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Requires the Office of Foreign Assets Control (OFAC) to run a limited pilot that lets private companies obtain licenses to carry out nominal financial transactions as part of their investigations. The pilot must be coordinated with FinCEN, include monthly reporting by licensed firms, regular reports (including classified briefings) to specified congressional committees, and automatically end five years after it begins.
The Director of the Office of Foreign Assets Control must establish a pilot program under which a private sector firm may receive a license to conduct nominal financial transactions in furtherance of the firm’s investigations. The pilot must be established not later than 1 year after the date of enactment of this section.
When establishing and carrying out the pilot program, the Director of the Office of Foreign Assets Control must coordinate with the Director of the Financial Crimes Enforcement Network to support activities of the Financial Crimes Enforcement Network Exchange (as described in 31 U.S.C. 310(d)).
Each private sector firm that receives a license under the pilot must submit a detailed monthly report to the Director of the Office of Foreign Assets Control on the activities conducted under that license.
The Director of the Office of Foreign Assets Control must submit a report to specified House and Senate committees on the date that is 1 year after the pilot is established, and annually thereafter until the end of the 1-year period beginning on the date the pilot is terminated. Each such report must include: (A) the number of licenses requested under the pilot; (B) the number of licenses granted under the pilot; and (C) a broad discussion of the utility of the pilot program.
After submitting each report described above, the Director of the Office of Foreign Assets Control must provide the same congressional committees with a classified briefing containing: (A) additional detail on applicants for a license; (B) identification of the firms granted a license; (C) information on the operation of the pilot, including how long each license lasted and personnel needed to manage the pilot; (D) information gleaned by OFAC from running the pilot; (E) the utility of that information; (F) any obstacles to the operation or utility of the pilot; and (G) any recommendations for improving or extending the pilot program.
Who is affected and how:
Private financial and compliance teams, and specialized private investigative firms: These entities may gain a new legal tool to execute controlled, nominal transactions (e.g., trial payments, test transfers) that help trace fraud, sanctions evasion, or other illicit finance schemes. Licensing creates compliance obligations (monthly reporting) and potential legal protections while operating under OFAC authorization.
Financial regulators and enforcement agencies (OFAC, FinCEN, law enforcement): OFAC will take on program design, licensing, monitoring, and reporting duties; FinCEN will coordinate on intelligence and anti‑money‑laundering controls. Agencies will incur administrative and oversight workloads and must define safeguards to prevent misuse or inadvertent sanctions violations.
Financial institutions and broader business community: Banks and payment processors may face requests for information or transactional flows tied to licensed activities; they will need to reconcile cooperation with privacy rules, suspicious-activity reporting, and existing sanctions compliance obligations.
Congress and oversight stakeholders: Regular and classified briefings increase congressional visibility into how the program is used and its national‑security implications.
Potential benefits:
Potential risks and costs:
Net effect:
Last progress July 22, 2025 (6 months ago)
Introduced on February 21, 2025 by Joyce Beatty
On motion to suspend the rules and pass the bill Agreed to by voice vote. (text: CR H3517)
Received in the Senate and Read twice and referred to the Committee on Banking, Housing, and Urban Affairs.