--- title: "United States — Alaska (US-AK) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/united-states-alaska/ source_html: /jurisdictions/united-states-alaska/index.html description: "Financial integrity intelligence for United States – Alaska (US-AK): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: c92a8246b4e9ff8da4c88dbffb274e0f83702e0594b3c7d3548ca3bedcb72793 generator: "fe-fleet/md-twin@1.0" --- # United States — Alaska (US-AK) — Financial-Integrity Intelligence · Sentinel Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved. Financial Integrity Monitor # United States — Alaska US-AK Domains covered 8 of 8 Sources 163 Role actions 8 Horizon <90d 1 Jurisdiction profile FATF status: Compliant Tier: B Risk direction: Increasing Enablement vs enforcement: Mixed Alaska operates under the federal BSA/FinCEN framework plus state licensing under the Alaska Uniform Money Services Act (AS 06.55), administered by the Division of Banking and Securities (DBS), which supervises MSBs, money transmitters and virtual-currency businesses and maintains an OFAC information-sharing MOU. More Alaska has no independent AML statute or beneficial-ownership registry beyond incorporation of federal BSA obligations, and relies on the now-narrowed federal Corporate Transparency Act for BO visibility. Key deficiencies - No state beneficial-ownership registry; sole reliance on the federal CTA, which since March 2025 exempts domestically formed entities (including Alaska LLCs) from BOI reporting - Alaska/Anchorage residential real estate is outside FinCEN's title-insurance GTO coverage, leaving all-cash shell-company purchases unreported pending the March 2026 RRE Rule rollout - Rising use of Alaska-registered agents/LLCs by out-of-state and international clients with limited verification, per ICIJ corporate-formation reporting - Emerging, loosely supervised crypto-ATM (CVC kiosk) footprint tied nationally to elder-fraud and scam-related fund flows Recent developments (18m) - FinCEN CDD/beneficial-ownership 'Account Opening Exceptive Relief Order' (FIN-2026-R001, Feb 13, 2026) loosening new-account BO verification nationally - FinCEN CVC Kiosk Notice FIN-2025-NTC1 (Aug 4, 2025) addressing crypto-ATM fraud and money-laundering typologies applicable to Alaska's kiosk footprint - CTA domestic 'reporting company' exemption interim final rule (March 21, 2025), removing Alaska-formed entities from federal BOI reporting - FinCEN AML/CFT Program reform NPRM (April 7, 2026) proposing a risk-based supervisory overhaul of BSA program requirements, comment period closed June 9, 2026 - GENIUS Act stablecoin framework enacted (July 2025), extending BSA/AML and OFAC sanctions-compliance obligations to payment stablecoin issuers nationwide United States federal law that applies in United States – Alaska is covered once, on the [United States](/jurisdictions/us/) page. This page covers United States – Alaska’s own layer: its own law, regulators and enforcement. Brief ## Lead signal #### Lead Signal Alaska's financial-integrity posture moved this cycle on the strength of two coordinated developments in the states crypto-kiosk oversight architecture. On 7 October 2026, the Alaska Division of Banking and Securities joined a 34-regulator multistate settlement and consent order against Coinme Inc. (NMLS #1185542), finding that the virtual-currency-kiosk operator had failed to maintain an effective Bank Secrecy Act/Anti-Money Laundering program. The order requires Coinme to shut down affected kiosks, complete an independent BSA/AML review, and pay 2.5 million dollars in penalties and costs. The enforcement action lands six days after a new statutory licensing gate for kiosk operators, enacted under SB 249 (Ch. 50 SLA 26), took effect on 1 October 2026, requiring virtual-currency-kiosk operators to hold a money-transmission license, obtain prior departmental approval for each location, cap fees, post fraud warnings, file periodic reports, and maintain written anti-fraud and BSA/AML-consistent policies. Read full brief #### Lead Signal Alaska's financial-integrity posture moved this cycle on the strength of two coordinated developments in the states crypto-kiosk oversight architecture. On 7 October 2026, the Alaska Division of Banking and Securities joined a 34-regulator multistate settlement and consent order against Coinme Inc. (NMLS #1185542), finding that the virtual-currency-kiosk operator had failed to maintain an effective Bank Secrecy Act/Anti-Money Laundering program. The order requires Coinme to shut down affected kiosks, complete an independent BSA/AML review, and pay 2.5 million dollars in penalties and costs. The enforcement action lands six days after a new statutory licensing gate for kiosk operators, enacted under SB 249 (Ch. 50 SLA 26), took effect on 1 October 2026, requiring virtual-currency-kiosk operators to hold a money-transmission license, obtain prior departmental approval for each location, cap fees, post fraud warnings, file periodic reports, and maintain written anti-fraud and BSA/AML-consistent policies. Read together, the statute and the enforcement action describe an architecture rather than an isolated incident: Alaska built the licensing and AML-policy gate for kiosk operators and, within days, demonstrated a willingness to use the states existing Uniform Money Services Act framework to discipline a kiosk operator for the deficiency the new gate is designed to prevent. The underlying money-transmission statute, AS 06.55, has long carried a BSA/AML program obligation for licensees; SB 249 extends that obligation explicitly to the kiosk-operator category, and the Coinme order shows the obligation is being enforced in practice rather than left dormant on the books. #### Other Developments A broader statutory rewrite is already enacted and will commence on a later date. Separately from the kiosk-specific statute, SB 86 (Ch. 48 SLA 26) rewrites AS 06.55 to add virtual-currency exchange, transfer, storage, and administration on behalf of another person to the definition of licensed money-transmission activity, and raises the maximum civil penalty to 10,000 dollars per day. Most provisions of SB 86 commence on 1 July 2027, with existing licensees permitted to continue under current licenses until renewal or 1 July 2028, whichever is later. The enrolled bill text is a primary legislative source and the enactment fact is well supported; the practical compliance detail of how the broadened definition will be applied to specific virtual-currency business models remains to be seen as the commencement date approaches. The kiosk statute's operational detail rests on secondary commentary rather than exclusively on the enrolled text. While the core fact that SB 249 requires a money-transmission license for kiosk operators is well evidenced from a primary regulatory source, the granular detail of the reporting and fee-cap requirements described in secondary legal commentary has not been independently cross-checked against the enrolled bill text itself, and is treated accordingly as a probable rather than confirmed account of the statutes full operational content. #### Cross-Monitor Connections The Coinme multistate order is a finding that properly belongs to this crypto and financial-innovation signal but also touches payments-market infrastructure directly: a kiosk operator licensed to transmit money and bound by AML-policy duties is simultaneously a retail payment access point, so the same consent order that evidences a BSA/AML program failure also evidences a licensing and conduct failure visible to payment-market monitoring. The 34-regulator multistate structure of the action is itself a signal of enablement and enforcement coordination worth tracking across state lines rather than reading as an Alaska-specific episode. No sanctions-architecture, beneficial-ownership, enabler-jurisdiction, conflict-finance, or compliance-technology signal specific to Alaska arose this cycle, and no commercial transaction among integrity-infrastructure firms was evidenced for this jurisdiction. #### Outlook The near-term marker to watch is whether other kiosk operators licensed in Alaska undergo the same scrutiny that produced the Coinme order, which would confirm the enforcement posture as a sustained program rather than a single multistate settlement. The more structurally significant date is 1 July 2027, when SB 86's broadened statutory definition of virtual-currency business activity is due to commence, with existing licensees permitted to continue operating under current licenses until renewal or 1 July 2028, whichever is later, as scheduled. Until that date, Alaska's crypto-adjacent money-transmission oversight operates under a bifurcated structure: the kiosk-specific gate and AML-policy duty already in force, and the broader statutory redefinition still pending. Earlier periodic briefs (8) 4 Nov 2026 · fim-2026-11-01 #### Lead Signal Alaska's financial-integrity posture moved on the strength of two coordinated developments in the states crypto-kiosk oversight architecture. On 7 October 2026, the Alaska Division of Banking and Securities joined a 34-regulator multistate settlement and consent order against Coinme Inc. (NMLS #1185542), finding that the virtual-currency-kiosk operator had failed to maintain an effective Bank Secrecy Act/Anti-Money Laundering program. The order requires Coinme to shut down affected kiosks, complete an independent BSA/AML review, and pay 2.5 million dollars in penalties and costs. The enforcement action lands six days after a new statutory licensing gate for kiosk operators, enacted under SB 249 (Ch. 50 SLA 26), took effect on 1 October 2026, requiring virtual-currency-kiosk operators to hold a money-transmission license, obtain prior departmental approval for each location, cap fees, post fraud warnings, file periodic reports, and maintain written anti-fraud and BSA/AML-consistent policies. Read together, the statute and the enforcement action describe an architecture rather than an isolated incident: Alaska built the licensing and AML-policy gate for kiosk operators and, within days, demonstrated a willingness to use the states existing Uniform Money Services Act framework to discipline a kiosk operator for the deficiency the new gate is designed to prevent. The underlying money-transmission statute, AS 06.55, has long carried a BSA/AML program obligation for licensees; SB 249 extends that obligation explicitly to the kiosk-operator category, and the Coinme order shows the obligation is being enforced in practice rather than left dormant on the books. #### Other Developments A broader statutory rewrite is already enacted and will commence on a later date. Separately from the kiosk-specific statute, SB 86 (Ch. 48 SLA 26) rewrites AS 06.55 to add virtual-currency exchange, transfer, storage, and administration on behalf of another person to the definition of licensed money-transmission activity, and raises the maximum civil penalty to 10,000 dollars per day. Most provisions of SB 86 commence on 1 July 2027, with existing licensees permitted to continue under current licenses until renewal or 1 July 2028, whichever is later. The enrolled bill text is a primary legislative source and the enactment fact is well supported; the practical compliance detail of how the broadened definition will be applied to specific virtual-currency business models remains to be seen as the commencement date approaches. The kiosk statute's operational detail rests on secondary commentary rather than exclusively on the enrolled text. While the core fact that SB 249 requires a money-transmission license for kiosk operators is well evidenced from a primary regulatory source, the granular detail of the reporting and fee-cap requirements described in secondary legal commentary has not been independently cross-checked against the enrolled bill text itself, and is treated accordingly as a probable rather than confirmed account of the statutes full operational content. #### Cross-Monitor Connections The Coinme multistate order is a finding that properly belongs to this crypto and financial-innovation signal but also touches payments-market infrastructure directly: a kiosk operator licensed to transmit money and bound by AML-policy duties is simultaneously a retail payment access point, so the same consent order that evidences a BSA/AML program failure also evidences a licensing and conduct failure visible to payment-market monitoring. The 34-regulator multistate structure of the action is itself a signal of enablement and enforcement coordination worth tracking across state lines rather than reading as an Alaska-specific episode. No sanctions-architecture, beneficial-ownership, enabler-jurisdiction, conflict-finance, or compliance-technology signal specific to Alaska arose, and no commercial transaction among integrity-infrastructure firms was evidenced for this jurisdiction. #### Outlook The near-term marker to watch is whether other kiosk operators licensed in Alaska undergo the same scrutiny that produced the Coinme order, which would confirm the enforcement posture as a sustained program rather than a single multistate settlement. The more structurally significant date is 1 July 2027, when SB 86's broadened statutory definition of virtual-currency business activity is due to commence, with existing licensees permitted to continue operating under current licenses until renewal or 1 July 2028, whichever is later, as scheduled. Until that date, Alaska's crypto-adjacent money-transmission oversight operates under a bifurcated structure: the kiosk-specific gate and AML-policy duty already in force, and the broader statutory redefinition still pending. 