FinCEN moves to delay AML/CTF rule for investment advisers, Brazil clarifies its anti-corruption law, and Japan imposes additional Russia sanctions – plus other key updates.
Lexology PRO explores some of the most useful articles published on Lexology and externally across key areas of anti-money laundering and counter-terrorist financing (AML/CTF), anti-bribery and corruption, sanctions, and beneficial ownership compliance to help businesses stay abreast of key issues.
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Anti-money laundering
On 22 September 2025, the US Financial Crimes Enforcement Network (FinCEN) signalled its intent to postpone the date of its AML/CTF programme and suspicious activity reporting (SAR) requirements for investment advisers. FinCEN proposed 1 January 2028 as the new implementation date, a two-year delay from the current 1 January 2026 deadline. FinCEN estimates that the delay could reduce compliance costs by US$1.45 billion over the two-year period. Comments on the proposed extension are invited until 22 October 2025.
On 21 September 2025, Israel’s Banking Corporations Sanctions Committee fined Bank Leumi Le-Israel 2.1 million new shekels (US$627,786) for breaching the Money Laundering Prohibition Law 2000. The violations, identified during a regulatory audit, involved failures related to SAR and deficiencies in customer due diligence. The bank received a reduced penalty for cooperating with the auditor.
On 16 September 2025, Germany’s Federal Financial Supervisory Authority (BaFin) fined Varengold Bank €3.3 million (US$3.9 million) for “significant deficiencies” in its AML controls for Iran-related payments. BaFin also imposed an additional penalty of €500,000 (US$589,275) for violating a previous order issued by the regulator in 2023 (German language only) requiring it to stop processing certain transactions linked to Iran.
On 12 September 2025, the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) levied a US$1.2 million fine against the Saskatchewan Indian Gaming Authority for AML violations revealed during a compliance review. According to FINTRAC, the company kept outdated compliance policies and failed to file suspicious transaction reports despite clear indicators of potential money laundering and terrorist financing, among other violations.
Anti-bribery and corruption
On 22 September 2025, mass protests erupted in Manila over a multi-billion-dollar corruption scandal involving government flood control projects. The protest relates to allegations that lawmakers, officials, and construction company owners diverted public funds through fraudulent contracts.
On 10 September 2025, Brazil’s Office of the Comptroller General (CGU) issued eight administrative statements to clarify and standardise enforcement of the Law on Anti-Corruption (No.12,846) 2013 – the country’s governing anti-corruption law. The CGU confirmed that corporate bribery can include the offering of any goods or services – including immaterial ones such as moral or political benefits – to public officials, whether in Brazil or abroad.
Sanctions
On 19 September 2025, EU Commission President Ursula von der Leyen announced the 19th sanctions package against Russia, which proposes banning Russian LNG imports, lowering the crude oil price cap to US$47.6, and blacklisting 118 more vessels and major energy companies. The package also seeks to close financial loopholes, tighten export controls on battlefield technology, and further restrict Russian access to global markets.
On 17 September 2025, the European Commission proposed suspending key trade provisions of the EU-Israel Association Agreement, citing Israel’s breach of Article 2 on human rights and democratic principles. The package includes sanctions on Hamas, extremist Israeli ministers, and violent West Bank Settlers.
On 12 September 2025, Japan revised the Foreign Exchange and Foreign Trade Act 1949 to impose additional sanctions against Russia. The amendment includes asset freezes and bans certain exports to Russian organisations linked to the war in Ukraine, in a push to align Japan with international sanctions efforts.
Beneficial ownership
On 11 September 2025, the Swiss Federal Parliament adopted legislation to create a Federal Beneficial Ownership Register (French language only), aligning Switzerland’s AML framework with standards set out by the Financial Action Task Force. The new law requires companies to declare their beneficial owners in a centralised, non-public register managed by Switzerland’s justice ministry and police force.