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

United States (Federal National) US

Domains covered

8 of 8

Sources

211

Role actions

Horizon <90d

Jurisdiction profile

FATF status: Largely Compliant Tier: A Risk direction: Increasing Enablement vs enforcement: Mixed

US AML/CFT rests on the Bank Secrecy Act as amended by the AML Act of 2020, FinCEN regulations, OFAC sanctions authorities, and (nominally) the Corporate Transparency Act.

Since early 2025 Treasury has rolled back domestic beneficial-ownership reporting, delayed/vacated real-estate AML rules, relaxed CDD account-opening verification, while simultaneously escalating crypto/stablecoin enforcement (Huione, DPRK, ISIS financiers) and issuing GENIUS Act stablecoin AML rules.

Key deficiencies

Domestic beneficial ownership reporting under the Corporate Transparency Act rescinded for US persons/companies, leaving a major BO transparency gap
Residential Real Estate Rule vacated by federal court, removing a planned AML control on non-financed legal-entity property purchases
CDD Rule exceptive relief reduces financial institutions' obligation to re-verify beneficial ownership at each account opening
FATF 5th-round follow-up ratings show partial/non-compliance on 8 of 40 Recommendations, including timely access to beneficial ownership information

Recent developments (18m)

FinCEN interim final rule (March 2025) rescinded BOI reporting for US companies/persons under the CTA, narrowing it to foreign reporting companies only
2026 National Money Laundering, Terrorist Financing, and Proliferation Financing Risk Assessments published by Treasury (March 2026)
GENIUS Act signed into law (July 2025); FinCEN/OFAC joint NPRM (April 2026) to apply BSA AML and sanctions-screening obligations to stablecoin issuers
FinCEN CDD Rule Account Opening Exceptive Relief Order issued (February 13, 2026)
Residential Real Estate Rule vacated by E.D. Texas court (March 19, 2026); FinCEN/DOJ appealing
FinCEN Section 311 finding and final rule severing Huione Group from the US financial system (May-October 2025); FBI cloud-infrastructure seizure against Huione successors (June 2026)
DOJ unsealed Prince Group/Chen Zhi indictment with record 127,271 BTC (~$15bn) forfeiture and coordinated OFAC designations (October 2025)
AML/CFT Program NPRM to modernize BSA compliance-program requirements, comment period closed June 9, 2026

Member jurisdictions

This page covers United States federal law once. Each member’s page covers its own law, regulators and enforcement (51 of 51 members covered here).

Brief

Lead signal

Lead Signal

The United States enforcement and regulatory posture this cycle shows a split pattern: sanctions designation activity against sanctions-evasion architecture continued to escalate even as the federal anti-money-laundering rulemaking agenda for digital assets narrowed. On 28 October 2026, the Office of Foreign Assets Control designated ten individuals and one entity for converting proceeds of a Democratic Peoples Republic of Korea information-technology-worker fraud scheme through Russia-based crypto conversion channels, naming eight Ethereum and Tron addresses as part of the action. This extends an established sanctions architecture, already built around the fraudulent overseas employment of DPRK nationals, into the specific chokepoint of crypto-to-fiat conversion routed through Russian intermediaries. The designation is corroborated by two secondary sources; no Treasury SDN notice was independently retrieved this cycle, so the finding is carried at a probable rather than confirmed level of confidence.

Read full brief

Lead Signal

At nearly the same moment, the Financial Crimes Enforcement Network withdrew two long-pending digital-asset rulemakings, effective 6 October 2026: the 2020 proposal that would have imposed recordkeeping and verification duties on transactions involving unhosted wallets, and the 2023 proposal that would have used the Section 311 special-measures authority against convertible virtual currency mixing. Both proposals had sat unresolved for several years; their formal withdrawal removes them from the pending rulemaking docket and confirms that no such recordkeeping or special-measures duty is currently in force or in train for unhosted-wallet or mixing transactions. Read together, the two developments describe an architecture in which enforcement reach against identified illicit crypto flows is being extended at the transaction level, while the broader rulemaking perimeter that would have captured a wider class of unhosted-wallet and mixing activity by rule is being narrowed.

Other Developments

Divergent sanctions listings between allied regimes. The United Kingdom's Treasury sanctions authority added thirty-eight names to its Russia sanctions list on 8 October 2026, including three crypto exchanges, in a round that targeted a different set of entities than the DPRK-focused designation OFAC issued on 28 October. The two actions illustrate continuing autonomous listing behavior between the US and UK sanctions programmes even where both are nominally aimed at Russia-linked financial conduct; a firm screening against one list cannot assume coverage of the other.

Narrowing of the proposed crypto-AML rulemaking perimeter. The FinCEN withdrawal of the unhosted-wallet and mixing proposals is a confirmed, Tier-1-sourced development. It does not reverse any obligation currently in force, since both proposals remained unadopted since their proposal in 2020 and 2023 respectively; its significance lies in closing off, for the foreseeable term, the specific rulemaking path toward requiring recordkeeping and verification for unhosted-wallet counterparties and reporting obligations tied to mixing-service exposure.

Cross-Monitor Connections

The DPRK IT-worker fraud designation sits at the intersection of sanctions enforcement and the broader question of crypto-infrastructure exposure to state-linked illicit finance: the named Ethereum and Tron addresses function as the technical layer through which proceeds move from fraud to fiat, and firms with crypto-asset exposure or correspondent relationships touching Russian intermediaries carry the nearest-term screening burden from this designation. The FinCEN rulemaking withdrawal is best read as an architecture-level signal for any monitor tracking the pace and direction of US digital-asset regulatory perimeter-setting: a rulemaking path that had been open since 2020 is now closed, which changes the baseline against which future unhosted-wallet or mixing-related proposals, if any, would need to be judged.

Outlook

The near-term picture for sanctions-related crypto exposure is one of continued designation activity against specific illicit-finance chains, run in parallel with a federal rulemaking agenda that is, for now, narrower rather than broader on digital-asset AML obligations. Firms with DPRK, Russia, or crypto-conversion exposure should expect screening-list movement to continue episodically rather than through a broadened standing rule. Confirmation of the OFAC designation through a primary Treasury notice remains outstanding and would firm up the current probable-confidence assessment.

Earlier periodic briefs (3)

25 Oct 2026 · fim-2026-10-25

Lead Signal

The United States enters this period with an active, escalating sanctions-designation cadence running alongside a newly enacted congressionally-mandated designation mechanism. OFAC designated 16 individuals and 10 entities on 15 October 2026 for allegedly enabling Iran sanctions evasion and sustaining Iran's military and proxy forces, pursuant to EO 14404. Separately, the newly enacted Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 imposed an 18 October 2026 statutory deadline for mandatory SDN-list designations under the Act, with recurring 180-day reviews thereafter, meaning OFAC's existing discretionary designation authority now runs in parallel with a congressionally-compelled designation track that did not previously exist.

Other Developments

OFAC's International Criminal Court designation drew open allied objection. OFAC added the entire International Criminal Court to the Specially Designated Nationals and Blocked Persons List under EO 14203 on 9 October 2026, issuing four related general licenses. The UN Secretary-General and multiple G7 allies publicly objected, evidencing a continuing divergence between US and allied sanctions-designation practice that has not narrowed this period.

OFAC entered a settlement with Bank of America. A settlement agreement between OFAC and Bank of America, N.A. was recorded on OFAC's own recent-actions page; the amount and underlying conduct were not disclosed in the source available this period.

A federal digital-asset market-structure statute has failed to materialise. The Digital Asset Market Clarity Act of 2025 failed a Senate cloture vote by a margin of 49-50 on 15 September 2026. In its place, the SEC and CFTC are proceeding with parallel digital-asset rulemakings, leaving no unified statutory jurisdictional split between the two agencies over digital commodities.

