Anti-Money Laundering compliance programs
Anti-money laundering compliance in Trade and Geopolitical Risk is being reshaped by converging pressure from the U.S. Financial Crimes Enforcement Network, the Office of Foreign Assets Control, and the European Banking Authority, each of which has extended AML expectations into trade finance, dual-use goods financing, and correspondent banking relationships tied to sanctioned jurisdictions. FinCEN's 2024 beneficial ownership reporting rule under the Corporate Transparency Act now intersects directly with trade-entity due diligence, forcing compliance teams to reconcile ownership data against restricted-party screening before transactions clear. The gaps are procedural, not theoretical.
Watch
- FinCEN beneficial ownership database access rules: when trade-finance teams can query it
- EBA's revised AML/CFT guidelines on correspondent banking de-risking in high-risk jurisdictions
- OFAC 50 Percent Rule applied to trade counterparties with indirect sanctioned-entity ownership
- Pending FinCEN rulemaking on AML program requirements for investment advisers: spillover to trade funds
- FATF Recommendation 16 wire-transfer obligations as adopted in Asia-Pacific member jurisdictions
Recent material activity in Trade & Geopolitical Risk
Active monitoring in place across Trade & Geopolitical Risk. Material developments related to anti-money laundering compliance programs will appear here as they are published.