2024 Trends Report - Institute for Financial Integrity

Report

2024 Trends Report

In 2024, the United States and international partners will continue to focus on global financial integrity, closing regulatory loopholes, and holding evaders of sanctions and trade controls, as well as their facilitators accountable to make sanctions and AML/CFT regimes more effective.

This report explores five major priorities the international community will focus on.

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Understanding the FATF: A Guide for Private Sector Stakeholders Part 2

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The FATF’s mutual evaluation process has been the single greatest catalyst for improvements to the global AML/CFT regime in recent years. It’s critical for financial crime compliance and risk management professionals to understand this process and related standards and listings.

From Alerts to Accountability

April 21, 2026

This article explores the gap between activity and outcomes, where screening programs tend to fall short, and what regulators actually expect.

Data as a Critical Business and Compliance Asset

April 15, 2026

Data is an increasingly critical asset. It plays a key role in due diligence, identifying and responding against illicit finance, and identifying fraud, as well as for commercial decisions and business success. Explore global data protection and retention requirements in this article.

Understanding the FATF: A Guide for Private Sector Stakeholders

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March 2026 Monthly Sanctions and Export Controls Report

April 2, 2026

Explore this month’s Sanctions and Export Controls Update, highlighting IFI’s take on key developments from March 2026.

February 2026 Monthly Sanctions and Export Controls Report

March 3, 2026

Explore this month’s Sanctions and Export Controls Update, highlighting IFI’s take on key developments from February 2026.

Electronic Fund Transfer Consumer Protection

February 5, 2026

The Electronic Fund Transfer Act (EFTA) was established to protect consumers using electronic fund transfers. Explore what is considered in scope and the changes proposed to include crypto.

January 2026 Monthly Sanctions and Export Controls Report

February 3, 2026

There were several major sanctions-related developments in January, most notably the U.S.’s easing of sanctions to facilitate Venezuelan oil sales and the ratcheting up of western sanctions in response to Tehran’s violent crackdown on protestors, among others.

Following the Illicit Funds

January 28, 2026

As crypto grows, so does regulatory oversight. From SARs and CTRs to MSB registration and potential FBAR requirements, crypto businesses are now firmly within the scope of financial regulations.

Blind Spots in the System

January 21, 2026

When transaction monitoring fails, the cost goes far beyond fines. This article explores why many programs still miss critical red flags and how effective training helps teams to strengthen detection, calibration, and oversight where it matters most.

December 2025 Monthly Sanctions and Export Controls Report

January 6, 2026

Explore this month’s Sanctions and Export Controls Update, highlighting IFI’s take on key developments from December 2025.

The Use of Secondary Sanctions

December 16, 2025

Secondary sanctions extend the reach of a country’s regulatory authority to foreign individuals and entities with no direct connection to the sanctioning country.

AML/CFT and Sanctions Enforcement Actions in 2025

December 9, 2025

2025 will go down as a historic year for AML/CFT and sanctions-related enforcement actions in two ways. It’s the first time in over 20 years that no banks have faced major penalties, and state regulators began jointly penalizing institutions.

November 2025 Sanctions and Export Controls Update

December 2, 2025

Explore this month’s Sanctions and Export Controls Update, highlighting IFI’s take on key developments from November 2025.

OFAC’s 50 Percent Rule

November 12, 2025

This article delves into OFAC’s 50 Percent Rule, common pitfalls, and best practices for avoiding costly mistakes.

October 2025 Sanctions and Export Controls Update

November 5, 2025

Explore this month’s Sanctions and Export Controls Update, highlighting IFI’s take on key developments from Ocotober 2025.

Navigating the Convergence of Sanctions Evasion, Export Control Evasion, and Money Laundering

October 22, 2025

Explore the convergence of illicit finance domains through real-life examples including Russia’s procurement of drone components, Iran’s evasion networks, and China’s acquisition of restricted chips.

September 2025 Sanctions and Export Controls Update

October 1, 2025

Explore this month’s Sanctions and Export Controls Update, highlighting IFI’s take on key developments from September 2025.

August 2025 Sanctions and Export Controls Update

September 3, 2025

Explore this month’s Sanctions and Export Controls Update, highlighting IFI’s take on key developments from August 2025.

