- FIU held the “AML/CFT Policy Advisory Committee” meeting and announced the “2026 Key Operational Plan for AML”
The Financial Intelligence Unit (FIU) held the “Anti-Money Laundering / Counter-Financing of Terrorism (AML/CFT) Policy Advisory Committee” meeting on Thursday, February 5, 2026 and announced the “2026 Key Operational Plan for AML.”
The FIU highlighted that it has achieved several key institutional milestones, including expanded suspicious transaction reporting (STR) and dissemination of analytical information, the introduction of a reporting regime for virtual asset service providers (VASPs), and the world’s first legislative adoption of the ’travel rule’. Concurrently, the FIU acknowledged structural challenges such as the continued rise in crimes that harm the public and the growing use of high-risk transaction methods, as well as limitations in analytical infrastructure.
Accordingly, in 2026, the FIU plans to pursue the following tasks as its key policy priorities:
(i) strengthening capabilities to respond to serious crimes affecting the public and transnational crimes;
(ii) enhancing the AML framework for virtual assets;
(iii) improving the AML capabilities of financial companies, etc.; and
(iv) improving alignment with global standards.
[Key Strategies and Tasks]
This operational plan is expected to have a significant impact on how financial institutions, VASPs, and have the relevant industries fulfill their AML/CFT obligations going forward, as well as on the supervisory and inspection environment. Below we outline the key elements of the plan and its practical implications.
I. KEY DISCUSSIONS
A. Strengthening response capabilities against serious crimes affecting the public and transnational crimes
(i) Introduction of a Suspicious-Account Suspension Regime
Under the current framework, even where an account is suspected of being related to proceeds of crime, it has generally been difficult to freeze such account without a court order, except in limited circumstances. Going forward, however, a system is expected to be introduced under which the FIU may directly decide to suspend accounts suspected of criminal activity at the request of investigative authorities, and the legal basis for such system is planned to be established in the FTRA.
At the initial stage of implementation, the scope of application will be limited to certain serious crimes that harm the public, such as drug offenses, gambling, and terrorist financing, and the system will be operated primarily in respect of accounts identified at the request of investigative authorities. Thereafter, as the FIU’s own analytical capabilities accumulate, the scope is expected to be expanded on a phased basis. Concurrently, to minimize infringement of rights and interests (including property rights), the authorities plan to strictly define the grounds, procedures, and requirements for account-suspension decisions and to establish procedures for filing objections.
< Comparison of account suspension regimes >
(ii) Inclusion of international criminal organizations among persons subject to restrictions on financial transactions, etc.
At present, the designation of persons subject to restrictions on financial transactions, etc. is limited to persons involved in terrorism or the proliferation of weapons of mass destruction. Going forward, institutional improvements are expected to be pursued to expand the scope of such designation to include international criminal organizations, and a legal basis for this expansion is planned to be introduced under the Counter-Terrorism Financing Act.
This initiative is intended to secure more direct financial sanctions tools in response to the recent increase in transnational organized crime (for example, individuals associated with the Prince Group, a Cambodian criminal organization), and may be viewed as an effort to enhance alignment with the sanctions frameworks of major jurisdictions such as the United States and the United Kingdom.
(iii) Strengthening FIU review and analytical functions
To enhance the quality of STR analysis, the FIU plans to institutionalize strategic analysis on an ongoing basis and expand theme-based intensive analyses focusing on prevalent crimes such as drug offenses, scams, and illegal online gambling. The FIU also plans to enhance expertise through (i) introduction of an AI-based review and analysis system, (ii) expanded use of virtual-asset analytics tools (e.g. Chainalysis), and (iii) strengthened specialized training.
(iv) Enhancement of international cooperation
To respond to the increase in transnational crimes, including a Cambodian scam case, the FIU plans to gradually establish cooperation frameworks and expand the operation of hotlines and regular consultative bodies with China, Singapore, and the five Mekong countries (Cambodia, Vietnam, Laos, Thailand, and Myanmar). In addition, the FIU intends to strengthen its role within the Financial Action Task Force (FATF) and the Egmont Group, and to actively participate in international projects.
