AML Compliance

Banking Regulators Propose AML/CFT Program Requirements

The OCC, FDIC, and NCUA jointly proposed a rule requiring banks to establish and maintain effective AML/CFT programs reasonably designed to identify, assess, and mitigate illicit finance risks. The proposed amendments align with FinCEN's concurrent proposals to implement provisions of the Anti-Money Laundering Act of 2020 and the Bank Secrecy Act. The rulemaking also seeks to modernize federal supervision of AML/CFT programs by enhancing FinCEN's role in supervision and enforcement.

FDIC/OCC Final Rule Codifies Prohibition of Reputation Risk from Bank Supervision

The OCC and FDIC have finalized a rule codifying the elimination of reputation risk from their supervisory programs. The rule prohibits the agencies from criticizing or taking adverse action against institutions based on reputation risk, and bars agencies from requiring banks to close accounts or terminate services based on political, social, cultural, or religious views or constitutionally protected speech. The rule takes effect June 9, 2026.

EU Expands Terrorist Sanctions Listing Criteria, Adds Travel Ban

The Council of the EU adopted Decision (CFSP) 2026/455 and Regulation (EU) 2026/456, expanding the scope of EU restrictive measures to combat terrorism. The amendments add travel bans for listed individuals and broaden listing criteria to include leading members of listed groups and entities involved in financing, training, or recruitment of terrorists. The periodic review concluded with all existing listings maintained unchanged.

EU Sanctions Eight Russians for Human Rights Violations and Repression

The Council of the EU imposed restrictive measures on eight individuals responsible for serious human rights violations, repression of civil society, and undermining democracy in Russia. The designations include judges, prosecutors, and penal colony administrators involved in politically motivated trials and detention of activists including Aleksei Gorinov and journalist Maria Ponomarenko. Listed individuals are subject to asset freezes and travel bans preventing entry or transit through EU territory.

EU Designates Islamic Revolutionary Guard Corps as Terrorist Organisation

The Council of the EU formally designated the Islamic Revolutionary Guard Corps (IRGC) of Iran on its terrorist list under Common Position 2001/931/CFSP. The designation triggers asset freezes and prohibits EU operators from making funds or economic resources available to the group. This brings the total to 13 persons and 23 groups and entities subject to EU counter-terrorism restrictive measures.

EU Extends Hamas and PIJ Sanctions Until January 20, 2027

The Council of the EU extended restrictive measures against Hamas and the Palestinian Islamic Jihad until January 20, 2027. The sanctions include asset freezes and prohibitions on making funds available to 11 individuals and 3 entities. One deceased individual was removed from the list following an annual review.

EU Renews Guatemala Sanctions Until 13 January 2027

The Council of the EU renewed targeted restrictive measures against individuals and entities undermining democracy and rule of law in Guatemala until 13 January 2027. The sanctions currently apply to 8 individuals and 1 entity, imposing travel bans, asset freezes, and prohibitions on making funds available to listed parties. These measures support Guatemala's democratic transition following the 2023 general election.

EU Sanctions Syria: 32 Persons and Entity Listed Under Restrictive Measures

The Council of the European Union published Notice ST/7475/2026/INIT in the Official Journal C/2026/2138 of 10 April 2026, notifying 32 persons and entities of their designation under EU restrictive measures in view of the situation in Syria. The designations operate under Council Decision 2013/255/CFSP and Council Regulation (EU) No 36/2012, which impose asset freezes and transaction prohibitions on listed parties.

Hamidah Nabagala Added to ISIL/Al-Qaida Sanctions List

The European Commission published a notice in the Official Journal adding Hamidah Nabagala to the ISIL/Al-Qaida sanctions list under Council Regulation (EC) No 881/2002. The designation was made via Commission Implementing Regulation (EU) 2026/830. Financial institutions and entities holding assets belonging to the designated person must freeze those assets and report to the competent authorities.

356th Amendment to ISIL Al-Qaida Sanctions List

The European Commission published Implementing Regulation (EU) 2026/830, the 356th amendment to Council Regulation (EC) No 881/2002, updating the EU consolidated list of persons and entities subject to restrictive measures for association with ISIL (Da'esh) and Al-Qaida organisations. This implementing regulation amends the annex containing the consolidated list of designated persons, entities, and bodies.