July 2025 Sanctions and Export Controls Update

August 4, 2025

Explore this month’s Sanctions and Export Controls Update, highlighting IFI’s take on key developments from July 2025.

Out of the Shadows

July 23, 2025

Iran’s shadow banking system has laundered billions of dollars for the regime. In this article, we detail how the system works and how financial institutions can identify red flags associated with Iran’s oil smuggling and concealed payment networks.

Canada’s Strong Borders Act

July 8, 2025

Canada’s Strong Borders Act represents a sweeping overhaul of the country’s AML/CFT regime. The legislation introduces tougher penalties, expanded oversight, and stricter compliance and enforcement expectations.

June 2025 Sanctions & Export Controls Update

July 1, 2025

Explore this month’s Sanctions and Export Controls Update, highlighting IFI’s take on key developments from June 2025.

May 2025 Sanctions & Export Controls Update

June 3, 2025

Explore this month’s Sanctions and Export Controls Update, highlighting IFI’s take on key developments from the U.S., EU and UK in May 2025.

Lessons From Russia & Iran – What EU Sanctions Teach Us About Policy in Action

May 29, 2025

The EU’s Russia and Iran sanctions programs demonstrate using sanctions as strategic tools of influence, while also exposing the challenges in enforcement and importance of global coordination.

Trump’s IEEPA Tariffs – Blurring the Lines Between Trade Sanctions and Traditional Tariffs

May 13, 2025

The Trump administration’s unprecedented use of tariffs as a tool of national security and foreign policy to compel countries to change policies the U.S. opposes has blurred the lines between tariffs and trade sanctions.

Recent IAR Enforcement Actions

May 7, 2025

Recent SEC enforcement actions against IARs highlight critical compliance failures, including unregistered brokerage activities, misleading marketing practices, undisclosed conflicts of interest, and inadequate compliance policies.

April 2025 Sanctions & Export Controls Update

May 5, 2025

Explore this month’s Sanctions and Export Controls Update, highlighting IFI’s take on key developments from the U.S., EU and UK in April 2025.

Sweeping AML Requirements for RIAs and ERAs

May 1, 2025

FINCEN issued a final rule with new AML requirements for investment advisers. With the January 1, 2026 deadline approaching, RIA and ERA firms must begin building and implementing their compliance programs as soon as possible.

Syndicates of Terror

April 4, 2025

Eight Latin American drug cartels were recently designated by the United States as Foreign Terrorist Organizations and Specially Designated Global Terrorists. The U.S. designation enhances compliance risks for financial institutions and other companies transacting in Latin America.

Lifting Sanctions on Syria

March 28, 2025

Human rights activists have been advocating for the lifting of sanctions to help Syria rebuild after nearly 14 years of destruction. What would U.S. sanctions relief for Syria entail? What changes will likely be required?

Advancement in Digital Asset Markets

March 24, 2025

Review policies and regulation on crypto in the U.S., UK, EU, and globally, how this influences adoption, and measures to capitalize on rewards while managing illicit finance risks.

False Flags, Fake Docs, and Fraudulent Routes

March 19, 2025

Russia continues to evade the $60 per-barrel price cap on its seaborne oil shipments. What can financial institutions engaged in documentary trade in the energy sector and other industry stakeholders do to mitigate their risks?

Untangling the Threads of Global Economic Tools

March 13, 2025

Ever wonder how export controls, sanctions, and proliferation finance differ—and why it matters? This article breaks down these essential tools, explains their unique purposes, and highlights how they often overlap in the real world.

Navigating the Convergence of Sanctions & AML Regimes

March 11, 2025

In our recent webinar, the director of compliance and enforcement at OFAC and three financial integrity industry leaders discussed the importance of breaking down silos and shared other advice for AML/CFT and sanctions professionals.

Russia: Slew of Sanctions

March 3, 2025

Explore the highlights from our most recent webinar about Russia sanctions. What happened in 2024, how has the regulatory atmosphere changed, and how will the sanctions environment evolve in 2025?

Interlocking Action

February 27, 2025

Transnational crime requires a coordinated response. Examine the characteristics of transnational crime, breakdowns in internal cooperation within financial institutions that resulted in enforcement action, and the actions Chief Compliance Officers must take to ensure an effective and coordinated response within their institution.

