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Our latest thinking on financial crime compliance, regulatory change, technology, and the forces reshaping global risk management.
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Compliance Without Conscience: Why Algorithms Cannot Replace Ethical Judgement
When the Financial Action Task Force (FATF) published its updated Guidance on the Risk-Based Approach in 2023, it acknowledged for the first time the growing role of artificial intelligence (AI) and machine learning in anti-money laundering and counter-terrorist financing (AML/CTF) frameworks. The language was cautiously optimistic: these technologies, the FATF suggested, could strengthen the identification of suspicious activity, reduce false positives and allow compliance t

Elizabeth Travis
16 minutes ago7 min read


AML Fatigue: Has Compliance Lost Sight of Criminal Purpose?
When the Financial Action Task Force (FATF) published its original forty Recommendations in 1990, the objective was unambiguous: to deny criminals the ability to launder the proceeds of drug trafficking through the international financial system. Over the three decades that followed, this mandate expanded to encompass terrorist financing, proliferation finance, corruption, tax evasion and a widening catalogue of predicate offences. Successive rounds of mutual evaluations, new

Elizabeth Travis
Apr 136 min read


EBA Moves to Streamline SEPA Reporting Across the EU
The European Banking Authority has issued a new Decision designed to simplify how national authorities report SEPA data to EU institutions, marking a practical but important step in the implementation of the bloc’s instant payments regime. Published on 10 April 2026, the measure creates a single reporting channel from National Competent Authorities, or NCAs, to the EBA, which will then transmit the information to the European Commission. The move is intended to reduce duplica

OpusDatum
Apr 103 min read


OTSI Expands Export Licensing Powers for Sanctioned Goods
The Office of Trade Sanctions Implementation (OTSI) has announced a significant expansion of its licensing remit, marking a structural shift in the UK’s export sanctions framework. From 27 April 2026, OTSI will assume responsibility for licensing sanctioned goods and associated ancillary services exported to sanctioned destinations, building on its existing role overseeing standalone services such as professional and business services. This change clarifies the division of re

OpusDatum
Apr 92 min read


US Treasury Moves to Police Stablecoin Illicit Finance Risk
The US Treasury has moved quickly to put the GENIUS Act into operation, with FinCEN and OFAC jointly proposing a rule that would bring permitted payment stablecoin issuers into a formal anti-money laundering and sanctions compliance framework. The proposal is designed to support the growth of payment stablecoins while making clear that firms operating in this market will be expected to manage illicit finance risk to the same standard as other regulated financial institutions.

OpusDatum
Apr 82 min read


DOJ Targets Black-Market Peso Exchange Network in Texas Cartel Money Laundering Case
The US Department of Justice (DOJ) has secured a guilty plea from a Mexican national tied to a multimillion-dollar black-market peso exchange scheme, marking another significant enforcement action against cartel financing networks. Announced on 8 April 2026, the case centres on Gabriel Arturo Castillo, 52, of Monterrey, Nuevo León, who admitted his role in a two-year trade-based money laundering conspiracy designed to move drug proceeds from the US to Mexico without physicall

OpusDatum
Apr 83 min read


DOJ Disrupts Russian GRU Cybercrime Network Exploiting Router Vulnerabilities
The US Department of Justice (DOJ) has intensified its response to state-backed cybercrime with a court-authorised operation targeting a DNS hijacking network linked to Russia’s GRU. Announced on 7 April 2026, the action focused on dismantling infrastructure used by APT28, a well-known cyber espionage group, which had compromised thousands of routers to conduct large-scale credential harvesting and surveillance activity. The operation highlights a critical evolution in cyberc

OpusDatum
Apr 72 min read


FinCEN Moves to Overhaul AML Rules
FinCEN has proposed a sweeping rewrite of anti-money laundering and countering the financing of terrorism programme requirements that could materially reshape how financial institutions design, evidence and defend their compliance frameworks. Announced on 7 April 2026, the proposal is positioned as a fundamental reform of Bank Secrecy Act AML/CFT expectations, with Treasury arguing that firms should be judged less on process-heavy documentation and more on whether their contr

OpusDatum
Apr 74 min read


Sanctioning Themselves: How the Iran War Broke Western Sanctions Policy
In February 2022, the US, the UK and the European Union imposed the most comprehensive sanctions regime in modern history on the Russian Federation. The ambition was sweeping: sever the financial arteries funding military aggression, freeze the assets of those who enabled it and impose a cost so severe that the war economy could not sustain itself. Hundreds of individuals were designated. Russian banks were cut from SWIFT. Sectoral restrictions targeted energy, technology and

Elizabeth Travis
Apr 68 min read


Insider Trading Case Highlights Risks of Informal Information Sharing
An Arkansas man’s guilty plea to insider trading reinforces the U.S. Department of Justice’s (DOJ) continued focus on market abuse arising from informal personal relationships and misuse of confidential corporate information. The case illustrates how non-traditional information channels, including friendships with senior executives, remain a key enforcement priority for regulators and prosecutors. Douglas Dalton admitted securities fraud after trading on material nonpublic in

OpusDatum
Mar 312 min read


Who Pays for Compliance? The Unintended Consequences of Extraterritorial AML Law
In June 2000, the Financial Action Task Force (FATF) published its first list of Non-Cooperative Countries or Territories, identifying fifteen jurisdictions deemed deficient in their anti-money laundering (AML) controls. The initiative was presented as a necessary corrective: a mechanism for bringing the global financial system into alignment with a common set of standards. Twenty-six years on, the FATF’s mutual evaluation process has matured into one of the most powerful ins

Elizabeth Travis
Mar 308 min read


DOJ Clarifies How Companies Should Report National Security Law Breaches
The US Department of Justice has moved to remove any ambiguity around where companies should report potential criminal breaches of national security laws, making clear that voluntary self-disclosures should be sent directly to the National Security Division. The update, published on 30 March 2026, links national security enforcement more tightly to the Department-wide Corporate Enforcement Policy introduced earlier this month and gives businesses a clearer route to seek coope

OpusDatum
Mar 302 min read
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