The Financial Crimes Enforcement Network (FinCEN) issued a communication on November 21, 2025, addressed to U.S. financial institutions, urging them to incorporate the latest Financial Action Task Force (FATF) decisions regarding countries with strategic deficiencies in combating money laundering, terrorist financing, and the proliferation of weapons of mass destruction (ML/TF/PWMD) into their risk assessments.
The FATF maintains two categories of oversight: Jurisdictions under Increased Monitoring and High-Risk Jurisdictions subject to a Call for Action. In its October 24, 2025, update, the organization removed Burkina Faso, Mozambique, Nigeria, and South Africa from the Increased Monitoring list, recognizing significant improvements in their compliance frameworks.
The High-Risk Jurisdictions that remain subject to a Call for Action are Iran, the Democratic People’s Republic of Korea (North Korea), and Myanmar. Effective countermeasures are required for Iran and North Korea, while Myanmar remains subject to enhanced due diligence, without mandatory countermeasures.
FinCEN reminded U.S. financial institutions of the need to update policies, procedures, and internal controls, particularly concerning correspondent accounts of foreign institutions. The agency also emphasized that U.S. prohibitions on transactions and financial relationships with Iran and North Korea remain in full effect.
Finally, FinCEN highlighted that any transaction involving funds of potentially illicit origin or indications of money laundering, terrorist financing, or other regulatory violations must be reported through a Suspicious Activity Report (SAR) in accordance with applicable regulations.