Walking the Sanctions Tightrope

February 18, 2025

In today’s fast-evolving regulatory landscape, sanctions compliance can feel like an uphill battle. This guide explores the key challenges compliance officers face—ranging from multi-jurisdictional rules to cryptocurrency complexities—and offers practical tips to stay ahead.

The New Counter-Illicit Finance Regime

February 13, 2025

The convergence of AML/CFT and sanctions regimes has led to a paradigm shift. These disciplines may now be viewed as overlapping parts of a broader global counter-illicit finance regime.

Examining Evasion

February 10, 2025

Explore three recent examples with Russia, Iran, and North Korea, which represent some of the most common methods illicit actors have embraced to evade sanctions. Understanding them is an important starting point for private sector firms in assessing and responding to their exposure.

Biden Takes Final Shot at Russia’s Energy

January 30, 2025

The Biden administration on January 10, 2025, imposed the most severe sanctions on Russia’s energy sector since the start of Russia’s full-scale invasion of Ukraine. What should financial institutions and other firms know about these new designations, and how can they mitigate their risks?

The Chips Are Down

January 28, 2025

Recent enforcement actions indicate regulators are tightening their focus on the illicit cash that traverses the gaming industry. This article explores why casinos are a convenient money laundering venue and recent enforcement cases that highlight the risks the gaming industry faces globally.

2024’s Top 10 Major Developments

January 17, 2025

Explore the highlights from our recent webinar including an overview of the current illicit finance landscape, major events in 2024 as well as noted possible future developments as the global illicit finance regime grows and evolves.

Syria Sanctions Relief

January 16, 2025

The U.S. Treasury has issued a Syria General License to provide gradual sanctions relief for the Syrian people after the regime of Bashar al-Assad was toppled in December 2024. What does this sanctions relief mean to financial institutions and other firms hoping to transact in the country?

Sanctions in 2024: Global Pressure Points in the UN, U.S., EU, and UK

December 30, 2024

In 2024, the UN, U.S., EU, and UK ramped up sanctions targeting Russia, Iran, and conflict zones, focusing on critical sectors like energy, defense, and technology. In this article, we explore these coordinated efforts aimed at weakening adversarial regimes while navigating complex compliance and humanitarian challenges.

Toward a Financial Integrity Risk Management Program

December 19, 2024

This article explores the commonalities between AML, sanctions compliance, ABC, fraud risk management, and export control compliance programs and recommends that organizations consider using a holistic financial integrity risk management and compliance framework.

Webinar Recap – The Dos, Don’ts & Expert Insights on Beneficial Ownership

December 10, 2024

In our recent webinar, regulatory, investigative, and anticorruption policy experts discussed some of the nuances relating to the U.S. Corporate Transparency Act (CTA) and its Beneficial Ownership reporting requirement. Explore the highlights in this article.

The Sanctions Evasion Threat

November 26, 2024

It’s more important than ever for compliance officers to understand and recognize sanctions evasion typologies. In this article, we explore six of the most common techniques illicit actors use to evade sanctions.

Unverified and Unsure

November 7, 2024

The Commerce Department’s Bureau of Industry and Security maintains and administers several lists that involve goods, software, and technology, governed by the Export Administration Regulations. The Unverified List is just one of these. What is the Unverified List and what due diligence obligations do entities that transact with parties on the Unverified List have?

Onerous Ownership

November 5, 2024

New U.S. beneficial ownership reporting requirements went into effect on January 1, 2024, obliging many small businesses to report to FinCEN identifying information about the individuals who directly or indirectly own or control 25% or more of the company. This article explores what you need to know as well as concerns company owners have expressed about the privacy, security, and regulatory scrutiny that accompanies the new regulations.

Beneficial Ownership: Who Owns What?

October 17, 2024

U.S. efforts to curb illicit finance are in full swing, as the requirement to reveal the beneficial owners of certain entities registered or operating in the United States came into effect this year. In this article, we explore key requirements, benefits, and deadlines as well as address some of the concerns organizations may have about the new regulation.