3 Nov 2026 · fim-2026-11-03 #### Lead Signal Alaska has moved its crypto-kiosk sector from a lightly supervised corner of the money-services landscape into an actively policed one within the span of a single month. On 7 October 2026, the Alaska Division of Banking and Securities joined a thirty-four-regulator multistate settlement and consent order against Coinme Inc., a kiosk operator, over a failure to maintain an effective Bank Secrecy Act and anti-money-laundering program. The order requires Coinme to shut down its kiosks, complete an independent BSA/AML review, and pay 2.5 million dollars in penalties and costs. The timing is not coincidental: Senate Bill 249 (Chapter 50, Session Laws of Alaska 2026) took effect six days earlier, on 1 October 2026, requiring virtual-currency-kiosk operators to hold a money-transmission license, secure prior departmental approval before siting each kiosk, cap fees, post fraud warnings, and maintain written anti-fraud and BSA/AML-consistent policies alongside periodic reporting. Read together, the two developments show a state regulator that built a licensing gate and then, almost immediately, used an existing multistate enforcement channel to test what that gate was meant to prevent. The significance lies in the architecture rather than the incident alone. Alaska did not wait for its own enforcement history to accumulate before acting; it relied on a coordinated interstate settlement structure that already existed, applying it to a sector the state had just finished regulating directly. That sequencing -- statute first, multistate enforcement second, within weeks -- is the more durable signal than the Coinme matter itself, because it indicates the state's kiosk oversight apparatus is designed to function as both gate and backstop from the outset, rather than growing enforcement teeth only after a period of dormant licensing. #### Other Developments A second, broader statutory rewrite remains on the horizon. Senate Bill 86 (Chapter 48, Session Laws of Alaska 2026) will amend Alaska's money-transmission statute, AS 06.55, to bring virtual-currency exchange, transfer, storage, and administration expressly within the definition of money transmission, add reserve and customer-entitlement and disclosure duties, and raise the maximum civil penalty to 10,000 dollars per day. Most of its provisions, including the formal statutory definition of virtual-currency business activity, do not commence until 1 July 2027, and existing money-services-business licensees may continue operating under current licenses until renewal or 1 July 2028. SB 86 is therefore a confirmed enactment with a deferred effective architecture, distinct from SB 249's immediate kiosk-specific requirements that are already in force. The AML/CTF regime is being built in layers rather than through a single consolidating act. SB 249's kiosk-specific licensing, siting-approval, and reporting duties are already operative, while SB 86's broader money-transmission modernization sits pending. The practical effect for anyone operating in this space is a near-term compliance obligation under SB 249 running concurrently with a known, dated future obligation under SB 86 -- a two-track timeline that obliged entities need to track separately rather than treating as a single reform event. #### Cross-Monitor Connections The Coinme consent order is a financial-crime-architecture story with a direct corridor into payments-infrastructure monitoring: the same kiosk network implicated in the deficient BSA/AML program is also a retail payment-access point, so the enforcement action and the licensing statute together describe both an illicit-finance control gap and a market-access regulatory change for the operators of that infrastructure. Conflict-finance and sanctions-evasion monitoring have no Alaska-specific signal, but the kiosk-sector build-out is the kind of previously under-supervised cash-to-crypto on-ramp that such monitoring would be expected to watch should evasion typologies migrate toward state-level kiosk networks with lighter federal visibility. #### Outlook The near-term question is whether the Coinme consent order functions as a one-off correction or the first of a pattern as other kiosk operators come under SB 249's licensing and siting-approval regime. Because SB 249 requires prior departmental approval for each kiosk location, the Division of Banking and Securities now has a structural mechanism to identify and act on deficient operators before harm accumulates, rather than only after the fact. The longer horizon is SB 86's commencement, scheduled for 1 July 2027 as currently enacted; as scheduled, that date will fold the kiosk-specific regime into a broader statutory definition of virtual-currency business activity, and existing licensees face a further transition point at 1 July 2028. Whether enforcement activity of the Coinme type continues at the current pace, or whether it was itself a product of the multistate settlement's own timeline rather than an Alaska-specific escalation, is not yet resolvable from the material available. 25 Oct 2026 · fim-2026-10-25 #### Lead Signal Alaska has moved, in the same statutory cycle, to close a supervisory gap it had itself identified in the market for virtual-currency kiosks. The state is a co-lead regulator in a thirty-four-state Bank Secrecy Act and anti-money-laundering consent order against the kiosk operator Coinme, Inc., which requires the company to cease all kiosk operations nationwide before 1 January 2027, submit to an independent review of its compliance programme, and pay 2.5 million dollars in penalties and costs, with a further 4 million dollars at risk if the shutdown deadline is missed. Alongside the enforcement action, Senate Bill 249 brought a kiosk-specific licensing and anti-fraud regime into force on 1 October 2026, requiring kiosk operators to hold a money-transmission licence, obtain prior approval for each physical location, observe transaction caps, and maintain a written policy that references Bank Secrecy Act obligations. The two developments sit on top of a broader structural change already enacted but not yet fully in effect: Senate Bill 86 re-platforms Alaska's money-transmission statute to bring virtual-currency exchange, transfer, storage and administration explicitly within the licensing perimeter, adopts a nationwide multistate licensing system, and raises the maximum civil penalty to 10,000 dollars a day. Most of its provisions take effect on 1 July 2027, with existing licensees permitted to continue under their current licences until renewal or 1 July 2028, whichever comes later. Read together, the kiosk-specific action is immediate and the money-transmission overhaul is staged, but both point the same direction: a jurisdiction that had comparatively light state-level coverage of virtual-currency money services is now actively building and enforcing one. #### Other Developments Consent-order mechanics confirm multistate coordination. The Coinme order was entered through Georgia's and Washington's own regulatory channels, with Alaska's Division of Banking and Securities confirmed as a participating lead regulator; this is a useful illustration of how subnational authorities in the United States pool enforcement weight against a single national kiosk operator rather than acting alone. Penalty design intended to be self-enforcing. The structure of the Coinme order, a fixed shutdown date paired with an escalating financial consequence for missing it, is a design feature increasingly used in money-services enforcement to avoid open-ended compliance timelines. Civil penalty ceiling raised across the statute, not just for kiosks. Senate Bill 86 raises the maximum civil penalty under the money-transmission statute as a whole to 10,000 dollars a day for a continuing violation, which widens the deterrent available to the Division well beyond the kiosk sub-sector once the 2027 effective date arrives. #### Cross-Monitor Connections The same underlying facts, the Coinme consent order, the kiosk licensing regime, and the money-transmission modernisation, also carry direct relevance to payments-market structure and to digital-asset regulatory tracking conducted elsewhere in this research programme, since a kiosk operator's compliance posture, a state's licensing perimeter, and a crypto-specific regulatory regime are three readings of one evidentiary base rather than three separate facts. Where those adjacent views cover market-structure or licensing-taxonomy questions in more depth, they should be read as complementary rather than duplicative of the anti-money-laundering reading presented here. #### Outlook The near-term marker to watch is 1 January 2027, the deadline for Coinme's national kiosk wind-down, after which a missed deadline triggers an additional financial penalty. The medium-term marker is 1 July 2027, when most of Senate Bill 86's provisions take effect and the money-transmission definition formally extends to virtual-currency activity statewide; a further transitional date of 1 July 2028 governs how long existing licensees may continue operating under their current licences. Taken together, these dates describe a staged tightening rather than a single event, and the compliance posture of virtual-currency kiosk and money-transmission businesses operating in Alaska should be read against both the immediate kiosk-specific rules already in force and the broader statute still to commence. 