The strategic view of the month.
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The FATF June Plenary repriced the grey list — Bosnia and Herzegovina and Iraq in, Algeria and Namibia out — and wrote humanitarian exemptions into Recommendation 6, while OFAC turned sanctions against scam empires and terror finance and launched a delisting portal. A fragile Gulf de-escalation began redrawing corridor risk yet again.
May sharpened the two-sided sanctions problem — Economic Fury designations against Iran's exchange-house and shipping networks on one side, Venezuela and Russia general licenses on the other — while supervisors drilled into the governance plumbing of AML programmes: overrides, backlogs, model validation, and regulatory change management.
April was the effectiveness examination: supervisors worldwide moved from asking whether controls exist to whether they demonstrably work — while OFAC struck the Shamkhani oil network, FinCEN and OFAC proposed a sanctions compliance programme rule, and beneficial ownership data access moved from policy to plumbing.
War in the Gulf pushed sanctions compliance to operational tempo: rolling designations, a collapsed Strait of Hormuz, crypto capital flight, and a temporary Russian oil license — while regulators kept advancing AMLA, crypto AML rules, and programme effectiveness expectations.
