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).