AML / Financial Crime

Key dates

2026-11-03

The EAER expanded and amended the Swiss sanctions lists relating to Russia and Belarus.

2026-11-04

The Federal Council decided to adopt the EU’s 21st Russia and Belarus sanctions package and related measures.

2026-11-04

The amended sanctions lists entered into force at 23:00 Swiss time.

2026-11-05

The sectoral measures, including the strengthened crypto-sector restrictions and transaction prohibitions, entered into force.

Suggested considerations

• Compliance teams may wish to refresh sanctions screening against the amended Swiss Russia and Belarus lists, including customer, beneficial-owner, authorised-signatory, counterparty and payment screening records.
• Swiss crypto-sector companies should consider reviewing ownership registers, pending acquisitions, shareholder changes, control arrangements and beneficial-ownership information for Russian nationals and persons resident in Russia, including indirect acquisition structures.
• Firms should consider mapping exposure to the newly prohibited banks, financial institutions, crypto-service providers and other entities, and placing appropriate holds on affected transactions and assets pending resolution.
• Financial intermediaries may wish to document asset-freeze decisions and report affected business relationships to SECO in accordance with the applicable Ukraine sanctions ordinance.
• Where sanctions-related facts create suspicion of money laundering or terrorist financing, firms should consider completing the additional clarifications required by Article 6 AMLA and filing an immediate report under Article 9 AMLA if the suspicion cannot be dispelled.
• Firms may wish to update sanctions procedures, transaction-monitoring scenarios, onboarding questionnaires and escalation controls to distinguish SECO sanctions reporting from separate AMLA reporting.
• Compliance teams may wish to review external exposure to EU sanctions controls as well as Swiss measures; independent Swiss sanctions commentary describes the regime as not being a general Russia or Belarus embargo, but highlights continuing expansion of financial, crypto, services and circumvention controls.

What changed

The EAER expanded and amended the Russia and Belarus sanctions lists, adding 254 individuals, companies and organisations to measures including asset freezes and restrictions on making funds or economic resources available. Switzerland also introduced transaction prohibitions covering, among others, 33 Russian banks, one bank in a third country, 17 financial institutions and crypto-service providers, five third-country companies, four Russian airports and two Russian ports.

Key dates

2025-06-12

The SFC launched the consultation on expanding section 34 of the SFO and introducing similar restrictions under the AMLO.

2025-08-11

The consultation period closed; the SFC reported receiving nine submissions from industry associations, professional bodies, a bank and other interested parties.

2026-11-06

The SFC published its consultation conclusions, updated the FAQs and announced its intention to introduce an amendment bill into LegCo.

Suggested considerations

• Compliance teams may wish to inventory legal-entity names, business names, brands, websites, domains, mobile applications, social-media handles, product names and marketing descriptions against the SFC's proposed Table A and Table B titles.
• Firms should consider mapping each relevant name to the activities actually performed, including trading, brokerage, matching, exchange, clearing, settlement, custody and virtual-asset services, and documenting whether SFO or AMLO licensing could be required.
• Unregulated entities may wish to assess whether current names imply SFC licensing, regulated status or an association with a well-known exchange, clearing house or VATP, including through abbreviations, translated names and closely resembling wording.
• Licensed VATPs and financial groups may wish to review whether group-company names, partnerships, white-label arrangements, sponsorships or marketing references could create an apparent association with an established operation that does not exist.
• Legal and compliance functions may wish to monitor the amendment bill, LegCo proceedings, commencement provisions, transitional arrangements, the final restricted-title list and any future mechanism for updating that list.
• Firms considering a new name or business launch may wish to obtain independent Hong Kong legal advice and, where appropriate, seek SFC authorisation before adopting a potentially restricted title; the SFC has not announced a final application deadline or commencement date.
• Marketing and financial-promotion controls may be updated to require enhanced review of terms such as "exchange", "trading platform", "clearing house", "virtual asset", "digital asset", "token" and "crypto" once the amendments are enacted.

What changed

The SFC will proceed with legislative amendments to expand the existing section 34 SFO restrictions beyond titles such as "stock exchange" and "commodity exchange". The expanded scope is intended to cover titles commonly used instead of "exchange", titles describing SFO-regulated products, titles referring specifically to clearing operations, and names or acronyms implying association with established or well-known exchanges, clearing houses, VATPs or similar operations, whether located in Hong Kong or elsewhere and whether regulated or unregulated.

Key dates

2026-11-02

WBF amended Annex 2 of the Ordinance of 25 May 2005 on Measures against Sudan (SR 946.231.18), modifying three individual entries.

2026-11-03 Deadline

The amended Sudan sanctions measures enter into force at 23:00 Swiss time; affected financial intermediaries must apply the relevant prohibitions, freeze assets and report affected relationships and blocked assets as required by the ordinance.

Suggested considerations

• Compliance teams should consider updating sanctions-screening data, including aliases and identifying information, from SESAM and the amended Annex 2 before the 23:00 effective time on 3 November 2026.
• Firms should consider screening customers, beneficial owners, counterparties, payment beneficiaries, securities positions and existing business relationships against all three modified entries, including historical and transliterated names where relevant.
• Where a potential match is identified, firms should consider applying the Article 2 financial-sanctions restrictions, preventing further availability of assets or economic resources, preserving relevant records and escalating the case for false-positive resolution and sanctions governance review.
• Firms should consider notifying SECO of affected business relationships and blocked assets in accordance with SR 946.231.18 and maintaining evidence of the decision, controls applied and notification submitted.
• Compliance teams may wish to assess whether a sanctions hit or related transaction creates additional money-laundering concerns requiring enhanced inquiries under Article 6 GwG and, if suspicions cannot be dispelled, an immediate Article 9 GwG report to the Money Laundering Reporting Office.
• Firms with cross-border operations should consider separately assessing whether the modified persons are also subject to EU, UK, US or other sanctions regimes, because the Swiss listing and any foreign restrictions may differ in scope and ownership or control consequences.
• Firms should consider validating batch-screening, real-time payment-screening, case-management and alert-escalation controls after the SESAM update, given the short notice between publication and effectiveness.

What changed

Three individual entries in Annex 2 were modified; the update is implemented through the Swiss SESAM sanctions database. The amended listings are subject to the financial sanctions in Article 2 paragraph 1 of SR 946.231.18, including the freezing of assets and economic resources and the prohibition on directly or indirectly making assets or economic resources available to listed persons. The relevant travel-ban provisions under Article 4 paragraph 1 also apply. Financial intermediaries must report affected business relationships and blocked assets to SECO.

Key dates

2026-09-30

The FCA’s application window for the new UK cryptoasset regime opened.

2026-10-01

The application window opened for the FCA Regulatory Sandbox themed cohort on climate scenario models.

2026-11-02

The FCA published Wholesale banks supervision - Insights 3 (Autumn 2026).

2026-11-30 Deadline

The application window closes for the FCA Regulatory Sandbox climate scenario models cohort.

2027-02-28 Deadline

FCA-encouraged deadline for wholesale banks to submit a variation-of-permission application for new regulated cryptoasset activities to obtain the stated pre-regime application treatment.

2027-10-25

The new UK cryptoasset regime comes into force.