New BIS Export Compliance Guidance for Financial Institutions

October 15, 2024

The U.S. Bureau of Industry and Security recently published guidance for financial institutions on complying with strategic trade controls and discussing best practices, red flags, screening, and reporting. The latest guidance provides greater detail on due diligence and risk management to help financial institutions detect and deter emerging and evolving export controls evasion.

The Risks of De-Risking

September 18, 2024

Compliance officers are guardians at the gate: protecting their organization and the global financial system from abuse while also ensuring that licit funds flow undisturbed. This is a delicate balance, as global regulations continue to grow in complexity, prompting some financial institutions to de-risk from high-risk clients. What are high-risk clients? Must a bank cease its relationships with these clients?

AML Compliance for Small Businesses

September 4, 2024

Small businesses face the challenge of navigating the intricate landscape of anti-money laundering (AML) regulations. Despite the challenges posed by evolving global standards and limited resources, small businesses can use tailored strategies to fortify their compliance frameworks and thrive in a complex regulatory environment.

Adapting to Digital Assets Risks

August 8, 2024

In our recent webinar, "Mastering Compliance in Digital Assets through Multi-Tiered Defense Strategies," industry leaders examined the intricacies of digital asset compliance. Featuring a panel of industry experts including Andrew Rosenberg, Elizabeth Severinovskaya, and Catherine Woods, this blog post summarizes the key insights shared during the event.

The Convergence of Sanctions & AML

July 24, 2024

The convergence of sanctions and anti-money laundering efforts has significantly accelerated since Russia’s full-scale invasion of Ukraine in February 2022. FINTRAC in June 2024 released a special bulletin focusing on financial activity associated with suspected sanctions evasion. The report highlighted shared methodologies and insights to help compliance teams collaborate on best practices.

Targeting Russia’s IT Dependencies

July 16, 2024

Delve into the recent determination issued by OFAC, which imposes significant additional restrictions on the provision to Russia of IT consultancy and design services as well as IT support and cloud-based services of enterprise management and design and manufacturing software. Multinational tech corporations, financial institutions, and other companies still operating in Russia will likely require licenses to continue operating there.

Crypto Under the Microscope

July 11, 2024

In the fast-evolving digital assets market, compliance is not just a regulatory requirement—it's a strategic imperative. From Binance's multi-billion-dollar settlement to the dramatic collapse of FTX, recent enforcement actions have sent shockwaves through the industry, underscoring the critical need for a robust compliance system.

Understanding and Addressing Fraud and Corruption Risks

July 2, 2024

In our recent webinar, industry experts delved into the crucial topic of fraud and corruption risks. From seasoned professionals to anti-corruption activists, the webinar featured a panel of distinguished speakers: Steve Burgess, Nikki Kenyon, Chris Williams, and James Wasserstrom. This blog post aims to summarize the key points discussed during the session, equipping readers with the knowledge necessary to navigate these risks effectively.

OFAC’s Compliance Guidance in Action

June 18, 2024

The Treasury Department’s Office of Foreign Assets Control (OFAC) five years ago published its Framework for OFAC Compliance Commitments. This guidance remains the most comprehensive articulation of OFAC’s compliance expectations to date. Although it notably stopped short of mandating a sanctions compliance program (SCP), recent enforcement actions demonstrate the implications of not having an SCP in place.

Types of Sanctions – A Vast and Varying Landscape

June 4, 2024

In the United States, most sanctions programs combine multiple types of designations that vary across multiple dimensions. U.S. designations are constantly changing, and more individuals, entities, vessels, and aircraft are being added to OFAC’s sanctions list. Explore the five primary types of sanctions in our latest article.

Russian Use of Crypto for Sanctions Evasion on the Rise

May 21, 2024

Experts agree there isn't enough liquidity in the virtual assets space to enable largescale sanctions evasion by Moscow, but sanctioned individuals and entities have used virtual currencies—most notably Tether—to access the global financial system and pay for restricted goods and technologies. Explore recent designations, how cryptocurrencies and other virtual assets are being leveraged to facilitate evasion as well as risk mitigation strategies for financial institutions in our latest article.

