orders-detention-for-finance-minister-paudel-in-money-laundering-probe) - [Nepal Frees Former Premier Held Over Deadly Crackdown on Youth Protests | OCCRP](https://www.occrp.org/en/news/nepal-frees-former-premier-held-over-deadly-crackdown-on-youth-protests) - [Casinos and Crypto Major Drivers of Money Laundering in East and Southeast Asia | OCCRP](https://www.occrp.org/en/news/casinos-and-crypto-major-drivers-of-money-laundering-in-east-and-southeast-asia) - [Currency Transaction Reports Expose Drug Traffickers Laundering Profits Through Casinos | FinCEN.gov](https://www.fincen.gov/resources/law-enforcement/case-examples/currency-transaction-reports-expose-drug-traffickers) - [National Risk Register - 2025 edition](https://assets.publishing.service.gov.uk/media/67b5f85732b2aab18314bbe4/National_Risk_Register_2025.pdf) - [Frequently Asked Questions | FinCEN.gov](https://www.fincen.gov/boi-faqs) - [Beneficial Ownership Information Reporting | FinCEN.gov](https://www.fincen.gov/boi) - [Haiti](https://www.fatf-gafi.org/en/countries/detail/Haiti.html) - [FATF](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [FATF](https://www.fatf-gafi.org/content/fatf-gafi/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2025.html) - [APG/FATF (Mutual Evaluation of Nepal)](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/Nepal-APG-MER-2023.pdf.coredownload.inline.pdf) - [APG/FATF (1st Follow-Up Report)](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/Nepal-FUR-APG-June-2024.pdf.coredownload.inline.pdf) - [European Commission (DG FISMA)](https://finance.ec.europa.eu/news/commission-updates-list-high-risk-countries-strengthen-international-fight-against-financial-crime-2025-06-10_en) - [HM Treasury](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2) - [FinCEN, U.S. Department of the Treasury](https://www.fincen.gov/news/news-releases/financial-action-task-force-identifies-jurisdictions-anti-money-laundering-2) - [OCCRP](https://www.occrp.org/en/feature/nepals-anti-corruption-crackdown-new-era-or-false-dawn) - [OCCRP](https://www.occrp.org/en/news/nepal-arrests-alleged-power-broker-deepak-bhatta-in-money-laundering-probe) - [ICIJ](https://www.icij.org/inside-icij/2021/06/after-nepaleaks-sparks-anti-corruption-reform-weak-data-transparency-still-a-hurdle-for-reporters/) Coverage gaps fim-int-2026-07-07-G001: No source visibility into whether N… fim-int-2026-07-07-G001: No source visibility into whether Nepal's third NRA update, including VA/VASP risk, has commenced beyond the missed January 2025 target; a DMLI/NRB NRA publication or FATF October 2026 progress statement would resolve this. [resolved] fim-int-2026-07-07-G002: No data confirming volume, geograph… fim-int-2026-07-07-G002: No data confirming volume, geographic corridors, or provider count for illegal hundi/MVTS operators; NRB or DMLI enforcement statistics would raise this Assessed-tier finding toward High confidence. [resolved] fim-int-2026-07-07-G003: No confirmation of whether the Comp… fim-int-2026-07-07-G003: No confirmation of whether the Company Registrar has begun any beneficial-ownership verification pilot ahead of the delayed NRA update; a Company Registrar circular or legislative amendment would resolve this. [resolved] fim-int-2026-07-07-G004: No visibility into a DNFBP supervis… fim-int-2026-07-07-G004: No visibility into a DNFBP supervisory commencement timeline for casinos, real estate, DPMS, or legal/accounting sectors; an NRB/DMLI supervisory manual or APG interim report would clarify this. [resolved] fim-int-2026-07-07-G005: No court-outcome data yet on the Su… fim-int-2026-07-07-G005: No court-outcome data yet on the Supreme Court show-cause proceeding concerning the Lamichhane charge withdrawal; a published Supreme Court order would resolve the F1 state-capture uncertainty. [resolved] fim-int-2026-08-05-G001: Per-Member-State 6AMLD transpositio… fim-int-2026-08-05-G001: Per-Member-State 6AMLD transposition status was not resolved this cycle; unable to identify which EEA states lag the transposition deadline. [resolved] fim-int-2026-08-05-G002: US/UK sanctions-listing delta was n… fim-int-2026-08-05-G002: US/UK sanctions-listing delta was not identified to compare against the EU's autonomous 30-vessel addition, limiting the T6 divergence assessment to a single-sided observation. [resolved] fim-int-2026-08-05-G003: A second, geographically distinct T… fim-int-2026-08-05-G003: A second, geographically distinct TBML corridor (e.g. UAE over/under-invoicing) could not be substantiated this cycle to complement the confirmed CJNG fuel-theft corridor. [resolved] fim-int-2026-08-05-G004: No FinCEN/FCA/JMLSG AI/ML transacti… fim-int-2026-08-05-G004: No FinCEN/FCA/JMLSG AI/ML transaction-monitoring model-risk guidance update was found this cycle to assess against Nepal's own AI/ML encouragement language, leaving the D6 supervisory-expectation-vs-practice gap unresolved. [resolved] fim-int-2026-08-05-G005: No material change was found in UNO… fim-int-2026-08-05-G005: No material change was found in UNODC narco-finance reporting or FATF assessment-trajectory channels for Colombia despite an active search this cycle. [resolved] fim-int-2026-08-21-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-08-21-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): No T1 gazette text of the Money Laundering Prevention Third Amendment Ordinance 2083 retrieved this cycle. [resolved] fim-int-2026-08-21-G002: No usable primary-source signal fou… fim-int-2026-08-21-G002: No usable primary-source signal found this cycle for Tier D jurisdictions LA, MX, CO. [resolved] fim-int-2026-08-21-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-08-21-G003 ({'scheme': 'financial_integrity', 'value': 'D4'}): No Nepal-specific D4 conflict-finance material found this cycle. [resolved] fim-int-2026-09-05-G001: No T1 government-primary source (NR… fim-int-2026-09-05-G001: No T1 government-primary source (NRB/CIB direct statement) retrieved this cycle for the hundi/gold-smuggling financing scale; corroboration rests on T2/T3 sources only. [resolved] fim-int-2026-09-05-G002: EU Delegated Regulation 2025/1184 O… fim-int-2026-09-05-G002: EU Delegated Regulation 2025/1184 Official Journal text was not independently retrieved this cycle; the designation rests on a single T3 secondary source. [resolved] fim-int-2026-09-05-G003: Tier-D watch jurisdictions (KH, LA,… fim-int-2026-09-05-G003: Tier-D watch jurisdictions (KH, LA, MX, CO) were not searched this cycle as retrieval budget was allocated to NP-scoped queries under the union dispatch. [resolved] fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', 'value': 'D4'}): No NP-specific D4 conflict finance substantive finding was located this cycle. [resolved] fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', 'value': 'D6'}): D6 compliance-technology posture was not substantively researched for Nepal this cycle; the enforcement-gap-log obligation remains unmet and should be closed next cycle. [resolved] fim-int-2026-09-28-G003: Tier D watch jurisdictions (KH, LA,… fim-int-2026-09-28-G003: Tier D watch jurisdictions (KH, LA, MX, CO) were not actively searched this pass; the pooled web-search budget was allocated to NP-specific queries across five consumers. [resolved] fim-int-2026-10-18-G001: Tier D jurisdictions (KH, LA, MX, C… fim-int-2026-10-18-G001: Tier D jurisdictions (KH, LA, MX, CO) were not actively searched this cycle; research budget was concentrated on the bound jurisdiction NP per union dispatch. [resolved] fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): No FATF/APG primary publication corroborates the specific 4-of-11 Immediate Outcome claim reported by the Ministry of Finance official; confidence capped at Probable pending FATF confirmation. [resolved] fim-int-2026-10-25-G001: No FATF/APG primary document (fatf-… fim-int-2026-10-25-G001: No FATF/APG primary document (fatf-gafi.org or apgml.org) was retrieved this cycle to corroborate the 2-of-15 action-plan completion figure; source rests on a single T2 news outlet summarising an unnamed progress report. [resolved] fim-int-2026-10-25-G002: Tier D jurisdictions (KH, LA, MX, C… fim-int-2026-10-25-G002: Tier D jurisdictions (KH, LA, MX, CO) were not actively re-swept this cycle given search-budget prioritisation of Nepal's FATF-plenary signal. [resolved] fim-int-2026-10-25-G003: No NRB primary circular establishin… fim-int-2026-10-25-G003: No NRB primary circular establishing the new Anti-Money Laundering Supervision Department was retrieved directly this cycle. [resolved] fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): No T1 (fatf-gafi.org) source was directly retrieved for the FATF Plenary outcome this cycle; reliance on two T2/T3 secondary sources caps confidence at Probable. [open] fim-int-2026-11-01-G002: D2/D3/D4/D6 substantive findings fo… fim-int-2026-11-01-G002: D2/D3/D4/D6 substantive findings for Nepal could not be researched this cycle; this dispatch is JID-bound and the global Tier-D watch (KH/LA/MX/CO) falls outside its scope. [open] fim-int-2026-11-01-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G003 ({'scheme': 'financial_integrity', 'value': 'D7'}): min_t1_per_instrument_met basis for FATF Plenary finding not established; no T1 (gafi.org) source retrieved directly this pass. [open] fim-int-2026-11-08-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-11-08-G001 ({'scheme': 'financial_integrity', 'value': 'D3'}): No D3 enabler-jurisdiction findings for Nepal were located this cycle. [open] fim-int-2026-11-08-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-11-08-G002 ({'scheme': 'financial_integrity', 'value': 'D6'}): No D6 compliance-technology development specific to Nepal was located this cycle. [open] fim-int-2026-11-08-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-11-08-G003 ({'scheme': 'financial_integrity', 'value': 'D7'}): FATF.org's own June 2026 Plenary statement was not directly retrieved this cycle; the grey-list retention finding rests on secondary T2 press corroboration only. [open] FIM-GAP-001 (D2): Nepal's Office of the Company Registrar ha… FIM-GAP-001 (D2): Nepal's Office of the Company Registrar has no proactive mechanism to verify beneficial ownership information; data is fully reliant on customer self-declaration, and Recommendations 24/25 were rated non-compliant/major shortcomings in the 2023 MER. FIM-GAP-002 (D3): Risk-based AML/CFT supervision of DNFBPs (… FIM-GAP-002 (D3): Risk-based AML/CFT supervision of DNFBPs (casinos, real estate agents, dealers in precious metals/stones, lawyers/accountants) has not yet commenced in Nepal, despite these sectors being flagged as high-risk in the 2020 NRA. FIM-GAP-003 (D2): Nepal's Attorney General withdrew organize… FIM-GAP-003 (D2): Nepal's Attorney General withdrew organized-crime and money-laundering charges against former Home Minister Rabi Lamichhane shortly before elections, prompting a Supreme Court 'show cause' order; petitioners called the withdrawal unconstitutional and politically timed. FIM-GAP-004 (D6): Multiple Nepali government agencies handli… FIM-GAP-004 (D6): Multiple Nepali government agencies handling AML-relevant data (cooperatives, real estate, revenue/tax, import-export, precious-metals trade) still lack electronic record-keeping, forcing manual file retrieval and undermining any prospect of automated transaction-monitoring or analytics-driven supervision. FIM-GAP-005 (D5): Nepal's virtual-asset prohibition was neve… FIM-GAP-005 (D5): Nepal's virtual-asset prohibition was never informed by a risk assessment of VA/VASP activity, and no NRA update covering VA/VASP or new-technology risk has been completed since 2020, despite a January 