B. Enhancing the virtual asset anti-money laundering framework
For further details regarding the virtual asset AML framework, please refer to the BKL Newsletter dated February 9, 2026.
(i) Strengthening transaction monitoring, including expansion of the virtual asset Travel Rule
Currently, the Travel Rule applies only to transfers of virtual asset worth KRW 1 million or more between domestic exchanges. In response to the diversification of transaction types, institutional improvements are expected to be pursued to expand the scope of application to transactions of assets worth less than KRW 1 million and to impose information collection obligations on receiving exchanges. In addition, transactions between domestic exchanges and overseas exchanges or private wallets will, in principle, be permitted on a limited basis only where the sender and recipient are the same person. Transactions other than those involving low-risk overseas exchanges will be classified as high-risk transactions, to which enhanced customer due diligence (EDD), transaction amount limits, strengthened STR obligations, and other additional risk-mitigation controls will be applied.
(ii) Enhancement of the AML framework relating to stablecoins
At present, stablecoins are treated in the same manner as general virtual assets without a dedicated AML regulatory framework. However, considering the Financial Action Task Force (FATF)’s assessment that money laundering risks may increase if stablecoins become widely used as a means of payment, efforts are underway to establish a tailored regulatory framework. In line with the institutionalization of stablecoins, the AML framework will be comprehensively strengthened across the entire lifecycle, including issuance, circulation, and use, and amendments to the FTRA are currently underway for this purpose.
(iii) Strengthened supervision of VASPs and strict sanctions
Currently, most VASPs have weak foundational AML capabilities due to persistent operating losses and other financial difficulties. In addition, recent on-site inspections of the five KRW-market operators identified numerous violations of the FTRA, including inadequate customer due diligence and transactions with unreported operators. As a result, sanctions such as business suspensions and administrative fines have already been imposed on certain operators. Going forward, financial authorities plan to (i) inspect and encourage managerial improvements among smaller operators and (ii) pursue strict sanctions against operators that violate applicable laws and regulations.
C. Enhancing AML capabilities of financial companies, etc.
(i) Improvement of the AML responsibility framework
The FTRA will clarify that the reporting officer must be an executive officer, strengthening accountability for AML-related management. In addition, fragmented provisions on the preparation and operation of internal guidelines will be reorganized and consolidated, and sanctions provisions for violations will be clarified.
(ii) Legislative institutionalization of AML compliance evaluations
Participation in the AML compliance evaluation, which is currently conducted on a voluntary basis twice a year, will be made mandatory. Legal grounds will be prepared to impose sanctions in cases involving the submission of false information or refusal to submit required materials.
(iii) Enhancement of AML inspections and sanctions
AML inspection and sanctions frameworks will also be improved, including by focusing on companies with high money-laundering risk. As part of efforts to further embed a risk-based approach in inspections and sanctions, stricter sanctions will be imposed where risk levels are high. Conversely, where risk levels are low, if a financial company agrees to corrective measures, remedial actions, and measures to prevent recurrence, the authorities may terminate sanction procedures or order corrective measures in lieu of sanctions. In this regard, the authorities are reviewing the introduction of a “consent order system,” under which enhanced sanctions would be imposed if corrective measures are not implemented.
D. Improving alignment with global standards
(i) Establishment of a framework to identify, verify, and use beneficial ownership information of legal entities
At present, financial company, etc. individually identify the beneficial owners of their corporate customers. However, unlike in the United States and Europe, there is no centralized framework for the management and verification of such information. In accordance with the revised FATF Recommendation 24, the FIU plans to gradually establish a framework under which beneficial ownership information of legal entities will be managed and utilized at the government level.
Specifically, the FIU intends, in the initial phase, to build a database of beneficial owners of legal entities by utilizing beneficial ownership information obtained by financial companies, etc. in connection with STR filings. Thereafter consider expanding the scope of such database. In the mid to long term, the FIU plans to allow legal entities themselves, AML-obligated entities such as financial company, etc., and law enforcement authorities to access and cross-verify the database, thereby effectively preventing money laundering involving shell or sham companies and fake passbook accounts opened in the name of legal entities.
