Financial Crime Horizon Scanner: Sanctions Shifts, Transparency Rules & AML Priorities

Key highlights include:

UK and EU

• The FCA has intensified its supervisory approach to AML systems and controls, with a sharper focus on proactive oversight and remediation expectations.
• Updated UK sanctions enforcement guidance provides clearer direction on compliance obligations and enforcement risk.
• Recent guidance from the Serious Fraud Office signals that enforcement activity under the failure to prevent fraud offence may soon accelerate.
• The EU has reached a provisional agreement on its long awaited new Directive on combating corruption, marking a major step toward stronger, harmonized EU-wide anti-corruption standards.

Download the UK and EU-wide Horizon Scanner

US

• The Department of Justice has introduced its first-ever Department-wide Corporate Enforcement Policy, establishing a consistent framework for assessing corporate misconduct.
• OFAC has issued sanctions relief for Syria and made further updates to its Venezuela sanctions program.
• A federal court has upheld the constitutionality of the Corporate Transparency Act, and New York State’s beneficial ownership reporting requirements have now taken effect.
• Implementation of the GENIUS Act continues, alongside additional proposals for regulating digital assets.
• FinCEN has released further AML guidance, while Congress considers broader efforts to modernise the Bank Secrecy Act.

Download the US Horizon Scanner