Fake News vs. Real News – The Importance of Media in Due Diligence

May 6, 2024

We exist in an age when mass media outlets are criticized for bias and manipulation, and when foreign disinformation efforts further erode trust in traditional journalism. Confidence in media reports not just as a compliance tool, but also as reliable news sources is likely at near record lows as well. However, adverse media reports are a critical compliance tool that can serve as a springboard for more extensive due diligence research and can help identify potential indicators of sanctions evasion and other financial crimes.

Counterproliferation Finance Detection and Deterrence – What Can Financial Institutions Do?

April 23, 2024

The U.S. Treasury recently identified proliferation networks operating on behalf of Russia, North Korea, China, Iran, Syria, and Pakistan as threats to U.S. national security. These networks exploited the U.S. financial system to finance the proliferation of weapons of mass destruction (WMD), including financing to procure WMD components and raising revenues to support efforts by these state actors to advance their WMD activities.

2024 National Proliferation Financing Risk Assessment

April 19, 2024

The U.S. Department of the Treasury published the 2024 National Proliferation Financing Risk Assessment in February 2024 providing an in-depth analysis of the threats and vulnerabilities related to proliferation financing (PF) and highlighting key countries and non-state actors working to gain access to weapons of mass destruction (WMDs) and their components and to conventional restricted weapons and technologies.

Liberating Limits: OFAC Licenses

April 8, 2024

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) safeguards national security and helps advance U.S. foreign policy objectives by administering the U.S. sanctions regime. OFAC’s general and specific licenses serve as key mechanisms for authorizing and regulating certain transactions that would otherwise be prohibited under sanctions programs. The exceptions provided by licenses help businesses and individuals navigate international transactions without violating U.S. sanctions policies.

Stuck and Seized – Consequences of Forced Labor

March 26, 2024

Global economies are more interconnected than ever, and human rights abuses can have a profound impact on supply chains and disrupt the flow of goods. Recent deliveries of certain luxury vehicles, such as Porsches, Audis, and Bentleys have been delayed because a small component that links those vehicles with computer networks was produced by a Chinese company linked to forced labor and surveillance of Uyghur populations in China.

Russia Sanctions Evasion Case Study: Viktor Labin

March 18, 2024

When conducting customer due diligence and enhanced due diligence, simple screening for names that may be on sanctions lists is no longer sufficient given the increasing complexity of Russia’s sanctions evasion efforts and the volatile regulatory environment because of Moscow’s aggression against Ukraine. Extra research is necessary to ensure compliance with sanctions laws and adherence with your company’s own risk policies. This research, however, can be complex, and structured analytic techniques and tools are necessary for effective due diligence.

Binging Griselda? Let’s Talk Drug Trafficking Sanctions

March 7, 2024

Netflix’s new series Griselda tells the story of Griselda Blanco. Known as the “Godmother of Cocaine,” Blanco trafficked cocaine from Colombia to Miami from the 1970s to the early 2000s. Despite her criminal activities, Blanco managed to evade law enforcement for many years. There were no sanctions against Blanco at the time, since the Kingpin Act, a U.S. law aimed at combating international drug trafficking and organized crime, was enacted in 1999 after Blanco’s sentencing.

Risky Russia – Government Agencies Warn Businesses of Possible Trouble

March 5, 2024

The US Departments of State, Treasury, Commerce, and Labor in late February issued a business advisory warning firms and financial institutions about the serious legal, financial, and reputational risks of doing business in Russia. According to the State Department’s assessment, Russia’s kleptocratic environment undermines fair competition and the rule of law, exposing businesses to the risk of extortion, appropriation of assets, and US law enforcement action.

Thanks to Russia, Cross-Border Sanctions Collaboration at All-Time High

February 28, 2024

Russia's unprovoked invasion and continued aggression in Ukraine has led to an unprecedented level of collaboration by sanctions stakeholders across jurisdictions, agencies, and sectors. IFI is publishing a series of blogs to highlight this increased collaboration. In this first blog, we take a look at cooperation across borders and most notably by the REPO Task Force and Price Cap Coalition.

Beyond The Hype: The True Role of Virtual Assets in Russia Sanctions Evasion

February 27, 2024

With the onset of stringent sanctions against Russia in 2022, US officials and financial analysts began to speculate about the potential for cryptocurrencies to serve as a means for evasion. But can virtual assets enables a nation's efforts to evade sanctions?

