All in BSA

On September 19, 2025, the OFAC published a new Unblocking/Transfer Report Form to support compliance with reporting requirements under the Reporting, Procedures and Penalties Regulations. According to the  OFAC, the new form offers a simplified way to report property that has been unblocked or transferred, which eases the burden on filers and improves OFAC's processing efficiency.

On September 12, 2025, the FDIC issued a notice and request for comment on a proposed information collection, a Survey of the Costs of AML/CFT Compliance. The survey seeks to gather information on the direct costs incurred by banks, savings associations, and credit unions in complying with the BSA/AML/CFT requirements, and the amount attributable to AML/CFT compliance that overlap with those of other activities such as fraud and credit monitoring. 

On September 8, 2025, FinCEN reiisued a modified Geographic Targeting Order (GTO) to combat illicit cartel and other criminal activity, including money laundering, along the southwest border of the United States. FinCEN previously issued a notice of a GTO requiring certain money services businesses along the southwest border to report and retain records of transactions in currency of more than $200 but not more than $10,000, and to verify the identity of persons presenting such transactions.

On September 5, 2025, FinCEN issued guidance to encourage and promote appropriate, voluntary cross-border sharing of information between and among financial institutions, including appropriate foreign financial institutions. According to FinCEN, the Guidance aims to help combat the threats posed by money laundering, terrorist financing, and other illicit finance activity, including from drug trafficking organizations, foreign terrorist organizations, and fraudsters.

On August 19, 2025, FinCEN extended the effective dates for orders issued on June 25, 2025, prohibiting certain transmittal of funds involving three Mexico-based financial institutions. Covered financial institutions will now have until October 20, 2025, to implement the orders prohibiting certain transmittal of funds involving CIBanco S.A., Institución de Banca Multiple (CIBanco), Intercam Banco S.A., Institución de Banca Multiple (Intercam), and Vector Casa de Bolsa, S.A. de C.V. (Vector).