May 01, 2025

7 min read

Compliance Digest—April 2025

Learn about all the latest compliance updates from the past month.

Arina Rumyanceva

Legal Counsel at Sumsub

Every month, Sumsub’s Compliance Team prepares a digest with all the latest updates in the world of AML and beyond. We cover multiple industries from AML to gaming.

If you want to get the latest news every month in one place, subscribe to our newsletter.

AML

Global 🌎

FATF revises Recommendation 16 on payment transparency

What happened? The Financial Action Task Force (FATF) launched a second public consultation on proposed revisions to Recommendation 16 (R.16) and its Interpretive Note (INR.16), which cover payment transparency and anti-money laundering (AML)/counter-financing of terrorism (CFT) standards for cross-border and domestic payments. This follows an extensive first consultation period in 2024, during which FATF received significant feedback from stakeholders.

Key changes include:

Structural revisions for greater clarity, especially regarding card exemptions, de minimis thresholds, and differing requirements for domestic vs. cross-border transactions.
Enhanced requirements for sharing and verifying originator and beneficiary information, using structured data formats aligned with ISO 20022 standards.
Clarification of roles and responsibilities across the payment chain, including new guidance on sanctions screening and the handling of cross-border cash withdrawals.
Updates to the objectives section to explicitly reference United Nations Security Council Resolutions (UNSCRs) on proliferation financing and fraud, broadening the scope beyond terrorism financing.
Consideration of proportionality, financial inclusion, data protection, and privacy concerns raised by stakeholders, particularly regarding the impact on smaller institutions and socially excluded communities.

Who’s affected: Mostly financial institutions

Deadline: The revised draft was open for public comment until April 18, 2025, with final adoption expected in June 2025 and phased implementation through 2030

Singapore 🇸🇬

MAS releases consultation paper on proposed amendments to AML/CFT guidelines

What happened? Last month, the Monetary Authority of Singapore (MAS) issued a consultation paper proposing amendments to its Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Notices and Guidelines. The main objectives of these amendments are to:

Clarify that money laundering (ML) includes proliferation financing (PF), and require that ML/terrorism financing (TF) risk assessments by financial institutions (FIs) and variable capital companies (VCCs) also cover PF risks.
Align MAS Notice TCA-N03 (related to trust companies) with recent legislative changes to the Trustees Act 1967 and updated Financial Action Task Force (FATF) standards, particularly by expanding the definition of “trust relevant party” and specifying additional information to be collected about these parties.
Update AML/CFT guidelines to clarify supervisory expectations, especially regarding the timelines for filing suspicious transaction reports (STRs), and to reflect other clarifications made by MAS over the years.
Remove the requirement for FIs and VCCs to automatically send copies of STRs to MAS, instead requiring submission only upon MAS’ request

Who’s affected? All financial institutions: licensed, approved, authorised, designated, recognized, registered, or otherwise regulated by MAS

Deadline: The amendments are expected to take effect on June 30, 2025. MAS is inviting comments on the proposals, with the deadline for written submissions set for May 6, 2025.

Canada 🇨🇦

Canada’s FINTRAC expands AML regulations

Effective April 1, 2025, the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) expanded anti-money laundering (AML) and anti-terrorist financing (ATF) requirements to include financing or leasing entities under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. This regulatory change means that any person or entity engaged in the business of financing or leasing-specifically in relation to property for business purposes (excluding real estate), property valued at $100,000 or more (excluding real estate), or passenger vehicles in Canada must now comply with a comprehensive set of AML/ATF obligations. The requirements for these entities include:

Implementing a formal compliance program.
Verifying the identity of clients for certain transactions and activities, including large cash or virtual currency transactions, suspicious transactions, and all financing or leasing arrangements.
Conducting ongoing monitoring of business relationships and maintaining detailed records of transactions, client identification, beneficial ownership, and politically exposed persons.
Submitting reports to FINTRAC, such as suspicious transaction reports, large cash transaction reports, large virtual currency transaction reports, and property reports related to listed persons or entities.
Determining and documenting third-party involvement where required.
Keeping all relevant records for at least 5 years.

In the first year of these new obligations, FINTRAC will focus on engagement, outreach, and guidance to help new reporting entities understand and implement the requirements.

Who’s affected? Financing or leasing entities: Any business or individual engaged in financing or leasing property for business purposes (excluding real property), property valued at $100,000 or more (excluding real property), or passenger vehicles is directly affected. They must now comply with all relevant AML/CTF obligations, including client due diligence, reporting, and record-keeping. The affected entities will be subject to compliance examinations and potential administrative monetary penalties for non-compliance.

Deadline: in force

Read more: Financing or leasing entities

Gambling

Italy 🇮🇹

Italy issues Decree on penalties for gambling market violations

What happened
On April 24, 2025, Italy published Decree 18 March 2025, n. 57 in the Official Gazette (GU Series no. 95), introducing regulations for assessing, contesting, and imposing financial penalties on gaming concessionaires for non-compliance. This decree applies to agreements under Decree 25 March 2024, no. 41, which governs Italian online gambling concessions for remote public games. Section 12 of the new decree specifically outlines the methodology for calculating financial penalties.

Who’s affected?