FinCEN's effectiveness-based AML program proposal remains under discussion, unfinalized. FinCEN's 7 April 2026 notice of proposed rulemaking would reform Bank Secrecy Act AML/CFT program requirements around a demonstrated-effectiveness standard tied to FinCEN's published AML/CFT Priorities, rather than the existing standard built around the mere existence of required program pillars. No Federal Register finalization notice was located this period; the proposal fully supersedes, and withdraws, FinCEN's prior July 2024 proposed rule on the same subject.

The federal beneficial-ownership reporting exemption stands unchanged. FinCEN's permanent exemption of domestic reporting companies and US-person beneficial owners from Corporate Transparency Act beneficial-ownership-information reporting, effective since 14 August 2026, continues to apply; foreign reporting companies registered in the US remain covered and must still report.

Cross-Monitor Connections

The OCC's parallel finalization of its GENIUS Act payment-stablecoin rule is a structural development tracked more fully on the payments side of this operation, but it bears directly on this monitor's crypto/digital-asset integrity tracking because the stablecoin regime's AML and sanctions-compliance treatment has been explicitly deferred to a separate, as-yet-unissued Treasury rulemaking rather than addressed in the OCC's final rule — a gap this monitor will continue to watch as the broader digital-asset compliance perimeter around sanctions screening and designation exposure remains unsettled. The sanctions-regime divergence evidenced by the ICC designation also connects to broader state-capture and allied-relations monitoring elsewhere in this operation, where the pattern of US/allied disagreement over designation scope is a structural signal independent of any single incident.

Outlook

Watch whether FinCEN's AML/CFT program NPRM is finalized, and in what form, given its material shift from a pillars-existence standard to an effectiveness standard; no finalization timeline was confirmed this period beyond general expectation of further rulemaking activity into 2027. The Graham Act's recurring 180-day statutory review cycle for mandatory SDN designations is now a standing structural feature of the US sanctions architecture and will generate a predictable cadence of further designation activity independent of OFAC's own discretionary enforcement tempo. Continuing allied objection to the ICC designation, and whether it produces any formal diplomatic or multilateral response beyond statements of regret, is also worth monitoring into the next period.

18 Oct 2026 · fim-2026-10-18

Lead Signal

The United States sanctions architecture crossed a structural threshold this cycle. The Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 (Pub. L. 119-111), approved 18 September 2026, has most of its operative provisions taking effect 18 October 2026, converting what had been an executive-order-based Russia sanctions regime into mandatory statute. This is an architecture shift rather than an incident: discretionary presidential authority over Russia-linked designations is replaced by statutory triggers, mandatory screening and reporting obligations under Sections 102 through 104, and a recurring 180-day review cycle. The durability consequence is significant. An executive order can be revised or revoked at the stroke of a pen; a statute requires Congress to act to unwind it. Financial institutions that had built compliance programmes around the flexibility of an executive-order regime now face a fixed statutory floor that will not move with changes in the White House absent new legislation.

The commencement sits alongside a dense run of OFAC designation and delisting activity between 9 and 16 October 2026, spanning Iran, Cuba, Venezuela, and Burma programmes, plus a counter-narcotics and counter-terrorism action against the Cartel del Noreste's horse-racing-linked financial network. Taken together, the statutory commencement and the designation tempo signal an enforcement posture that is intensifying in both legal durability and operational frequency at the same time.

Other Developments

OCC debanking findings raise scrutiny of bank account-access practice. The Office of the Comptroller of the Currency published findings that all nine of the largest OCC-supervised national banks maintained, between 2020 and September 2025, policies or practices capable of politicized or unlawful debanking. The review implements Executive Order 14331, "Guaranteeing Fair Banking for All Americans," and signals that the regulator now treats reputational-risk-based account-access decisions as a governance matter subject to supervisory review, not simply an institution-level risk appetite choice. This is an enabler-jurisdiction-adjacent finding: it speaks to how access to the regulated financial system is granted or withheld inside a well-regulated centre, which is itself an analytically significant question independent of any single enforcement action.

BSA/AML Program Rule reform remains at the consultation stage. FinCEN, together with the FDIC, OCC and NCUA, has proposed replacing the current process-based compliance standard with a two-prong effectiveness-based "establish" and "maintain" standard. The comment period closed 9 June 2026 and no final rule had issued as of this cycle. The proposal would judge institutions on demonstrable risk-based outcomes rather than documentation volume, a meaningful philosophical shift in how AML programme adequacy is measured, but it remains prospective.

Stablecoin AML and sanctions rulemaking continues on parallel non-final tracks. Treasury, the OCC, FinCEN and OFAC are each advancing distinct components of the GENIUS Act implementing framework, with the OCC targeting a final rule by 31 October 2026. FinCEN's earlier proposals on crypto-mixer and unhosted-wallet reporting remain withdrawn, meaning existing SAR and BSA obligations continue to apply unchanged to those activities in the interim.

Cross-Monitor Connections

The GENIUS Act stablecoin rulemaking sits directly at the intersection of this monitor's crypto/digital-asset domain and the World Payments Monitor's licensing and stablecoin tracking: the same OCC rule timeline and the same Treasury Section 3 proposal are relevant to both the integrity exposure of a permitted payment stablecoin issuer and its market-access conditions. The OCC debanking findings likewise connect to broader questions of enabler-jurisdiction practice that the World Payments Monitor tracks from a conduct and safeguarding angle; the same underlying supervisory report informs both lenses without either colonising the other's analytical ground.

Outlook

The Graham Act's 180-day recurring review mechanism means the next scheduled checkpoint on Russia-sanctions scope will fall within roughly six months of the 18 October 2026 commencement date, a structural feature worth tracking independently of any single designation. The OCC's stated target of a final GENIUS Act stablecoin rule by 31 October 2026 is a near-term date to watch, as scheduled, though the FinCEN BSA/AML Program Rule's trajectory toward a final rule remains considerably less certain, with no date yet fixed beyond the closed June 2026 comment period.

12 Oct 2026 · fim-2026-10-12

Lead Signal

The United States financial-integrity posture this cycle is structurally mixed, moving in two opposite directions at once. On the sanctions side, architecture is expanding: the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 (H.R. 5334) was signed into law on September 18, 2026, codifying and expanding mandatory secondary sanctions on Russia's financial, energy and defense sectors, authorizing tariffs of up to 500 percent on certain transactions and up to 100 percent more broadly, and extending the Iran Sanctions Act of 1996 through 2031. Concurrently, FinCEN issued Alert FIN-2026-Alert007 on October 1, 2026 regarding the A7 Network, a Russia-Iran sanctions-evasion and money-laundering service leveraging digital-asset channels, alongside a concurrent OFAC Specially Designated Nationals designation the same day. On the transparency side, the picture has narrowed rather than expanded: a FinCEN final rule, effective August 14, 2026, permanently exempts US persons and domestic reporting entities from Corporate Transparency Act beneficial-ownership reporting, shifting that obligation almost entirely onto foreign reporting companies.

Other Developments

FinCEN withdraws crypto AML rulemakings. FinCEN withdrew its December 2020 proposed rule on self-hosted wallets and its 2023 proposed rule on crypto mixing, with the withdrawal announced October 5 and published in the Federal Register October 6, 2026. The $3,000 Travel Rule threshold for covered transfers, including crypto transfers, remains unchanged notwithstanding this withdrawal. Commercial dealflow continues in digital-asset infrastructure. OKX completed an undisclosed-size funding round at a reported $25 billion valuation (October 6, 2026) with participation from Ripple Labs, Circle Internet Group, Standard Chartered's SC Ventures and QRT; this figure traces to secondary reporting rather than a primary filing. Separately, Anchorage Digital's acquisition activity in the payments space continues a pattern of TradFi-crypto infrastructure convergence relevant to integrity-monitoring purposes.

