Blog Post
Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Deficiencies
Published
12 months agoon
WASHINGTON—The Financial Crimes Enforcement Network (FinCEN) is informing U.S. financial institutions that the Financial Action Task Force (FATF), an intergovernmental body that establishes international standards for anti-money laundering, countering the financing of terrorism, and countering the financing of proliferation of weapons of mass destruction (AML/CFT/CPF), issued an additional public statement at the conclusion of its plenary meeting this month reiterating how the Russian Federation’s war of aggression against Ukraine continues to run counter to FATF’s principles, and, thus, the suspension of the membership of the Russian Federation continues to stand.[1] The FATF highlighted the potential risks to the international financial system, including growing financial connectivity of Russia with the Democratic People’s Republic of Korea (DPRK) and Iran, and risks of proliferation financing, malicious cyber activities, and ransomware attacks. In order to protect the international financial system, the FATF continues to urge all jurisdictions to remain vigilant to these risks.[2]
The FATF also updated its lists of jurisdictions with strategic AML/CFT/CPF deficiencies.[3] U.S. financial institutions should consider the FATF’s stance toward these jurisdictions when reviewing their obligations and risk-based policies, procedures, and practices.[4]
On February 23, 2024, the FATF added Kenya and Namibia to its list of Jurisdictions Under Increased Monitoring and removed Barbados, Gibraltar, Uganda, and the United Arab Emirates from that list.
The FATF’s list of High-Risk Jurisdictions Subject to a Call for Action remains the same, with Iran, DPRK, and Burma subject to calls for action. Iran and DPRK are still subject to the FATF’s countermeasures, while Burma is still subject to the application of enhanced due diligence, but not countermeasures.[5]
As part of the FATF’s listing and monitoring process to ensure compliance with its international standards, the FATF issued two statements: (1) Jurisdictions Under Increased Monitoring, which publicly identifies jurisdictions with strategic deficiencies in their AML/CFT/CPF regimes that have committed to, or are actively working with, the FATF to address those deficiencies in accordance with an agreed upon timeline; and (2) High-Risk Jurisdictions Subject to a Call for Action, which publicly identifies jurisdictions with significant strategic deficiencies in their AML/CFT/CPF regimes and calls on all FATF members to apply enhanced due diligence, and, in the most serious cases, apply countermeasures to protect the international financial system from the money laundering, terrorist financing, and proliferation financing risks emanating from the identified countries.
Jurisdictions Under Increased Monitoring
With respect to the FATF-identified Jurisdictions Under Increased Monitoring, U.S. covered financial institutions are reminded of their obligations to comply with the due diligence obligations for foreign financial institutions (FFI) under 31 CFR § 1010.610(a) in addition to their general obligations under 31 U.S.C. § 5318(h) and its implementing regulations. As required under 31 CFR § 1010.610(a), covered financial institutions should ensure that their due diligence programs, which address correspondent accounts maintained for FFIs, include appropriate, specific, risk-based, and, where necessary, enhanced policies, procedures, and controls that are reasonably designed to detect and report known or suspected money laundering activity conducted through or involving any correspondent account established, maintained, administered, or managed in the United States. Furthermore, money services businesses (MSBs) have parallel requirements with respect to foreign agents or foreign counterparties, as described in FinCEN Interpretive Release 2004-1, which clarifies that the AML program regulation requires MSBs to establish adequate and appropriate policies, procedures, and controls commensurate with the risk of money laundering and the financing of terrorism posed by their relationship with foreign agents or foreign counterparties. Additional information on these parallel requirements (covering both domestic and foreign agents and foreign counterparts) may be found in FinCEN’s Guidance on Existing AML Program Rule Compliance Obligations for MSB Principals with Respect to Agent Monitoring. Such reasonable steps should not, however, put into question a financial institution’s ability to maintain or otherwise continue appropriate relationships with customers or other financial institutions, and should not be used as the basis to engage in wholesale or indiscriminate de-risking of any class of customers or financial institutions. Financial institutions should also refer to previous interagency guidance on providing services to foreign embassies, consulates, and missions.
