US Treasury publishes risk assessments on Money Laundering, Terrorist Financing, and Proliferation Financing

12 March 2026

The US Treasury has published 3 risk assessments on terrorism, money laundering, and proliferation financing, all of which discuss sanctions. It also published its report to Congress on the use of innovative technology to counter illicit finance involving digital assets. Each risk assessment provides an overview of key issues.

Terrorist Financing Risk Assessment

The terrorist financing risk assessment evaluates the threat from global terrorism. It says:

• There has been a continued pattern of US supporters sending funds abroad or fundraising on behalf of terrorist organisations.

• Although threats from existing sanctioned terrorist groups including ISIS and Al-Qaida continue to exist, the designation of Antifa groups and cartels means terrorism sanctions now apply to a wider range of threats.

The risk assessment says that major vulnerabilities include:

• Money services businesses (MSBs), and particularly Hawala services, which have been exploited to facilitate fundraising by sanctioned terrorist groups.

• Non-profit organisations which are created to evade sanctions for terrorist financing purposes. The risk assessment repeats the importance of financial institutions adopting risk-based sanctions controls for non-profit organisations.

Proliferation Financing Risk Assessment

The proliferation financing risk assessment evaluates the threat from actors seeking to finance weapons of mass destruction programs. It says:

• The major proliferation threats to the US are Iran and North Korea, both of which are subject to UN and US sanctions.

• Following the dissolution of the UN panel of experts which was established to analyse non-compliance with UN sanctions on North Korea, the US has assisted in the establishment of a Multilateral Sanctions Monitoring Team to monitor UN DPRK sanctions violations and evasion.

• After the Iran sanctions snapback in September 2025, UN Member States must exercise increased vigilance over Iranian banks. The Threat Assessment calls on the private sector to review and update their Iran sanctions framework following the snapback.

The risk assessment says that the prominent role of the US financial system in global trade, the use of foreign-based front companies, and the complex nature of dual-use export controls pose vulnerabilities for non-proliferation efforts. At a sectoral level, foreign correspondent banks face heightened sanctions evasion vulnerabilities because of their lack of direct relationships with respondent banks in foreign jurisdictions.

The risk assessment provides typologies relevant to proliferation financing. It highlights abuse of the global technology ecosystem to evade sanctions, including DPRK IT worker fraud schemes, the use of digital assets to evade US sanctions, and the use of intermediaries to circumvent US export controls.

Money Laundering Risk Assessment

The money laundering risk assessment says:

• The US has deployed sanctions to disrupt digital asset investment scams and cartel money laundering schemes.

• Sanctions compliance programmes at banks are “generally adept at identifying sanctions violations” as less than 1/3 of recent enforcement actions related to sanctions.

• The SEC plans to review the sanctions compliance programmes of broker-dealers in 2026, given their exposure to potential money-laundering and sanctions risks, which is illustrated by OFAC’s 2025 settlement with Interactive Brokers LLC.

• Investment advisers have served as entry points into the US market for proceeds of sanctions circumvention, which has resulted in two published OFAC enforcement actions against IPI Partners and GVA Capital Ltd.

• The US is working to improve sanctions and AML regulation for the digital assets sector. Sanctions compliance obligations are currently the same regardless of whether a transaction is made by digital assets or through fiat currency.

• Shell companies, front companies, and trusts have been used to facilitate sanctions evasion schemes, with particular risks posed by companies and trusts incorporated or settled outside of the US.