Last Week's Major Developments in Sanctions - April 6, 2026, to April 10, 2026

In a major AML-related development, FinCEN issued a proposed rule that would significantly reshape how financial institutions design and operate their AML/CFT programs under the Bank Secrecy Act. The proposal supersedes FinCEN's July 2024 proposed rule, which is being withdrawn. The core shift is from "checkbox compliance" toward demonstrated effectiveness. Under the proposal, examiners would be required to distinguish between program design failures and implementation failures. Importantly, the rule would curtail examiner discretion: auditors and supervisors would not be permitted to substitute their own judgment for a financial institution's risk-based program choices, provided those choices are reasonably designed. The proposal also reinforces the principle that institutions are best placed to assess their own illicit finance risks, and should allocate resources accordingly. The rule would also introduce a notice and consultation framework between federal banking supervisors and FinCEN before significant AML/CFT supervisory actions are taken, affirming FinCEN's role as the lead authority in this space. The proposed rule reflects statutory changes from the Anti-Money Laundering Act of 2020 and is open for comment. (The proposed rule, FinCEN's press release, and the accompanying fact sheet) More on this later!

OFAC issued Russia-related General License 13Q, extending the authorization to engage in certain payments of taxes, fees, or import duties to, and purchases or receipt of permits, licenses, registrations, certifications, or tax refunds from the Russian Central Bank, National Wealth Fund, or Ministry of Finance, that would otherwise be prohibited by Directive 4 of Executive Order 14024 for three more months through July 9, 2026. (Here) Concurrently, OFAC amended two Russia-related Frequently Asked Questions, FAQs 999 and 1118 to reflect the new General License. (Here)
OFAC published the Spanish translation of five Venezuela-related General Licenses and 19 FAQs associated with them. (Here)
In a notable development, OFAC and FinCEN issued a notice of proposed rulemaking (NPRM) jointly to implement the GENIUS Act's directive to subject permitted payment stablecoin issuers to AML requirements and to require them to maintain an effective sanctions compliance program. This is a first time OFAC requires maintaining s sanctions program. (Here) More on this later! If you need help submitting comments on the rule, due on June 9, 2026 at 11:59 PM EDT, send an email to info@sanctionsexpert.com

OFSI extended General License INT/2026/8893924 for the wind down of activities Maritime Mutual Re-Insurance until July 8, 2026. (Here)

Recent Posts