The United Nations (UN) continues to adopt several resolutions implementing economic and financial sanctions. Member States are bound by the provisions of these UN Security Council Resolutions (UNSCRs), and certain provisions of these resolutions are especially relevant to financial institutions. Financial institutions should be familiar with the requirements and prohibitions contained in relevant UNSCRs. In addition to UN sanctions, the U.S. Government maintains a robust sanctions program. For a description of current Office of Foreign Assets Control (OFAC) sanctions programs, please consult OFAC’s Sanctions Programs and Country Information.
High-Risk Jurisdictions Subject to a Call for Action
With respect to the FATF-identified High-Risk Jurisdictions Subject to a Call for Action, Burma remains in this category and the FATF urges jurisdictions to apply enhanced due diligence proportionate to the risks. As a general matter, FinCEN advises U.S. financial institutions to apply enhanced due diligence when maintaining correspondent accounts for foreign banks operating under a banking license issued by a country designated by an intergovernmental group or organization of which the United States is a member, as noncooperative with respect to international anti-money laundering principles or procedures, and with which designation the U.S. representative to the group or organization concurs.[6] U.S. financial institutions should continue to consult existing FinCEN and OFAC guidance on engaging in financial transactions with Burma.[7]
With respect to the FATF-identified High-Risk Jurisdictions Subject to a Call for Action, specifically, countermeasures, in the case of DPRK and Iran, U.S. financial institutions must comply with the extensive U.S. restrictions and prohibitions against opening or maintaining any correspondent accounts, directly or indirectly, for North Korean or Iranian financial institutions. Existing U.S. sanctions and FinCEN regulations already prohibit any such correspondent account relationships.
The Government of Iran and Iranian financial institutions remain persons whose property and interests in property are blocked under E.O. 13599 and section 560.211 of the Iranian Transactions and Sanctions Regulations (ITSR), 31 CFR Part 560. U.S. financial institutions and other U.S. persons continue to be broadly prohibited under the ITSR from engaging in transactions or dealings with Iran, the Government of Iran, and Iranian financial institutions, including opening or maintaining correspondent accounts for Iranian financial institutions. These sanctions impose obligations on U.S. persons that go beyond the relevant FATF recommendations. In addition to OFAC-administered sanctions, on October 25, 2019, FinCEN found Iran to be a Jurisdiction of Primary Money Laundering Concern and issued a final rule, pursuant to Section 311 of the USA PATRIOT Act, imposing the fifth special measure available under Section 311. This rule prohibits U.S. financial institutions from opening or maintaining correspondent accounts for, or on behalf of, an Iranian financial institution, and the use of foreign financial institutions’ correspondent accounts at covered United States financial institutions to process transactions involving Iranian financial institutions (31 CFR § 1010.661).
For jurisdictions removed from the FATF listing and monitoring process, U.S. financial institutions should take the FATF’s decisions and the reasons behind the delisting into consideration when assessing risk, consistent with financial institutions’ obligations under 31 CFR § 1010.610(a) and 31 CFR § 1010.210.
If a financial institution knows, suspects, or has reason to suspect that a transaction involves funds derived from illegal activity or that a customer has otherwise engaged in activities indicative of money laundering, terrorist financing, or other violation of federal law or regulation, the financial institution must file a Suspicious Activity Report.
***
Questions or comments regarding the contents of this release should be addressed to the FinCEN Regulatory Support Section at [email protected].
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Blog Post
Recording Loan Transactions and Interest Payments for Financial Accuracy
Published
2 days agoon
March 29, 2025
Accurate financial record-keeping is essential for any business, especially when it comes to managing loan transactions and interest payments. Properly tracking these financial obligations ensures compliance with accounting standards, simplifies tax reporting, and provides a clear picture of a company’s financial health. Whether you are a small business owner or a financial professional, understanding the correct way to record loans and interest expenses is key to maintaining an accurate and transparent accounting system.
