Compliance Brief - June 3, 2026 - Global RADAR
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Compliance Brief – June 3, 2026

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Global RADAR · Edition 2 · Published Wednesday, June 3, 2026

Weekly Compliance Brief

GAO tells Treasury its Corporate Transparency Act exemption left a beneficial ownership gap

What’s new in compliance. Why it matters. What it means for your operations.

From the Founder
The GAO report should not have surprised anyone. When Treasury exempted US-formed entities from beneficial ownership reporting in March 2025, it created a blind spot that every compliance officer, COO, and board risk committee now has to fill privately. The next exam cycle will not be kind to firms that did not adapt.
Dominic Suszek
Founder and CEO, Global RADAR
30-Second Read

→ GAO calls out Treasury: the CTA exemption created a beneficial ownership gap

→ GENIUS Act stablecoin AML rule comments close June 9, only six days away

→ UK OFSI added 85 designations targeting Russia drones, child deportation, propaganda

Skip to: Top Story · Enforcement · Guidance · Calendar

1. Top story of the week

GAO has told Treasury its Corporate Transparency Act exemption leaves a real beneficial ownership gap. On May 29 the Government Accountability Office published a report finding Treasury’s March 2025 decision to remove US persons and US-formed companies from beneficial ownership reporting has created an information gap that has not been addressed. FinCEN now collects BOI only from foreign reporting companies, and the GAO recommends Treasury determine how to fill the visibility loss.

Why This Matters

Your customer due diligence cannot rely on FinCEN’s beneficial ownership database to catch US shell company risks anymore. The gap the GAO flagged is one your KYC, EDD, and SAR functions now own by default.

Operational Implications

Three steps for this week:

  1. Update your CDD documentation to note the FinCEN BOI database no longer covers US-formed entities.
  2. Rebuild your shell company red flag list before your next exam; the examiners will ask.
  3. Brief your board risk committee that the BO blind spot is now a firm-owned residual risk, not a regulator-owned one. The exam cycle will treat “we relied on FinCEN” as a failed control.

2. Enforcement and penalties

  • OFAC, May 26: Federal Register notice formalized blocking of Ayadi Chafiq Bin Muhammad, a long-standing Al-Qaida-linked individual, refreshing addresses across Germany, UK, Belgium, Austria.
  • UK OFSI, late May: 85 designations across two tranches, targeting forced deportation of Ukrainian children (29) and Kremlin information warfare actors (56).
  • AUSTRAC, May 6: Investigation into Tabcorp’s AML/CTF program disclosed via ASX filing, signaling deeper scrutiny of the wagering sector.
  • FCA, May 2026: Court approved distribution of recovered Argento Wealth assets, alongside warnings that firms must do more on sanctions breaches.
Why This Matters

The enforcement signal this week is breadth, not headline size. US, UK, and Australian regulators each opened or refreshed a different angle of risk, from sanctions evasion to wagering-sector AML. Your screening, monitoring, and program-effectiveness controls will be tested in different ways depending on where you operate.

Operational Implications

Two operational moves this week:

  1. Run a screening look-back against the refreshed Al-Qaida-linked OFAC entries; if no hit triggers and you have UK or EU correspondent exposure, document the negative result for the file.
  2. If you operate in Australia or hold any gaming or wagering exposure, brief your compliance committee that Tabcorp signals AUSTRAC will widen scrutiny of the sector. The “we are not Tabcorp” answer will not satisfy a supervisor anymore.

3. New guidance and rulemaking

  • FinCEN and OFAC GENIUS Act stablecoin rule, comments due June 9: AML and sanctions program requirements for permitted payment stablecoin issuers close Monday after a 60-day window.
  • FinCEN whistleblower NPRM, comments due June 1: Operationalizes financial incentives for reporting BSA, sanctions, and national security violations; final rule next.
  • EU AMLA, May 28: Held public hearing on the Business-Wide Risk Assessment Guidelines, a foundational document for the EU’s harmonized AML/CFT supervision starting 2028.
  • FinCEN IRGC alert, May 11 (still active): Red flags on Iranian Revolutionary Guard Corps oil smuggling, shell companies, and stablecoin use should be embedded into transaction monitoring now.
Why This Matters

Three of these four items shape your future state: the GENIUS Act rule will define good stablecoin AML, the whistleblower program will change how violations surface, and the AMLA guidelines will set the EU baseline. You build the program now or you retrofit later.

Operational Implications

A practical comment-period playbook:

  1. Submit a GENIUS Act comment by June 9 even if it is two paragraphs. Silence reads as agreement, and the final text will reflect whoever shows up.
  2. Embed the IRGC red flags from the May 11 FinCEN alert into your transaction monitoring system this week, not next quarter. OFAC will treat the alert as on-notice once enforcement starts.

4. Coming up in the next 30 days

Date Event or deadline
June 9, 2026 GENIUS Act stablecoin issuer AML and sanctions rule comment window closes (FinCEN, OFAC).
June 9, 2026 ACAMS New Jersey Chapter virtual event, 1 CAMS continuing education credit.
June 10, 2026 EU AMLA webinar on the reporting package for identifying obliged entities eligible for direct supervision.
June 17, 2026 ACAMS featured virtual event, 7 CAMS continuing education credits.
June 25, 2026 ACAMS Luxembourg Chapter event, Enforcement of Sanctions as the Third Pillar of AML.
June 30, 2026 End of Mexican FATF Presidency; UK’s Giles Thomson begins his fixed two-year term July 1.
July 1, 2026 AUSTRAC Tranche 2 obligations commence for legal, accounting, real estate, jewellery, and VASPs.
July 18, 2026 Statutory deadline for FinCEN and OFAC to issue final GENIUS Act stablecoin regulations.

Next Wednesday

Comments on the GENIUS Act stablecoin rule have just closed. Next week we will publish the three institutional comments getting attention and what they signal about the final text.

Want a 30-minute review of your beneficial ownership documentation against the GAO’s findings? Book a call with a Global RADAR compliance specialist.

Book the 30-minute call

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Best regards,
Dominic Suszek
Founder and CEO, Global RADAR
globalradar.com

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