All in BSA

On 2/21/25, the US Department of Treasury reported that the Financial Action Task Force (FATF) concluded a plenary in Paris, where Treasury representatives participated in discussions on proliferation and terrorist financing risks, financial inclusion, and payment standards, leading to draft updates for public consultation. The Treasury also reported that FATF launched a public consultation on sanctions evasion schemes and endorsed changes to its recommendations to reinforce a risk-based approach to combating illicit finance, including ensuring preventive or mitigation measures are commensurate with the risks identified.

On 2/20/25, OFAC launched a new “File Finder” application for use on its website. The application is browser-based and allows “users to search through and efficiently navigate all of OFAC’s website content,” according to a release by OFAC. OFAC explains that the new application “searches all static content on OFAC's website (PDF documents, word documents, etc.) by document title, document type, and the contents of each document. Searchable content typically includes general licensees, federal register notices, executive orders (and other legal documents), press charts, advisories, specific guidance, as well as many other records.”

On February 19, 2025, FinCEN updated the Alert on its Beneficial Ownership Reporting page stating that beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are once again back in effect as a result of the decision by the U.S. District Court for the Eastern District of Texas in Smith, et al. v. U.S. Department of the Treasury, et al. However, FinCEN is generally extending the deadline by 30 calendar days from February 19, 2025, for most companies considering that reporting companies may need additional time to comply with their BOI reporting obligations.

VIDEO: Incorporating FinCEN Priorities into Risk Assessment

In this Compliance Clip, Adam discusses the importance of integrating FinCEN's national priorities into financial institutions' BSA/AML/CFT risk assessments, highlighting recent proposals from FinCEN and regulatory agencies aimed at updating compliance requirements. Adam provides ways on how financial institutions can proactively incorporate these priorities into their risk assessments. A transcript of this video is now available.

On January 24, 2025, FinCEN updated its Alert published Beneficial Ownership Reporting webpage to inform that reporting companies are not currently required to file beneficial ownership information with FinCEN despite the Supreme Court’s stay of the nationwide injunction issued by a federal judge in Texas (Texas Top Cop Shop, Inc. v. McHenry—formerly, Texas Top Cop Shop v. Garland). 

On December 17, 2024, the OFAC sanctioned two individuals and one entity involved in a network that launders millions of dollars of illicit funds generated by the Democratic People’s Republic of Korea (DPRK) information technology (IT) workers and cybercrime to support the DPRK Government. The sanctions are part of OFAC’s ongoing efforts to disrupt the DPRK’s money laundering operations, which finance the regime’s unlawful weapons of mass destruction (WMD) and ballistic missile programs. 

On December 18, 2024, FinCEN issued an alert to raise awareness of fraud schemes abusing FinCEN’s name, insignia, and authorities for financial gain. These FinCEN-specific fraud schemes include scams that exploit beneficial ownership information reporting; misuse FinCEN’s Money Services Business Registration tool; or involve the impersonation of, or misrepresent affiliation with, FinCEN and its employees.