Online gambling concessionaires operating under Italy’s remote gaming framework, who are now subject to standardized penalty procedures for non-compliance.
Regulatory bodies, including the Italian Customs and Monopolies Agency (ADM), responsible for enforcing the new penalty system.

Deadline: The decree enters into force on May 9, 2025. It requires compliance from affected parties immediately upon implementation.

UK 🇬🇧

UK government launches consultation on remote gambling taxation

What happened?

On April 28, 2025, the UK government launched a consultation on reforming the taxation of remote (online) gambling. The proposal recommends replacing the current system—where operators may face up to three separate taxes—with a single, unified Remote Betting & Gaming Duty (RBGD). Currently, remote gambling is subject to:

General Betting Duty (GBD): 15% on fixed-odds bets (10% for sports spread bets, 3% for financial spread bets).
Pool Betting Duty (PBD): 15% on non-fixed odds bets, excluding horse and dog racing.
Remote Gaming Duty (RGD): 21% on gross profit from online gaming offered to UK customers.

The government’s proposal would consolidate all these into the new RBGD, covering online betting and gaming activities such as casino games, bingo, general betting, and pool betting. The aim is to streamline the system, reflecting the similarities across remote gambling products, and to reduce administrative complexity for operators who currently may need to comply with multiple tax regimes and file separate returns for each.

The consultation seeks input to:

Ensure the remote gambling tax framework is suitable for the industry
Create a tax system that accounts for the common features of remote gambling
Simplify processes and lessen administrative burdens for operators

Who’s affected? Remote gambling service providers and market stakeholders

Deadline: The consultation is running for a period of 12 weeks ending at midnight of July 21, 2025.

Lithuania 🇱🇹

Lithuanian gambling regulator releases guidance on payment blocking for financial institutions

What happened?

On April 25, 2025, the Gaming Control Authority of Lithuania issued guidance on implementing new provisions under the amended Law on Gambling and Law on Lotteries, effective from May 1, 2025. These amendments introduce a payment-blocking obligation for financial institutions. Payment service providers (PSPs) must ensure that payment card and online payment transactions related to online gambling and lottery activities are only processed with entities authorized by the Gaming Control Authority. Transactions involving unlicensed operators must be automatically blocked. To support compliance, the regulator will maintain and regularly update a publicly accessible White List of authorized entities on its website.

Who’s affected?

Payment service providers (PSPs) operating in Lithuania, who must integrate the White List into their payment monitoring systems and block unauthorized transactions.
Online gambling and lottery operators, who must be listed on the Authority’s White List to lawfully process payments.
Unlicensed operators, who will be excluded from the domestic payment system and face automatic transaction blocks.
Managers and responsible persons at illegal institutions, who could face administrative penalties for non-compliance.

Deadline: The amended provisions and payment-blocking obligations take effect on May 1, 2025. PSPs are expected to have integrated the White List into their systems by this date to ensure compliance and avoid administrative sanctions

Ireland 🇮🇪

What happened? The Gambling Regulatory Authority of Ireland (GRAI) has issued a call for input from the gambling industry and other stakeholders on the development of a Social Impact Fund. This fund is intended to support initiatives that mitigate the social harms associated with gambling. The GRAI is seeking feedback on the design, governance, and operation of the fund to ensure it effectively addresses the social impacts of gambling in Ireland.

The consultation aims to gather views on:

How the fund should be financed (e.g., contributions from operators).
The governance structure of the fund.
The types of projects and initiatives that should be supported.
The criteria for allocating funds.
Reporting and accountability mechanisms.

This initiative is part of GRAI’s broader commitment to responsible gambling and social responsibility in the gaming sector.

Who’s affected?

Gambling operators in Ireland: Licensed operators will likely be contributors to the Social Impact Fund and will be affected by any new regulatory or financial obligations.
Industry stakeholders: Including industry bodies, advocacy groups, and service providers involved in gambling and responsible gambling initiatives.

Deadline: The consultation period is open until May 15, 2025

Suggested read: What is Responsible Gaming?

Crypto

UK 🇬🇧

FCA executive addresses global responses to digital asset regulation

What happened?

The Financial Conduct Authority (FCA) Chief Data, Information and Intelligence Officer delivered a speech titled “Global responses to digital asset regulation”. In this speech, the FCA executive:

Highlighted the rapid growth and global nature of digital assets (such as cryptocurrencies and stablecoins).
Stressed the need for international cooperation and harmonization in regulating digital assets, due to their cross-border nature and potential risks (including financial crime, consumer harm, and market instability).
Outlined the FCA’s approach to digital asset regulation, emphasizing consumer protection, market integrity, and financial stability.
Discussed the importance of global standards (such as those set by the Financial Action Task Force, FATF) and the FCA’s participation in international regulatory forums.
Provided updates on the UK’s regulatory developments for digital assets, including the extension of the financial promotions regime to cryptoassets, as well as ongoing consultations and planned future regulation for stablecoins and broader crypto activities.
Called on industry stakeholders to engage with regulators and contribute to the development of effective, proportionate regulation.

Who’s affected?

Digital asset businesses (crypto exchanges, wallet providers, stablecoin issuers, DeFi platforms) operating in or targeting the UK market.

Deadline: N/a

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