The United States targets a shadow banking network and asks banks to sharpen their alerts, while the Dominican Banking Superintendency digitizes sanctions notices. Across the region, financial intelligence is increasingly aimed at organized crime.
1. KYC/AML: Shadow banking back on the radar
On October 1, the U.S. Treasury acted against the so-called A7 Network, which it describes as a Russia-linked shadow banking network used by Iran to evade sanctions. FinCEN proposed a special measure that would prohibit funds transfers involving the network's sub-agents and issued an alert to help institutions detect and report suspicious activity; in parallel, OFAC designated it a transnational criminal organization.
Why does this matter in Latin America? Any bank, remittance company or fintech with U.S. dollar correspondent relationships inherits these expectations through its counterparties. The KYC lesson is clear: screening names against lists is not enough; you need to understand the web of intermediaries, beneficial owners and agents behind a transfer.
2. GAFILAT
No official updates in the last four days. As recent context, in late September the body held an exchange program among the region's FIUs focused on artificial intelligence, a signal of where supervision is heading.
3. Dominican Republic: Supervision goes digital
On September 30, the Superintendency of Banks (SB) issued Circular CSB-REG-2026000018, which updates its automated system for requests and information submissions and adds a new "Sanctions Notifications" module. For supervised entities, this means sanctions will be communicated through a digital channel, with greater traceability and tighter response expectations.
In addition, on October 2 the SB published Circular Letter CCI-REG-2026000013, a financial inclusion guide for older adults at bank offices and branches. While not an AML rule, it affects onboarding: identification and due diligence processes must be accessible without lowering controls.
4. Latin America: Financial intelligence targets organized crime
In Argentina, the Financial Intelligence Unit (UIF) hosted a workshop in Rosario on September 30 on organized crime and illicit financial flows, together with the Ministry of Justice and Santa Fe authorities, with around 130 participants. Its president called for an FIU that "searches, detects and acts in time," backed by daily inter-agency coordination. This follows the UIF's recent restructuring to strengthen its presence in the Litoral region. The message for obliged entities: the quality and timeliness of suspicious transaction reports will be valued more and more.
Practical takeaways for regulated companies
- Review exposure to informal payment networks: update monitoring scenarios with the FinCEN alert's indicators if you operate in dollars or with U.S. correspondents.
- Go beyond lists: combine sanctions screening with beneficial ownership and counterparty analysis.
- Get ready for digital supervision: in the DR, assign owners and internal deadlines to handle the SB's new notifications module.
- Inclusive yet secure onboarding: adapt verification flows for older customers without weakening due diligence.
- Timely reporting: measure the time from alert to STR; regulators reward speed.
At Global KYC & Compliance Solutions, we help automate these tasks so your team can focus on work that demands expert judgment.
Sources
- FinCEN – Operation Economic Outcast (Oct 1, 2026)
- FinCEN – Proposed special measure on the A7 Network
- GAFILAT – Subregional FIU exchange on AI
- DR Superintendency of Banks – Circular CSB-REG-2026000018
- DR Superintendency of Banks – Circular Letter CCI-REG-2026000013
- UIF Argentina – Rosario workshop
- UIF Argentina – Litoral region restructuring