Cross-Monitor Connections

The A7 Network's use of digital-asset channels for sanctions evasion connects directly to crypto-monitor coverage of on-chain activity and stablecoin regimes, since the same digital-asset rails under scrutiny for evasion typologies are also the subject of ongoing GENIUS Act stablecoin-issuance rulemaking. The Graham Act's expanded secondary-sanctions and tariff authority has implications for world-payments monitoring of correspondent-banking and settlement-access dynamics, particularly for third countries that purchase Russian energy and may face mandatory designation. The CTA beneficial-ownership exemption for US persons is relevant to any monitor tracking corporate-transparency data quality as an input to KYB and beneficial-ownership verification globally.

Outlook

The Graham Act's mandatory secondary-sanctions and tariff provisions carry a statutory presidential-review and designation deadline of October 18, 2026; implementing regulations and specific designations under that deadline remain forthcoming and are the most immediate marker to watch. Separately, Treasury's GENIUS Act Section 3 stablecoin-issuance rulemaking, with its NPRM issued August 18, 2026, remains in process with a further rulemaking phase expected around the first quarter of 2027; this will determine how AML and sanctions compliance program requirements apply to payment stablecoin issuers going forward.

Domain intelligence (D1–D8)

D1 Sanctions

no_changeactive

Sanctions

On 28 October 2026, the Office of Foreign Assets Control designated ten individuals and one entity for converting proceeds of a Democratic Peoples Republic of Korea information-technology-worker fraud scheme through Russia-based crypto conversion channels. Eight Ethereum and Tron addresses were named as part of the action, marking an extension of the established DPRK IT-worker fraud sanctions architecture into the crypto cash-out layer specifically. The pattern being addressed is one in which fraudulently obtained technology-sector wages, or proceeds presented as such, are converted into usable value through intermediaries operating from Russian territory, with blockchain addresses serving as the traceable node in that conversion chain. This finding is corroborated by two secondary sources; no Treasury SDN notice was independently retrieved this cycle, so the designation is carried at a probable rather than confirmed level of confidence, and firms relying on this account should expect confirmation once a primary notice is available.

The same week, the United Kingdom's sanctions authority added thirty-eight names to its own Russia sanctions list, including three crypto exchanges, in a round issued on 8 October 2026 that targeted a different set of entities than the US action. The two rounds illustrate a structural feature of the current sanctions landscape rather than a single incident: allied sanctions regimes continue to designate autonomously, on different timelines and against different target sets, even when both programmes are nominally directed at Russia-linked financial conduct. For institutions that screen against both UK and US lists, the practical implication is that neither list alone describes the full universe of restricted Russia-linked or Russia-routed counterparties relevant to DPRK-related crypto conversion activity; screening built against only one regime would miss the other's additions entirely.

Outlook

Sanctions activity in this area is likely to continue on an escalating trajectory, with DPRK-linked crypto conversion schemes remaining a live target for OFAC designation and allied regimes continuing to add names on their own schedules rather than in coordinated rounds. Firms with exposure to crypto-asset conversion involving Russian intermediaries, or to DPRK-adjacent technology-sector contracting arrangements, face continuing screening-list movement. Confirmation of the 28 October designation through a primary Treasury notice remains the key outstanding step that would firm up the current assessment from probable to confirmed.

Judgment: US sanctions enforcement against Russia-related and cartel-linked financial flows intensified in 2025-2026, with record individual penalties and new correspondent-banking severance measures. Probable

D2 Beneficial Ownership

no_changematerial_changestanding position

Beneficial Ownership and Corporate Transparency

As standing structural context: the EU AML Package is architecturally composed of three distinct instruments — the directly applicable AML Regulation (AMLR, Reg (EU) 2024/1624), the sixth AML Directive (6AMLD, transposed per Member State), and the AMLA Regulation (Reg (EU) 2024/1620) establishing the Anti-Money Laundering Authority — and its direct/indirect-supervision perimeter is shifting EU beneficial-ownership and obliged-entity supervision from purely national authorities toward a hybrid EU-level regime. For the United States, a non-EEA jurisdiction, this EU architecture is contextual backdrop rather than the primary subject matter; the directly relevant development this cycle is domestic. No AMLA horizon anchors were carried in the interpreter output for this cycle, so this paragraph is stated from standing architectural context rather than a fresh finding, and limited_signal_flag is set accordingly for that portion of the picture.

The directly relevant U.S. development is FinCEN's finalized rule, effective August 2026, permanently narrowing Corporate Transparency Act beneficial-ownership reporting to foreign entities only. U.S.-formed companies and U.S. persons are now exempted from the federal reporting requirement that the 2021 Corporate Transparency Act (31 U.S.C. Section 5336) had established, and FinCEN has deleted previously filed U.S.-person beneficial-ownership data from its registry. This is a material contraction of the domestic beneficial-ownership transparency perimeter: the registry that had been built toward comprehensive coverage of U.S.-formed entities is now limited to foreign entities operating in the United States, a structural reduction in federal visibility into domestic shell-company ownership rather than an episodic policy adjustment.

Outlook

The central question going forward is whether this narrowing persists as settled federal policy or draws legislative or judicial challenge, given the scale of visibility loss into U.S.-formed entity ownership structures that it represents. Given the EU's parallel move toward AMLA-centralized supervision, the divergence between a contracting U.S. domestic BO regime and an expanding EU supervisory architecture is a structural contrast worth tracking across future cycles.

Judgment: The US beneficial-ownership regime has narrowed substantially in 2026, shifting the compliance burden onto the separate, as-yet-unrevised CDD Rule. Probable

D3 Enabler Jurisdictions

no_changewatchstanding position

Enabler Jurisdictions

The analytical interest in enabler-jurisdiction findings this cycle lies not in a permissive offshore centre but inside the United States' own best-regulated tier. The Office of the Comptroller of the Currency has published findings that all nine of the largest OCC-supervised national banks maintained, over the period from 2020 to September 2025, policies or practices capable of amounting to politicized or unlawful debanking. The review was conducted to implement Executive Order 14331, "Guaranteeing Fair Banking for All Americans," and its scope -- covering every one of the largest national banks under OCC supervision, not a sample -- is itself notable. This is the architecture-over-incident principle applied in reverse: rather than a single enforcement action against a single institution, the finding describes a systemic pattern across the entire top tier of federally supervised banking.

Framing this as an enabler-jurisdiction question requires attention to what debanking represents functionally: a unilateral decision by a regulated institution to deny or withdraw access to the financial system, exercised on the basis of reputational-risk policies rather than a specific legal prohibition. Where such policies are applied inconsistently, or on a basis later characterized as politicized, the result is a form of de-risking that sits adjacent to, but analytically distinct from, the de-risking literature usually associated with correspondent banking withdrawal from higher-risk foreign jurisdictions. Here the withdrawal of access occurs entirely within the US domestic banking system, which raises a different governance question: not whether a jurisdiction's AML/CFT framework is weak, but whether a well-regulated jurisdiction's largest institutions are exercising discretionary access-denial powers in a manner now subject to direct executive and supervisory scrutiny.

The absence, so far, of any publicly identified enforcement action flowing directly from these OCC findings is itself worth noting explicitly, consistent with the principle that non-enforcement in a well-regulated centre is analytically significant in its own right. A finding that is published but not (yet) accompanied by a remediation order or penalty leaves open whether the OCC intends supervisory guidance, individual bank remediation plans, or a future rulemaking as the follow-through mechanism. Each of those paths carries a materially different signal for how seriously the practice will be curtailed going forward.

