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Every list change, dated and sourced, the morning it happens

Two briefings: the Sanctions Monitor every working morning, the Compliance Alert every Friday. English, French and Arabic. Every change read against the issuing authority's own notice.

Last updated Issue 145
Today's Sanctions Monitor · Issue 145

London Names an IRGC Counter-Espionage Chief and a Zindashti Network Facilitator as Brussels Renews Its Chemical Weapons List

UK designates an IRGC counter-espionage chief and a Zindashti facilitator; OFSI rent licence; EU chemical weapons renewal.

New designations2
Removals0
Entries amended0
What to do today
  1. 01

    Freeze and screen the two new UK designations Load Ruhollah Bazghandi (a.k.a. Rouhollah Azimi, Persian spelling included, passport D10008106) and Shahram Ali Reza Tamarzadeh Jakki (a.k.a. Farhad Ali Tamarzadeh), and apply the director disqualification to any UK company records.

  2. 02

    Re-label existing OFAC alerts on both men Add the UK references IRN0282 and IRN0283 to open and closed cases, and keep the 7 March 1981 OFAC date of birth as an alternative rather than a reason to discount a match.

  3. 03

    Apply OFSI General Licence INT/2026/10050568 to leasehold payments Process ground rent and service charges from designated tenants only into UK landlord or agent accounts, for leases that pre-date the designation, and keep records for six years.

Read the full issue, with the party table
This week's Compliance Alert

Payment rails and shipping lanes in the frame.

Issue 21 · · 8 stories
Read the full Alert
Sanctions spotlight

Washington targets what it calls Iran's remaining shadow fleet

Screen vessels by IMO number, not name, and check ship registries, agents and port-service payments that touch these African-flagged tankers. Foreign banks that facilitate significant transactions face correspondent-account risk.

OFAC

UK Russia package hits Kyrgyz payment rails and the owner of Cryptomus

Treat Cryptomus, Heleket and Certa Payments as aliases of Xeltox, including at merchant level, and review payment corridors that route through Kyrgyz processors. Match on registration and IMO numbers before escalating.

FCDO

OFAC lists two French charities in a Hamas financing network

Charities and payment firms handling Gaza appeals should screen trustees and beneficiaries, not just the charity name, and look for crypto transfers that follow donation spikes.

OFAC

OFAC deletes 125 SDN entries in its third modernisation round

A US delisting ends only the US obligation. Before closing a match, check the UK, EU and UN lists: Aliaksei Auramenka, for example, is still listed by the UK and the EU. Refresh stored identifiers for the 22 amended entries.

OFAC
Enforcement actions

American Express bank to pay $350m as US regulators issue AML consent orders

Card networks and issuers should test how fraud referrals feed suspicious activity reporting, and how network, ATM and third-party partners are overseen. These are the areas the Fed order singles out.

Federal Reserve

Dutch central bank fines Modulr Finance B.V. €722,160 for weak monitoring

Payment and e-money firms that onboard through partners remain responsible for monitoring. Test whether aggregation rules catch structured flows that stay under single-transaction thresholds.

DNB
Trends

FinCEN withdraws its crypto mixing and unhosted wallet proposals

No rule is not the same as no risk. Keep mixer and unhosted-wallet exposure in transaction monitoring and customer risk scoring, and document the rationale for your thresholds.

FinCEN

EU AMLA consults on a central AML database and sets crypto priorities

Material AML breaches at one EU supervisor will become visible to others. Firms with EU licences, and African fintechs passporting into the EU, should expect findings to travel.

AMLA
How this is produced

How the briefings are put together

  1. 01 · Cadence

    The Sanctions Monitor publishes on working days and the Compliance Alert on Fridays. Where a day carries no mentionable update, no issue is published for that day. Each issue keeps its own permanent address and is not edited after publication.

  2. 02 · Primary sources

    Every change is read against the issuing authority’s own notice, and that notice is linked in the issue. Anything that lands after an issue goes out is carried by the next one.

  3. 03 · Corrections and status

    Corrections are published on the issue they affect, dated, with the original text retained rather than overwritten. This is compliance information, not legal advice. Verify against primary official sources before taking compliance action.

Sources

Every source we read

92 sources automated today: regulators, financial intelligence units, multilateral bodies and the open public record, across nine regions. Follow any source for its own filtered archive.

Data and matching by country
Questions compliance teams ask

Frequently asked questions

  • How often does the OFAC SDN list actually change?

    In practice the list changes on most working days, not on a fixed schedule. Across the twelve months to 18 September 2026 the Monitor recorded changes on 214 of 250 US business days, a median of six party level changes per publishing day. Screening on a monthly cycle therefore leaves an average exposure window of roughly fifteen business days between a designation and your first screening run against it.

  • What does the CBN March 2026 baseline standard require of a deposit money bank?

    It requires a documented AML and CFT control framework mapped to named standards, with evidence that each control operates. The load falls on four areas: customer risk rating at onboarding and on review, sanctions screening against current list versions, transaction monitoring with tuned and tested thresholds, and reporting to the NFIU within the statutory window. Institutions are expected to evidence dates, list versions and approvals, not simply to hold a policy.

  • How does an NFIU suspicious transaction report differ from a currency transaction report?

    A currency transaction report is threshold driven and mechanical: it is filed because a cash transaction crossed a reporting amount, regardless of suspicion. A suspicious transaction report is judgement driven: it is filed because the institution has grounds to suspect the funds or the conduct, whatever the amount. A CTR needs the transaction record. An STR needs the reasoning that led to suspicion, recorded at the time.

  • What changes for a payment service provider as distinct from a bank?

    The obligations are the same in kind but different in shape. A payment service provider usually carries higher volume, lower value and a merchant book rather than a retail deposit book, so weight moves from customer due diligence at account opening to merchant onboarding, ongoing merchant risk and velocity monitoring. Beneficial ownership on merchants becomes the harder problem, and settlement exposure replaces cash handling as the dominant risk.

  • What is a general licence and how do you paper against one?

    A general licence permits a class of transaction that would otherwise be prohibited, without an application. Papering against one means recording the licence number, the exact clause relied on, the dates the activity falls within, and the evidence that the transaction meets every condition. Most carry a reporting obligation, commonly within fourteen or thirty days. Keep the licence text as it stood on the transaction date, because licences are amended and superseded.

  • How should we treat a delisting that follows an expired authority?

    Treat it as an expiry, not an exoneration. Where the national emergency or determination carrying a designation lapses, the record comes off without any finding that the original grounds were wrong. Unblock where you are required to, but retain the evidence file, the decision note and the transaction history, and keep the party on internal review. Redesignation under a replacement instrument does not require new conduct.

  • What belongs in a Nigerian AML platform RFP?

    Ask for evidence rather than claims: list coverage with update frequency and publishing lag per source, screening performance at your book size, false positive rates measured on analyst dispositions rather than estimated, NFIU filing formats supported end to end, audit trail and model change control, data residency, and a named implementation team with reference deployments at comparable volume. Ask every vendor to answer against your own book.

  • How do you evaluate a transaction monitoring vendor at production scale?

    Run a backtest on your own settled traffic, not a sample. Measure alerts per thousand transactions, precision confirmed by analyst disposition, time from event to alert at peak, and behaviour during a replay of your busiest day. Ask for the tuning method and who signs off a threshold change. A vendor that cannot show precision measured on dispositions, separately from precision estimated on unreviewed alerts, has not measured it.

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