Treasury Targets Financial Network Supporting Iran’s Military

Adam Witmer
Regulatory Update, BSA

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).

OFAC Published New Unblocking/Transfer Form

Adam Witmer
BSA, Regulatory Update

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.

FDIC Requests Comments on AML/CFT Compliance Costs Survey

Adam Witmer
BSA, Regulatory Update

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. 

Comptroller’s Statement at Financial Stability Oversight Council Meeting

Adam Witmer
Regulatory Update

On September 10, 2025, Comptroller of the Currency Jonathan V. Gould issued a statement at the Financial Stability Oversight Council (FSOC) meeting about the OCC's work to reset the risk tolerance for the federal banking system. Comptroller Gould discussed the OCC’s work to review the agency’s post-2008 chartering, regulatory, and supervisory framework to ensure the federal banking system remains relevant and fulfills its mission.

FDIC Revises Enforcement Actions Manual on Cease-and-Desist Terminations

Adam Witmer
Regulatory Update

On September 8, 2025, the FDIC updated chapter four of its Formal and Informal Enforcement Actions Manual, entitled Cease-and-Desist Actions, regarding the agency’s minimum standards for terminating cease-and-desist and consent orders issued under Section 8(b) of the Federal Deposit Insurance Act. The manual provides direction for professional staff related to the work necessary to pursue formal and informal enforcement actions. 

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