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Welcome to the October 2025 summary of news you can use as your bank or other financial institution attempts to stay up to date on the world of BSA/AML compliance. Our monthly series of curated news about FinCrime regulatory developments, resources and stories.
In this edition, three main stories emerge:
- The UAE significantly enhances its legal framework for AML/CFT/PF
- FinCEN issues new FAQs about Suspicious Activity Reporting Requirements
- The U.S. and U.K. take largest action ever targeting cybercriminal networks in Southeast Asia
The UAE significantly enhances its legal framework for AML/CFT/PF
On October 14, 2025, Federal Decree-Law No. 10 of 2025 took effect in the United Arab Emirates. Also called “The New Law”, it repeals Federal Decree-Law No. 20 of 2018. The New Law broadens the scope of the AML/CTF regime, with the biggest changes being the incorporation of non-proliferation and clarification of key definitions. The three most important improvements include:
Countering Proliferation Financing: New offences include criminalization of arms and proliferation financing, making it illegal to finance (without authorization)—directly or indirectly—arms or weapons of mass destruction (including related dual-use goods and technology). Under The New Law, terrorism financing offense may be committed by anyone who finances terrorism by the use of digital systems, virtual assets, or encryption technologies. This includes not only people who know, but also people who should know, that the funds will be used for such a purpose.
Lower Evidentiary Threshold: Before this law, prosecutors were required to prove specific knowledge that the funds in question were criminal proceeds, or will be used for terror financing or money laundering related to it. But under the New Law, “sufficient evidence or circumstantial evidence” is enough, and knowledge can be inferred from the “factual and objective circumstances”. This means that money laundering, terror financing, and proliferation financing can be committed if a person knew, or should have known, that an offence would be committed.
Greater Investigative and Enforcement Powers: The UAE’s Financial Intelligence Unit can now:
- Freeze funds for up to 30 days, and the Public Prosecutor can extend that even further. The time limit was just 7 days.
- Suspend transactions for up to 10 working days without prior notice.
Federal and local law enforcement agencies also now have wide-reaching authority to access any information that can help identify and track criminal property.
FinCEN issues new FAQs about Suspicious Activity Reporting Requirements
On October 9, 2025, The Financial Crimes Enforcement Network (FinCEN), jointly with the Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), and the Office of the Comptroller of the Currency (OCC), issued answers to frequently asked questions (FAQs) regarding suspicious activity reports (SARs) and other anti-money laundering/countering the financing of terrorism (AML/CFT) considerations for financial institutions covered by SAR rules.
The answers to these FAQs clarify regulatory requirements related to SARs to assist financial institutions with their compliance obligations while enabling institutions to focus resources on activities that produce the greatest value to law enforcement agencies and other authorized government users of Bank Secrecy Act (BSA) reporting.
Read more here: SAR-FAQs-October-2025.pdf
The U.S. and U.K. Take Largest Action Ever Targeting Cybercriminal Networks in Southeast Asia
On October 14, 2025, The U.S. Department of the Treasury announced that Treasury’s Office of Foreign Assets Control (OFAC) and Financial Crimes Enforcement Network (FinCEN), in close coordination with the United Kingdom’s Foreign, Commonwealth, and Development Office (FCDO), took complementary actions against criminal networks responsible for targeting citizens of the United States and other allied nations through online scams and the laundering of stolen funds.
OFAC has imposed sweeping sanctions on 146 targets within the Prince Group Transnational Criminal Organization (Prince Group TCO), a Cambodia-based that operates a transnational criminal empire through online investment scams targeting Americans and others worldwide. In addition, FinCEN finalized a rule under section 311 of the USA PATRIOT Act to sever the Cambodia-based financial services conglomerate, Huione Group, from the U.S. financial system. For years, Huione Group has laundered proceeds of virtual currency scams and heists on behalf of malicious cyber actors.
Read more here: U.S. and U.K. Take Largest Action Ever Targeting Cybercriminal Networks in Southeast Asia | U.S. Department of the Treasury
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