2025 completion target. ## Evidence #### Confidence-tiered claims 4 of 11 Immediate Outcomes fully addressed, 2 more expected higher rating [[Source 1]](#sec-sources) Probable · 1 source retained_on_grey_list [[Source 1]](#sec-sources) Probable · 1 source APG follow-up report analysing progress on MER technical compliance deficiencies [[Source 1]](#sec-sources) Probable · 1 source key gaps in supervision, preventive measures, BO transparency, investigations, prosecutions, targeted financial sanctions [[Source 1]](#sec-sources) Probable · 1 source mandatory KYC, real-time FIU monitoring, STRs, dedicated AML compliance officer per casino [[Source 1]](#sec-sources) Probable · 1 source launched July 19 2026, deposits/payouts via eSewa and Khalti [[Source 1]](#sec-sources) Uncertain · 1 source real-time digital remittance service linking Nepal's National Payments Interface with India's UPI, launched June 2026 [[Source 1]](#sec-sources) Probable · 1 source heavily amended and expanded [[Source 1]](#sec-sources) Probable · 1 source 42 crypto-related arrests in FY2025/26 (7 foreign nationals, 35 Nepali citizens) [[Source 1]](#sec-sources) Probable · 1 source foreign-currency payment/exchange limits for businesses and individuals increased [[Source 1]](#sec-sources) Probable · 1 source Only 2 of 15 prescribed FATF action points fully completed as of September 2026, ahead of the 28-30 October 2026 Paris Plenary. [[Source 1]](#sec-sources) Probable · 1 source Nepal Rastra Bank has established a dedicated Anti-Money Laundering Supervision Department and the government has approved a national risk assessment, as part of reforms ahead of the October 2026 FATF review. [[Source 1]](#sec-sources) Uncertain · 1 source FATF/APG commentary reiterates that oversight of high-risk sectors such as cooperatives, casinos and real estate remains weak. [[Source 1]](#sec-sources) Probable · 1 source As of the June 2026 Paris Plenary, meaningful progress had been made on only nine of the 15 items outlined in Nepal's FATF action plan; by September 2026 only two are fully completed, three largely complete, six partially addressed, three unaddressed. [[Source 1]](#sec-sources) Probable · 1 source NRB's comprehensive cryptocurrency prohibition (Foreign Exchange (Regulation) Act 2019/1962, NRB Act 2058) remains unchanged this cycle; a draft Foreign Exchange (Regulation and Management) Bill, 2026 (public comment opened 13 July 2026) would formalise the ban in primary legislation but had not progressed to parliamentary registration as of this cycle. [[Source 1]](#sec-sources) Probable · 1 source grey_list_retained [[Source 1]](#sec-sources) Probable · 1 source NPR 2,160,120,821 (approx USD 26.99m) [[Source 1]](#sec-sources) Probable · 1 source arrested_for_unlicensed_crypto_and_betting [[Source 1]](#sec-sources) Probable · 1 source ML threat High, vulnerability Medium, combined risk Medium-High [[Source 1]](#sec-sources) Probable · 1 source retained on FATF grey list following June 2026 Plenary review [[Source 1]](#sec-sources) Probable · 1 source mandatory beneficial-ownership disclosure for public and large private companies in annual financial statements, with penalties of NPR 500,000-5,000,000 and up to 3 years' imprisonment for false disclosure [[Source 1]](#sec-sources) Probable · 1 source AML/CFT regulator for investment companies with paid-up capital of NPR 5 crore or annual transaction volume of NPR 10 crore, effective 2 January 2025 [[Source 1]](#sec-sources) Uncertain · 1 source 321 crypto-linked suspicious-transaction cases forwarded to investigative authorities (232 to Nepal Police, 115 to Department of Revenue Investigation, 6 to Department of Money Laundering Investigation) [[Source 1]](#sec-sources) Probable · 1 source Guidance Relating to Beneficial Ownership, 2026, issued under the Assets (Money) Laundering Prevention Act [[Source 1]](#sec-sources) Probable · 1 source