Outlook

The key marker to watch is whether the OCC's debanking findings translate into supervisory guidance, individual-bank remediation requirements, or rulemaking, none of which had been announced as of this cycle. Given the review's implementation of a named executive order, continued political attention to the issue should be expected, and institutions within the reviewed population should anticipate that reputational-risk-based account-access policies will remain under active supervisory scrutiny going forward.

Judgment: The structural gap in US AML coverage of non-financial gatekeepers remains unresolved. Probable

D4 Conflict Finance

no_changewatch

No material conflict-finance development specific to the US was surfaced this cycle.

Judgment: No new evidence this cycle on US conflict-finance exposure. Uncertain

D5 Crypto / Digital Assets / Financial Innovation

no_changeactive

Crypto / Digital Assets / Financial Innovation

FinCEN withdrew two long-pending digital-asset rulemakings effective 6 October 2026: the 2020 proposal that would have imposed recordkeeping and verification requirements on transactions involving unhosted wallets, and the 2023 proposal that would have applied Section 311 special-measures authority to convertible virtual currency mixing. Both had remained unadopted since their original proposal dates, and their formal withdrawal confirms that no recordkeeping, verification, or special-measures duty tied to unhosted-wallet counterparties or mixing-service exposure is currently in force or pending under US federal law. This is a confirmed, Tier-1-sourced development directly retrieved from FinCEN's own publication, and it narrows the proposed US digital-asset anti-money-laundering rulemaking perimeter rather than expanding it.

This narrowing sits alongside, rather than in place of, continuing sanctions enforcement against crypto-based illicit finance: the same period saw OFAC designate individuals and an entity for converting DPRK IT-worker fraud proceeds through Russia-based crypto conversion channels, naming specific blockchain addresses. The juxtaposition is structurally significant for digital-asset firms: the rulemaking path toward a broader, rule-based AML perimeter for unhosted wallets and mixing services has been closed for the foreseeable term, while targeted sanctions designation against specific illicit-finance chains identified through those same transaction types continues on an active basis. A firm's exposure to unhosted-wallet counterparties or mixing-adjacent flows is therefore governed, for now, by existing sanctions-screening and general BSA obligations rather than by any new recordkeeping-specific rule.

Outlook

With the unhosted-wallet and mixing rulemakings withdrawn, the near-term US digital-asset AML rulemaking agenda is narrower than it was at the start of the year. Firms should not expect a near-term reissue of either proposal absent a new initiating action from FinCEN. At the same time, sanctions designation activity touching crypto conversion chains, as seen in the 28 October DPRK-related action, indicates that enforcement attention on crypto-based illicit finance has not diminished even as the standing rulemaking perimeter has contracted; firms should expect continued exposure to designation risk through their crypto-counterparty relationships regardless of the rulemaking posture.

Judgment: US enforcement continues to target unregistered or deficient-AML crypto exchanges and P2P platforms at significant penalty scale. Probable

D6 Compliance Technology & Active Defence

no_changewatch

US compliance-technology posture is mixed this cycle: FinCEN's CDD Rule Account Opening Exceptive Relief Order (Feb 2026) pulls back from perpetual-KYC re-verification even as the pending AML/CFT Program NPRM (comment period closed June 2026) proposes RegTech/innovation accommodations within a modernized, risk-based BSA program-requirements framework.

Judgment: No new evidence this cycle on US compliance-technology regulatory posture. Uncertain

D7 AML/CTF Regime

no_changematerial_changestanding position

AML/CTF Regime

The core AML/CTF program-architecture question for US-regulated financial institutions remains open this period. FinCEN's 7 April 2026 notice of proposed rulemaking would fundamentally reform Bank Secrecy Act AML/CFT program requirements, implementing the AML Act of 2020 by shifting the governing standard from one centred on the mere existence of the traditionally required program pillars to one requiring demonstrated program effectiveness, measured against FinCEN's own published AML/CFT Priorities. This is an architecturally significant proposed shift: it would reorient institutional AML compliance from a checklist-compliance posture toward a risk-proportionate, outcomes-tested posture, with institutions required to demonstrate that resources are allocated in proportion to actual risk exposure rather than evenly across pillars regardless of risk concentration.

No Federal Register finalization notice for this proposal was located this period, and the proposal's status remains at the consultation stage. Notably, the April 2026 proposal fully supersedes and formally withdraws FinCEN's earlier, July 2024 proposed rule on the same underlying subject, indicating that FinCEN itself regards the effectiveness-standard approach embodied in the current proposal as a considered revision of its own prior thinking rather than a minor technical amendment. For institutions currently building compliance programs to the existing pillars-based standard, this proposal — while not yet binding — signals a direction of travel that compliance functions building forward-looking program architecture should already be accounting for, even though no legal obligation to meet an effectiveness standard currently exists.

Outlook

Whether and when FinCEN finalizes this NPRM, and whether the final rule's effectiveness standard differs materially from what was proposed in April 2026, is the central open question for this domain going into the next period. No finalization timeline was confirmed this period beyond a general expectation that further rulemaking activity will continue into 2027.

Judgment: The US AML/CTF regime is mid-transition: the CDD/BO perimeter has narrowed, a new risk-assessment pillar is proposed, and a FATF mutual evaluation report is imminent, together signalling a period of regime realignment rather than stability. Probable

D8 Commercial Activity

no_changewatchstanding position

Commercial Activity

Commercial dealflow in the US digital-asset and payments-adjacent sector continued this cycle in a manner relevant to integrity-infrastructure monitoring. OKX completed an undisclosed-size funding round at a reported $25 billion valuation, reported October 6, 2026, with participation from Ripple Labs, Circle Internet Group, Standard Chartered's SC Ventures and QRT. This figure traces to Wikipedia reporting citing Bloomberg and Reuters sourcing rather than a primary regulatory filing, and should be read with that sourcing limitation in mind, though the participant list itself — spanning a crypto-native exchange, a stablecoin issuer, and a traditional banking group's venture arm — illustrates continued convergence between traditional finance and digital-asset infrastructure.

Separately, continued acquisition activity by digital-asset infrastructure firms in the payments space, including Anchorage Digital's reported acquisition activity, reflects a broader pattern of custody and exchange providers embedding payments capability directly into their platforms rather than relying solely on third-party payment rails.

Outlook

This continued TradFi-crypto convergence in commercial dealflow is relevant to integrity monitoring insofar as it expands the surface area of entities operating at the intersection of traditional finance and digital-asset infrastructure, a space that is also the subject of active sanctions-evasion typology work (see the Sanctions and Crypto/Digital Assets domains above). Continued monitoring of primary-source disclosure for these transactions, rather than secondary reporting, would strengthen confidence in the underlying figures.

Judgment: No M&A, investment or product-launch event specific to AML/KYC or sanctions-screening vendors was evidenced this cycle. Uncertain

Regulatory horizon

In Force Pending2026-Q4 · ±quarter

US FATF 5th-round Mutual Evaluation

Will re-rate US technical compliance and effectiveness on all FATF Immediate Outcomes.

Source

In Force Pending2026-Q4 · ±quarter

Graham Act (H.R. 5334) implementation deadline for presidential review/designations

Mandatory secondary sanctions/tariffs on Russia-linked persons and on third countries significantly purchasing Russian energy become operative as OFAC designates qualifying persons.

OFAC / President (Treasury) Source

In Force2026-Q4 · ±quarter

New York LLC Transparency Act — foreign-LLC compliance deadline

Foreign LLCs qualified before 2026 face a hard compliance deadline distinct from the ongoing 30-day rule for newly qualifying entities.

Source

Proposed2027 · ±year

FinCEN proposed BSA risk-assessment pillar NPRM

Proposed rule would codify a mandatory, dynamic risk-assessment process across financial institution types, restructuring the BSA compliance-program pillars.

