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FinCEN Warns on Foreign-Agent-Directed Payments as FATF Updates Its Lists

By GlobalKYCS Compliance TeamPublished

FinCEN warns about payments directed by foreign agents through money services businesses, FATF removes four jurisdictions from its monitoring list and the Dominican banking regulator issues a trust-services charter of rights.

This week brings a U.S. alert on suspicious payments, changes to the FATF lists and a Dominican circular that requires updates to digital channels.

1. KYC/AML: FinCEN Warns on Foreign-Agent-Directed Payments

On October 30, 2026 FinCEN issued alert FIN-2026-Alert009 on foreign-agent-directed transactions, together with notice FIN-2026-NTC2 on the use of charities and non-profit organizations for illicit activity. The alert targets banks and other institutions that serve U.S.-based money services businesses (MSBs) and puts suspicious payments of this kind at more than $8 billion between 2021 and 2025.

Red flags include payments to third parties with no apparent link to the foreign agent (newly created firms or firms with no web presence), generic reasons such as “settlement”, reluctance to provide invoices or contracts, round-dollar amounts, and transfers to third countries named in the document. FinCEN asks for timely reporting using the key term FIN2026FOREIGNAGENT and sets no new deadlines. From the notice on non-profits, the essentials are P.O. box addresses, no real operations, and sudden donations or public funds.

On October 29 OFAC also issued Iran General License FF-1, which authorizes the wind down of transactions involving the International Development Bank for Investment and Finance; its scope and deadlines are in the official text.

2. GAFILAT

We found no verifiable GAFILAT announcements this week: its news page did not respond, so we claim nothing on its behalf. The October FATF plenary is verifiable: on October 30 it removed Bulgaria, Côte d’Ivoire, the Democratic Republic of the Congo and Monaco from the increased-monitoring list, while Iran, North Korea and Burma remain on the call-for-action list.

3. Dominican Republic

On October 30 the Superintendency of Banks published Circular CSB-REG-2026000020, signed on October 28, which implements a charter of rights and duties for users of trust services. It is not an anti-money-laundering rule, but it requires financial intermediaries and trust companies to make the charter available on websites, in branches and on virtual channels before, during and after the contract is signed, to display it on the main menu of portals and apps, and to keep a copy of signed documents showing it was read and accepted.

Article 9 sets 30 calendar days for digital channels and 90 days for contracts. Counted from publication, that is about November 29, 2026 and January 28, 2027, our own calculation, which the circular does not state. Non-compliance is penalized under Laws 183-02 and 189-11 and their regulations.

4. Latin America

No Latin American or Caribbean jurisdiction appears among the changes FinCEN reported after the FATF plenary, although the release does not reproduce the full list, so check it against FATF’s own source. Argentina’s FIU has posted no news since October 13. For institutions with U.S. correspondents or remittance partners, more questions about third-party-directed payments are a reasonable expectation; that is an editorial inference, not a requirement of the alert.

Practical takeaway

  • Build the FinCEN alert’s red flags into remittance and cross-border payment monitoring, focusing on third parties with no clear link.
  • Update your country lists and risk matrices with the changes from the October FATF plenary.
  • If your institution has Iran exposure, review General License FF-1 in OFAC’s official text.
  • If you provide trust services in the Dominican Republic, plan the digital changes before the end of November and keep evidence that clients accepted the charter.

Sources