18 Oct 2026 · fim-2026-10-18 #### Lead Signal Alaska has converted a largely conditional, fiat-leg-only treatment of virtual-currency business activity into an explicit money-transmission licensing perimeter, and the states enforcement arm has already used part of that new authority against a national operator. The Alaska Division of Banking and Securities co-led a 34-state consent order against Coinme, Inc., a virtual-currency kiosk operator, requiring Coinme to shut down its kiosks, complete an independent Bank Secrecy Act/Anti-Money Laundering review, and pay 2.5 million dollars in penalties and costs. The settlement, dated 8 October 2026, resolves what regulators described as serious deficiencies, including a failure to maintain an effective BSA/AML program. This is not an isolated enforcement episode but the first visible exercise of authority created earlier in the year: SB86 (Ch. 48 SLA 26) replaced Alaskas prior money-transmission statute to bring virtual-currency exchange, transfer, storage and administration within licensed money transmission, while SB249 (Ch. 50 SLA 26) created a dedicated kiosk-licensing and conduct sub-regime that took effect 1 October 2026, just a week before the Coinme settlement was announced. The architecture matters more than the incident. Alaska did not simply fine one kiosk operator; it modernised its statutory base (AS 06.55, the Alaska Uniform Money Services Act) so that virtual-currency activity sits inside the same licensing, background-check and BSA-consistent compliance perimeter as traditional money transmission, and then immediately demonstrated willingness to use the kiosk-specific piece of that perimeter. The broader SB86 licensing provisions are enacted but not yet effective until 1 July 2027, with existing licensees permitted to continue under current licenses until renewal or 1 July 2028, whichever comes first. The kiosk rules under SB249, by contrast, are already in force and already enforced. #### Other Developments No variance in beneficial-ownership baseline. Alaska continues to have no state-level beneficial-ownership registry beyond the federal Corporate Transparency Act baseline; this cycle identified no change to that standing position. #### Cross-Monitor Connections The Coinme settlement and the SB86/SB249 licensing overhaul sit squarely at the intersection of this monitors AML/CTF and crypto/digital-asset-innovation tracking and the World Payments Monitors licensing and stablecoin/digital-money coverage: the same statutory amendments that create a money-transmission licensing requirement for virtual-currency business activity are also payments-market-access events, and the same kiosk consent order is both a BSA/AML enforcement finding and a consumer-facing payments-conduct action. Readers tracking crypto-asset-operator registration transitions across jurisdictions should treat Alaskas 1 July 2027 commencement date and 1 July 2028 transition deadline as data points in the broader state-by-state crypto money-transmission licensing trend this monitor has been following. #### Outlook The near-term marker is 1 July 2027, when the main SB86 licensing provisions commence, bringing NMLS-based licensing, background checks and (as scheduled) net-worth and surety requirements into force for virtual-currency business activity licensees; the specific dollar thresholds for those requirements were not located this cycle and remain a gap. A second marker, 1 July 2028, closes the transition window for existing money-services licensees operating under legacy licenses. Given that Alaska has already shown willingness to use its new kiosk authority enforcement-first, further BSA/AML actions against kiosk operators or unlicensed virtual-currency businesses operating in the state are a plausible continuation of the current trajectory, though this is illustrative orientation rather than a prediction. 11 Oct 2026 · fim-2026-10-11 #### Lead Signal Alaska materially expanded its money-transmission licensing perimeter to expressly cover virtual-currency business activity with the enactment of the Alaska Uniform Money Transmission Modernization Act, SB86, Chapter 48 SLA 2026, on June 30, 2026. The statute repeals and reenacts large portions of AS 06.55 and establishes AS 06.55.150, requiring a person engaging in virtual-currency business activity to, from, or within Alaska to hold a money-transmission licence, unless exempt under AS 06.55.802. This closes a prior jurisdictional gap that had previously rested on administrative-code interpretation alone, bringing virtual-currency business activity within an express statutory AML perimeter for the first time. #### Other Developments Transitional licence continuity. Existing Alaska money-services licensees may continue operating under their pre-SB86 licenses until the earlier of their next renewal or July 1, 2028, creating a multi-year window during which legacy and newly licensed virtual-currency money transmitters operate under differing procedural regimes. BSA and SAR compliance baseline. SB86's implementing framework requires licensees to comply with federal law, including suspicious activity reporting, layering the new state licensing perimeter onto the existing federal Bank Secrecy Act obligation rather than displacing it. Alaska's Division of Banking and Securities remains the designated money-transmission licensor and AML supervisory authority; no separate state financial intelligence unit exists, and SAR obligations continue to run through the federal layer. #### Cross-Monitor Connections The SB86 licensing expansion is a structural finding shared with the world-payments monitor, which reads the same statute through a payments-conduct and market-access lens, and with the crypto monitor, which reads it through a token-business licensing lens. All three readings rest on the identical underlying statutory text; the financial-integrity reading foregrounds the closure of the AML perimeter gap, where virtual-currency business activity is now unambiguously captured by a licensing regime carrying BSA/SAR compliance duties, rather than the licensing-access or consumer-disclosure dimensions those other monitors foreground. #### Outlook Whether the Alaska Division of Banking and Securities has adopted implementing regulations under SB86 since its June 30, 2026 enactment is unresolved as of this record, and whether Alaska's pre-SB86 virtual-currency surety-bond requirement survives unchanged under the reenacted AS 06.55 remains unconfirmed. The transition window running to July 1, 2028 means the full AML-relevant licensee population will not operate exclusively under the new regime until that date at the earliest, as scheduled. 4 Oct 2026 · fim-2026-10-04 #### Lead Signal Alaska has closed a long-standing gap in its money-services framework. Two statutes, Senate Bill 86 (the Alaska Uniform Money Transmission Modernization Act, Ch. 48 SLA 26) and Senate Bill 249 (the Virtual Currency Kiosks Act, Ch. 50 SLA 26), both took effect on 1 October 2026, bringing virtual currency business activity and kiosk operation within the state licensed-activity perimeter for the first time. SB 86 creates a separately-scoped licence covering exchanging, transferring, storing or administering virtual currency on behalf of another, moves licensing administration onto NMLS, and raises the maximum civil penalty for continuing licensing violations. SB 249 layers a kiosk-specific sub-regime on top: operators must hold a money-transmitter licence, obtain prior approval from the Division of Banking and Securities for each physical kiosk location, maintain written anti-fraud and BSA/AML-consistent policies, and file quarterly and annual reports that include suspicious-transaction counts. State-level commentary frames the change as closing a pre-existing regulatory gap for crypto kiosks rather than responding to an emerging illicit-finance threat, and the finding is assessed as Confirmed on the strength of the regulator's own program page and the legislature's bill-history and enrolled text. The structural significance sits in the licensing architecture rather than in any single enforcement episode. Alaska now has a functioning on/off-ramp perimeter for virtual currency, administered through the same NMLS channel used for conventional money transmission, which gives the Division of Banking and Securities a supervisory foothold over kiosk operators it did not previously possess. #### Other Developments Civil-penalty exposure rises materially. SB 86 raises the maximum civil penalty for continuing licensing violations to a reported ten thousand dollars per day, a mechanism corroborated by the statute itself, with the specific figure resting on secondary legal commentary not yet cross-checked against the enrolled statute's own section numbers. Existing licensees retain transitional continuity. Money-services licensees already operating under current licenses may continue to do so until renewal, meaning the new virtual-currency-specific licensing track applies prospectively rather than forcing an immediate re-licensing event across the existing book. The kiosk sub-regime is reporting-heavy. Beyond the location-approval requirement, SB 249 obliges kiosk operators to maintain anti-fraud and BSA/AML-consistent written policies and to report suspicious-transaction counts to the regulator on a quarterly and annual cycle, giving Alaska a dedicated kiosk-level reporting channel it previously lacked. #### Cross-Monitor Connections The licensing and consumer-protection mechanics of SB 86 and SB 249 are the same underlying statutory commencement that the crypto and world-payments monitors are tracking from their own vantage points: crypto for the licensing-perimeter and stablecoin-adjacent safeguarding implications, world-payments for the market-access and consumer-protection dimensions of the same two statutes. From a financial-integrity perspective, the structural point is that the new regime functions as a state-level complement to the federal FinCEN and OFAC framework for payment-platform service identification and the broader federal programme for digital-asset oversight under development, rather than a freestanding sanctions or AML innovation in its own right. #### Outlook Both statutes commenced on 1 October 2026, only days before this research window closed, so the research record does not yet establish whether the Division of Banking and Securities has issued implementing regulations or NMLS filing guidance to operationalise the two new licensing tracks. Specific numeric figures, including the exact civil-penalty amount, remain anchored to secondary legal-commentary sources pending confirmation against the enrolled statute's own section numbers. The near-term question is less whether the licensing perimeter will hold than how quickly existing and prospective kiosk operators move through the NMLS and location-approval process, and whether the Division publishes guidance that resolves the open sourcing gaps identified this cycle. 