On November 21, 2025, the Financial Crimes Enforcement Network (“FinCEN”) informed U.S. financial institutions of new updates to the list of jurisdictions with anti-money laundering, countering the financing of terrorism, and countering the financing of the proliferation of weapons of mass destruction (“AML/CFT/CPF”) deficiencies. The Financial Action Task Force (“FATF”), which sets international standards for AML/CFT/CPF, updated its list of Jurisdictions Under Increased Monitoring (jurisdictions with strategic AML/CFT/CPF deficiencies that are actively working with the FATF to address their deficiencies) to remove Burkina Faso, Mozambique, Nigeria, and South Africa from that list.
FinCEN reported that the FATF made no changes to the list of High-Risk Jurisdictions Subject to a Call for Action (jurisdictions with significant strategic AML/CFT/CPF deficiencies), which still contains Iran, the Democratic People’s Republic of Korea (“DPRK”), and Burma. The FATF continues to call for jurisdictions to apply effective countermeasures on the DPRK and Iran. The FATF also cited additional countermeasures specifically aimed at curtailing AML/CFT/CPF in Iran, including the National Security Presidential Memorandum (NSPM)-2 issued by the President in February 2025 and the imposition of the fifth special measure available under section 311 of the USA PATRIOT Act issued by FinCEN in 2019. FinCEN also noted that Executive Order 13599, which was issued pursuant to the Iranian Transactions and Sanctions Regulations (ITSR) in 2012, broadly prohibits transactions with Iran, its government and Iranian financial institutions and goes beyond the relevant FATF recommendations. While Burma is not subject to countermeasures at this time, the FATF continues to call for jurisdictions to apply enhanced due diligence proportionate to the risks in transactions with Burmese operators.