Recording the Initial Loan Transaction
When a business secures a loan, the first step is properly recording the transaction in its accounting records. The loan amount should be recorded as a liability on the balance sheet, reflecting the total borrowed. At the same time, the cash received from the loan increases the company’s assets, keeping the accounting equation balanced. Depending on the nature of the loan, it may be classified as a short-term or long-term liability. Short-term loans, which are payable within a year, appear under current liabilities, while long-term loans extending beyond a year are categorized under non-current liabilities. Proper classification is important for financial reporting and for understanding a company’s liquidity position.
Understanding Loan Repayments
Once loan repayments begin, each payment typically consists of two components: principal and interest. The principal portion reduces the outstanding loan balance, while the interest is recorded as an expense. Correctly distinguishing between these components is critical, as they have different accounting and tax implications. The principal repayment affects the balance sheet by reducing liabilities, whereas the interest expense is recorded on the income statement and can often be deducted from taxable income.
Interest Payments and Their Financial Impact
Interest payments represent the cost of borrowing money and must be recorded separately from the principal repayment. Since interest expenses impact profitability, accurate tracking is essential for financial planning and tax reporting. Businesses must ensure they correctly allocate payments between interest and principal based on the loan’s amortization schedule. Amortization schedules outline how much of each payment goes toward interest and how much reduces the principal. Over time, the interest portion of payments decreases while the principal repayment increases. Using accounting software can help automate these calculations and ensure accuracy in financial reporting.
Utilizing Amortization Schedules
Most business loans follow an amortization schedule, which details the breakdown of each payment over the loan’s lifespan. Early payments in the schedule typically consist of a higher proportion of interest, with the principal component increasing over time. Understanding this structure allows businesses to plan their cash flow more effectively. Many businesses use accounting software to automatically track and apply amortization schedules, reducing the risk of errors in recording interest and principal payments.
Reconciling Loan Transactions
Regular reconciliation of loan statements with accounting records is crucial to detect discrepancies early. Businesses should compare loan balances in their books against lender-provided statements to identify any missing or incorrect entries. This process ensures financial accuracy and helps businesses stay on top of their debt obligations. Consistent reconciliation also provides valuable insights into a company’s financial position, enabling better decision-making regarding debt management and future borrowing needs.
Tax Considerations for Interest Payments
One of the key advantages of properly recording interest expenses is the potential tax benefits. In most cases, interest paid on business loans is tax-deductible, reducing taxable income and overall tax liability. To maximize these benefits, businesses must maintain detailed and accurate records of all interest payments. Proper documentation is also essential in the event of a tax audit, as authorities may require evidence of legitimate business expenses.
Importance of Transparency in Financial Reporting
Accurate loan recording is not just about compliance—it also plays a crucial role in financial transparency. Investors, lenders, and stakeholders rely on a company’s financial statements to assess its stability and growth potential. Misreporting loan transactions can distort financial statements, leading to misinformed business decisions and potential regulatory issues. By maintaining clear and accurate loan records, businesses can ensure financial integrity and build trust with stakeholders.
Leveraging Accounting Software for Loan Management
Managing loan transactions manually can be complex and time-consuming. Many businesses invest in accounting software that automates the recording of loan payments, interest calculations, and amortization schedules. These tools help reduce human error and provide real-time insights into a company’s financial standing. Additionally, software integration with banking systems allows for seamless transaction tracking and automated reconciliation.
Final Thoughts: Ensuring Accuracy in Loan Accounting
Properly recording loan transactions and interest payments is essential for maintaining financial accuracy, ensuring regulatory compliance, and optimizing tax benefits. By understanding loan structures, utilizing amortization schedules, and reconciling financial records regularly, businesses can manage their debt efficiently. Leveraging accounting software further streamlines the process, reducing errors and improving overall financial transparency. Ultimately, accurate loan accounting empowers businesses to make informed financial decisions, maintain healthy cash flow, and support long-term growth.

Navigating the regulatory landscape for nonprofits in New York City can be challenging, especially when working with city agencies. One of the most critical compliance requirements is Form 65A, which governs subcontractor approval processes. Understanding and adhering to these regulations is essential for maintaining funding, avoiding penalties, and ensuring the smooth operation of nonprofit programs.
