Sanctionfy

Blog

Practitioner-level analysis on sanctions, BSA/AML, and trade finance compliance.

Recent

·Compliance Ops & Tooling

How AI Is Actually Changing Sanctions Screening (and Where It Shouldn't)

FinCEN's 2026 NPRM signals that demonstrably effective AI adoption may count in enforcement decisions. Where AI genuinely improves sanctions screening — and the five boundaries where handing the decision to a model creates more regulatory risk than it removes.

·BSA/AML & Banking

FinCEN's 2026 AML/CFT Reform: Why the National Priorities Are About to Get Teeth

FinCEN's April 2026 NPRM (91 FR 18304) would fundamentally reform AML/CFT program rules under the BSA — making the 2021 national priorities mandatory inputs to every covered institution's risk assessment. The comment window closed June 9, 2026 — what institutions should do now.

·OFAC & US Sanctions·Flagship

The OFAC 50 Percent Rule: Sanctions Ownership and the 2026 Sham Transactions Guidance

A practitioner's guide to the OFAC 50 Percent Rule — ownership aggregation, indirect ownership, FAQ 401 examples, the March 2026 Sham Transactions Guidance, the GVA Capital, IPI Partners, and Gracetown enforcement actions, and the BIS Affiliates Rule taking effect November 10, 2026.

·OFAC & US Sanctions·Flagship

Blocking Reports vs. Voluntary Self-Disclosures: How OFAC's Two Reporting Tracks Interact

A practitioner's decision guide to the OFAC reporting requirements under §§ 501.603 and 501.604, the voluntary self-disclosure framework, and how the two tracks interact — with a quick-reference table, a two-track decision flow, and downloadable operational checklists.

·Practice Notes & Opinion

Sanctionfy Is Back

After three years dormant, Sanctionfy is being rebuilt — this time as a practitioner-grade resource paired with free tools for sanctions, BSA/AML, and trade finance compliance work.

Archive (7)

Older posts from before the Sanctionfy relaunch. Some content may reflect rules and guidance that have since changed.