One of the biggest organizational challenges for law enforcement agencies and Financial Intelligence Units (FIUs) in cross-border money laundering (ML) investigations is dealing with jurisdictions that do not have an FIU or lack proper AML enforcement structures. When funds are transferred through countries without effective AML frameworks, it becomes difficult to trace, freeze, or recover illicit assets.
Key challenges include:
Lack of mutual legal assistance agreements (MLAs), which slows down or prevents information-sharing.
Weak AML regulations in some countries, making it easier for criminals to exploit financial systems.
Jurisdictional conflicts, as different countries have different legal definitions and enforcement mechanisms for money laundering.

The Office of Foreign Assets Control (OFAC), part of the U.S. Department of the Treasury, is responsible for theadministration and enforcement of economic and trade sanctions. These sanctions are based on U.S. foreign policy and national security objectives and target:
Foreign countries and regimes
Terrorist organizations
Narcotics traffickers
Individuals and entities engaged in activities related to the proliferation of weapons of mass destruction OFAC acts under various authorities, including national emergency powers granted by the President and specific legislation. One of its primary tools is theSpecially Designated Nationals(SDN) List, which identifies individuals and entities whose assets are blocked and with whom U.S. persons are generally prohibited from dealing.
It is important to note that OFAC is not responsible for designating jurisdictions as primary money laundering concerns (a task handled by FinCEN under Section 311 of the USA PATRIOT Act), nor does it manage trade agreements.

Strong senior management support establishes accountability, allocates resources, and reinforces a culture of compliance throughout the organization. Effective AML programs require leadership commitment to ensure policies are implemented properly, risks are addressed promptly, and compliance teams maintain appropriate authority and independence.

Nominee shareholders may be used for legitimate commercial reasons; however, FATF guidance identifies nominee arrangements as a significant money laundering risk when they obscure beneficial ownership.
The greatest risk arises when nominee shareholders provide anonymity to the true beneficial owner, preventing transparency in public registers and complicating due diligence. Criminals may exploit this opacity to conceal ownership, evade sanctions, launder illicit proceeds, or avoid tax and regulatory scrutiny.
The ability to hide ownership undermines one of the core objectives of AML/CFT frameworks:
identifying and verifying beneficial owners. As a result, regulators require enhanced due diligence and clear documentation when nominee shareholders are involved.
Other features--such as administrative efficiency, compliance with local laws, or ease of share transfer--do not inherently increase financial crime risk when transparency and disclosure requirements are met.