Understanding Form 65A and Its Purpose
Form 65A is a compliance requirement for nonprofit organizations that engage in third-party contracts while receiving funding from New York City agencies. This form ensures transparency and financial accountability when nonprofits subcontract work to external vendors. The city uses this process to monitor subcontractor relationships and verify that funds are used responsibly. Nonprofits that fail to comply risk payment delays, contract disputes, and potential funding losses.
The $25,000 Threshold for Subcontractor Approval
The most important aspect of Form 65A is its threshold requirement. Any nonprofit that enters into a subcontractor agreement exceeding $25,000 must seek formal approval from the city. This applies not only to single contracts but also to multiple agreements with the same vendor if their total value surpasses this threshold. Understanding this rule is crucial for financial planning and vendor management, as failing to obtain approval can lead to significant administrative and financial consequences.
Registering Subcontractors and Required Documentation
The first step in the Form 65A compliance process is registering subcontractors in the City’s Payee Information Portal (PIP). Nonprofits must submit comprehensive details about the proposed vendor, including contract terms, service descriptions, and maximum payment values. If a contract exceeds $25,000, nonprofits must also provide proof of a competitive bidding process. Typically, this requires three bids from potential vendors unless the organization chooses a pre-approved Essensa network vendor. Proper documentation ensures a smooth approval process and minimizes the risk of rejection.
Key Timeline Considerations for Approval
Timeliness is essential when managing Form 65A submissions. Many New York City agencies require a minimum of 30 days to review and approve subcontractor agreements. Because of this, nonprofits should plan ahead and avoid engaging subcontractors before obtaining official authorization. In many cases, approvals are processed through Passport, the city’s digital procurement system, or via written confirmation. Organizations that fail to account for these processing times risk delays in project implementation and funding disbursement.
Risks of Non-Compliance and Financial Consequences
Failure to comply with Form 65A requirements can result in serious repercussions. If a nonprofit engages a subcontractor without prior approval, city agencies have the right to withhold payment for services rendered. This can lead to severe cash flow issues, disrupting operations and potentially jeopardizing critical programs. Non-compliance may also damage an organization’s reputation and eligibility for future city contracts. By prioritizing compliance, nonprofits can avoid these risks and maintain financial stability.
Best Practices for Ensuring Compliance
To simplify compliance and reduce administrative burdens, nonprofits should adopt best practices for managing subcontractor agreements. Key strategies include:
- Submitting complete documentation upfront – Providing all necessary information at the time of submission minimizes delays caused by incomplete paperwork.
- Maintaining organized contract records – Keeping detailed records of all third-party agreements ensures that organizations can track contract values and submission deadlines.
- Aligning subcontractor terms with city contract requirements – Ensuring that subcontractor agreements reflect the terms and conditions of the primary city contract helps avoid conflicts during the approval process.
- Implementing a vendor management system – Tracking all agreements and cumulative spending with subcontractors can prevent unintentional violations of the $25,000 threshold.
Understanding Second-Tier Subcontractor Approval
Many nonprofits overlook the fact that second-tier subcontractors—vendors hired by an approved subcontractor—must also be reviewed under Form 65A requirements. Organizations should establish clear vendor oversight protocols to ensure that all subcontractors, including those hired indirectly, comply with city regulations. By proactively managing these relationships, nonprofits can prevent compliance issues before they arise.
Staying Compliant While Advancing Your Mission
For nonprofits working with New York City agencies, Form 65A compliance is a crucial aspect of financial and operational management. By understanding the approval process, adhering to documentation requirements, and maintaining strict oversight of subcontractor agreements, organizations can avoid funding disruptions and regulatory penalties. With a proactive approach to compliance, nonprofits can focus on their mission—serving communities and making a positive impact—without unnecessary administrative hurdles.
Blog Post
How to better Handle Employee Reimbursements for Efficiency and Accuracy
Published
2 weeks agoon
March 16, 2025
In today’s fast-paced business environment, managing employee reimbursements effectively is essential for financial accuracy, compliance, and employee satisfaction. A well-structured reimbursement process ensures that employees are reimbursed fairly and promptly while minimizing administrative burdens and preventing financial mismanagement. Below are the best practices for streamlining your employee reimbursement process.