28 Sep 2026 · fim-2026-09-28 #### Lead Signal Alaska has enacted SB 86 (Chapter 48 SLA 26), a modernization of its money-transmission statute that folds virtual-currency exchange and custody activity fully into the states licensing perimeter for the first time. The bill replaces the 2007 Uniform Money Services Act with a framework aligned to the Model Money Transmission Modernization Act and adds a dedicated Virtual Currency Business Activity article to AS 06.55. The legislative record confirms enactment with a status date of 2026-07-02. This is a structural development rather than an enforcement event: Alaska is closing a supervisory gap that had previously been managed through ad hoc licensing arrangements, and it is doing so by explicitly tying licensee examination practice to Bank Secrecy Act record-keeping standards and OFAC and other sanctions screening, according to hearing testimony from the Division of Banking and Securities. The practical effect is a materially higher bar for virtual-currency businesses operating in the state. Applicants for a virtual-currency license now face a 500,000 dollar electronic surety bond, compared with a 25,000 dollar base bond for standard money transmitters, a twentyfold increase that signals the states view of the elevated risk profile of virtual-currency activity relative to conventional remittance and transmission business. #### Other Developments Licensee base and virtual-currency volume disclosed at hearing. Testimony accompanying SB 86 disclosed that Alaska licensed 189 money-transmitter and currency-exchange entities in calendar year 2025, up from 173 in calendar year 2024, of which 39 transmit virtual currency. Those 39 entities are reported to represent roughly 2.2 billion dollars of the states 7.9 billion dollars in total 2025 money-transmission value. The core licensee-count table is agency-published and carries strong sourcing; the virtual-currency subset and dollar-volume breakout were reported via hearing coverage rather than a primary agency table, and should be read with that caveat. Implementing regulations and fee restructuring anticipated. The Division of Banking and Securities is expected to issue implementing regulations and a tiered, volume-based fee structure to replace the prior flat 1,000 dollar renewal fee, with an estimated timeline of the first quarter of 2027. This is a forward-looking regulatory development rather than a settled fact, and the timeline should be treated as indicative pending formal rulemaking. #### Cross-Monitor Connections The SB 86 licensing overhaul is the same underlying development that surfaces in the Crypto monitor as a Crypto Licensing and Consumer Protection finding, and in the World Payments monitor as a Licensing, Authorisation and Market Access finding. Readers tracking Alaska across those monitors will see the identical statutory change described through each monitors own analytical lens: here, the emphasis is on the AML/CTF examination-alignment language and the closing of a supervisory gap for virtual-currency businesses; the payments and crypto monitors emphasize market-access and consumer-disclosure consequences of the same statute. No conflict-finance, sanctions-evasion, beneficial-ownership, or enabler-jurisdiction nexus was identified for Alaska this cycle, consistent with the states role as a subnational unit operating beneath a federally administered sanctions and beneficial-ownership architecture. #### Outlook The near-term marker to watch is the Division of Banking and Securities rulemaking process, expected around Q1 2027, which will settle the tiered fee structure and may clarify examination procedures for virtual-currency licensees in more granular terms than the enacting statute itself. Because Alaska sits within a nested federal-state administration model for AML/CTF, sanctions, and beneficial-ownership matters, the state-level signal here is properly read as an infrastructure-hardening development at the licensing layer, not as an independent shift in Alaskas federal-level AML/CTF exposure. Whether the BSA/OFAC-alignment language translates into observable examination outcomes will only become clear over further reporting cycles. 5 Sep 2026 · fim-2026-08-21 #### Lead Signal Alaska enacted two companion statutes this cycle that materially reshape the state's virtual-currency oversight architecture. SB 86 (Ch. 48 SLA 26) brings virtual currency business activity within the state's money-transmission licensing perimeter, requiring a licence before a firm may engage in virtual currency business activity in Alaska, alongside multistate NMLS registration and renewal and new safety-and-soundness standards. SB 249 (Ch. 50 SLA 26) goes further on the operational side: virtual-currency kiosk operators must hold a money-transmission licence, register kiosk locations, and maintain written anti-fraud and BSA/AML-consistent policies, with quarterly per-kiosk and annual reports covering gross revenue, refunds and suspicious transactions, effective 1 October 2026. Alaska's AML/CTF regime remains governed by the federal Bank Secrecy Act and FinCEN framework; SB 86 and SB 249 layer a state money-transmission licensing regime and a kiosk-specific BSA/AML-consistent-policy and SAR-style reporting mandate on top of that federal baseline, rather than displacing it. Read together, this is architecture, not incident: Alaska's own risk-tracker characterisation treats the change as enablement-closing and structural rather than enforcement-responsive or episodic, meaning the new licensing and AML-adjacent obligations close a prior regulatory gap for virtual-currency businesses and kiosks rather than answering a detected illicit-finance episode. #### Other Developments Elder-fraud-driven transaction controls. SB 249 also sets daily and monthly transaction-volume and fee caps for virtual-currency kiosk transfers. The legislative driver cited for this provision was documented elder-fraud losses: Senator Tilton cited more than $26 million in 2024 Alaska online-fraud losses, a third of it borne by seniors. This is a case where a consumer-protection rationale produces a structural AML/CFT-adjacent outcome, a pattern this monitor's three-pillar balance deliberately weighs alongside enforcement-volume-driven findings, since fraud-control legislation of this kind is otherwise easy to under-count against higher-volume AML enforcement actions elsewhere. #### Cross-Monitor Connections The same Alaska enactment carries distinct readings across the adjacent monitoring lenses tracking this jurisdiction in parallel within this fleet. The payments-oversight lens is concerned with the licensing and market-access dimension of SB 86 and SB 249: a new state licence requirement for virtual-currency businesses and kiosk operators, aligned to multistate registration practice. The digital-asset lens is concerned with the consumer-protection and product-specific dimension: kiosk transaction caps, fraud warnings, and a victim-refund pathway for defrauded kiosk users. Both readings trace to the same underlying enactment; the financial-integrity reading is distinguished by its focus on the BSA/AML-consistent-policy and SAR-style-reporting architecture the statutes impose on kiosk operators ahead of the 1 October 2026 effective date, and on what that architecture does or does not close off as a laundering or fraud-proceeds vector. #### Outlook The date to track is 1 October 2026, when SB 249's kiosk licensing, transaction-limit and BSA/AML-consistent-policy requirements take effect. Whether the Alaska Division of Banking and Securities has published implementing regulations or forms ahead of that date remains unresolved this cycle, and this cycle's findings rest on secondary legal-alert corroboration rather than direct review of the enacted statutory text of SB 86 or SB 249, a gap worth closing before the effective date. The near-term question is less about new enforcement exposure than about implementation capacity: whether kiosk operators can meet the licensing and reporting requirements on Alaska's compressed timeline, and whether that timeline proves typical of, or an outlier against, other states' emerging kiosk-oversight frameworks. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion For Alaska, the defining sanctions-architecture fact of this cycle is not enablement but exposure: the dominant Alaska salmon, pollock and crab export sector sits at the receiving end of a persistent Russian sanctions-evasion channel rather than serving as any part of its infrastructure. Russian-origin seafood continues to be processed in third countries, chiefly China, and re-exported toward the United States under altered product classification, circumventing the OFAC Seafood Determination that expanded the import prohibitions of Executive Order 14068 as amended by Executive Order 14114. This is assessed, on Tier-1 OFAC sourcing, as an active and ongoing evasion architecture, meaning the loophole is structural and persistent rather than a single detected transaction, and the principal commercial casualty is the competitiveness of the Alaska fisheries sector against seafood that has, in substance, evaded the ban designed to protect it. The customer typologies most exposed to this architecture are trade finance and corporate counterparties handling seafood import documentation, precisely the typology through which the catalogued red-flag indicator, Russian-origin seafood processed in a third country then re-exported toward the US market under a new product classification, would be observable in practice at the trade-document stage rather than at account opening. Continue reading That scheme sits within a wider pattern of sanctions-regime divergence that directly affects Alaska-linked maritime and trade counterparties. The three principal Western sanctions regimes continue to diverge in both the scope and the method of shadow-fleet vessel designation. US designations stand at roughly 180 or more vessels on a listing-only basis. The 20th EU Russia sanctions package lifted its own shadow-fleet list to 632 vessels, adding 46 in this cycle, and for the first time activated an anti-circumvention tool to designate a third-country virtual-asset service provider, a Kyrgyzstani exchange trading the ruble-backed A7A5 stablecoin, marking a structural widening of EU sanctions architecture beyond listing and freezing toward VASP-targeted anti-circumvention measures. The United Kingdom, with a shadow-fleet list of roughly 600 vessels, moved furthest from the listing-and-freeze model altogether: Royal Marine Commandos and the National Crime Agency conducted the first physical boarding and interdiction of a sanctioned tanker, the SMYRTOS, in the English Channel in June 2026, a methodological divergence toward kinetic interdiction that has no US or EU equivalent this cycle. Assessed cross-regime synthesis holds that this divergence in scope and enforcement method creates genuine compliance friction for Alaska-linked maritime and trade counterparties, which must screen against three materially different vessel-designation universes and anticipate three different enforcement postures depending on jurisdiction of transit. Against this backdrop, the United States itself remains off the FATF grey and black lists as of the June 2026 Plenary, a clean status that nonetheless obliges Alaska-chartered and state-licensed institutions to continue applying enhanced due diligence to counterparties in jurisdictions newly subject to increased monitoring or removed from it. The absence of a US listing is itself worth stating explicitly under the architecture-over-incident principle: it is a structural precondition for Alaska correspondent-banking access rather than a passive fact, and its persistence this cycle is a stability signal rather than a null one. The seafood evasion scheme also carries a conflict-finance dimension addressed in greater depth under D4: assessed reasoning holds that continued third-country laundering of Russian seafood export revenue sustains a war-economy revenue stream for the Russian Federation notwithstanding the formal US ban, a linkage that reinforces rather than displaces the sanctions-architecture reading offered here. Read together, the seafood evasion scheme and the shadow-fleet divergence describe a jurisdiction, Alaska, whose sanctions-architecture exposure runs almost entirely through inherited federal frameworks, the OFAC Seafood Determination and vessel-designation programs, rather than through any state-level policy choice, while the practical harm, competitive erosion in the fisheries sector and compliance friction for maritime trade counterparties, is concentrated precisely where the Alaska economy is most exposed. #### Outlook The next FATF Plenary, expected in October 2026, will reassess grey- and black-list status for several jurisdictions and will bear directly on the enhanced-due-diligence obligations that Alaska institutions with cross-border correspondent exposure must apply; this is assessed as a quarter-band uncertainty item rather than a settled outcome. Separately, continued widening of the US, EU and UK shadow-fleet designation divergence, and any further activation of anti-circumvention tools of the kind the EU deployed against the Kyrgyzstani VASP this cycle, would further complicate the compliance posture required of Alaska-linked maritime and trade counterparties operating across all three regimes. Illustrative scenario content addressing how sanctions-evasion architecture might evolve is provided separately under the standing