Suggested considerations

• Firms should consider performing a control-by-control review of critical data ingestion, including completeness checks, reconciliation, coding-change testing, source-to-consumption lineage and evidence of design and operating effectiveness for financial-crime and surveillance controls.
• Compliance and technology teams may wish to test communications surveillance after system changes, including lexicon configuration, geographic and channel coverage, third-party-provider interfaces, ingestion completeness and retention or auditability of records for in-scope activities.
• Firms should consider reconciling the technology-asset inventory to procurement, disposal, redeployment, identity and endpoint-management records across all regions, assigning clear lifecycle accountability and confirming that assets cannot leave service without security and inventory updates, including encryption status.
• Algorithmic-trading firms should consider testing enhancements across the complete order lifecycle, including near-simultaneous and geographically distributed fills, order-management and fill-notification interactions, overfills, stop-loss scenarios, venue behaviour, pre-trade limits, kill or cancel mechanisms and post-implementation monitoring, with governance aligned to UK MiFID RTS 6.
• Firms should consider testing DLP controls against deliberate circumvention, including split messages, altered classifications, changed file formats, embedded images and misleading subjects, while reviewing staff training, monitoring, escalation and privacy safeguards.
• Operational-resilience owners may wish to refresh important-business-service impact tolerances using potential disruption to trading, settlement, clients, counterparties and time-critical market processes rather than relying solely on generic recovery-time or availability metrics.
• Firms should consider separating current resilience capability from planned remediation in self-assessments, linking incidents, near misses and test results to mapping and remediation decisions, and validating completed remediation through retesting.
• Settlement-related firms should consider the effect of T+1 on post-trade dependencies, reconciliation, funding, exception management, recovery capability, scenario testing and impact-tolerance calibration.

What changed

The FCA has not introduced new binding rules through this publication; it has consolidated supervisory findings and clarified areas against which wholesale banks may be assessed. Firms are expected to be able to evidence complete data lineage and ingestion controls, auditable recording and communications surveillance even where third parties are used, reliable asset inventories, end-to-end algorithmic-trading testing and controls consistent with UK MiFID RTS 6, and DLP controls capable of addressing adaptive evasion techniques.

Key dates

2026-10-29

The SEC announced charges against BG Wealth Sharing Ltd and DSJ Exchange Pty Ltd and filed the related enforcement complaint in the U.S. District Court for the Northern District of California.

Suggested considerations

• Compliance teams may wish to review third-party crypto platforms, advisers, issuers, introducers, and promoters for unsupported claims that an SEC filing represents licensing, approval, endorsement, or authorization.
• Firms should consider independently verifying Form ADV, Form D, and other regulatory filings through official regulator databases and documenting the precise legal effect of each filing before relying on it in due diligence or investor communications.
• Marketing and financial-promotion controls may wish to test for claims of risk-free or guaranteed returns, extraordinary monthly performance, government approval, SEC registration, fake certificates, and statements that a Rule 506(c) filing authorizes operation of a crypto exchange.
• Firms with exposure to BG Wealth Sharing, DSJ Exchange, or associated promoters should consider escalating the relationship for legal, fraud, sanctions, counterparty, and suspicious-activity review and preserving relevant communications, transaction records, and onboarding materials.
• Investment advisers and other regulated firms may wish to assess whether referral, custody, payment, or platform relationships involving similar schemes create customer-protection, books-and-records, disclosure, or reputational risks.
• Compliance teams may wish to incorporate the related state and foreign warnings into typology monitoring, particularly indicators such as recruitment-based compensation, blocked withdrawals, advance exit or compliance fees, fake account balances, and periodic payments used to sustain investor confidence.

What changed

This is an enforcement action, not a new rule or generally applicable compliance requirement. The SEC alleges violations of the antifraud provisions of the Securities Act of 1933 and Securities Exchange Act of 1934 by both entities, and violations of Sections 204(a) and 207 of the Investment Advisers Act of 1940 by BG Wealth. The SEC is seeking permanent injunctions, disgorgement with prejudgment interest, civil penalties against both entities, and conduct-based injunctions against BG Wealth.

Key dates

2026-10-26

Current date and FCA publication context for the review; firms have been told to take prompt action, but this is not a statutory compliance deadline.

2028-12-01

The FCA says the point-in-time publication may be treated as retired by December 2028 if it has not been removed sooner; this is not stated as a mandatory implementation deadline.

Suggested considerations

• Compliance teams may wish to map how the firm identifies direct defence businesses, defence supply-chain participants, dual-use technology businesses and relevant customers that are not accurately captured by SIC codes.
• Firms should consider testing whether onboarding and enhanced due diligence requests are risk-based, non-duplicative and proportionate to the individual customer's activities, jurisdictions, products, end use and supply chain, rather than triggered solely by a broad defence-sector label.
• Firms should consider reviewing blanket exclusions, revenue thresholds, automatic escalation rules and approval stages affecting defence customers, documenting why any retained restrictions are justified by legal, financial-crime, reputational or commercial-risk considerations.
• Firms should consider defining and governing reputational, ESG and sustainability criteria used in account opening, servicing, product access, restriction or closure decisions, with evidence that the criteria are consistently applied and aligned with stated risk appetite.
• Firms should consider establishing or improving management information covering defence-sector identification, application volumes, approval and rejection rates, onboarding duration, repeated information requests, escalation frequency, restrictions, closures, complaints and outcomes by customer risk category.
• Senior management and relevant committees may wish to review whether the available information allows them to challenge inconsistent treatment, unexplained delays or outcomes that arise from internal processes rather than the customer's actual risk.
• Where legally permissible and appropriate, firms should consider keeping applicants informed about additional checks, progress and likely decision timescales, and explaining decisions sufficiently to reduce avoidable uncertainty.
• Firms should continue to apply customer due diligence, enhanced due diligence, sanctions and other financial-crime controls required by applicable law; the FCA's message is to make those controls targeted and proportionate, not to reduce them.

What changed

No binding regulatory obligations or new thresholds have been introduced. The FCA has nevertheless written to firms providing banking services to SMEs and expects prompt action under existing requirements. Firms should review whether onboarding, enhanced due diligence, escalation, servicing, restriction and closure processes distinguish among different defence activities and reflect the specific customer, geographic, product, supply-chain, end-use, financial-crime and reputational risks.

Key dates

2026-04-21

Voluntary restrictions were imposed on Kingscrown Finance Ltd.

2026-09-25

Further voluntary restrictions were imposed on Kingscrown Finance Ltd, including limits on receiving payments from existing customers and an orderly wind-down requirement.

2026-10-07

Voluntary restrictions were imposed on MOMSB Ltd and Momentus Capital Ltd, including restrictions on new customers, new lending arrangements and certain payments from existing customers, together with independent AML-framework reviews.

2026-10-09

Voluntary restrictions were imposed on Grosvenor Funding Ltd and Grosvenor Funding (North West) Ltd, including restrictions on new customers, new lending arrangements and certain payments from existing customers, together with independent AML-framework reviews.

2026-10-15

Voluntary restrictions were imposed on Abbital Ltd, including specified conditions for taking on customers, entering into lending arrangements and accepting payments, together with an independent review of its AML systems and controls.

