Featured Summary:
- Iran’s September 2026 reform update failed to resolve deficiencies in terrorist-financing laws and targeted financial sanctions
- Myanmar remains under scrutiny over extensive fraud and cyber-scam operations, with stronger FATF measures possible in February 2027
- FATF is maintaining countermeasures against Iran while requiring enhanced due diligence for Myanmar-linked financial risks
- The US Treasury has backed tighter controls on illicit finance as FATF prepares new assessments of digital asset supervision and international financial systems
Iran’s September 2026 submission to the Financial Action Task Force (FATF) failed to resolve longstanding deficiencies in its terrorist-financing laws and financial sanctions system.
The organisation’s October assessment found that Iran had not completed most of the reforms agreed under its 2016 action plan, leaving restrictions on its international financial relationships in place.
Myanmar remains under scrutiny over extensive fraud and cyber-scam operations. FATF identified significant money-laundering risks despite steps towards improving international cooperation and establishing an anti-online-scams centre.
Its November report examined how scam networks across Southeast Asia move stolen funds through bank accounts, payment providers and digital assets.
At its October 28–30 plenary in Paris, FATF retained Iran and Myanmar on its high-risk list alongside North Korea. Iran remains subject to calls for financial countermeasures, while institutions handling Myanmar-linked transactions face enhanced due diligence requirements. Stronger measures could follow if Myanmar fails to demonstrate sufficient progress by February 2027.
The US Treasury endorsed FATF’s position on November 6, urging restrictions on correspondent banking and financial transactions involving Iran.
It also called for stronger international action against Southeast Asian scam networks and the financial services used to transfer criminal proceeds.
FATF Maintains Financial Restrictions Against Iran
Iran has faced FATF calls for financial countermeasures since February 2020 after failing to complete an action plan agreed in 2016. The plan expired in January 2018, and FATF had already called for increased supervision of Iranian financial institutions’ overseas operations, additional transaction reporting and stricter external audits in October 2019.
Iran’s September 2026 submission showed limited progress towards establishing procedures for receiving international asset-freezing requests.
FATF found that Iranian law still contained exceptions to terrorist-financing offences and lacked a targeted financial sanctions system meeting international standards.
The organisation also maintained objections to Iran’s reservations under the Palermo Convention and the International Convention for the Suppression of the Financing of Terrorism.
The October 30 decision called on jurisdictions to restrict new correspondent banking relationships with Iranian financial institutions and review existing arrangements according to risk.
Countermeasures also extend to virtual asset service providers, overseas branches and representative offices. National regulators determine how these requirements apply to banks, payment providers and other financial businesses under their jurisdiction.
FATF’s measures are separate from US sanctions, which impose additional legal restrictions on transactions subject to American jurisdiction.
The organisation also requires countries to consider humanitarian payments, food and medical supplies, diplomatic expenses and personal remittances when applying financial controls, rather than treating every Iran-related transaction as prohibited.
FATF Maintains Scrutiny of Myanmar’s Scam-Linked Financial Risks
Myanmar’s outstanding FATF action plan requires stronger investigations and prosecutions of money laundering, particularly cases involving cross-border financial crime.
Authorities must improve the use of financial intelligence, demonstrate effective supervision of financial institutions and strengthen international cooperation in tracing criminal proceeds. The plan expired in September 2021, but FATF’s October 2026 assessment found that significant deficiencies remained.
FATF’s November 5 report estimated that scam compounds generate tens of billions of dollars in annual losses worldwide. Approximately 120,000 people were estimated to have been forced into online scam operations in Myanmar.
The report documented criminal networks using money mule accounts, payment services, informal transfer systems and cryptocurrency exchanges to move stolen funds across jurisdictions.
In one investigated case, more than $100 million in victim payments was traced to a virtual asset wallet cluster associated with a scam compound, although the finding was not attributed specifically to Myanmar.
US enforcement has targeted organisations connected to Myanmar’s scam industry. In November 2025, the Treasury sanctioned the Democratic Karen Benevolent Army, four senior figures and associated companies for facilitating cyber-scam operations.
A separate September action targeted nine individuals and entities connected to operations in Shwe Kokko. Treasury estimated that scams originating across Southeast Asia cost Americans more than $10 billion in 2024, a regional figure rather than a Myanmar-specific loss.
FATF requires enhanced due diligence for financial relationships and transactions involving Myanmar, including closer examination of suspicious activity.
It has not called for the broader countermeasures applied to Iran, and legitimate humanitarian payments and remittances must not be unnecessarily restricted. Myanmar must demonstrate sufficient progress by February 2027 or face consideration of stronger financial measures.
FATF Clears Four Countries as New Financial Reviews Approach
The Financial Action Task Force (FATF) removed Bulgaria, Côte d’Ivoire, the Democratic Republic of the Congo and Monaco from increased monitoring on October 30 after confirming that they had completed their agreed reforms.
Their removal from the grey list followed on-site assessments of measures addressing weaknesses in financial supervision, money-laundering investigations and international cooperation. None of the four countries had been on FATF’s high-risk blacklist.
Cryptocurrency regulation is the next area facing closer examination. FATF has initiated targeted reviews of jurisdictions with substantial virtual asset activity and deficiencies in implementing international standards.
The assessments will examine how countries supervise cryptocurrency exchanges and other virtual asset service providers, including their ability to detect suspicious transactions and prevent the movement of illicit funds. Initial findings are scheduled for June 2027, with further results expected in October.
FATF also adopted mutual evaluation reports for the United States and Mexico at its October plenary. Both are scheduled for publication in December 2026 following final quality reviews.
The assessments examine compliance with anti-money-laundering standards and the effectiveness of national enforcement systems. Under the latest evaluation framework, countries receive recommended actions with a three-year implementation period.
FATF Sets New Deadlines for Financial Crime Reviews
The Financial Action Task Force (FATF) will meet with financial supervisors, intelligence agencies and private-sector representatives in Dallas on December 1–2, 2026, to examine how anti-money-laundering resources can be concentrated on higher-risk transactions and activities. A policy statement is expected after the meeting, addressing how authorities and financial institutions should apply risk-based controls.
FATF’s evaluations of the United States and Mexico are due for publication in December, with recommendations for addressing deficiencies identified during their assessments.
Reviews of cryptocurrency supervision will follow in June and October 2027, examining whether jurisdictions with substantial virtual asset activity are enforcing international standards.
Myanmar faces an earlier decision in February 2027. FATF could call for additional countermeasures if the country fails to demonstrate sufficient progress in addressing its money-laundering deficiencies.
Iran remains subject to existing countermeasures until it completes its outstanding action plan and FATF determines that the required reforms have been implemented.
Banks, payment providers and virtual asset businesses must continue applying the controls required by their national authorities when handling transactions involving either country.
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