Compliance intelligence · updated daily

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 148
Today's Sanctions Monitor · Issue 148

Washington Cuts Off an Iraqi Bank and Iran's Exchange Houses, and Names a Havana Bank for Serving Tehran

OFAC names an Iraqi bank, two Iranian offshore banks and four exchange houses; State designates Cuba's BICSA.

New designations27
Removals0
Entries amended3
What to do today
  1. 01

    Load the 27 US designations and re-screen Add the 16 individuals and 11 entities from 15 October, using the SWIFT codes, LEI and Iranian national ID numbers to confirm matches, and re-screen customers, beneficial owners and payment counterparties.

  2. 02

    Find and exit IDB and BICSA exposure Check nostro, vostro and trade finance relationships with the Iraq Development Bank (IDBQIQBA) and BICSA (BIDCCUHH); wind down by 30 October and 14 November respectively, paying any amount due into a blocked account.

  3. 03

    Review exchange-house and Gulf trading flows Iranian exchange houses, Hong Kong trading companies and Dubai intermediaries are the pattern; look for payments involving the four exchange houses, Elitesphere Trading or Razavi's companies, and file a suspicious activity report where warranted.

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

Brussels lists 1,569 Russian arms makers as Washington fines Bank of America more than $1.21 billion

Issue 22 · · 7 stories
Read the full Alert
Sanctions spotlight

EU lists 1,569 Russian defence-industry companies and executives in one act

Match on INN, OGRN and tax number as well as on names, in Latin and Cyrillic. Most of the new names are not on the US or UK lists, and EU ownership and control rules extend the freeze to what they own.

Council

Treasury hits Iran's shadow banking through an Iraqi bank, offshore banks and exchange houses

Foreign banks face secondary sanctions risk for dealing with these parties. Review Iraqi and Cuban correspondent relationships and exchange-house flows through the UAE and Hong Kong, and confine any dealings with the Iraqi bank to the General License FF wind-down.

OFAC

OFAC sanctions 15 parties behind Cartel del Noreste's racing, fuel and construction businesses

Check fuel, construction, haulage and horse-racing counterparties in northern Mexico. The 13 parties also listed under E.O. 13224 carry secondary sanctions risk for foreign banks.

OFAC

United States designates the International Criminal Court and issues four general licences

Institutions with a US nexus that deal with the Court, or supply it, should map each payment to a specific general licence and keep the record. General License 13 expires on 7 April 2027.

OFAC
Enforcement actions

Bank of America penalised more than $1.21 billion by FinCEN, the OCC and OFAC

Measure how long a new designation takes to reach live screening, and check that suspicious activity reports come from your own detection rather than from law enforcement requests: the two weaknesses at the centre of this case.

FinCEN

Freight forwarder Pegasus Worldwide Logistics settles with OFAC for $175,015

Logistics and trade-services firms need to screen suppliers and consignors, not only customers, and to answer OFAC subpoenas completely and on time.

OFAC
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

Over 97 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

Recent issues

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.

Subscribe

The Monitor arrives every working morning. The Alert arrives every Friday. Choose one or both. Nothing on this site is gated: the subscription is a convenience, not a condition of reading.

Briefings
Language

See what the same record does inside the platform.