All in Regulatory Update

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.