Establish Clear Reimbursement Policies
A transparent and well-documented reimbursement policy is the foundation of an efficient process. Clearly define what expenses are eligible for reimbursement, such as travel costs, office supplies, or client meetings. Outline submission deadlines, required documentation, and approval procedures. Ensure these guidelines are easily accessible to all employees, either through an internal portal or employee handbook. Consistency in enforcing policies helps prevent misunderstandings and reduces the risk of fraudulent claims.
Leverage Digital Expense Management Systems
Manual expense reporting can lead to errors, delays, and inefficiencies. Implementing digital expense management software automates the reimbursement process, making it faster and more accurate. These systems allow employees to submit expenses in real-time, track approvals, and receive payments seamlessly. Automation reduces paperwork, minimizes human error, and improves financial transparency.
Set Reasonable Submission Deadlines
Encouraging employees to submit reimbursement claims promptly helps maintain accurate financial records and ensures timely payments. Setting deadlines, such as requiring monthly or quarterly expense reports, prevents last-minute rushes and helps the finance team manage cash flow effectively. Communicate these deadlines clearly and send reminders to employees to avoid delays in processing.
Require Detailed Documentation for Expense Claims
Proper documentation is crucial for compliance and financial accountability. Employees should provide itemized receipts, invoices, or proof of transactions for each claimed expense. Additionally, requiring a brief description of the expense purpose ensures alignment with company policies and tax regulations. Standardizing documentation requirements minimizes disputes and simplifies audits.
Implement a Multi-Level Approval System
A tiered approval process adds an extra layer of oversight while maintaining efficiency. For example, low-value reimbursements can be approved by direct supervisors, while high-value claims require review from senior management or the finance department. This system ensures that routine expenses are processed quickly while larger expenditures receive the necessary scrutiny.
Conduct Regular Audits for Compliance and Fraud Prevention
Periodic audits of reimbursement claims help identify trends, ensure policy adherence, and detect potential fraud. Reviewing expenses regularly allows businesses to spot inconsistencies, prevent duplicate claims, and adjust policies as needed. Automated auditing tools can flag suspicious activity, reducing the risk of financial misconduct.
Provide Employee Training on Reimbursement Policies
Many reimbursement issues stem from a lack of understanding of company policies. Conduct training sessions or provide instructional materials to educate employees on reimbursement procedures, policy updates, and best practices for submitting claims. Ensuring employees are well-informed helps prevent errors and reduces the need for excessive back-and-forth communication.
Offer Direct Deposit for Faster Reimbursements
Processing reimbursements through direct deposit instead of issuing paper checks accelerates payments and improves employee satisfaction. Employees appreciate timely reimbursements, especially for significant out-of-pocket expenses. Direct deposit also streamlines administrative work, reducing the time and costs associated with manual check processing.
Integrate Reimbursement Processes with Accounting Systems
For seamless financial management, the reimbursement process should integrate with the company’s accounting software. This ensures accurate financial reporting, simplifies reconciliation, and reduces manual data entry errors. Integration also allows businesses to track reimbursement expenses in real time, aiding in budgeting and forecasting.
Implement a Corporate Card Program for Frequent Business Expenses
For employees who frequently incur business expenses, issuing corporate credit cards can simplify the reimbursement process. Corporate cards eliminate the need for employees to use personal funds and wait for reimbursement. Additionally, transactions are automatically recorded in expense management systems, reducing paperwork and improving tracking. Businesses can also negotiate better terms with corporate card providers, including cashback rewards and expense categorization features.
Building a Transparent and Efficient Reimbursement System
An effective employee reimbursement system promotes financial transparency, ensures compliance, and enhances employee satisfaction. By implementing clear policies, leveraging technology, enforcing proper documentation, and streamlining approval processes, businesses can create a reimbursement structure that minimizes delays and prevents errors. When employees trust that their expenses will be reimbursed efficiently, they can focus on their work without financial concerns.
By following these best practices, businesses can optimize their reimbursement processes, reduce administrative burdens, and maintain financial integrity while supporting employees in their professional activities.

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