intelligence-register disclaimer and is not a prediction of how these developments will in fact unfold. Judgment: No AK-specific sanctions-architecture movement this cycle. Uncertain #### Beneficial Ownership and Corporate Transparency For Alaska, the material beneficial-ownership story this cycle is a US federal one, and it runs in two directions at once. A March 2025 FinCEN interim final rule redefined the Corporate Transparency Act reporting-company category to cover only foreign entities, exempting all domestically formed entities, including Alaska-formed limited liability companies, from federal beneficial-ownership-information reporting to FinCEN. This is assessed as a structural rollback of the core CTA transparency mechanism specifically for US-formed shells, and the effect falls disproportionately on states, including Alaska, that have marketed accessible, low-disclosure LLC formation. The Alaska corporate registry itself imposes no beneficial-ownership disclosure requirement at formation, and no independent state anti-money-laundering statute exists beyond Bank Secrecy Act incorporation for licensed money-services businesses, meaning the transparency posture of Alaska now depends entirely on a federal framework that has itself narrowed. Compounding that narrowing, a February 2026 FinCEN exceptive relief order, FIN-2026-R001, grants covered institutions, including Alaska banks and credit unions, relief from Customer Due Diligence Rule beneficial-owner identification and verification requirements at new-account opening nationwide, a supervisory-measure easing of an existing obligation rather than a new imposition. Continue reading Set against both of these loosening moves is a genuine structural improvement: the FinCEN Residential Real Estate Rule took nationwide effect on March 1, 2026, extending Bank Secrecy Act style non-financed residential-transfer reporting to Alaska for the first time and closing a monitoring gap that the prior Geographic Targeting Order metro-list approach had left open. Transactions in Alaska, previously outside any federal real-estate reporting requirement, are now within it; post-implementation compliance data confirming how this plays out in practice for Alaska and Anchorage transactions specifically is not yet available and is flagged as a coverage gap rather than assumed. This registry-level gap is not new, but it is now sharper: the Alaska Division of Corporations, Business and Professional Licensing has never required beneficial-ownership disclosure at LLC or corporation formation, a persistent structural gap that, prior to March 2025, was at least partially offset by the federal CTA domestic reporting-company obligation. With that federal backstop now removed for domestically formed entities, beneficial-ownership visibility in Alaska rests almost entirely on voluntary or client-driven disclosure at the institutional level, a position that assessed synthesis characterizes as a material weakening of the overall transparency architecture rather than a return to a prior baseline. Globally, the EU AML Package sets the structural direction for beneficial-ownership and corporate-transparency reform, but it is not the primary subject matter for a US jurisdiction such as Alaska, which sits entirely outside its supervisory perimeter. As standing architecture, the EU framework comprises three distinct instruments: the directly applicable AML Regulation, or AMLR, Regulation (EU) 2024/1624; the sixth AML Directive, or 6AMLD, transposed at Member State level; and the AMLA Regulation, Regulation (EU) 2024/1620, which establishes the Anti-Money Laundering Authority and shifts supervision of high-risk cross-border obliged entities from purely national authorities toward a hybrid EU-level regime of direct and indirect supervision. This is durable backdrop rather than a US-AK development: assessed synthesis this cycle confirms the AMLR, 6AMLD and AMLA architecture is not directly applicable to Alaska, whose only touchpoint is the correspondent-banking equivalence question, which has not been resolved in EU-US guidance this cycle and remains a documented coverage gap. The relevant lens for Alaska readers is therefore that a hybrid supervisory model is taking shape elsewhere while the transparency posture of Alaska is narrowing under its own federal framework. #### Outlook The interaction between the CTA domestic exemption, the CDD account-opening relief order, and the Residential Real Estate Rule leaves beneficial-ownership visibility in Alaska structurally weaker at the entity level even as it strengthens at the real-estate transaction level; whether this net position holds, worsens, or is revisited depends substantially on litigation and rulemaking activity around the CTA exemption that lies outside the evidence base for this cycle. EU AMLA direct-supervision selection and correspondent-banking equivalence guidance, were it to be issued, would be the most consequential external development for Alaska-domiciled banks with EU counterparty exposure; none has been identified this cycle. Illustrative scenario content addressing how the AMLA transition might reshape supervisory and evasion dynamics is provided separately under the standing intelligence-register disclaimer and should not be read as a prediction of Alaska-specific outcomes. Judgment: No AK-specific BO-registry development identified this cycle. Uncertain #### Enabler Jurisdictions and Professional Facilitators The enabler-jurisdiction profile of Alaska this cycle is best read as evolving rather than settled. Investigative reporting assesses that registered-agent and corporate-services firms in Alaska, alongside comparable firms in Nevada and South Dakota, are attracting overflow shell-company formation demand from out-of-state and international clients with limited onboarding verification, as Wyoming, historically the most-cited low-disclosure formation hub, faces greater scrutiny. This pattern is corroborated at Tier-2 investigative sourcing only this cycle and is consistent with, though not independently confirmed beyond, prior shell-company formation reporting; it is held at Assessed rather than High confidence for that reason. The underlying structural gap that makes Alaska a plausible destination for this overflow demand is a persistent one: the Alaska Division of Corporations, Business and Professional Licensing imposes no beneficial-ownership disclosure requirement at LLC or corporation formation, and no independent state anti-money-laundering statute exists beyond Bank Secrecy Act incorporation for licensed money-services businesses. With the federal Corporate Transparency Act domestic reporting-company exemption now in effect, this state-level gap is no longer offset by any federal backstop for Alaska-formed entities, sharpening rather than creating enabler-jurisdiction exposure for Alaska. The customer typologies most exposed to this dynamic are corporate and high-net-worth clients using registered-agent services, precisely the typology also implicated in prior domestic shell-company risk assessment work; the observability of this risk sits primarily at onboarding, where limited verification of far-flung clients is the documented red flag, rather than at the transaction-monitoring stage. Continue reading Separately, and at national rather than Alaska-specific scale, a FinCEN consent order against Canaccord Genuity LLC evidences continued professional-facilitator control failure with direct Alaska-client reach. FinCEN found the broker-dealer willfully failed to implement reasonable anti-money-laundering controls for OTC and microcap securities trading, failing to file at least 160 suspicious activity reports despite thousands of underlying suspicious transactions across a national client base that includes Alaska. This is a Tier-1, High-confidence finding and stands as the clearest evidence this cycle that professional-facilitator failure is not confined to shell-formation registered agents but extends to regulated broker-dealers serving Alaska clients through national platforms. Read together, these two strands describe an enabler-jurisdiction picture in which Alaska functions as a plausible secondary node for opaque entity formation because of a persistent registry-level gap, while simultaneously being exposed, as any other state would be, to national-scale professional-facilitator control failures in the regulated securities sector. Neither strand indicates that Alaska is choosing to enable illicit flows through active state policy; both indicate that gaps in disclosure requirements and control-framework enforcement, rather than deliberate facilitation, are the operative mechanism, consistent with the capacity-versus-choice distinction this filter is designed to draw. #### Outlook Whether the Alaska shell-formation pattern documented at Tier-2 sourcing this cycle is corroborated by a Tier-1 source, such as a state-level enforcement action or a federal indictment naming Alaska-registered entities, would materially change the confidence assessment in either direction. No Alaska-specific Division of Banking and Securities or US Attorney District of Alaska enforcement action bearing on either the shell-formation pattern or broker-dealer control failures has been identified this cycle, a documented coverage gap that limits the strength of any enforcement-intensity claim specific to Alaska. Illustrative scenario content addressing how enabler-jurisdiction dynamics of this kind might evolve is provided separately under the standing intelligence-register disclaimer. Judgment: No AK-specific enabler-jurisdiction signal this cycle. Uncertain #### Conflict Finance and Extractive-Industry Integrity The seafood sanctions-evasion architecture addressed under D1 carries a conflict-finance dimension that the evidence base for this cycle treats as a distinct and analytically significant layer rather than a footnote to the sanctions story. Assessed reasoning holds that Russian Federation seafood exporters are laundering export revenue via third-country processing, chiefly in China, specifically in a manner that sustains a war-economy revenue stream despite the formal US import ban imposed by the OFAC Seafood Determination. This is not framed as a speculative extension of the sanctions-evasion finding but as its direct strategic consequence: the ban was designed to constrain a specific channel of Russian government-linked export revenue, and its persistent circumvention means that channel continues to function, largely undiminished in substance even where nominally prohibited in form. Continue reading This finding matters for the three-pillar balance this monitor is required to maintain. Sanctions-evasion findings generate high enforcement volume in the AML register, generally in the form of vessel designations, entity listings and consent orders, and it is easy for the conflict-finance and counter-proliferation-finance dimensions of the same underlying activity to be under-weighted relative to that volume. The seafood scheme is precisely such a case: it produces comparatively few discrete enforcement actions relative to its financial significance, because circumvention through legitimate-seeming third-country processing does not generate the same enforcement artifacts, designations, freezes, indictments, as more visible evasion methods such as flag-hopping vessels or shell-company banking. Its conflict-finance significance is therefore assessed rather than directly observed in enforcement data, and that assessed status should not be read as lower strategic importance; it reflects the structural difficulty of detecting revenue-laundering embedded in ordinary-seeming trade flows rather than any diminished confidence in the underlying mechanism. For Alaska specifically, the conflict-finance framing does not change the role of the jurisdiction, target rather than enabler, but it does sharpen the strategic stakes of