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Following the latest FATF plenary, FinCEN relayed updates to the lists of high-risk and monitored jurisdictions for AML, CFT, and counter-proliferation finance. Institutions must recalibrate customer, correspondent, and transaction risk assessments accordingly.
Required Action
Refresh country risk ratings, EDD triggers, and sanctions/AML screening against updated FATF jurisdiction lists.
As part of the White House Task Force to Eliminate Fraud, Treasury and FinCEN issued an alert asking financial institutions to detect and report fraud affecting federal benefits programs in Minnesota. Firms should operationalize new red flags and reporting expectations.
Required Action
Update fraud typologies, SAR filing procedures, and transaction monitoring rules to reflect FinCEN's Minnesota alert.
The designation extends sanctions pressure to professional service providers enabling Iranian oil revenue flows. Banks must assess exposure to the firm, its principals, and linked vessels, shippers, and insurers.
Required Action
Screen client and counterparty bases for Karnakis and Karnakis and related shadow fleet exposures; file SARs where applicable.
FinCEN's analysis highlights fraud risk in federal benefit disbursement channels. Deposit-taking institutions should refine monitoring for aid-related inflows, mule accounts, and identity theft indicators.
Required Action
Review SAR filings and transaction monitoring rules covering student aid disbursements and synthetic identity typologies.
The Alert expands AML/CFT typologies to religious charity flows exploited by Iran. Institutions should update NPO due diligence, screen for identified networks, and apply the SAR key term when filing.
Required Action
Incorporate the Alert's red flags into TM scenarios and SAR narratives for charity and NPO-related transactions tied to Iran.
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