(ii) Introduction of AML obligations for DNFBPs
In order to enhance alignment with FATF international standards, the FIU plans to seriously consider the introduction of AML obligations for designated non-financial businesses and professions (DNFBPs), including lawyers, certified public accountants, and tax accountants. Currently, among DNFBPs, only casino operators assume AML obligations. However, the FATF recommends imposing customer due diligence and suspicious transaction reporting obligations on professionals who perform certain activities, such as real estate transactions, management of client funds/assets or accounts, and company formation and administration.
The FIU has stated that it will review the introduction of such obligations primarily based on the FATF’s core recommendations (customer due diligence and STR obligations), and that the specific scope and modalities will be established through amendments to the FTRA following consultations with the relevant professional sectors.
(iii) Joint government task force in preparation for the FATF mutual evaluation
In preparation for the fifth round of the FATF mutual evaluation scheduled for 2028, the FIU plans to establish and operate a joint government task force involving relevant ministries and agencies. Through this task force’s efforts, the FIU intends to recalibrate AML/CFT policies at the national level, review the implementation status of legal and institutional improvements, and conduct preliminary mock evaluations to strengthen overall preparedness.
II. IMPLICATIONS
The “2026 Key Operational Plan for AML” is assessed as signaling a systematic and comprehensive advancement of the AML framework across the entire financial sector, including a comprehensive amendment to the FTRA for the first time in approximately 25 years, to address money laundering risks arising from transnational crime and the use of virtual assets.
Accordingly, there is a growing need for financial companies, etc. and VASPs to go beyond a merely reactive regulatory compliance approach and to conduct a comprehensive review of their currently operating AML systems and the status of their compliance with obligations under the FTRA. In addition, financial companies, etc. and VASPs will be required to review and enhance AML operations, including internal rules, transaction monitoring, and customer due diligence frameworks, to align with the policy directions presented by the FIU.
A. Strengthening response capabilities against serious crimes affecting the public and transnational crimes
(i) Enhancement of frameworks for FIU requests for account suspension
If a suspicious-account suspension system is introduced, accounts may be suspended pursuant to an FIU decision even before a court judgment. Financial companies and VASPs will need to proactively establish procedures covering receipt of FIU requests, internal review and implementation, customer notification, and objection-handling. In addition, there will be an increasing need to develop detailed internal manuals to prevent gaps between internal rules and actual operational practices.
(ii) Enhancement of transaction monitoring and STR rules for high-risk crime types
As specific serious crimes harming the public (e.g., drugs, gambling, terrorist financing) are explicitly identified as crimes subject to account suspension, the need to more precisely detect transaction patterns linked to those crimes and to provide more specific explanations of criminal linkage when preparing STRs is expected to increase. This, in conjunction with the FIU’s strengthened review and analytical functions and the advancement of AI-based analysis, suggests that the substantive usability and quality of STRs, rather than the sheer number of reports filed, will become more important.
B. Enhancing the virtual asset AML framework
(i) Need to redesign transaction monitoring systems in preparation for the “full-scale application” of the Travel Rule
If the scope of the Travel Rule is expanded to cover transactions less than KRW 1 million and information collection obligations are imposed on receiving exchanges as well, the level of monitoring applied to virtual asset transfer transactions is expected to increase significantly. In particular, as transactions between domestic exchanges and overseas exchanges or private wallets will be permitted only on a limited basis, and transactions other than those involving low-risk overseas exchanges will be classified as high-risk transactions, a comprehensive review of internal systems and operational standards may be required, including counterparty identification, criteria for determining common ownership or control, and risk classification frameworks.
(ii) Full-scale expansion of AML obligations relating to the issuance and circulation of stablecoins
If a dedicated AML regulatory framework is introduced for stablecoins, issuers will be required to assume customer due diligence, STR, and internal control obligations comparable to those applicable to financial companies, etc. This may necessitate a comprehensive re-evaluation of business structures and operating models for certain VASPs. In addition, as enhanced due diligence (EDD) and risk-based approaches (RBA) are strengthened with respect to stablecoin transactions involving private wallets and overseas operators, and as the freezing and burning functionalities are required to be embedded at the issuance stage, technical and operational readiness is expected to become increasingly important.
