All in BSA

On November 21, 2025, FinCEN released an advisory on the FATF-identified jurisdictions with AML/CFT/CPF deficiencies. This advisory informs U.S. financial institutions about jurisdictions the Financial Action Task Force (FATF) has identified as having strategic deficiencies in their anti-money laundering, countering the financing of terrorism, and countering the financing of proliferation (AML/CFT/CPF) regimes.

On November 13, 2025, FinCEN issued a finding and notice of proposed rulemaking that identifies transactions involving ten identified Mexico-based gambling establishments as a class of transactions to be of primary money laundering concern. FinCEN proposes to limit these gambling establishments' access to the U.S. financial system by prohibiting covered financial institutions from opening accounts for foreign banks that process transactions for these ten gambling establishments.

On November 12, 2025, the OFAC designated the Democratic Karen Benevolent Army (DKBA) and four senior leaders for supporting Burma-based cyber scam centers that target Americans through fraudulent investment schemes. In addition, the OFAC designated three other organizations linked to Chinese organized crime and have worked with the DKBA and other armed groups to develop these scam centers.

On November 4, 2025, the OFAC sanctioned eight individuals and two entities for their role in laundering funds derived from a variety of illicit Democratic People’s Republic of Korea (DPRK) schemes, including cybercrime and information technology (IT) worker fraud. According to the Multilateral Sanctions Monitoring Team’s report, these operations have been linked to the funding for the DPRK’s weapons of mass destruction (WMD) programs and destruction of physical computer equipment.

On October 23, 2025, FinCEN published a Financial Trend Analysis (FTA) identifying approximately $9 billion of potential Iranian shadow banking activity that occurred through U.S. correspondent accounts in 2024. The analysis draws on reports from U.S. financial institutions about transactions before the maximum pressure campaign and supplements FinCEN’s June advisory on Iran’s illicit oil smuggling, shadow banking, and weapons procurement activities.

On October 14, 2025, the OFAC and FinCEN, in close coordination with the United Kingdom’s Foreign, Commonwealth, and Development Office (FCDO), took complementary actions against criminal networks responsible for targeting citizens of the United States and other allied nations through online scams and the laundering of stolen funds. OFAC has sanctioned 146 targets within the Prince Group Transnational Criminal Organization, a Cambodia-based network led by Chen Zhi, known for online investment scams targeting Americans and others globally.