All in BSA

On September 30, 2025, FinCEN announced that it will postpone reporting requirements of the Anti-Money Laundering Regulations for Residential Real Estate Transfers Rule (RRE Rule) until March 1, 2026. FinCEN stated that this is to provide industry with more time to comply while still adequately protecting the U.S. financial system from money laundering, terrorist financing, and other serious illicit finance threats.

On September 16, 2025, the OFAC designated a pair of Iranian financial facilitators and more than a dozen Hong Kong- and United Arab Emirates (UAE)-based individuals and entities. These entities were sanctioned for their roles in coordinating funds transfers, including from the sale of Iranian oil, that benefit the IRGC-Qods Force (QF), and Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL).

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.