the underlying evasion architecture. The Alaska fisheries sector is not merely disadvantaged by unfair trade competition; it is competing against seafood whose successful market entry represents a live, ongoing transfer of value to a war-economy revenue stream that a specific US sanctions instrument was designed to interrupt. This reframes the seafood evasion issue, for Alaska stakeholders, from a trade-competitiveness grievance into a sanctions-architecture failure with direct conflict-finance consequences, a distinction that matters for how the issue should be prioritized relative to other Alaska-relevant financial-integrity findings this cycle. This finding is also the basis for the cross-monitor referral to SCEM this cycle, whose conflict-finance tracking is the appropriate venue for deeper analysis of how war-economy financing for Russia integrates seafood-revenue laundering alongside other extractive and trade-based revenue streams; the role of this monitor is to flag the linkage and assess its financial-integrity mechanics, not to duplicate SCEM domain expertise. The structural persistence of the scheme, rather than any single transaction, is what elevates it to conflict-finance significance under the architecture-over-incident principle: a one-off shipment mislabeled at a border crossing would be an incident; a continuing pathway that survives a sanctions expansion and the Seafood Determination itself, and remains active through this cycle evidence dated July 2026, is architecture. That persistence is the basis on which the underlying evidence is held at Assessed, rather than Possible, confidence for the conflict-finance layering, even though the war-economy revenue characterization itself, as distinct from the underlying evasion mechanics, has not been independently confirmed at Tier-1 sourcing this cycle. #### Outlook No new enforcement or regulatory development specific to the conflict-finance dimension of the seafood scheme has been identified this cycle beyond the underlying D1 evasion finding itself; the conflict-finance framing is an analytical layering of existing evidence rather than a new evidentiary event, and readers should not expect a distinct D4 enforcement action to follow directly from it. Whether OFAC or Congress moves to close the third-country transformation loophole that currently permits this evasion, for instance through a rule change addressing processing-based origin determination, would be the most consequential development to watch, and none has been identified in the evidence base for this cycle. Illustrative scenario content addressing how conflict-finance revenue-laundering architecture of this kind might evolve is provided separately under the standing intelligence-register disclaimer and should not be read as a prediction of any specific regulatory response. Judgment: No AK-specific conflict-finance signal this cycle. Uncertain #### Crypto / Digital Assets / Financial Innovation Alaska's digital-asset oversight architecture tightened materially this cycle through the convergence of a new kiosk-licensing statute and a live multistate enforcement action against a kiosk operator. SB 249 (Ch. 50 SLA 26) took effect on 1 October 2026, requiring virtual-currency-kiosk operators to hold a money-transmission license, secure the Division of Banking and Securities prior approval before siting each kiosk, observe fee caps, post fraud warnings, file periodic reports, and maintain written anti-fraud and BSA/AML-consistent policies. Six days after the statute took effect, the Division joined a 34-regulator multistate settlement and consent order against Coinme Inc. (NMLS #1185542), finding the kiosk operator had failed to maintain an effective BSA/AML program; the order requires kiosk shutdowns, an independent BSA/AML review, and a 2.5 million dollar penalty and cost payment. Continue reading The sequencing is the analytically significant feature: a jurisdiction built a kiosk-specific licensing and AML-policy gate and, within days, enforced the underlying AML-program obligation against an operator through the existing multistate regulatory cooperation structure. This reads as a coordinated infrastructure move rather than a reactive one-off, since the statutory gate and the enforcement action address the same underlying BSA/AML-program deficiency from two directions simultaneously - one prospective and licensing-based, one retrospective and enforcement-based. Separately, SB 86 (Ch. 48 SLA 26) rewrites the states core money-transmission statute, AS 06.55, to bring virtual-currency exchange, transfer, storage, and administration on behalf of another person within the definition of licensed money-transmission activity, and raises the maximum civil penalty to 10,000 dollars per day. This is the broader structural vehicle into which the kiosk-specific statute fits; most of its provisions commence on 1 July 2027, with a transition period for existing licensees extending to 1 July 2028 at the latest. The enactment itself is confirmed from the enrolled bill text; the practical reach of the redefinition onto specific virtual-currency business models, including custodial arrangements not organized as kiosks, will become clearer as the commencement date approaches and the Division issues implementing guidance. The kiosk statute's finer operational detail - the specific reporting cadence and fee-cap mechanics - is currently evidenced mainly through secondary legal commentary rather than independently verified against the enrolled text, so that layer of detail is treated as probable rather than confirmed pending closer verification against the statute itself. #### Outlook The most consequential date ahead is 1 July 2027, when SB 86's core virtual-currency definitional change is due to commence, as scheduled, bringing custodial crypto activity formally within the states money-transmission licensing perimeter; existing licensees may continue operating under current licenses until renewal or 1 July 2028, whichever is later. In the nearer term, the Coinme consent order sets a template worth watching: whether the Division applies the same BSA/AML-program scrutiny to other kiosk operators licensed under the now-effective SB 249 gate will indicate whether this cycle's enforcement action is the first of a sustained program or an isolated settlement joined through multistate coordination. Judgment: Alaska's new SB249 kiosk statute (effective 2026-10-01) and the AK-DBS-led multistate Coinme BSA/AML consent order (2026-10-07) together mark a step-change in state-level crypto-kiosk AML enforcement infrastructure. Probable #### Compliance Technology and Active Defence Two FinCEN developments this cycle define the compliance-technology and active-defence posture applicable to Alaska-chartered and state-licensed institutions, and they point in different directions on the question of regulatory prescriptiveness. First, FinCEN has proposed a fundamental risk-based reform of Bank Secrecy Act and anti-money-laundering program requirements, an NPRM whose comment period closed June 9, 2026 without the rule yet being finalised. The proposal, as assessed from FinCEN own materials, would shift banks nationwide, including Alaska-chartered institutions, away from prescriptive, tick-box program requirements and toward reasonably designed, risk-based expectations, while elevating the role of FinCEN in supervisory consultation with federal banking regulators. Because the rule remains at the proposed stage and its ultimate content and finalisation timeline are not yet settled, this development is held at Assessed rather than High confidence, and the domain trajectory is accordingly recorded as uncertain rather than either improving or worsening. Continue reading Second, and separately, FinCEN issued guidance in August 2025, Notice FIN-2025-NTC1, specifically heightening suspicious-activity-report filing expectations for crypto-ATM kiosk operators, citing sector growth from 4,128 kiosks in 2019 to 37,342 in 2025. This is a compliance-technology and supervisory-expectation development rather than an enforcement action against any named entity, and it is held at High confidence on Tier-1 sourcing. Read against the crypto-ATM fraud pipeline documented under D5, this notice represents the supervisory apparatus attempting to catch up with a sector whose physical and transactional footprint, including in Alaska, has expanded far faster than the compliance-technology and monitoring infrastructure built to cover it; the notice itself is evidence of that gap being recognised at the regulatory level, even where it has not yet been closed in practice. Taken together, these two developments describe a compliance-technology environment in active transition rather than settled state: a fundamental program-design reform under consideration for banks generally, and a narrower, already-issued supervisory-expectation update for the crypto-ATM sector specifically. For Alaska institutions, both fall entirely within the inherited federal Bank Secrecy Act and FinCEN framework; neither is a state-level Alaska development, and no Alaska Division of Banking and Securities guidance responding to either has been identified this cycle, a documented coverage gap. The active-defence dimension of this domain, meaning the extent to which compliance-technology tooling, rather than supervisory guidance alone, is evolving to detect the schemes documented elsewhere in this cycle evidence base (seafood trade-document evasion, crypto-ATM kiosk fraud, shell-company onboarding gaps) remains largely unaddressed in the primary sourcing for this cycle; the evidence base speaks to regulatory expectation-setting rather than to specific technological or control-framework responses by covered institutions, and that gap is itself worth naming under the architecture-over-incident framing of this domain rather than assuming compliance technology is keeping pace simply because guidance has been issued. No compliance-technology-specific typology observation was recorded against the ratified typology library this cycle; the typology_observations surface for this run is empty, which is read as an absence of new technology-detection typology matches rather than as an assessment that no such typologies apply. #### Outlook The FinCEN AML and CFT program reform NPRM is the most consequential item on the regulatory horizon for this domain, with finalisation not expected before approximately the second quarter of 2027, a year-band uncertainty item; whether the final rule adopts, narrows, or expands the risk-based reorientation proposed will materially affect the compliance-technology investment calculus for Alaska-chartered institutions of all sizes. Whether the heightened filing expectations of the CVC Kiosk Notice translate into measurable changes in kiosk-operator suspicious-activity-report volume, in Alaska specifically or nationally, is not yet observable in the evidence base for this cycle and is flagged as a gap for future cycles to close. Illustrative scenario content addressing how compliance-technology and active-defence postures might evolve in response to these regulatory-horizon items is provided separately under the standing intelligence-register disclaimer and is not a prediction of specific technological or supervisory outcomes. Judgment: No AK-specific RegTech/compliance-technology development this cycle. Uncertain #### AML/CTF Regime Alaska's standing AML/CTF regime for money-services businesses is codified in AS 06.55, the states Uniform Money Services Act, and this cycle demonstrates that regime extending explicitly and in practice to a previously under-specified category of licensee. Virtual-currency-kiosk operators, through SB 249 (Ch. 50 SLA 26), now carry an express statutory duty to maintain written anti-fraud and BSA/AML-consistent policies as a condition of their money-transmission license, effective 1 October 2026. The statute requires