Source

Proposed2027-Q1 · ±quarter

GENIUS Act full stablecoin issuance/offer/sale rulemaking

Would define 'issue'/'offer'/'sale' for payment stablecoins and establish extraterritorial scope.

Source

Proposed2027-Q1 · ±quarter

GENIUS Act Section 3 implementation (Treasury NPRM on stablecoin issuance/offer/sale)

Defines 'issue', 'issuer', and 'located in the United States' for payment stablecoins and requires AML/sanctions compliance programs for permitted payment stablecoin issuers.

US Department of the Treasury Source

Proposed2027-Q1 · ±quarter

Treasury/OCC GENIUS Act implementing rules (stablecoin AML/sanctions compliance)

Would establish a dedicated federal AML/sanctions-compliance regime for permitted payment stablecoin issuers as BSA-covered financial institutions.

US Treasury, OCC, FinCEN, OFAC Source

Consultation2027-Q1 · ±half_year

FinCEN AML/CFT Program Rule (BSA modernization)

Would refocus AML/CFT program obligations around risk-based effectiveness and credit AI/federated-learning monitoring tools.

Source

Consultation2027-Q2 · ±half_year

FinCEN/Federal Banking Agencies BSA/AML Program Rule (effectiveness-based standard)

Financial institutions would be judged on demonstrable risk-based outcomes rather than documentation volume.

FinCEN, FDIC, OCC, NCUA Source

In Force Pending1 Jan 2028 · ±year

FinCEN AML Program and SAR Rule for Investment Advisers effective date

Covered investment advisers remain without a direct BSA program obligation until 1 January 2028.

Source

10 dated · 4 pending date · baseline fim-2026-07-08

Role action cards

MLRO

OFAC designated DPRK-linked crypto conversion actors on 28 October while FinCEN withdrew two pending crypto-AML rulemakings on 6 October.

Sanctions screening against the newly designated individuals, entity and eight blockchain addresses is the immediate action-relevant item; the withdrawn rulemakings mean no new recordkeeping or special-measures duty for unhosted-wallet or mixing exposure has come into force to supplement this screening obligation.

2 evidence refs

Compliance

The proposed US crypto-AML rulemaking perimeter narrowed with the withdrawal of the unhosted-wallet and mixing proposals.

Policy frameworks built in anticipation of the withdrawn rules can be reassessed, since no recordkeeping or verification duty specific to unhosted wallets or mixing services is now pending; existing sanctions-screening and general BSA obligations remain the operative controls for this exposure.

1 evidence refs

Legal

UK and US sanctions rounds this cycle targeted different entity sets within overlapping Russia-linked crypto conversion activity.

Liability exposure from screening against only one jurisdiction's list is live: the UK's 8 October round of 38 designations and the US's 28 October DPRK-focused round named different entities, so reliance on a single list for client-instruction clearance leaves a gap.

2 evidence refs

Board

Sanctions enforcement against crypto-based illicit finance continued even as the federal crypto-AML rulemaking agenda narrowed.

The institution's financial-crime risk from crypto-counterparty exposure is not reduced by the rulemaking withdrawal; designation risk under existing sanctions authority continues on an active, escalating basis.

2 evidence refs

CTO

FinCEN withdrew its unhosted-wallet recordkeeping and CVC-mixing special-measures proposals, effective 6 October 2026.

No technical build is currently required to meet a federal recordkeeping or verification rule for unhosted-wallet counterparties or mixing-service exposure, since both proposed rules have been withdrawn rather than adopted; address-level sanctions screening capability, as used in the 28 October designation, remains the relevant technical control.

2 evidence refs

Risk

Crypto-conversion chokepoints tied to DPRK IT-worker fraud and Russia-based intermediaries were named in a new OFAC designation.

Exposure concentration in crypto-asset correspondent relationships touching Russian intermediaries or DPRK-adjacent technology contracting warrants attention; this is an escalating-trajectory signal within the sanctions domain running in parallel with a deteriorating-trajectory signal in the crypto-AML rulemaking domain.

2 evidence refs

Operations

Eight Ethereum and Tron addresses were added to OFAC's designation list on 28 October 2026 as part of a DPRK IT-worker fraud action.

Screening systems should incorporate the newly designated addresses and names; no corresponding new transaction-monitoring threshold or workflow change is required for unhosted-wallet or mixing transactions, since the proposals that would have created one were withdrawn rather than finalized.

2 evidence refs

Audit

No material change for this persona this cycle.

No material change for this persona this cycle

Scenario sketches

Illustrative knock-on effect of a narrowed unhosted-wallet rulemaking perimeter

As an illustration only: if no new unhosted-wallet recordkeeping rule is reissued over the medium term, a crypto-asset operator could, in principle, face a widening gap between its sanctions-screening obligations (which remain fully in force and were just reinforced by the 28 October DPRK-related designation) and any rule-based recordkeeping duty specific to unhosted-wallet counterparties (which currently does not exist following the October withdrawal). Such an operator might then rely more heavily on case-by-case sanctions screening of counterparty addresses than on a standing recordkeeping regime to detect unhosted-wallet exposure to designated persons.

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 · OFAC/OFSI/EU Sanctions Divergence	escalating	OFAC's 2025 enforcement total ($265.7M across 14 actions) more than quintupled 2024's figure, with Russia-related sanctions cited in 8 of 14 actions.
T2 · EU AML Package Transposition	no_change	No US-specific development; not applicable to this jurisdiction's own transposition status.
T3 · Crypto/VASP Regulatory Framework	escalating	Record US enforcement against unregistered crypto MSBs (OKX $504M, Paxful $3.5M) continued this cycle.
T4 · Beneficial Ownership / Corporate Transparency Reform	watch	US CTA beneficial-ownership reporting narrowed to foreign entities only, effective 14 Aug 2026; CDD Rule revision announced but not yet proposed.
T5 · FATF Mutual Evaluation Cycle	watch	US fifth-round mutual evaluation adopted by FATF Plenary 30 Oct 2026; report publication due Dec 2026.
T6 · Sanctions Regime Divergence	escalating	First use of FEND OFF Fentanyl Act special-measure authority against cartel-linked financial institutions in FY2025.

Registers

Enforcement actions

18 May 2026
22 Jun 2026
20 May 2026
14 Oct 2025
14 Oct 2025
17 Mar 2026
13 Feb 2026
30 Jun 2026
1 Jul 2026
30 Jun 2026
13 Oct 2026
13 Oct 2026
23 Oct 2026
24 Feb 2025
12 Jun 2025
23 Oct 2024
OFAC settlement for 32 apparent violations of Iran sanctions after AEL purchased Iran-origin LPG disguised as Omani/Iraqi cargo and caused ~$192m in USD payments to be processed through US financial institutions. 18 May 2026
OFAC designated three individuals and six entities, including three crypto companies, for facilitating ISIS financial transactions across Europe, the Middle East and Africa using TRON-based crypto transfers. 22 Jun 2026
OFAC sanctioned more than a dozen individuals and entities responsible for converting bulk US fentanyl-sale cash proceeds into cryptocurrency for cross-border transfer to Mexico. 20 May 2026
FinCEN finalized a Section 311 USA PATRIOT Act rule severing Huione Group -- identified as a primary money laundering concern facilitating over $4bn in suspicious transactions linked to pig-butchering scams and DPRK cyber-heist laundering -- from the US financial system. 14 Oct 2025
DOJ unsealed an indictment charging Prince Group chairman Chen Zhi with orchestrating a global pig-butchering empire built on forced labor and fraud, coordinated with the largest cryptocurrency forfeiture in history and OFAC designations of 146 individuals/entities tied to the network. 14 Oct 2025
OFAC settled with an individual for apparent violations of Syrian Sanctions Regulations. 17 Mar 2026
FinCEN issued the Account Opening Exceptive Relief Order (FIN-2026-R001), relieving covered financial institutions from re-identifying/re-verifying beneficial owners of legal entity customers at each new account opening. 13 Feb 2026

