All in Regulatory Update

On February 26, 2025, FinCEN released an advisory on the FATF-identified jurisdictions with AML/CFT/CPF deficiencies. In this latest update, the FATF added Laos and Nepal to the list of Jurisdictions Under Increased Monitoring and removed the Philippines. The list of High-Risk Jurisdictions Subject to a Call for Action remains unchanged, with Iran, North Korea (DPRK), and Burma still subject to FATF’s highest level of scrutiny. Specifically, FATF continues to call for countermeasures against Iran and DPRK, while Burma remains subject to enhanced due diligence.

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.