The 50% Rule Is Dead; Long Live the 50% Rule: A Shift in Sanctions Compliance
In April 2026, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued new guidance on sanctions evasion, signalling a notable evolution in how sanctions compliance is understood and enforced. While the long-standing “50% Rule” remains formally intact, regulators have made it clear that relying solely on this rule is no longer sufficient. The shift reflects a broader and more nuanced approach to identifying sanctioned entities and hidden economic interests.
The Central Bank of the United Arab Emirates (CBUAE) has issued an updated and comprehensive set of guidelines on Anti-Money Laundering (AML), Combating the Financing of Terrorism (CFT), and Countering the Financing of Proliferation (CPF) for Licensed Financial Institutions (LFIs). This update represents a significant step in strengthening the UAE’s financial regulatory framework and ensuring that institutions are equipped to address evolving financial crime risks in a rapidly changing global environment.
UAE Confiscates $1.15 Billion in Major Anti-Money Laundering Crackdown
The United Arab Emirates (UAE) has intensified its fight against money laundering, confiscating assets worth AED 4.2 billion (approximately US$1.15 billion) and freezing an additional AED 150 million (US$40.8 million) in 2025. The figures, released by the National Committee for Anti-Money Laundering and Combating the Financing of Terrorism and Financing of Illegal Organisations (NAMLCFTC), reflect one of the country’s largest annual enforcement actions against financial crime.
CBUAE Notice 3075: Strengthening Sanctions Risk Appetite, Screening and Monitoring Controls
The Central Bank of the UAE’s latest notice reinforces the importance for Financial Institutions to maintain effective, risk-based sanctions compliance programmes. The guidance highlights key areas including sanctions risk appetite, policy updates, screening system effectiveness, transaction monitoring and emerging risks such as maritime trade and digital assets
EU Court Rules U.S. Sanctions Lists Alone Cannot Bar Access to Basic Bank Accounts
The Court of Justice of the European Union (CJEU) has delivered a significant ruling that reinforces the rights of consumers while preserving the integrity of the financial system. In a judgement delivered on 11 June 2026, the court held that an individual’s inclusion on a United States sanctions list cannot, by itself, justify the refusal to open a basic bank account within the European Union. Instead, banks must conduct an individual assessment of the customer’s risk before denying access to banking services.
FATF Grey List Update: Key Changes Announced on 19 June 2026 and Their Global Impact
The Financial Action Task Force (FATF) released its latest update on 19 June 2026, declaring changes to its list of jurisdictions under increased monitoring, commonly known as the FATF Grey List.
The June 2026 Plenary resulted in two countries being added to the Grey List and two countries being removed after demonstrating significant progress in strengthening their anti-money laundering and counter-terrorist financing (AML/CFT) frameworks.