2026-10-23

The FCA announced the restrictions and reiterated its enhanced oversight of Annex 1 firms and due-diligence expectations for regulated firms dealing with them.

Suggested considerations

• Annex 1 firms should consider reviewing their business-wide AML risk assessment, customer and beneficial-owner due diligence, ongoing monitoring, suspicious-activity escalation, governance, management information, resourcing and independent-testing arrangements against the Money Laundering Regulations 2017.
• Annex 1 firms seeking registration or under FCA assessment should consider ensuring that policies and controls are tailored to their actual lending activities, customer base, delivery channels and growth plans, rather than relying on generic or group-level documentation.
• The six named firms should consider mapping their operational processes, customer communications, payment arrangements and lending activity to the precise terms of their voluntary restrictions and preserving evidence of compliance with those terms.
• FCA-authorised firms should consider identifying all Annex 1 counterparties and refreshing onboarding and periodic-review procedures to obtain direct confirmation of registration, conduct independent verification, understand the counterparty's business model and assess whether its AML controls create heightened relationship risk.
• Regulated firms should consider recording the rationale for accepting, continuing or restricting relationships with Annex 1 firms and escalating discrepancies between a firm's registered activities, actual activities, ownership, governance or AML framework.
• Groups with multiple Annex 1 entities should consider documenting entity-specific risk assessments and controls, since group-wide or off-the-shelf procedures may not demonstrate that each entity manages its own risks effectively.
• Lenders and their service providers should consider contingency arrangements for restricted firms, including payment handling, loan-book servicing, customer communications and orderly wind-down scenarios.

What changed

Kingscrown Finance Ltd is subject to restrictions limiting how it may receive payments from existing customers and requiring an orderly wind-down of its existing loan book. MOMSB Ltd, Momentus Capital Ltd, Grosvenor Funding Ltd and Grosvenor Funding (North West) Ltd are restricted from taking on new customers or entering into new lending arrangements, subject to the specified exceptions; restrictions also apply to accepting payments from existing customers, and the firms must obtain independent reviews of their AML frameworks.

Key dates

2026-10-23

FCA consultation CP26/38 opened and published.

2026-12-24 Deadline

Deadline for submitting responses to the FCA consultation.

2027-10-01

The FCA describes the new cryptoasset regime as applying from October 2027; the precise commencement date should be confirmed against the final legislation and FCA rules.

Suggested considerations

• Compliance teams may wish to review the proposed changes and submit consultation responses through the FCA online form by 24 December 2026, particularly where the proposals would create material implementation costs or operational challenges.
• Firms should consider mapping current fraud, AML/CTF, sanctions, proliferation-financing, data-security and financial-crime systems-and-controls frameworks against the consultation themes, while recognising that the proposals are not yet final guidance.
• Cryptoasset businesses and firms intending to provide regulated cryptoasset services may wish to assess readiness for the new regime expected in October 2027, including AML/KYC controls, blockchain analytics, Travel Rule processes, sanctions screening, transaction monitoring and governance.
• Firms using AI or external technology providers for transaction monitoring, customer screening or other financial-crime controls should consider documenting model governance, validation, parameter testing, explainability, human oversight, data security, third-party oversight and retention of decision records.
• Senior management and boards may wish to review whether financial-crime management information, risk assessments and escalation arrangements adequately cover proliferation financing, sanctions evasion, cryptoasset risks and reliance on outsourced or AI-enabled controls.
• Firms may wish to monitor the FCA's final Policy Statement and consolidated Financial Crime Guide, since the final text may differ from the consultation proposals and is likely to inform future supervisory assessments.

What changed

No new binding rules have been made by this consultation. The FCA proposes to revise non-Handbook guidance and practical examples in the Financial Crime Guide to reflect emerging risks and regulatory developments, including AI and third-party tools used in financial-crime controls, cryptoasset-specific risks, evolving financial and trade sanctions, proliferation financing, data security, fraud, and AML/CTF systems and controls.

Key dates

2024-04-01

Bank of America self-identified the inaccurate wire-transmittor information issue, according to the OCC enforcement order; the date is included as an approximate month-level historical reference represented by the first day of the month.

2024-10-01

Bank of America stopped the inaccurate transmittor-information practice in 2024; the OCC order does not provide an exact day, so this is an approximate month-level historical reference represented by the first day of the month.

2026-10-08

The OCC announced the American Express National Bank cease-and-desist order and $350 million civil money penalty.

2026-10-13

The OCC announced the Bank of America $750 million civil money penalty, described as the largest penalty in OCC history, in coordination with Treasury and FinCEN actions.

2026-10-22

The OCC published the October 2026 consolidated enforcement-actions release.

Suggested considerations

• Firms should consider reassessing whether their BSA/AML risk assessments cover the risks of all material products and services, rather than concentrating on narrower deposit activity while underweighting credit-card, charge-card, correspondent, or payment activity.
• Compliance teams may wish to test end-to-end transaction-monitoring workflows for alert generation, escalation, investigation, disposition, and SAR filing, including backlog governance, aging thresholds, management information, and evidence that suspected trade-based money laundering is escalated promptly.
• Firms should consider validating that customer identification, customer due diligence, beneficial-ownership information, and ongoing-risk-rating processes are complete, accurate, risk-based, and aligned to the institution's actual customer and product populations.
• Banks may wish to perform a targeted review of outgoing wire data to confirm that originator or transmittor names and other required fields are accurate, consistently populated, retained, and not overwritten by deficient interfaces or manual processes.
• Boards and senior management should consider documenting sufficient staffing, subject-matter expertise, training, independent testing, audit coverage, and issue-remediation ownership for BSA/AML programs.
• Institutions operating under prior supervisory findings should consider independent validation that corrective actions are complete, effective, sustainable, and supported by evidence, rather than merely implemented procedurally.
• Compliance teams should consider reviewing whether third-party, correspondent, and payment-processing arrangements create data-quality or monitoring dependencies that could delay SAR filing or impair law-enforcement traceability.

What changed

This publication announces enforcement outcomes rather than a new rule or generally applicable deadline. American Express National Bank is subject to a cease-and-desist order and a $350 million penalty for an inadequately designed and monitored BSA/AML program, inadequate resources and expertise, internal-control weaknesses, weak independent testing and training, systemic failures involving approximately $13 billion of suspected trade-based money-laundering activity, and customer identification and customer due diligence deficiencies.

Key dates

2026-10-21

FCA published GC26/7 and opened the guidance consultation.

2026-11-18 Deadline

Deadline for consultation responses to GC26/7.

2027-01-01

FCA plans to publish final DeFi guidance during January 2027; no specific publication day has been stated.

2027-10-25

The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 are due to bring new cryptoasset activities into the FCA regulatory perimeter.