Ukraine’s War on Two Fronts – Fighting Corruption Amidst Russia’s Continued Attacks

February 20, 2024

As the second anniversary of Russia’s full-scale war of aggression in Ukraine approaches, winning on the battlefield remains the top mission objective for the Armed Forces of Ukraine, the Ukrainian people, and Ukraine’s international partners. While the full-scale invasion began two years ago, addressing systemic governmental and economic corruption has been an enduring battle for Ukraine since it gained its independence from the Soviet Union in 1991.

Exhausting Russian Resources by Sanctioning Western Software

February 8, 2024

Despite the Kremlin's attempts to reduce reliance on Western software for crucial systems, this transition is advancing slowly, presenting significant opportunities to hinder Russia's military effectiveness and economic activities. Read on for more information on the current role of Western technology and guidance for governments and companies formulating sanctions proposals.

Evading Export Controls – Russia’s Key to Success

February 6, 2024

Russia has used third-party intermediaries to evade sanctions and export controls for years and has disguised the involvement of SDNs or sanctioned entities in transactions to obscure the true identities of end users. This activity has increased since Russia’s invasion of Ukraine in 2022 due to Russia’s need for military equipment.

Bitcoin Breakthrough – Navigating the New Era of SEC-Approved Spot Bitcoin ETPs

January 26, 2024

The US Securities and Exchange Commission's (SEC) landmark approval of 11 Spot Bitcoin Exchange-Traded Products (ETPs) from several leading financial firms, including BlackRock, Fidelity, and Grayscale Investments, this month marks a significant shift in the regulatory landscape for virtual assets.

How to Avoid Becoming an Unwitting Facilitator of Russian Sanctions Evasion

January 17, 2024

What steps can organizations take to avoid becoming unwitting suppliers of critical components and tools for the Russian military?

The Importance of a Sanctions Compliance Program – Top 5 Mitigating Measures Highlighted by OFAC in 2023

January 11, 2024

OFAC in 2023 reached settlements with 17 companies, collecting more than $1.5 billion in penalties. Mitigating factors can help reduce the severity of penalties imposed by OFAC for sanctions violations and often involve significant remedial measures and enhancements to a company’s sanctions compliance program.

A Timeline of US, EU, and UK Sanctions on Russia in 2023

January 3, 2024

The United States, United Kingdom, and European Union, among others, have increased their focus on enforcement, updated sanctions lists and export controls to limit Russia’s access to sensitive technologies, and taken steps to punish illicit actors assisting Russia. Explore a list of the various sanctions imposed by the United states, EU, and UK in 2023.

Biden Signs Executive Order Targeting Foreign Banks Supporting Russia

December 29, 2023

US President Joe Biden on December 22, 2023, signed an executive order to authorize the US Treasury Department’s Office of Foreign Assets Control (OFAC) to designate foreign financial institutions that help Russia’s defense industry, as Moscow’s war against Ukraine approaches its two-year anniversary.

What Financial Institutions Can Learn from the Binance Settlement

December 7, 2023

Explore lessons learned from the recent Binance settlement including risk mitigation strategies for banks and other financial institutions.

Binance Settles with Regulators

November 21, 2023

Binance, the world’s largest cryptocurrency exchange, on November 21st pleaded guilty and agreed to pay more than $4.3 billion to resolve the US Justice Department’s investigation into its violations of the Bank..

Partial Sanctions Relief for Venezuela

October 31, 2023

On October 18, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued six general licenses authorizing categories of transactions that were previously prohibited under the U.S. sanctions program against Venezuela.

Best Practices for the Maritime Oil Industry to Detect Restricted Trade in Russian Oil

October 16, 2023

Price Cap Coalition partners have published an Advisory following reports that Russia has been evading the $60 per barrel price cap that was imposed by the Coalition last year. The Advisory provides some best practices and recommendations to the maritime oil industry to help stakeholders reduce their exposure to risks of Russian oil cap evasion by detecting restricted trade in Russian oil.

MiCAR Defined – The EU’s Blueprint for Crypto Regulation

July 10, 2023

The Markets in Crypto-Assets Regulation (MiCAR) went into effect on June 29, 2023, and will be fully applied by December 30, 2024.

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