Sanctions changes

4 Dec 2025
16 Sep 2025
1 Jan 2026
18 Jun 2026
24 Oct 2025
16 Jan 2026
1 Jul 2026
30 Jun 2026
30 Jun 2026
1 May 2026
17 Sep 2026
2 Oct 2026
1 Oct 2026
29 Sep 2026
29 Sep 2026
1 Oct 2026
29 Sep 2026
1 Oct 2026
18 Oct 2026
9 Oct 2026
13 Oct 2026
15 Oct 2026
15 Oct 2026
9 Oct 2026
15 Oct 2026
28 Oct 2026
28 Oct 2026
OFAC extended General License 128C authorizing maintenance, operation and wind-down of Lukoil International GmbH retail service stations outside Russia, mitigating retail-consumer effects of the Lukoil Russia-related designation. 4 Dec 2025
OFAC designated Iranian digital-asset exchanges Nobitex, Wallex, Bitpin and Ramzinex plus Nobitex's chairman, co-founders and CEO for facilitating Iran-linked sanctions evasion. 16 Sep 2025
OFAC designated UK-registered Iranian-linked DASP front companies Zedcex Exchange, Ltd. and Zedxion Exchange, Ltd. 1 Jan 2026
OFAC removed several Russia-related designations in mid-2026 sanctions list updates (June 4, June 11, June 18, 2026) while simultaneously issuing amended Russia-related general licenses and FAQs, reflecting a partial, incremental unwind of Russia sanctions coverage. 18 Jun 2026

Regulatory horizon (register)

New York LLC Transparency Act — foreign-LLC compliance deadline
FinCEN AML/CFT Program Rule (BSA modernization)
GENIUS Act full stablecoin issuance/offer/sale rulemaking
US FATF 5th-round Mutual Evaluation
Graham Act (H.R. 5334) implementation deadline for presidential review/designations
GENIUS Act Section 3 implementation (Treasury NPRM on stablecoin issuance/offer/sale)
FinCEN/Federal Banking Agencies BSA/AML Program Rule (effectiveness-based standard)
Treasury/OCC GENIUS Act implementing rules (stablecoin AML/sanctions compliance)
FinCEN BSA AML/CFT Program NPRM (effectiveness-based standard)
FinCEN AML Program and SAR Rule for Investment Advisers
FinCEN AML Program and SAR Rule for Investment Advisers effective date
FATF US mutual evaluation report publication
FinCEN CDD Rule revision
FinCEN proposed BSA risk-assessment pillar NPRM
GENIUS Act stablecoin AML/sanctions rules full implementation
AML/CFT Program NPRM finalization (BSA modernization)
Residential Real Estate Rule appeal outcome
Congressional CTA replacement legislation markup
FATF UK Presidency priorities and next US follow-up review

Active schemes

[CRITICAL] Chinese-language guarantee marketplace stablecoin laundering
[CRITICAL] DPRK crypto theft financing weapons programs
[HIGH] Iranian DASP front companies evading US sanctions
[HIGH] Domestic shell-company BO opacity post-CTA rollback
[HIGH] Cartel fentanyl proceeds cash-to-crypto pipeline

Sources

Coverage gaps

fim-int-2026-07-08-G001: The next FATF Enhanced Follow-Up Re…

fim-int-2026-07-08-G001: The next FATF Enhanced Follow-Up Report or mutual-evaluation output has not yet been published to confirm whether the March 2025 CTA rollback triggers a downgrade of the largely-compliant Recommendation 24 rating. [resolved]

fim-int-2026-07-08-G002: The final text and outcome of the H…

fim-int-2026-07-08-G002: The final text and outcome of the House committee's CTA-replacement legislation markup are not yet available, leaving the ultimate US statutory BO-reporting posture Possible rather than Assessed. [resolved]

fim-int-2026-07-08-G003: Confirmation of whether HM Treasury…

fim-int-2026-07-08-G003: Confirmation of whether HM Treasury/OFSI has independently designated the UK-registered Zedcex/Zedxion entities is absent, leaving the US-UK listing-scope gap unverified beyond the US side. [resolved]

fim-int-2026-07-08-G004: A second, higher-tier (T1/T2) corro…

fim-int-2026-07-08-G004: A second, higher-tier (T1/T2) corroborating source for the claim that the US is currently undergoing an active FATF mutual-evaluation cycle would upgrade that claim beyond its current single-source-category Possible confidence. [resolved]

fim-int-2026-07-11-G001: The FinCEN NPRM full regulatory tex…

fim-int-2026-07-11-G001: The FinCEN NPRM full regulatory text was not directly reviewed this cycle; confidence rests on T3 law-firm secondary reporting only. [resolved]

fim-int-2026-07-11-G002: No fresh Laos-specific material sur…

fim-int-2026-07-11-G002: No fresh Laos-specific material surfaced beyond continued FATF grey-list retention; basis for any risk-direction change is unavailable. [resolved]

fim-int-2026-07-11-G003: No direct FinCEN or FCA RegTech sup…

fim-int-2026-07-11-G003: No direct FinCEN or FCA RegTech supervisory-guidance document was reviewed to substantiate D6 beyond NPRM-commentary inference. [resolved]

fim-int-2026-09-28-G001: Tier D jurisdiction watch (Cambodia…

fim-int-2026-09-28-G001: Tier D jurisdiction watch (Cambodia, Laos, Mexico, Colombia) was not researched this cycle, which was scoped to the single bound jurisdiction US under the union dispatch's per-JID operator lock. [resolved]

fim-int-2026-09-28-G002: UK ECCTA 2023 failure-to-prevent-fr…

fim-int-2026-09-28-G002: UK ECCTA 2023 failure-to-prevent-fraud regulatory horizon item was not researched this cycle due to single-JID US scoping. [resolved]

fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', '…

fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', 'value': 'D3'}): D3 (Enabler Jurisdictions) and D4 (Conflict Finance) had no US-specific findings within this cycle's search scope; coverage is thin. [resolved]

fim-int-2026-09-28-G004 ({'scheme': 'financial_integrity', '…

fim-int-2026-09-28-G004 ({'scheme': 'financial_integrity', 'value': 'D7'}): The FinCEN AML-effectiveness supervisory-posture shift was only confirmed via T3 secondary commentary; primary NPRM text was not independently retrieved this cycle, capping confidence at Probable. [resolved]

fim-int-2026-10-04-G001: No dedicated TBML-corridor search w…

fim-int-2026-10-04-G001: No dedicated TBML-corridor search was run this cycle due to pooled search-budget constraints; only cartel/Cuba-adjacent signals surfaced. [resolved]

fim-int-2026-10-04-G002: No Cambodia, Laos or Colombia-speci…

fim-int-2026-10-04-G002: No Cambodia, Laos or Colombia-specific search was run this cycle; D3 enabler jurisdictions coverage is thin. [resolved]

fim-int-2026-10-12-G001 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-12-G001 ({'scheme': 'financial_integrity', 'value': 'D3'}): No US-specific D3 enabler-jurisdiction finding was located this cycle; a T1/T2 source on US professional-facilitator dynamics would close this gap. [resolved]

fim-int-2026-10-12-G002 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-12-G002 ({'scheme': 'financial_integrity', 'value': 'D4'}): No US-specific D4 conflict-finance finding was located this cycle. [resolved]

