This Week in Global Compliance — AML Governance Scrutiny and Crypto Sanctions Complexity Rise

January 23, 2026 — Week of 17–23 January

Executive Summary

The week saw elevated AML governance scrutiny and sustained pressure on sanctions controls as regulators and law enforcement sharpened focus on compliance program effectiveness across both emergent and traditional channels.

In Australia, the national AML regulator invoked a rarely used statutory power to mandate an external audit of a global payments platform’s AML/CTF program, signalling intensifying oversight of fintech compliance frameworks and transaction monitoring across cross-border payment systems. At the same time, crypto-asset sanctions risk emerged with renewed scrutiny of central bank use of stablecoins to bypass traditional financial system restrictions, highlighting weaknesses in controls governing geo-economic evasion via digital assets.

These developments reinforce that governance, identity controls, and dynamic sanctions risk remain core operational priorities for compliance leaders.

Top Signals

1. Australian AML regulator orders external audit for multinational fintech

Australia’s financial crime authority (AUSTRAC) ordered the appointment of an external auditor to assess whether a major global payments platform’s AML/CTF programs meet statutory obligations, citing concerns about transaction monitoring, customer due diligence and reporting practices.

Why it matters:
Regulators are increasingly using external governance mechanisms to compel compliance program rigor — a practice that can materially elevate supervisory expectations for fintechs and banks alike, particularly in transaction monitoring and suspicious activity oversight.

2. Stablecoin use by a central bank highlights sanctions risk persistence

Blockchain analytics reporting indicated that Iran’s central bank has moved significant volumes of a major stablecoin as part of currency and sanctions mitigation strategies, underscoring the continued exploitation of digital assets for geo-economic sanctions evasion.

Why it matters:
This pattern emphasises that sanctions compliance must account for non-traditional counterparties and instruments, requiring enhanced on-chain analytics integration and sanctions screening that extends beyond entity lists into behavioural and instrument-level monitoring.

Deep Dives

1. Enforcement — AML governance in the crosshairs

AUSTRAC’s intervention represents a shift toward governance accountability: external audits by independent firms are now a tool to assess whether compliance frameworks are not merely nominal but operationally effective.

Practical impact:

Strengthen board-level oversight of AML/CTF programs.
Validate transaction monitoring logic and thresholds against real-world risk exposures.
Ensure suspicious matter reporting protocols align with statutory expectations and escalate appropriately.

2. Sanctions — Digital asset channels and sovereign actors

The reported use of stablecoins by a sovereign institution to sidestep banking restrictions reinforces that sanctions compliance continues to encounter instrument innovation as a risk vector. Controls calibrated for fiat rails must evolve to interpret and act on crypto transaction patterns that serve evasion objectives.