Suggested considerations

• Compliance teams may wish to map each DeFi use case, protocol, smart-contract dependency, service provider and customer-facing activity against the firm's existing SYSC 15A, SYSC 6 and Money Laundering Regulations obligations.
• Firms should consider documenting governance and accountability for DeFi arrangements, including who controls or can materially influence protocol changes, access permissions, treasury assets, upgrades, emergency controls and customer outcomes.
• Operational resilience teams may wish to assess important business services, impact tolerances, vulnerabilities, third-party and smart-contract dependencies, oracle and bridge risks, key-management arrangements, cyberattack scenarios and credible disruption testing.
• Financial-crime teams should consider whether existing customer due diligence, transaction monitoring, sanctions screening, blockchain analytics, wallet-risk assessment, suspicious activity escalation and record-keeping controls remain effective for pseudonymous, automated or cross-chain activity.
• Firms may wish to review outsourcing and third-party risk assessments for protocol developers, validators, custodians, wallet providers, analytics providers, cloud infrastructure and other critical DeFi dependencies.
• Legal and regulatory teams should assess whether current and planned activities fall within the existing perimeter or the new cryptoasset activities introduced by the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026, including whether there is an identifiable controlling entity.
• Affected stakeholders may wish to submit responses to the FCA by 18 November 2026 and identify any areas where the illustrative guidance is unclear, disproportionate or difficult to apply to genuinely decentralised arrangements.
• Firms may wish to track the FCA's planned final guidance in January 2027 and update risk assessments, policies, control testing and implementation plans before the new cryptoasset regime commences.

What changed

The FCA is proposing guidance describing the operational resilience and financial crime risks associated with DeFi and providing illustrative measures firms may consider. The guidance is relevant to firms within SYSC 15A, SYSC 6 and the Money Laundering Regulations, including firms using distributed-ledger technology, automated protocols, open and interoperable systems or arrangements with limited traditional intermediation. It is intended to clarify application of existing requirements rather than establish a separate DeFi regime or new Handbook obligations.

Key dates

2026-10-21

The OCC issued Bulletin 2026-51 and stated that applications and waiver requests will be accepted only after OMB approves the related information collection.

2027-01-18 Deadline

The GENIUS Act and OCC final rule become effective; the Prior Approval Requirement generally applies, and unauthorized issuance of a payment stablecoin in the United States may carry criminal penalties.

2028-01-18 Deadline

The maximum statutory period for a waiver beginning on January 18, 2027 expires, subject to the terms and shorter duration of any individual waiver.

Suggested considerations

• Firms should determine whether they are currently issuing a payment stablecoin in the United States and whether they fall within the OCC application pathway or another primary federal payment stablecoin regulator's pathway.
• Existing issuers should consider preparing and submitting a substantially complete OCC application as soon as the agency announces that applications are accepted, rather than relying on the waiver as a substitute for authorization.
• Applicants should map their submission against every prescribed application question and documentation requirement, including the business plan, management, reserve assets, issuance and redemption processes, risk management, capital and liquidity, shared services, BSA/AML, OFAC, third-party risk, enterprise risk, compliance risk, and audit functions.
• Compliance teams may wish to prepare a separate written waiver request addressing the Prior Approval Requirement, identifying any additional GENIUS Act or final-rule requirements that cannot be met by January 18, 2027, and explaining the requested duration and operational rationale.
• Issuers should monitor the OCC's GENIUS Act landing page and press releases for OMB approval and the opening of the application and waiver process, because the bulletin does not provide a fixed application-opening date.
• Firms should maintain evidence supporting the completeness and accuracy of their applications and establish a process to respond promptly to OCC requests for missing information within the 30-day review cycles.
• Prospective issuers that are not already operating in the United States should consider planning for operations to begin only after OCC approval, consistent with the agency's stated position on waiver eligibility.
• Regulatory change teams should continue tracking separate FinCEN, OFAC, OCC, and other agency rulemakings concerning AML, CFT, sanctions, and customer-identification requirements rather than assuming that an OCC application or Prior Approval Requirement waiver resolves those obligations.

What changed

Beginning January 18, 2027, a person generally must be approved as a permitted payment stablecoin issuer before issuing a payment stablecoin in the United States; unauthorized issuance may carry criminal penalties. Under GENIUS Act section 5(f) and 12 CFR 15.30(g), an issuer with a substantially complete OCC application pending on January 18, 2027 may request a written waiver of the Prior Approval Requirement and other statutory or final-rule requirements that it cannot satisfy by the effective date.

Key dates

2021-04-22

Beginning of the period in which ASIC alleges the Panacea Capital Cryptocurrency Investment Fund was offered without an AFS licence.

2022-06-17

End of the period in which ASIC alleges the Crypto Fund operated without an AFS licence.

2024-03-21

ASIC announced that Brian Creigh was permanently banned from providing financial services or being involved in a financial services business.

2026-10-19

Creigh was charged in the Melbourne Magistrates’ Court and granted conditional bail.

2026-10-20

ASIC published the enforcement release announcing the criminal charges.

Suggested considerations

• Firms should consider confirming that every entity and individual providing financial product advice, dealing, arranging or other financial services in Australia holds the required AFS licence or is properly appointed as an authorised representative for the relevant activities.
• Compliance teams may wish to map digital-asset products against the financial product and financial services definitions in Chapter 7 of the Corporations Act 2001 (Cth), including where pooled investor money is used to pursue returns from a portfolio of digital assets.
• Firms should consider reviewing marketing materials, fact sheets and investor communications for unsupported claims about licensing status, capital protection, guarantees, historical performance, targeted returns and the nature of underlying investments.
• Compliance teams may wish to strengthen onboarding and ongoing due diligence for digital-asset fund operators, directors, promoters, overseas counterparties and receiving entities, including checks against ASIC banning and disqualification records.
• Firms should consider reviewing transaction-monitoring and escalation controls for investor funds moving to offshore entities or unrelated investment vehicles, with particular attention to circumstances that could raise proceeds-of-crime or fraud concerns.
• Distributors and professional intermediaries may wish to retain evidence of licence verification, product governance reviews, investor disclosures and the basis for any representations made to prospective investors.
• Firms should consider treating the charges as allegations not yet determined by a court and separating the criminal proceeding from ASIC’s earlier administrative banning action when assessing legal, conduct and reputational risk.

What changed

No new licensing rule or general obligation was introduced. The publication announces enforcement proceedings: one charge under section 911A(1) of the Corporations Act 2001 (Cth) for carrying on a financial services business without an AFS licence, and one charge under section 400.3(1) of the Criminal Code (Cth) for dealing with proceeds of crime worth $1 million or more. The matter is being prosecuted by the Commonwealth Director of Public Prosecutions following ASIC’s referral of a criminal brief.

Key dates

2022-05-12

The CFTC filed its complaint against Alexandre and EminiFX, alleging fraudulent solicitation, misappropriation, and operation of an unregistered commodity pool.

2026-07-01

As of July 2026, the court-appointed receiver had returned more than $98 million to over 28,000 investors.

2026-10-19

The CFTC announced that the Southern District of New York had entered orders granting summary judgment, injunctive relief, and a civil monetary penalty against Alexandre and EminiFX.