fim-int-2026-10-12-G003: No US-specific FATF Grey List movem…

fim-int-2026-10-12-G003: No US-specific FATF Grey List movement was located this cycle; search depth on this tracker was limited. [resolved]

fim-int-2026-10-12-G004: Tier D jurisdictions (Cambodia, Lao…

fim-int-2026-10-12-G004: Tier D jurisdictions (Cambodia, Laos, Mexico, Colombia) were not actively searched this cycle due to pooled search-budget constraints. [resolved]

fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): No material change found in UN Panel of Experts (Yemen) / OFAC / OFSI Houthi-linked channels specifically within this window; standing designations only. [resolved]

fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', 'value': 'D2'}): Thin coverage this cycle on D2 (beneficial ownership) and D4 (conflict finance) beyond standing designations. [resolved]

fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', 'value': 'D3'}): No US-specific D3 (enabler jurisdiction) finding surfaced this cycle despite active search. [resolved]

fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', 'value': 'D4'}): No US-specific D4 (conflict finance) finding surfaced this cycle despite active search. [resolved]

fim-int-2026-10-25-G003 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-25-G003 ({'scheme': 'financial_integrity', 'value': 'D7'}): No Federal Register finalization notice was located this cycle for the FinCEN BSA AML/CFT Program NPRM; status remains at consultation stage. [resolved]

fim-int-2026-11-01-G010 ({'scheme': 'financial_integrity', '…

fim-int-2026-11-01-G010 ({'scheme': 'financial_integrity', 'value': 'D2'}): D2 Beneficial Ownership, D3 Enabler Jurisdictions, D4 Conflict Finance and D6 Compliance Technology showed thin coverage this cycle per DR's domains_with_thin_coverage flag. [open]

fim-int-2026-11-01-G011 ({'scheme': 'financial_integrity', '…

fim-int-2026-11-01-G011 ({'scheme': 'financial_integrity', 'value': 'D1'}): No T1 ofac.treasury.gov SDN notice independently retrieved this cycle for the OFAC DPRK/Russia designation; corroborated only by two T2/T3 sources, capping confidence at Probable. [open]

fim-int-2026-11-01-G012: Tier D jurisdictions (KH/LA/MX/CO) …

fim-int-2026-11-01-G012: Tier D jurisdictions (KH/LA/MX/CO) not actively searched this cycle given the run's binding to JID=US. [open]

fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', '…

fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): No T1 ofac.treasury.gov SDN notice independently retrieved for the Oct 28, 2026 DPRK IT-worker designation; reliance is on two T2/T3 secondary sources. [open]

fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', '…

fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', 'value': 'D2'}): D2 (Beneficial Ownership), D3 (Enabler Jurisdictions), D4 (Conflict Finance) and D6 (Compliance Technology) had thin or no coverage this cycle. [open]

fim-int-2026-11-01-G003: Tier D jurisdictions (KH, LA, MX, C…

fim-int-2026-11-01-G003: Tier D jurisdictions (KH, LA, MX, CO) were not actively searched this cycle because the run was bound to JID=US only. [open]

fim-int-2026-11-04-G001: The FATF fifth-round mutual evaluat…

fim-int-2026-11-04-G001: The FATF fifth-round mutual evaluation report of the United States has been adopted but not yet published (due Dec 2026); detailed findings and recommended-action roadmap are not yet available to assess against. [open]

fim-int-2026-11-04-G002: Gatekeeper AML coverage gaps (lawye…

fim-int-2026-11-04-G002: Gatekeeper AML coverage gaps (lawyers, accountants, real estate agents, non-trust-company TCSPs) are flagged by secondary commentary but no T1 FATF finding specific to this cycle's window was identified. [open]

fim-int-2026-11-02-G001 ({'scheme': 'financial_integrity', '…

fim-int-2026-11-02-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): Export-control sanctions detail beyond OFAC 50 Percent Rule and RPPR reporting not reached within search budget. [open]

fim-int-2026-11-02-G002 ({'scheme': 'financial_integrity', '…

fim-int-2026-11-02-G002 ({'scheme': 'financial_integrity', 'value': 'D6'}): Compliance technology (RegTech/AI) supervisory expectations for D6 not reached within search budget this cycle. [open]

fim-int-2026-11-02-G003 ({'scheme': 'financial_integrity', '…

fim-int-2026-11-02-G003 ({'scheme': 'financial_integrity', 'value': 'D1'}): Counter-proliferation financing (CPF pillar) obligations not reached within search budget. [open]

fim-int-2026-11-02-G004 ({'scheme': 'financial_integrity', '…

fim-int-2026-11-02-G004 ({'scheme': 'financial_integrity', 'value': 'D7'}): Fraud and mule-account rules beyond the Zelle/Regulation E coverage in world-payments were not independently researched for the financial-integrity domain. [open]

fim-int-2026-11-02-G005 ({'scheme': 'financial_integrity', '…

fim-int-2026-11-02-G005 ({'scheme': 'financial_integrity', 'value': 'D2'}): US bearer-share and unexplained-wealth-order specifics not reached within search budget. [open]

FIM-GAP-001 (D2): Rescission of domestic BOI reporting under…

FIM-GAP-001 (D2): Rescission of domestic BOI reporting under the CTA (March 2025) removed the primary planned mechanism for exposing anonymous US shell-company beneficial owners, reverting to pre-2024 opacity for all US-formed entities.

FIM-GAP-002 (D2): The Residential Real Estate Rule, designed…

FIM-GAP-002 (D2): The Residential Real Estate Rule, designed to capture non-financed legal-entity/trust purchases of US residential property, was vacated by a federal court in March 2026; reporting persons currently face no liability for non-filing while the appeal is pending.

FIM-GAP-003 (D2): The CDD Rule Account Opening Exceptive Rel…

FIM-GAP-003 (D2): The CDD Rule Account Opening Exceptive Relief Order (Feb 2026) reduces the frequency at which financial institutions must re-identify and verify beneficial owners of legal-entity customers, moving away from a perpetual-KYC posture toward event-triggered review only.

FIM-GAP-004 (D3): Despite FinCEN's Section 311 action and FB…

FIM-GAP-004 (D3): Despite FinCEN's Section 311 action and FBI seizure against Huione Group, Elliptic tracks over 30 active Chinese-language guarantee marketplaces continuing to enable fraud, laundering and trafficking-linked commerce, with rapid merchant migration to successor platforms (Tudou and others) following each takedown.

Evidence

Confidence-tiered claims

Hamas financing network and Iranian industrial/military-procurement networks (Operation Economic Outcast) [Source 1]

Probable · 1 source

SDN delegations by Oct 18, 2026 against Russia/Iran-related transaction parties, with recurring 180-day review. [Source 1]

Probable · 1 source

First binding GENIUS Act interim final rule establishing Stablecoin Certification Review Committee procedure and $10bn state/federal bifurcation threshold. [Source 1]

Probable · 1 source

Sinaloa Cartel ('Los Mayos' faction) leadership and corruption networks, including Baja California narco-corruption charts. [Source 1]

Probable · 1 source

Program Rule NPRM courts AI/federated-learning monitoring but no finalized supervisory AI/ML examination standard exists. [Source 1]

Probable · 1 source

New prohibition on 'U-Turn' transactions involving Cuba; 30-day wind-down authorization expiring Oct 30, 2026. [Source 1]

Probable · 1 source

5th-round FATF Mutual Evaluation; possible onsite Feb 2026, possible Plenary discussion Oct 2026. [Source 1]

Probable · 1 source

FinCEN's final rule (eff. Aug 14, 2026) permanently exempts US persons/domestic entities from Corporate Transparency Act beneficial-ownership reporting. [Source 1]

