Horizon Scanner – Financial Crime

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Horizon Scanner – Financial Crime

This report summarizes key financial crime related legal and regulatory developments that are expected to impact businesses over the next two years, as well as providing links to key electronic resources.

August 14, 2025

Global
Global
Global
In the latest edition of our Financial Crime Horizon Scanner, we highlight forthcoming updates and developments covering the UK, the EU and the US, explain what they mean for businesses and summarize next steps. 

Key highlights include:
 
UK

  1. The new corporate criminal offence of failing to prevent fraud under ECCTA comes into force on 1 September 2025.
  2. The NCA and FCA published its economic crime priorities in July 2025 and align with the new 2025 National Risk Assessment of money laundering and terrorist financing.
  3. The FCA published its updated guidance on politically exposed persons (PEPs) for anti-money laundering purposes.

US

  1. President Trump signed the GENIUS Act, regulating use of stablecoin for the first time.
  2. The DOJ issued updated enforcement priorities and guidelines to align with President Trump’s agenda.
  3. OFAC issued broad relief on Syrian sanctions and designated certain cartel members as terrorists.
  4. The effective date of a rule requiring investment advisers to implement AML programs under the Bank Secrecy Act was extended to January 2028.
  5. Non-US companies registered to conduct business in the United States must report information about certain beneficial owners to FinCEN.

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