C. Enhancing AML capabilities of financial company, etc.
(i) Need to reorganize governance as AML responsibilities are elevated to the executive level
Expressly requiring an executive officer to be reporting officer and strengthening accountability for AML-related management may be interpreted as an effort to reposition AML functions as a core responsibility at the senior management level. Accordingly, financial companies, etc. will need to review whether their AML responsibility matrices, job descriptions, and reporting lines are aligned with actual operational practices, and to more clearly define accountability and decision-making structures under their internal rules.
(ii) Growing importance of data management and reporting systems following the mandatory implementation of AML compliance evaluations
If the AML compliance evaluation, which has thus far been operated on a voluntary basis, is institutionalized by law, key management considerations are expected to extend beyond mere participation in evaluation to include the accuracy, consistency, and objective verifiability of submitted materials. As legal grounds for sanctions in cases of false submissions or refusal to submit required materials are expected to be established, there will be an increasing need to clearly define the calculation standards for AML-related indicators and evaluation data, and to put in place internal procedures for their verification and validation in advance.
D. Improving alignment with global standards
(i) Structural changes in how beneficial ownership information is managed
A shift is underway from the existing approach, under which beneficial ownership information of legal entities has been identified and managed at the level of individual financial companies, to a system led by the FIU involving the establishment of a centralized database and cross-verification mechanisms. As a result, financial companies and VASPs may face increased compliance burdens with respect to ensuring the accuracy, consistency, and timeliness of beneficial ownership information collected and retained from corporate customers. In addition, a comprehensive review of existing customer due diligence and beneficial ownership verification procedures may be required.
(ii) Growing importance of internal controls as STR and beneficial ownership data are utilized more
As beneficial ownership information will initially be database-built mainly through STR filings, the completeness and consistency of beneficial ownership information included in STRs may become a key metric. Beyond mere formal identification, there is likely to be an increasing need for the grounds for determining beneficial ownership and the systematic management of the related supporting documentation.
III. ROLE OF BKL’S AML STRATEGY CONSULTING TEAM
We, BKL’s AML Strategy Consulting Team provide comprehensive, end-to-end services designed to help clients prevent regulatory risks in advance and respond effectively in the aftermath, drawing on its extensive on-the-ground experience in the AML field and its deep expertise in response to regulatory authorities. Going beyond conventional advisory services, we contribute to strengthening clients’ AML response capabilities through practical, field-oriented solutions and systematic regulatory response strategies.
(i) AML system reviews: We analyze whether a company’s internal control framework is appropriately designed and effectively operating in actual business departments by conducting thorough AML system reviews. We directly examine the status of system implementation across relevant departments and, based on the findings, provides a report containing practical and actionable improvement measures. This report will serve as an important foundation for mitigating inspection and sanctions risks in advance.
(ii) Day-to-day advisory: We provide advice on routine AML-related matters, including prompt responses to day-to-day legal, operational, and risk-related inquiries. In addition, we proactively review potential AML risks arising from new product launches or changes in business structures and presents appropriate response strategies. Such advisory services also reflect the evolving regulatory environment, including FATF recommendations and FIU guidelines.
(iii) Independent AML audits: We conduct independent AML audits required under the FTRA as a key area of work. In conducting such audits, AML-specialized attorneys (holding ACAMS certification) and subject-matter experts directly participate on site, combining effective audit execution with consulting that reflects the characteristics and practical realities of the audited institution. Beyond a mere compliance check, we deliver tailored audit reports designed to drive substantive and sustainable improvements.
(iv) Inspection/sanctions response: We support response strategy, preparation of explanations/reports, and external communications, including the formulation of response strategies based on inspection findings by financial authorities, preparation of explanatory materials and reports, and advice on external communications. Where sanction procedures are initiated, we minimize clients’ burdens by representing them throughout the entire process, including attendance at hearings and submission of written opinions.
We, the AML Strategy Consulting Team serve not merely as a post-event risk manager, but as a strategic partner that helps clients proactively mitigate risks and respond flexibly to regulatory changes.
* * *
For any inquiry or questions regarding the content of this newsletter, please contact us.
[Korean version]