Suggested considerations

• Compliance teams may wish to inventory products, investment clubs, managed accounts, and digital-asset offerings that pool customer contributions and obtain exposure to forex, futures, options, or other commodity interests.
• Firms should consider assessing whether their activities constitute operating a commodity pool or acting as a commodity pool operator or associated person under the Commodity Exchange Act and CFTC regulations, including whether registration or an available exemption is required.
• Firms should consider validating marketing claims about returns, automated trading, proprietary technology, trading results, and risk, with particular scrutiny of unusually high or consistent returns such as weekly performance representations.
• Compliance teams may wish to test segregation, custody, reconciliation, withdrawal, and use-of-funds controls to detect commingling, personal use of customer assets, payments to earlier investors, and unexplained transfers.
• Firms should consider maintaining evidence supporting reported performance, trading activity, investor statements, and asset ownership so that customer communications can be reconciled to underlying records.
• Digital-asset businesses may wish to review whether crypto terminology or a technology-focused structure obscures activities that remain subject to commodities, anti-fraud, registration, or customer-protection requirements.
• Firms should consider escalating suspected misappropriation, fabricated performance, or unregistered commodity-pool activity through applicable internal investigation, suspicious-activity, and regulatory-reporting processes.

What changed

This is a final enforcement outcome rather than a new rule or generally applicable regulatory amendment. The Southern District of New York entered summary judgment and injunctive relief against Alexandre and EminiFX, finding that the defendants made fraudulent representations, misappropriated investor funds, and operated as an unregistered commodity pool operator, with Alexandre acting in an unregistered associated-person capacity. The judgment imposes $228,576,962 of restitution, $15,049,500 of disgorgement subject to offset by restitution payments, and a $45,148,500 civil monetary penalty.

Key dates

2026-10-14

The CFPB announced the debanking investigation and enforcement initiative; the OCC released its report on the nine largest national banks on the same date.

Suggested considerations

• Compliance teams may wish to inventory account closures, service restrictions, onboarding denials, credit denials, and material service-friction decisions since 2020, with particular attention to political or religious affiliations and lawful activities in firearms, oil and gas, coal, tobacco, digital assets, and other sectors identified by the OCC.
• Firms should consider testing whether customer-facing reasons for adverse decisions accurately and specifically reflect the documented internal rationale, including compliance with ECOA and Regulation B adverse-action notice requirements and applicable FCRA adverse-action notice requirements.
• Institutions may wish to review reputation-risk policies, sector restrictions, escalation criteria, committee materials, employee guidance, and risk taxonomies to confirm that decisions are based on objective, individualized, documented, and legally supportable risk considerations rather than generalized political, social, or reputational preferences.
• Compliance teams should consider preserving relevant complaints, account-review records, escalation communications, decision logs, adverse-action notices, and policy versions in anticipation of CFPB information requests or supervisory examination.
• Banks and covered nonbanks may wish to compare complaint-portal submissions and internal complaint data against account-closure and service-denial populations to identify unexplained patterns, inconsistent reasons, or failures to provide required notices.
• Firms should consider assessing whether deposit-account and payment-service decisions create potential UDAAP exposure even where ECOA or FCRA does not directly apply, while continuing to apply legitimate safety, soundness, sanctions, fraud, AML, credit, and operational-risk controls.
• Senior compliance and legal personnel may wish to establish governance for politically sensitive or sector-based account decisions so that risk-based controls are not removed indiscriminately and exceptions are documented, consistently applied, and subject to appropriate review.

What changed

The CFPB did not issue a new regulation or impose a new compliance deadline. It announced a supervisory and enforcement initiative implementing Executive Order 14331 and responding to the OCC's report covering conduct identified between 2020 and September 2025. The CFPB stated that it will investigate potential violations of the Equal Credit Opportunity Act, including Regulation B adverse-action requirements, the Fair Credit Reporting Act adverse-action requirements, and the prohibition on unfair, deceptive, or abusive acts or practices under the Consumer Financial Protection Act.

Key dates

2024-12-01

The OCC issued the December 2024 cease-and-desist order requiring Bank of America to address deficient BSA/AML controls; the publication does not specify the precise day of issuance.

2026-10-13

The OCC announced the $750 million civil money penalty and coordinated action with FinCEN.

Suggested considerations

• Compliance teams may wish to perform a documented gap assessment against 12 CFR 21.21 and 12 CFR 21.11, including transaction monitoring, customer and activity risk coverage, escalation procedures, SAR timeliness and accuracy, and recordkeeping.
• Banks should consider testing whether potentially suspicious activity is consistently escalated to appropriately skilled investigators and whether alert disposition processes can demonstrate timely decisions on SAR filing.
• BSA officers and relevant personnel should consider competency-based training covering suspicious-activity identification, investigation, SAR preparation, trade-based money laundering indicators, and escalation responsibilities, with evidence of completion and effectiveness testing.
• Internal audit and independent testing functions may wish to assess whether their scope, expertise, sampling, issue validation, and reporting are capable of detecting systemic BSA/AML weaknesses rather than merely confirming policy existence.
• Management and boards of directors should consider reviewing BSA/AML remediation governance, resourcing, milestones, risk acceptance, issue escalation, and the treatment of repeated or overdue corrective actions.
• Banks with material trade finance, correspondent banking, card, payments, or cross-border activity should consider targeted testing for trade-based money laundering typologies and transaction-monitoring coverage gaps.
• Institutions operating under a consent order or cease-and-desist order should consider independently validating that remediation is complete and effective, rather than relying solely on management representations or closure of project milestones.
• Compliance teams may wish to compare their control framework with the broader market reading of the action: industry reporting characterized the case as a record penalty driven by systemic and longstanding failures, while professional commentary on the evolving BSA/AML framework emphasizes the distinction between establishing an effective program and maintaining it in operation.

What changed

The publication is an enforcement action, not a new generally applicable rule or safe harbor. It establishes a major OCC enforcement precedent that persistent failures to implement an effective BSA/AML program after a formal supervisory order can result in exceptionally large penalties, including where deficiencies affect transaction monitoring, SAR escalation and filing, personnel competence, training, and audit effectiveness.

Key dates

2026-10-13

The FCA and NCA arrested three suspects, searched five residential premises in London and Manchester, and seized more than 30 mobile phones, laptops and tablets in an ongoing investigation.

Suggested considerations

• Compliance teams may wish to review whether market-abuse surveillance covers relevant instruments, trading venues, employee dealing, client orders, communications and potential information-sharing networks, with risk-based scenarios for insider dealing and manipulation.
• Firms should consider testing escalation procedures for suspected inside information, including preservation of communications and devices, prompt investigation, documented decision-making and submission of suspicious transaction and order reports where required.
• Firms subject to UK anti-money-laundering requirements may wish to assess whether insider-dealing alerts are linked to customer due diligence, transaction monitoring, suspicious activity reporting and source-of-funds or source-of-wealth reviews.
• Senior management and control functions may wish to confirm that restricted lists, wall-crossing procedures, information barriers, personal-account dealing controls, conflicts controls and staff training remain appropriate for organised or externally coordinated threats.
• Firms may wish to ensure that surveillance records, alert rationales, investigation files and relevant electronic communications can be retrieved promptly if the FCA requests information or conducts an enforcement investigation.
• Relevant firms should consider reminding employees and connected persons that disclosing or using inside information, recommending transactions, or encouraging others to trade can create criminal and regulatory exposure; any communication should avoid implying that the arrested individuals have been charged or found guilty.

