On June 23, Treasury announced coordinated action to disrupt a Southeast Asia-based transnational criminal organization (TCO) involved in fraud and money laundering operations. The TCO was previously designated by Treasury in October 2025 (previously covered by InfoBytes here) for its role in a global criminal enterprise allegedly built on what Treasury referred to as “scam compounds.” OFAC sanctioned nine individuals and 26 entities linked to the TCO, including its leadership, investors in the alleged scam compounds, and front companies, pursuant to Executive Order 13581 as amended. In parallel, FinCEN proposed amending an October 2025 final rule — which designates a Cambodia-based financial group as a foreign financial institution of primary money laundering concern under Section 311 of the USA PATRIOT Act — to include an additional entity and any successor entity within the group’s definition. Separately, DOJ announced the seizure of backend infrastructure used by the designated financial group to facilitate money laundering services.

OFAC’s designations target, among others, the TCO’s second-in-command, major investors in scam compounds used to facilitate fraud operations, and entities spanning real estate, aviation, banking, and front companies across Cambodia, Hong Kong, Thailand, and the United Kingdom. The action was taken in coordination with international law enforcement partners and in furtherance of Executive Order 14390, “Combating Cybercrime, Fraud, and Predatory Schemes Against American Citizens” (covered here).

FinCEN’s proposed rule addresses the designated group’s efforts to circumvent the special measure imposed under the final rule by continuing to operate as a financial institution under a different name. FinCEN stated that a newly licensed Cambodia-based payment services institution has effectively assumed the business role of the group’s prior payment entity following publication of the final rule. The proposed amendment would also add a defined term for “successor entity,” meaning any person that replaces the designated group by acquiring its assets, in whole or in part, or carrying out its affairs under a new name. Written comments on the proposed rule are due by July 27.