All in BSA

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.

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).