What changed

No new obligation, rule, threshold or compliance deadline was introduced. The publication announces an ongoing criminal investigation involving arrests, searches and evidence seizures, and confirms that the FCA is using its market-abuse and financial-crime enforcement powers jointly with the NCA. The FCA reported four insider-dealing convictions in 2025/26, including two cases producing combined prison sentences of 11 years, and fines totalling £1.77 million imposed on 12 people for insider dealing, market manipulation and misleading statements.

Key dates

2026-10-13

The SFC directed SEHK to suspend dealings in Baicha shares from 9:00 am under section 8(1) of the Securities and Futures (Stock Market Listing) Rules; the SFC also announced the restriction notices and continuing investigations.

2026-09-10

The SFC directed SEHK to suspend dealings in Cloudbreak Pharma Inc. shares from 9:00 am under section 8(1) of the Securities and Futures (Stock Market Listing) Rules.

2025-04-01

Dealings in Tianju Dihe shares were suspended and remained suspended as of the SFC publication.

Suggested considerations

• Compliance teams may wish to identify any client accounts, beneficial owners, introducers, nominees or related entities connected to the Nine Entities or Three Entities and ensure that no restricted assets are dealt with or processed without prior written SFC consent.
• Affected brokers should consider implementing account-level restrictions covering trading, transfers, withdrawals, pledges, corporate actions and indirect instructions, while preserving records showing how restrictions and escalation requirements were applied.
• IPO intermediaries may wish to reperform look-through due diligence on placees and their ultimate beneficial owners, including common addresses, directors, funding sources, financing providers, nominee arrangements, subscription concentrations and links across multiple IPOs.
• Sponsors, underwriters and placing agents should consider reviewing whether subscription funding, post-listing financing, purported financial-product investments or issuer-to-placee arrangements could create undisclosed circularity or an artificial appearance of demand.
• Firms may wish to enhance surveillance for coordinated IPO applications, unusually concentrated allocations, rapid post-listing disposals, cross-account transfers, common funding sources and flows between issuers, major placees and connected parties.
• Firms with exposure to Baicha, Cloudbreak or Tianju Dihe may wish to preserve relevant onboarding, order, allocation, communications, funding, transaction-monitoring and client-instruction records and assess whether any regulatory notification or cooperation obligation is engaged.
• Boards and senior management of IPO-related businesses may wish to assess whether existing governance and escalation arrangements adequately cover suspected market manipulation, false-market risks and conflicts involving licensed representatives or connected companies.

What changed

This is an enforcement action rather than a new generally applicable rule. Under section 8(1) of the Securities and Futures (Stock Market Listing) Rules, the SFC directed SEHK to suspend Baicha dealings while its investigation continues. The SFC imposed asset-preservation restrictions on six brokers in relation to accounts associated with Sun Ran and eight related companies, and on 29 brokers in relation to accounts associated with Liu Haoran and two related entities.

Key dates

2021-04-01

BaFin issued an earlier order requiring Deutsche Bank AG to remedy shortcomings in transaction monitoring; the publication gives April 2021 but not an exact day.

2023-11-01

BaFin issued a further order requiring Deutsche Bank AG to remedy transaction-monitoring shortcomings; the publication gives November 2023 but not an exact day.

2026-09-15

BaFin issued the order setting revised deadlines for Deutsche Bank AG’s remediation of transaction-monitoring data-processing deficiencies.

2026-10-06

The BaFin order became final and binding.

2026-10-09

BaFin published the enforcement update.

Suggested considerations

• Deutsche Bank compliance and programme-governance teams should obtain the operative BaFin order and map each revised deadline to the affected transaction-monitoring component, remediation milestone, accountable owner, testing evidence, and supervisory reporting obligation.
• The bank should consider validating that the system reorganisation has not reduced coverage of payment flows, customer and relationship risk indicators, alert generation, case-management records, or escalation and reporting processes during migration.
• Compliance teams should consider documenting how changed technical requirements were translated into revised data models, monitoring scenarios, thresholds, tuning decisions, controls, and model or rule validation outcomes.
• German credit institutions should consider benchmarking their transaction-monitoring governance, data lineage, system change controls, periodic effectiveness testing, and continuous-update processes against the requirements described in sections 25h KWG and 6(2) and 10(1) GwG.
• Firms should consider retaining evidence that suspicious-activity alerts are investigated promptly and that relevant transactions are reported to the FIU where required, including evidence of controls operating during system upgrades or parallel-running arrangements.
• Boards, supervisory boards, and senior managers responsible for AML oversight should consider reviewing whether remediation reporting clearly distinguishes completed corrective actions, residual deficiencies, dependencies, deadline changes, and risks requiring escalation.

What changed

The 2026-09-15 order revises deadlines contained in BaFin’s earlier 2021 and 2023 orders because Deutsche Bank is reorganising its transaction-monitoring system in response to changed technical requirements. The publication does not disclose the revised individual deadlines, identify each remaining deficiency, or impose a new obligation applicable to all institutions.

Key dates

2026-10-08

Federal Reserve and OCC announced coordinated enforcement actions; the OCC imposed a $350 million civil money penalty on American Express National Bank and issued a cease-and-desist order. The Federal Reserve action applied to American Express Company and American Express Travel Related Services Company, Inc.

2027-01-06 Deadline

Approximate deadline for American Express National Bank to submit the OCC-required written Action Plan within 90 days of the October 8, 2026 order, subject to the order's day-counting conventions.

Suggested considerations

• Compliance teams may wish to reassess whether the institution's BSA/AML risk assessment adequately covers its largest and most economically significant products, customer segments, transaction channels, and trade-related activity.
• Firms should consider testing whether customer identification, customer due diligence, beneficial-ownership information, and transaction-monitoring scenarios are appropriately calibrated to credit-card, charge-card, merchant, cross-border, and trade-based money-laundering risks.
• Management may wish to inventory staffing, subject-matter expertise, escalation capacity, data quality, model and rules governance, internal controls, independent testing, and BSA/AML training for employees and directors against the deficiencies identified in the coordinated orders.
• Compliance teams may wish to conduct a lookback of previously generated alerts and transactions to assess whether suspicious activity was timely investigated, escalated, documented, and reported through SARs, including whether systemic monitoring gaps affected historical activity.
• Boards and senior management should consider obtaining documented evidence that enterprise AML oversight is operating effectively at subsidiaries and that parent-level governance does not rely solely on narrow subsidiary or product risk assessments.
• Affected American Express entities should track the 90-day Action Plan submission requirement and prepare supporting remediation evidence, governance reporting, milestone tracking, and supervisory communications.
• Other regulated firms should consider treating the action as a supervisory signal that risk assessments, transaction monitoring, and SAR controls must be aligned to actual business volume and risk rather than to the products that are easiest to administer.

What changed

This is an enforcement action rather than a generally applicable new rule, but it establishes concrete remediation expectations for a large, complex card issuer. The coordinated OCC order requires American Express National Bank to submit, within 90 days of the October 8, 2026 order, an acceptable written Action Plan addressing all BSA/AML deficiencies and incorporating the order's substantive requirements; the OCC must provide prior written supervisory non-objection.

Key dates

2026-10-08

The OCC announced the cease-and-desist order and $350 million civil money penalty against American Express National Bank; the Federal Reserve announced a coordinated action against American Express Company and American Express Travel Related Services Company.

