All in Regulatory Update

On March 31, 2026, the OFAC issued a sanctions advisory to highlight sanctions risks arising from sham transactions used to evade sanctions and to identify factors to consider when evaluating whether property may be the subject of a sham transaction. Sham transactions occur when blocked individuals use intermediaries to falsely give up property to evade sanctions while still retaining an interest in it.

On March 30, 2026, FinCEN issued an Advisory to urge financial institutions to be vigilant in identifying and reporting suspicious transactions potentially related to health care fraud schemes targeting Medicare, Medicaid, and other Federal and state health care benefit programs. The Advisory builds on Treasury’s work to combat the potentially billions of dollars in rampant health care and government benefits fraud in Minnesota and across the country.

On March 30, 2026, FinCEN issued a proposed rule to fully implement a whistleblower program by establishing a framework for offering incentives and protections to encourage individuals to report tips on fraud-related violations of the Bank Secrecy Act, U.S. sanctions programs administered by Treasury’s OFAC, and several other laws critical to safeguarding the U.S. financial system and national security. The proposed rule would implement section 6314 of the Anti-Money Laundering Act of 2020 and the Anti-Money Laundering Whistleblower Improvement Act.