Probable · 1 source

FinCEN Alert FIN-2026-Alert007 on the A7 Network, a Russia-Iran sanctions-evasion/money-laundering service leveraging digital-asset channels; concurrent OFAC SDN designation on Oct 1, 2026. [Source 1]

Probable · 1 source

Signed Sept 18, 2026; codifies and expands mandatory secondary sanctions on Russia's financial/energy/defense sectors, tariff authorities up to 500%/100%, and extends Iran Sanctions Act of 1996 through 2031. [Source 1]

Probable · 1 source

FinCEN withdrew its Dec 2020 self-hosted-wallet proposed rule and its 2023 crypto-mixing proposed rule (announced Oct 5, published Federal Register Oct 6, 2026); $3,000 Travel Rule threshold unchanged. [Source 1]

Probable · 1 source

OKX completed an undisclosed-size funding round at a $25bn valuation (reported Oct 6, 2026) with participation from Ripple Labs, Circle Internet Group, Standard Chartered's SC Ventures, and QRT. [Source 1]

Uncertain · 1 source

Most operative provisions take effect 18 October 2026, converting executive-order-based Russia sanctions into mandatory statute. [Source 1]

Probable · 1 source

Dense run of designation/delisting actions 9-16 October 2026: Iran, Cuba, Venezuela, Burma, counter-narcotics/counter-terrorism (Cartel del Noreste horse-racing financial network). [Source 1]

Probable · 1 source

All nine largest OCC-supervised national banks had policies/practices between 2020 and September 2025 capable of politicized or unlawful debanking, implementing Executive Order 14331. [Source 1]

Probable · 1 source

BSA/AML Program Rule proposal to replace process-based compliance with an effectiveness-based two-prong 'establish' and 'maintain' standard; comment period closed 9 June 2026, final rule not yet issued. [Source 1]

Probable · 1 source

GENIUS Act stablecoin AML-and-prudential rulemaking advances on parallel tracks; OCC targeting final rule by 31 October 2026. [Source 1]

Probable · 1 source

FinCEN final rule permanently exempts domestic reporting companies and US-person beneficial owners from CTA BOI reporting, effective 14 Aug 2026; foreign reporting companies registered in the US remain covered. [Source 1]

Probable · 1 source

FinCEN's 7 April 2026 NPRM proposes to reform AML/CFT program requirements around an effectiveness standard rather than a program-existence/pillars standard; no finalization located this cycle. [Source 1]

Probable · 1 source

OFAC designated 16 individuals and 10 entities for enabling Iran sanctions evasion and sustaining Iran's military/proxy forces, pursuant to EO 14404; wind-down GL FF issued through 30 Oct 2026. [Source 1]

Probable · 1 source

OFAC added the entire International Criminal Court to the SDN List under EO 14203 on 9 Oct 2026, issuing four related general licenses; UN Secretary-General and multiple G7 allies publicly objected. [Source 1]

Probable · 1 source

The CLARITY Act failed a Senate cloture vote 49-50 on 15 Sept 2026; SEC and CFTC proceed with parallel digital-asset rulemakings in its place. [Source 1]

Probable · 1 source

OFAC entered into a settlement agreement with Bank of America, N.A.; amount and underlying conduct not stated in the source retrieved this cycle. [Source 1]

Probable · 1 source

The newly enacted Graham Act imposes an 18 Oct 2026 statutory deadline for mandatory SDN-list designations under the Act, with recurring 180-day reviews thereafter. [Source 1]

Probable · 1 source

OFAC designated 10 individuals and 1 entity for converting DPRK IT-worker fraud proceeds via Russia-based crypto conversion [Source 1]

Probable · 1 source

FinCEN withdrew 2020 unhosted-wallet recordkeeping proposal and 2023 CVC-mixing Section 311 special-measure proposal effective 2026-10-06 [Source 1]

Probable · 1 source

FATF October 2026 plenary removed Bulgaria, Cote d'Ivoire, DRC and Monaco from the Increased Monitoring list [Source 1]

Probable · 1 source

FinCEN/OCC/OFAC assessed a $1,961,600,000 settlement for willfully failing to maintain an effective AML program, conduct correspondent-account due diligence, and timely file SARs. [Source 1]

Probable · 1 source

DOJ/FinCEN assessed a $504,000,000 penalty for operating an unlicensed money-transmitting business without FinCEN registration or an adequate AML program. [Source 1]

Probable · 1 source

OFAC imposed a $215,988,868 penalty, the largest of 2025, for Russia-related sanctions violations and failure to comply with an OFAC subpoena. [Source 1]

Probable · 1 source

Final rule effective 14 August 2026 permanently exempts US persons/domestic companies from CTA beneficial-ownership reporting, narrowing 'reporting company' to foreign entities only. [Source 1]

Probable · 1 source

FinCEN has announced it will next revise the 2016 CDD Rule to address open questions created by the narrower CTA regime; no proposed rule yet published. [Source 1]

Probable · 1 source

FATF-APG-CFATF fifth-round mutual evaluation of the United States was adopted by the Plenary on 30 October 2026; report publication due December 2026. [Source 1]

Probable · 1 source

FinCEN's NPRM would restructure the BSA 'pillars' to codify a mandatory, dynamic risk-assessment process across financial institution types. [Source 1]

Probable · 1 source

FY2025: over $1.3 billion in civil money penalties, 4.8 million SARs filed, $991 million returned to fraud victims since 2015, first use of FEND OFF Fentanyl Act special-measure authority against cartel-linked financial institutions. [Source 1]

Probable · 1 source

foreign reporting companies only; all US-formed entities and their beneficial owners permanently exempt [Source 1]

Probable · 1 source

domestic beneficial-ownership information, following BOI narrowing [Source 1]

Probable · 1 source

SAR filing for transactions at/aggregating $5,000+ (bank) or $2,000+ (MSB) within 30 (extendable to 60) days of detection [Source 1]

Probable · 1 source

disclosure of SAR existence to any person involved in the reported transaction [Source 1]

Probable · 1 source

collection/retention/transmission of originator and beneficiary information for transmittals of $3,000 or more; same threshold applies to convertible virtual currency per 2019 FinCEN guidance [Source 1]

Probable · 1 source

entities owned 50% or more in aggregate by one or more blocked persons [Source 1]

Probable · 1 source

blocking reports within 10 business days of blocking; annual report by Sept 30 of property held as of June 30 [Source 1]

Probable · 1 source

correspondent accounts for foreign shell banks [Source 1]

Probable · 1 source

risk-based EDD program for foreign correspondent accounts; enhanced scrutiny for PEP private banking accounts of $1,000,000+ [Source 1]

Probable · 1 source

written, board-approved AML program with internal controls, independent testing, compliance officer, training and risk-based CDD [Source 1]

Probable · 1 source

mandatory 10-30% whistleblower award for AML/sanctions enforcement actions yielding over $1,000,000 in monetary sanctions [Source 1]

Probable · 1 source

suspected fraud and other specified unlawful activities, per June 2026 FinCEN guidance, beyond money laundering/terrorist financing [Source 1]

Probable · 1 source

willful violation: greater of $100,000 or 50% of account balance; non-willful: up to $10,000 [Source 1]

Probable · 1 source

fines up to $250,000 and imprisonment up to 5 years for willful violation [Source 1]

Probable · 1 source

issuers must maintain accurate books/records and reasonable internal accounting controls [Source 1]

Probable · 1 source

lawyers, accountants and non-trust-company TCSPs from BSA obliged-entity status; ENABLERS Act stalled in Senate, not enacted [Source 1]

Probable · 1 source

Real Estate Report for non-financed transfers of US residential property to legal entities/trusts, identifying beneficial owners [Source 1]

Probable · 1 source

2028-01-01, from original 2026-01-01 effective date [Source 1]

Probable · 1 source