Suggested considerations

• Compliance teams may wish to reassess whether the BSA/AML risk assessment accurately reflects the institution's largest and most complex products, customer segments, payment flows, geographies, channels, and transaction types, rather than relying primarily on deposit-account risk.
• Firms should consider testing whether customer identification, customer due diligence, beneficial-ownership information, and account-risk-rating processes provide sufficiently complete and reliable data for transaction monitoring and suspicious-activity reporting.
• Banks may wish to conduct a targeted lookback for trade-based money-laundering indicators in card, merchant, payment, cross-border, and related repayment activity, including activity involving insiders or connected accounts, and document escalation and reporting decisions.
• Compliance teams should consider validating that monitoring scenarios, alert thresholds, investigative workflows, case-management controls, quality assurance, and SAR filing processes can identify and report suspicious activity within applicable regulatory timeframes.
• Boards and senior management may wish to review whether BSA/AML staffing levels, expertise, reporting lines, technology, data governance, and independent-testing coverage are proportionate to the institution's size, complexity, and risk profile.
• Firms should consider strengthening role-based BSA/AML training for employees, directors, and senior management, with evidence of completion, competency, and periodic refreshers.
• Internal audit or another suitably independent function may wish to perform end-to-end testing of risk assessment, customer due diligence, monitoring, investigation, SAR decisioning, and governance controls, with tracked remediation and board-level reporting.
• U.S. banking organizations may wish to compare their programs against the OCC's findings and the market commentary emphasizing that the principal lesson is product-risk misalignment and the need for enterprise-wide controls, not merely remediation of isolated monitoring alerts.

What changed

This is an enforcement action and supervisory precedent, not a new generally applicable rule. The OCC required American Express National Bank to remediate a BSA/AML program that was not reasonably designed to assure and monitor compliance with the BSA and its implementing regulations. The findings specifically reinforce expectations that risk assessments cover the institution's actual product mix, including credit and charge cards; customer identification and customer due-diligence procedures support effective monitoring; transaction-monitoring and suspicious-activity reporting processes...

Key dates

2026-10-08

FINMA published the final partial revision of Circular 2016/7.

2026-11-01 Deadline

The revised Circular 2016/7 enters into force and the new supervisory expectations for digital onboarding apply.

2027-11-01 Deadline

Market commentary reports a transitional deadline for firms using qualified electronic signatures to add liveness detection and residence verification.

Suggested considerations

• Compliance teams should map each digital onboarding journey to the revised Circular 2016/7 method requirements, distinguishing video identification, online identification, Swiss e-ID and qualified electronic-signature workflows.
• Firms should assess whether their liveness-detection controls reliably establish that the applicant is a physically present living person and can resist photographs, replayed video, deepfakes and other AI-enabled manipulation.
• Firms should review identity-document validation rules and testing so that approved QR-code documents, including the Swiss driving licence, are handled on an equivalent basis to documents with an MRZ where the circular permits this.
• Firms should validate digital residence-verification processes, including whether the process reliably links the contracting party and the relevant device or infrastructure to the declared place of residence.
• Firms planning to use the Swiss e-ID should confirm technical readiness, evidence retention and treatment of the e-ID's non-copyable, non-archivable characteristics, while avoiding use of the e-ID for workflows limited to video identification.
• Firms should update AML, fraud-risk and onboarding policies, vendor requirements, testing scripts, staff procedures and customer disclosures before the effective date.
• Compliance teams may wish to reassess whether supplementary controls are warranted for higher-risk channels, such as device intelligence, fraud databases, transfer-account verification, duplicate-account detection or enhanced review, because FINMA's circular does not eliminate risk-based control expectations.
• Firms using qualified electronic signatures should confirm any transitional implementation requirements identified in the final circular and related commentary, including the reported 1 November 2027 date for adding liveness and residence verification to that route.

What changed

The Swiss e-ID may be used as an identification method when onboarding clients through digital channels under the Anti-Money Laundering Act, although market commentary indicates that it is available for online identification rather than video identification. Official identification documents bearing a QR code are treated as equivalent to documents containing a machine-readable zone, expanding the acceptable document formats for digital onboarding.

Key dates

2026-11-30 Deadline

Consultation period for ADGM FSRA Consultation Paper No. 5 of 2026 closes; comments may be submitted to [email protected].

Suggested considerations

• Compliance teams may wish to review the proposed Guidance and submit written comments to [email protected] by 2026-11-30, particularly on operational feasibility, proportionality and the treatment of permissionless protocols.
• Firms should consider inventorying current and planned DeFi activity, including protocol use, liquidity provision, staking, lending, borrowing, decentralised exchange activity, smart-contract interaction and client-facing exposure.
• Firms should consider mapping each DeFi activity to existing ADGM permissions and identifying activities that may require a variation of permission, additional controls or discontinuation.
• Risk and compliance functions may wish to assess whether existing governance arrangements clearly assign senior accountability for DeFi, approve protocols and counterparties, set exposure limits and address conflicts of interest.
• Firms should consider enhancing due diligence for protocol code, governance structures, upgrade and administrative privileges, oracle dependencies, bridge and composability risks, concentration, liquidity, sanctions exposure and the availability of legal recourse.
• AML and financial-crime teams may wish to assess transaction-monitoring, wallet-screening, sanctions-screening, blockchain analytics, travel-rule and suspicious-activity escalation controls for DeFi-related activity, taking account of limited visibility into beneficial ownership and counterparties.
• Operations and technology teams should consider whether incident-management procedures cover smart-contract exploits, oracle failures, governance attacks, de-pegging, bridge compromise, protocol insolvency, loss of access and material service disruption.
• Client-asset teams should review segregation, custody, ownership, valuation, reconciliation and disclosure arrangements where client assets interact with DeFi protocols or are exposed to protocol failure.

What changed

The proposed Guidance sets supervisory expectations for identifying, assessing, monitoring and managing risks arising from engagement with DeFi protocols and venues. It covers governance and accountability, risk assessments, due diligence, exposure and control measures, ongoing monitoring, financial-crime controls, incident escalation, recordkeeping, auditability, competence and client-asset safeguards. The proposal is guidance under consultation and does not itself introduce binding new rules at this stage.

Key dates

2026-02-09

AMLA opened the public consultation on the draft RTS concerning business relationships, occasional and linked transactions, lower thresholds, and customer due diligence.

2026-04-16

AMLA opened the public consultation on the draft RTS concerning group-wide requirements and additional measures for subsidiaries and branches in third countries.

2026-05-08

Public consultation closed for the business-relationship, transaction and customer-due-diligence draft RTS.

2026-06-15

Public consultation closed for the group-wide arrangements and third-country legal-impediment draft RTS.

2026-10-01

AMLA announced that it had finalised the three draft RTS and submitted them to the European Commission for formal adoption.

2026-10-07

CSSF published its communiqué drawing Luxembourg professionals’ attention to the draft RTS and recommending preparatory gap analysis and control work.

