Sponsors (2)
The bill enables private-sector investigative transactions and stronger FinCEN/OFAC coordination to better detect sanctions evasion and financial crime, but it creates ongoing compliance costs and confidentiality/legal risks that could reduce private participation and expose firms to liability.
Financial institutions and private compliance firms: authorized to conduct narrowly scoped nominal transactions to investigate sanctions evasion, improving detection and disruption of illicit finance.
Financial institutions and law enforcement/regulators: strengthening the FinCEN Exchange by coordinating OFAC/FinCEN activities improves law enforcement and regulatory responses to financial crime.
Taxpayers, Congress, and policymakers: required annual public reports and classified briefings on pilot results increase transparency and provide policymakers better information to oversee and refine the program.
Licensed firms and government contractors participating in the pilot: must submit detailed monthly reports, creating recurring compliance costs and operational burdens.
Financial institutions and counterparties: conducting nominal transactions under the pilot could create legal or financial exposure if scope or safeguards are insufficient, complicating compliance with other laws.
Private sector firms and tech workers: public reporting combined with classified briefings raises confidentiality and operational-exposure risks that may deter some firms from participating.
Based on analysis of 2 sections of legislative text.
Introduced February 21, 2025 by Joyce Beatty · Last progress July 22, 2025
Authorizes the Office of Foreign Assets Control (OFAC) to run a pilot program that lets private-sector firms obtain licenses to carry out limited, nominal financial transactions as part of their investigations. OFAC must set up the pilot within one year, coordinate with FinCEN, require monthly reporting from licensed firms, and provide regular public reports and classified briefings to specified Congressional committees; the pilot ends five years after it begins.