Suggested considerations

• Compliance teams may wish to complete a gap analysis against the AMLA final reports, particularly for customer and beneficial-owner information, verification sources, electronic identification, non-face-to-face onboarding and PEP screening.
• Firms should consider mapping current customer journeys and transaction-monitoring logic to the proposed distinction between business relationships, occasional transactions and linked transactions.
• Firms may wish to identify products, sectors and transaction types that could be affected by lower CDD thresholds for higher-risk activities, while avoiding reliance on unfinalised monetary thresholds.
• Financial groups should consider reviewing group-wide AML/CFT governance, risk assessments, policies, internal controls, training and secure information-sharing arrangements, including structures involving common ownership, management, compliance control, networks or partnerships.
• Groups with branches or subsidiaries in third countries should consider inventorying legal impediments to applying EU AMLR and group policies and preparing escalation, risk-mitigation and supervisory-response procedures.
• IT and operations teams may wish to assess changes needed for customer-data fields, linked-transaction detection, identity-verification evidence, electronic identification and intra-group information exchange.
• Firms should monitor the European Commission’s adoption process and the Official Journal publication because the final text, effective date and any amendments remain unknown; preparatory work should be calibrated to the proposed six-month transition period rather than treated as a current binding deadline.

What changed

The draft RTS under Article 19(9) of Regulation (EU) 2024/1624 would establish criteria for distinguishing business relationships, occasional transactions and linked transactions, and would identify high-risk obliged entities, sectors or transactions for which lower CDD thresholds should apply. The draft RTS under Article 28(1) would specify information and verification requirements for standard, simplified and enhanced CDD, including reliable and independent verification sources, electronic identification means, qualified trust services, non-face-to-face verification, and relevant treatment...

Key dates

2026-05-13

MAS published its consultation on proposed TLAC requirements for Singapore DSIBs and draft amendments to the Financial Services and Markets Act 2022.

2026-06-04

The published consultation materials stated the proposed external TLAC level of 14% of risk-weighted assets for local-bank DSIBs; the consultation period ran through June 2026.

2026-09-08

The Financial Services and Markets (Amendment) Bill 2026 was introduced for first reading in Parliament.

2026-10-06

Second reading speech delivered by Alvin Tan on behalf of the Minister-in-charge of MAS.

Suggested considerations

• DSIBs should consider mapping existing capital, subordinated debt, eligible senior unsecured debt and other potentially qualifying resources against the proposed TLAC eligibility criteria, without assuming that consultation proposals are final.
• DSIBs should consider modelling the potential impact of the consulted 14% of risk-weighted assets external-TLAC level, including the proposed exclusion of capital conservation buffer CET1 from double-counting and any applicable leverage or internal-TLAC requirements.
• DSIBs should consider reviewing funding, issuance and investor-distribution strategies because instruments issued to Singapore retail investors may not qualify as TLAC under the consulted framework.
• DSIBs should consider preparing systems and governance for TLAC reporting, public disclosure, data ownership, instrument eligibility attestations and eventual implementation-period tracking.
• All MAS-supervised financial institutions should consider refreshing proliferation-financing risk assessments, customer and transaction-screening controls, escalation procedures and management information so that controls clearly address proliferation-financing risks separately from money laundering and terrorism financing.
• Compliance teams should consider reviewing information-sharing and supervisory-cooperation procedures for requests involving proliferation-financing supervision by MAS, Singapore authorities or foreign counterpart authorities.
• Legal and regulatory teams should monitor Parliament's passage of the Bill, subsidiary legislation, MAS notices or regulations, and the Gazette commencement notification before treating the proposed obligations as legally effective.

What changed

The Bill would insert a new Division 3 in Part 7 of the Financial Services and Markets Act 2022, empowering MAS to require notified Division 6 financial institutions, including Singapore DSIBs, to maintain a minimum level of TLAC. The framework is expected to address the required TLAC level, eligible instruments and other financial resources, public disclosures, reporting and implementation timing.

Key dates

2020-12-23

FinCEN published the NPRM at 85 FR 83840 proposing additional reporting, recordkeeping, and identity-verification requirements for certain transactions involving unhosted or otherwise covered wallets.

2026-10-06

FinCEN withdrew the NPRM and stated that it would take no further action on that rulemaking.

Suggested considerations

• Compliance teams may wish to remove implementation workstreams, testing scenarios, and policy language that were created solely for the withdrawn NPRM's proposed $3,000 recordkeeping or $10,000 reporting thresholds.
• Firms should consider documenting that the NPRM was never effective and that its withdrawal does not eliminate existing obligations under the Bank Secrecy Act or applicable implementing regulations in 31 CFR parts 1010, 1020, and 1022.
• Banks and MSBs may wish to reassess whether current controls for transfers involving unhosted wallets remain risk-based and supported by documented AML risk assessments, rather than treating the withdrawn proposal's thresholds as mandatory rules.
• Crypto businesses should continue reviewing applicable customer-identification, customer-due-diligence, suspicious-activity-reporting, recordkeeping, transaction-monitoring, and OFAC sanctions requirements independently of this withdrawal.
• Regulatory-monitoring teams may wish to track whether FinCEN or Treasury develops a replacement digital-asset framework, particularly in light of the stated policy objective that digital-asset regulation be fit for purpose.

What changed

FinCEN withdrew the NPRM published at 85 FR 83840 and stated that it will take no further action on that rulemaking. The withdrawn proposal would have required banks and money services businesses to file reports when a transaction involving an unhosted or otherwise covered wallet exceeded $10,000, or multiple such transactions exceeded $10,000 in 24 hours. It also would have required records, counterparty information, and customer identity verification for covered transactions exceeding $3,000.

Key dates

2023-10-23

FinCEN published the proposed section 311 finding and special measure concerning international CVC mixing at 88 FR 72701.

2026-10-06

FinCEN's withdrawal of the finding and proposed rulemaking became effective upon Federal Register publication at 91 FR 63513.

Suggested considerations

• Compliance teams should discontinue implementation work that was undertaken solely for the withdrawn section 311 CVC-mixing proposal, including plans for the proposal-specific data fields, reporting workflows, and enhanced customer records.
• Firms should not interpret the withdrawal as authorization to process illicit mixer activity without controls; they should continue applying existing risk-based AML, sanctions, transaction-monitoring, escalation, and suspicious activity reporting procedures.
• Crypto exchanges and other covered institutions should review whether current transaction-monitoring scenarios appropriately identify mixer exposure and other indicators of money laundering or terrorist financing under existing requirements, without treating all privacy-preserving activity as inherently suspicious.
• Firms may wish to document the withdrawal in their regulatory inventory, rulemaking-impact assessments, and model or procedure change logs, while preserving controls that address independently applicable BSA or sanctions requirements.
• Compliance teams should monitor future FinCEN notices, section 311 actions, enforcement activity, and interpretive guidance because FinCEN expressly reserved the possibility of future measures concerning mixers.
• Legal and compliance functions should reassess any customer, product, or transaction restrictions adopted specifically in anticipation of the proposed rule and determine whether they remain justified by the firm's risk assessment, other legal requirements, or contractual obligations.

What changed

FinCEN withdrew the proposed rule published at 88 FR 72701 and the underlying section 311 finding concerning international CVC mixing. The proposed special measure one regime would have required covered financial institutions to report specified information for transactions they knew, suspected, or had reason to suspect involved international CVC mixing, including CVC type and amount, mixer and wallet information, transaction hashes, transaction dates, IP addresses, customer-identifying information, and a narrative description.