prior departmental approval before a kiosk is sited at a new location, fee caps, posted fraud warnings, and periodic reporting, placing kiosk operators within the same supervisory architecture that already governs other money-transmission licensees under AS 06.55. Continue reading The regime's teeth were demonstrated, not merely codified, within days of the kiosk statute taking effect: the Division of Banking and Securities joined a 34-regulator multistate consent order against Coinme Inc. on 7 October 2026, finding a failure to maintain an effective BSA/AML program and ordering kiosk shutdowns, an independent compliance review, and a 2.5 million dollar penalty and cost payment. This is the clearest available evidence that Alaska's AML/CTF program requirement for money-transmission licensees operates as a live supervisory expectation rather than a dormant statutory recital, and that the state participates actively in the multistate cooperative enforcement structures through which much state-level money-services-business AML supervision in the United States is actually exercised. The regime sits under the federal Bank Secrecy Act and FinCEN baseline that applies nationally to money-services businesses, with Alaska's own statute operating as the state-level licensing and supervisory layer on top of that baseline. There is no European Union AML Regulation, sixth Anti-Money Laundering Directive, or Anti-Money Laundering Authority application to this jurisdiction, since Alaska sits outside that architecture's perimeter entirely as a United States subnational jurisdiction; the relevant comparative frame is the federal BSA/FinCEN baseline together with other states parallel multistate enforcement cooperation, not the European instruments. The broader redefinition of virtual-currency business activity under SB 86 will, from 1 July 2027 as scheduled, bring additional categories of virtual-currency activity - exchange, transfer, storage, and administration on behalf of another - within the same AS 06.55 licensing and AML-program framework, extending the regime's reach beyond the kiosk-specific category addressed this cycle. #### Outlook The near-term question is whether the Coinme consent order is followed by comparable scrutiny of other kiosk operators now operating under the SB 249 licensing gate, which would confirm a sustained supervisory program rather than a single settlement. The structurally larger development remains SB 86's pending commencement on 1 July 2027, which will formally extend the AS 06.55 AML-program duty to the full range of virtual-currency business activity the statute now defines, subject to a transition period running to 1 July 2028 at the latest for existing licensees. Judgment: Alaska's standing AML/CTF regime for money-services businesses is codified in AS 06.55, now extending BSA/AML-consistent policy duties explicitly to virtual-currency-kiosk operators via SB249. Probable Judgment: No commercial transaction among integrity-infrastructure firms evidenced this cycle for US-AK. Uncertain Regulatory horizon In Force 2026-Q4 · ±quarter ### Virtual Currency Kiosks Act (SB 249) A standalone AML/consumer-protection sub-regime for virtual-currency kiosks commences, with transaction caps, fee caps, mandatory refunds for proven fraud, and quarterly/annual regulator reporting. [Alaska Division of Banking and Securities / Alaska Legislature Source](https://www.akleg.gov/basis/Bill/Detail/?Root=SB+249) In Force Pending 1 Jul 2027 · ±quarter ### SB 86 (Ch. 48 SLA 26) Money Transmission Modernization Act — virtual-currency provisions Alaska's money-transmission statute is rewritten to expressly bring virtual-currency exchange, transfer, storage and administration within money transmission, adds reserve/customer-entitlement and disclosure duties for virtual-currency licensees, and raises the maximum civil penalty to $10,000/day. [Source](https://www.akleg.gov/PDF/34/Bills/SB0086Z.PDF) 2 dated · 2 pending date · baseline financial-integrity-2026-07-05 Role action cards MLRO ### Alaska enforced its BSA/AML program requirement against a crypto-kiosk operator days after a new kiosk licensing statute took effect. The Coinme multistate consent order confirms that Alaska's regulator will act on BSA/AML program deficiencies at virtual-currency-kiosk operators, and the newly effective SB 249 licensing gate carries the same AML-policy duty forward for all kiosk licensees going forward. 2 evidence refs Compliance ### Alaska's money-transmission licensing perimeter now expressly covers virtual-currency kiosks, with a broader statutory redefinition pending for 2027. SB 249 closes the kiosk-specific licensing gap immediately, while SB 86 will extend the states money-transmission definition to virtual-currency exchange, transfer, storage and administration generally from mid-2027, with a transition period for existing licensees. 2 evidence refs Legal ### A 34-regulator multistate consent order against a kiosk operator demonstrates active enforcement of Alaska's money-services AML obligations. The order carries a kiosk shutdown requirement, an independent compliance review, and a 2.5 million dollar penalty, and sits alongside a civil penalty increase to 10,000 dollars per day under the pending SB 86 redefinition. 2 evidence refs Board ### Alaska has moved decisively on crypto-kiosk oversight, pairing new licensing law with live multistate enforcement. The combination of a newly effective licensing statute and an immediate enforcement action against a named operator signals a jurisdiction actively building and using its financial-crime supervisory infrastructure for digital-asset access points. 2 evidence refs CTO ### Virtual-currency kiosk infrastructure in Alaska is now subject to a licensing, siting-approval, and AML-policy gate, with a broader custodial-crypto definition due in 2027. Any kiosk or custodial virtual-currency platform touching Alaska must now account for per-location departmental approval and written BSA/AML-consistent policy obligations, and should track the 2027 commencement of the broader statutory redefinition of virtual-currency business activity. 2 evidence refs Risk ### Alaska's multistate enforcement action against a kiosk operator is an emerging-exposure signal for the crypto-kiosk typology generally. The deficiency found - an ineffective BSA/AML program - is a model-risk and typology signal applicable wherever kiosk operators are licensed, and the 34-regulator cooperative structure means any similar finding could propagate to other state regulators rapidly. 1 evidence refs Operations ### Kiosk operators now face reporting, fee-cap and fraud-warning obligations under Alaska's newly effective kiosk statute. Operational workflows for kiosk siting, periodic reporting and fraud-warning posting must now align with SB 249's requirements, which took effect on 1 October 2026. 1 evidence refs Audit ### The Coinme consent order illustrates what a BSA/AML program adequacy gap looks like in practice for a kiosk operator. The order's requirement for an independent BSA/AML review of Coinme's program is a concrete benchmark for what control-testing scope regulators expect from money-transmission licensees operating virtual-currency kiosks. 1 evidence refs Standing trackers (T1–T6) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture no_change No material change found bearing on US-AK this cycle. T2 · EU AML Package / AMLA no_change Not applicable to this US subnational jurisdiction. T3 · FATF Grey List no_change No US grey-list movement this cycle; not jurisdiction-specific to AK. T4 · Beneficial-Ownership Register Status no_change No AK-specific BO-registry development identified this cycle. T5 · Crypto & Digital-Asset Integrity material_change AK's new SB249 kiosk statute and the Coinme BSA/AML consent order mark a step-change in state-level crypto-kiosk AML enforcement infrastructure. T6 · Sanctions Regime Divergence no_change No AK-specific sanctions-divergence signal this cycle. Registers ### Enforcement actions - 13 Feb 2026 - 4 Aug 2025 - 1 Oct 2025 - 1 Mar 2026 - 7 Oct 2026 - 7 Oct 2026 - FinCEN issued the Account Opening Exceptive Relief Order (FIN-2026-R001), granting covered financial institutions relief from identifying and verifying beneficial owners of legal-entity customers at each new account opening under 31 CFR 1010.230(b). 13 Feb 2026 - FinCEN issued Notice FIN-2025-NTC1 alerting financial institutions and CVC kiosk operators to fraud typologies, red flags and BSA reporting obligations tied to the rapid national expansion of crypto ATMs, citing a rise from 4,128 to 37,342 kiosks between 2019 and 2025. 4 Aug 2025 - FinCEN designated Huione Group as a financial institution of primary money laundering concern under Section 311 (October 2025), later issuing a proposed rule to amend the definition; ICIJ subsequently found major exchanges (Binance, OKX) continued to receive large tether inflows from Huione-linked wallets after the finding. 1 Oct 2025 - FinCEN issued Consent Order No. 2026-01 finding Canaccord Genuity willfully failed to implement reasonable AML controls for OTC/microcap securities trading, failing to file at least 160 SARs despite thousands of underlying suspicious transactions across a national client base. 1 Mar 2026 ### Sanctions changes - 14 Jan 2025 - 23 Apr 2026 - 14 Jun 2026 - The United States designated over 180 vessels identified as part of Russia's 'shadow fleet' of oil tankers used to circumvent the price cap and sanctions regime, expanding OFAC's maritime sanctions architecture. 14 Jan 2025 - The EU adopted its 20th Russia sanctions package, adding 46 vessels (bringing the total to 632), designating a Kyrgyzstani crypto exchange trading the A7A5 ruble-backed stablecoin, banning port infrastructure services, and laying groundwork for a future maritime services ban on Russian oil transport. 23 Apr 2026 - UK forces conducted the first-ever physical boarding and interdiction of a sanctioned Russian shadow-fleet tanker (SMYRTOS) in the English Channel, using Royal Marine Commandos and National Crime Agency officers, escalating enforcement beyond listing-only measures. 14 Jun 2026 ### Regulatory horizon (register) - FATF October 2026 Plenary grey/black-list review - Alaska SB 249 virtual-currency kiosk regime effective date - SB 86 implementing regulations and tiered fee structure - Alaska Uniform Money Transmission Modernization Act (SB 86) - Virtual Currency Kiosks Act (SB 249) - SB86 transition period for existing AK money-services licensees - Alaska SB86 — money transmission modernization (virtual-currency provisions), AS 06.55 - SB 86 Money Transmission Modernization Act virtual-currency provisions - SB 86 (Ch. 48 SLA 26) Money Transmission Modernization Act — virtual-currency provisions - FinCEN AML/CFT Program reform rule finalization - GENIUS Act stablecoin AML/sanctions regulations take full effect - Residential Real Estate (RRE) Rule nationwide reporting effective - FATF October 2026 Plenary grey/black-list review ### Active schemes - [HIGH] Russian seafood laundered via third-country processing - Alaska as secondary shell-company registered-agent hub - Crypto ATM (CVC kiosk) fraud pipeline reaching Alaska - [HIGH] Federal BOI exemption strips Alaska LLC ownership visibility Sources - [Secretary of State for Defence on Russian Shadow Fleet interdiction - GOV.UK](https://www.gov.uk/government/speeches/secretary-of-state-for-defence-on-russian-shadow-fleet-interdiction) - [https://infobytes.orrick.com/2026-07-24/alaska-overhauls-money-transmission-licensing-imposes-new-virtual-currency-kiosk-requirements/](https://infobytes.orrick.com/2026-07-24/alaska-overhauls-money-transmission-licensing-imposes-new-virtual-currency-kiosk-requirements/) - [https://natlawreview.com/article/alaska-modernizes-money-transmission-framework-cover-virtual-currency](https://natlawreview.com/article/alaska-modernizes-money-transmission-framework-cover-virtual-currency) - [https://www.pymnts.com/legal/2026/alaska-updates-money-transmission-law-as-states-broaden-oversight-of-virtual-currency/](https://www.pymnts.com/legal/2026/alaska-updates-money-transmission-law-as-states-broaden-oversight-of-virtual-currency/) - [https://www.akleg.gov/basis/get_documents.asp?session=33&docid=13630](https://www.akleg.gov/basis/get_documents.asp?session=33&docid=13630) - [https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) - [https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [https://sanctionslawyers.net/blog-en/the-fatf-grey-list-and-blacklist-complete-guide/](https://sanctionslawyers.net/blog-en/the-fatf-grey-list-and-blacklist-complete-guide/) - [Alaska State Legislature](https://www.akleg.gov/basis/Bill/Detail/34?Root=SB++86) - [Alaska DCCED](https://www.akleg.gov/basis/get_documents.asp?session=34&docid=13521) - [Citizen Portal](https://citizenportal.ai/articles/7820646/alaska/2026-legislature-alaska/lawmakers-introduce-overhaul-of-alaskas-money-transmission-law-to-include-virtual-currency) - [National Law Review](https://natlawreview.com/article/alaska-modernizes-money-transmission-framework-cover-virtual-currency) - [Alaska DBS](https://www.commerce.alaska.gov/web/dbs/Default.aspx) - [Alaska State Legislature](https://www.akleg.gov/basis/get_documents.asp?session=34&docid=2568) - [Orrick, Herrington & Sutcliffe LLP](https://infobytes.orrick.com/2026-07-24/alaska-overhauls-money-transmission-licensing-imposes-new-virtual-currency-kiosk-requirements/) - [Sheppard, Mullin, Richter & Hampton LLP](https://www.sheppard.com/insights/blogs/alaska-modernizes-money-transmission-framework-to-cover-virtual-currency) - [Alaska State Legislature](https://www.akleg.gov/basis/get_documents.asp?session=34&docid=11199) - [https://www.akleg.gov/PDF/34/Bills/SB0086B.PDF](https://www.akleg.gov/PDF/34/Bills/SB0086B.PDF) - [https://www.sheppard.com/insights/blogs/alaska-modernizes-money-transmission-framework-to-cover-virtual-currency](https://www.sheppard.com/insights/blogs/alaska-modernizes-money-transmission-framework-to-cover-virtual-currency) - [https://www.mondaq.com/unitedstates/financial-services/1824938/alaska-modernizes-money-transmission-framework-to-cover-virtual-currency](https://www.mondaq.com/unitedstates/financial-services/1824938/alaska-modernizes-money-transmission-framework-to-cover-virtual-currency) - [https://www.akleg.gov/basis/get_documents.asp?session=34&docid=13521](https://www.akleg.gov/basis/get_documents.asp?session=34&docid=13521) - [https://www.commerce.alaska.gov/web/dbs/](https://www.commerce.alaska.gov/web/dbs/) - [Alaska Division of Banking & Securities](https://www.commerce.alaska.gov/web/dbs/) - [Conference of State Bank Supervisors (CSBS)](https://www.csbs.org/newsroom/state-financial-regulators-reach-25-million-settlement-crypto-kiosk-operator) - [Orrick InfoBytes](https://infobytes.orrick.com/2026-07-24/alaska-overhauls-money-transmission-licensing-imposes-new-virtual-currency-kiosk-requirements/) - [Alaska Dept. of Commerce, Community & Economic Development (legislative white paper)](https://www.akleg.gov/basis/get_documents.asp?session=34&docid=13521) - [https://dbf.georgia.gov/press-releases/2026-10-08/consent-order-entered-coinme-inc](https://dbf.georgia.gov/press-releases/2026-10-08/consent-order-entered-coinme-inc) - [https://dfi.wa.gov/news/press/washington-state-dfi-enters-multi-state-consent-order-coinme-inc](https://dfi.wa.gov/news/press/washington-state-dfi-enters-multi-state-consent-order-coinme-inc) - [https://www.akleg.gov/basis/Bill/Detail/34?Root=SB++86](https://www.akleg.gov/basis/Bill/Detail/34?Root=SB++86) - [Alaska Division of Banking and Securities](https://www.commerce.alaska.gov/web/dbs/EnforcementOrders) - [Alaska Division of Banking and Securities](https://www.commerce.alaska.gov/web/dbs/) - [Orrick, Herrington & Sutcliffe](https://infobytes.orrick.com/2026-07-24/alaska-overhauls-money-transmission-licensing-imposes-new-virtual-currency-kiosk-requirements/) - [Alaska State Legislature](https://www.akleg.gov/PDF/34/Bills/SB0086Z.PDF) - [Guidance | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance) - [The Anti-Money Laundering Act of 2020 | FinCEN.gov](https://www.fincen.gov/anti-money-laundering-act-2020) - [Enforcement Actions | FinCEN.gov](https://www.fincen.gov/news/enforcement-actions) - [What is crypto AML compliance?](https://www.elliptic.co/blockchain-basics/what-is-crypto-aml-compliance) - [FinCEN Proposes Rule to Fundamentally Reform Financial Institution Programs Designed to Fight Illicit Finance | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-proposes-rule-fundamentally-reform-financial-institution-programs) - [The FATF Recommendations](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html) - [PPSI-AMLCFT-NPRM.pdf](https://www.fincen.gov/system/files/2026-04/PPSI-AMLCFT-NPRM.pdf) - [FREQUENTLY ASKED QUESTIONS Issued: March 19, 2026](https://www.fincen.gov/system/files/2026-03/SWB-GTO-FAQs.pdf) - [History of Anti-Money Laundering Laws | FinCEN.gov](https://www.fincen.gov/history-anti-money-laundering-laws) - [Alerts/Advisories/Notices/Bulletins/Fact Sheets | FinCEN.gov](https://www.fincen.gov/resources/advisoriesbulletinsfact-sheets) - [State Contact Information For MSBs](https://www.fincen.gov/sites/default/files/shared/msbstatecontactsfinal.pdf) - [Crypto giants moved billions linked to money launderers, drug traffickers and North Korean hackers](https://www.icij.org/investigations/coin-laundry/cryptocurrency-exchanges-binance-okx-money-laundering-crime/) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [MEMORANDUM OF UNDERSTANDING Between the U.S. ...](https://ofac.treasury.gov/media/31246/download) - [How Bots, Banking and Stablecoins Will Dominate Fintech in 2026](https://www.bloomberg.com/news/articles/2025-12-30/how-bots-banking-and-stablecoins-will-dominate-fintech-in-2026) - [Amid a scam crackdown, crypto giants keep fueling bitcoin ATMs - ICIJ](https://www.icij.org/investigations/coin-laundry/amid-a-scam-crackdown-crypto-giants-keep-fueling-bitcoin-atms/) - [Application of FinCEN’s Regulations to Virtual Currency Software Development and Certain Investment Activity | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/application-fincens-regulations-virtual) - [Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2025-26) - [Tether Invests $100 Million in Crypto Bank Anchorage Digital - Bloomberg](https://www.bloomberg.com/news/articles/2026-02-05/tether-invests-100-million-in-crypto-bank-anchorage-digital) - [MSB Registrant Search | FinCEN.gov](https://www.fincen.gov/resources/msb-state-selector) - [State of Alaska Office of the Attorney General - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/1341961D:US) - [Financial Fraud Enforcement Task Force (FFETF) | FinCEN.gov](https://www.fincen.gov/financial-fraud-enforcement-task-force-ffetf) - [The Value of FinCEN Data - Law Enforcement ...](https://www.fincen.gov/resources/law-enforcement/case-examples) - [News | FinCEN.gov](https://www.fincen.gov/news) - [Press Releases | FinCEN.gov](https://www.fincen.gov/news/press-releases) - [1 The U.S. Department of the Treasury’s (Treasury) Financial](https://www.fincen.gov/system/files/2026-03/FinCEN-Advisory-Health-Care-Fraud.pdf) - [FINANCIAL ACTION TASK FORCE ON MONEY LAUNDERING FATF | FinCEN.gov](https://www.fincen.gov/financial-action-task-force-money-laundering-fatf) - [What We Do | FinCEN.gov](https://www.fincen.gov/about-fincen/what-we-do) - [Frequently Asked Questions | FinCEN.gov](https://www.fincen.gov/resources/frequently-asked-questions) - [Advisories | FinCEN.gov](https://www.fincen.gov/resources/advisoriesbulletinsfact-sheets/advisories) - [Frequently Asked Questions | FinCEN.gov](https://www.fincen.gov/boi-faqs) - [Financial Crimes Enforcement Network The Role of Domestic Shell Companies in](https://www.fincen.gov/system/files/shared/LLCAssessment_FINAL.pdf) - [Potential Money Laundering Risks Related to Shell Companies | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/potential-money-laundering-risks-related-shell-companies) - [The Role of Domestic Shell Companies in Financial Crime ...](https://www.fincen.gov/sites/default/files/shared/LLCAssessment_FINAL.pdf) - [Millions in Covid relief funds went to shadowy companies registered at a Wyoming storefront that hundreds of thousands of firms used as an address - ICIJ](https://www.icij.org/investigations/pandora-papers/millions-in-covid-relief-funds-went-to-shadowy-companies-at-a-wyoming-storefront-that-hundreds-of-thousands-of-firms-used-as-an-address/) - [Corrupt Money Concealed in Shell Companies and Other Opaque Legal Entities, Finds New StAR Study](https://www.unodc.org/unodc/en/press/releases/2011/October/corrupt-money-concealed-in-shell-companies-and-other-opaque-legal-entities-finds-new-star-study.html) - [Entities matched with “Shell” | ICIJ Offshore Leaks Database](https://offshoreleaks.icij.org/search?adr=on&ent=on&ppl=on&q=Shell) - [FinCEN Advisory - FIN-2017-A003 | FinCEN.gov](https://www.fincen.gov/resources/advisories/fincen-advisory-fin-2017-a003) - [Shell Companies, Secrecy and the U.S | Global Witness](https://www.globalwitness.org/en/press-releases/shell-companies-secrecy-and-us/) - [Shell Energy Company | ICIJ Offshore Leaks Database](https://offshoreleaks.icij.org/nodes/82002753) - [FinCEN Renews Residential Real Estate Geographic Targeting Orders | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-renews-residential-real-estate-geographic-targeting-orders-0) - [Geographic Targeting Order Covering TITLE INSURANCE COMPANY April 14, 2025](https://www.fincen.gov/system/files/shared/RRE-GTO-Order-April-14-2025-FINAL508.pdf) - [Geographic Targeting Order Covering TITLE INSURANCE COMPANY October 9, 2025](https://www.fincen.gov/system/files/2025-10/RRE-GTO-Order.pdf) - [FinCEN Renews Real Estate Geographic Targeting Orders | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-renews-real-estate-geographic-targeting-orders) - [Geographic Targeting Order Covering TITLE INSURANCE ...](https://www.fincen.gov/sites/default/files/shared/Real%20Estate%20GTO_Order_4.29.22_for%20Press%20Release.pdf) - [FREQUENTLY ASKED QUESTIONS Issued: October 9, 2025](https://www.fincen.gov/system/files/2025-10/RRE-GTO-FAQs.pdf) - [FinCEN Renews and Expands Real Estate Geographic Targeting Orders | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-renews-and-expands-real-estate-geographic-targeting-orders-2) - [FinCEN GEOGRAPHIC TARGETING ORDER, April 14, 2025](https://www.fincen.gov/sites/default/files/shared/RRE-GTO-Order-April-14-2025-FINAL508.pdf) - [Geographic Targeting Orders Involving Certain Real Estate ...](https://www.fincen.gov/system/files/shared/508_FAQ_April2023REGTO.pdf) - [Geographic Targeting Order Covering TITLE INSURANCE COMPANY April 19, 2024](https://www.fincen.gov/system/files/shared/RRE-GTOs-Phase-18-Order.pdf) - [1155 | Office of Foreign Assets Control](https://ofac.treasury.gov/faqs/1155) - [1156 | Office of Foreign Assets Control](https://ofac.treasury.gov/faqs/1156) - [1025. Executive Order (EO) 14068, “Prohibiting Certain ...](https://ofac.treasury.gov/faqs/1025) - [Frequently Asked Questions - Newly Added | Office of Foreign Assets Control](https://ofac.treasury.gov/faqs/added/2023-12-22) - [1157 | Office of Foreign Assets Control](https://ofac.treasury.gov/faqs/1157) - [OFAC Food Security Fact Sheet: Russia Sanctions and Agricultural Trade](https://ofac.treasury.gov/media/924341/download) - [1024 | Office of Foreign Assets Control](https://ofac.treasury.gov/faqs/1024) - [1027 | Office of Foreign Assets Control](https://ofac.treasury.gov/faqs/1027) - [Russian Harmful Foreign Activities Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions) - [DEPARTMENT OF THE TREASURY WASHINGTON, D.C. OFFICE OF FOREIGN ASSETS CONTROL](https://ofac.treasury.gov/media/932451/download) - [MEMORANDUM OF UNDERSTANDING Between the ...](https://ofac.treasury.gov/media/31246/download?inline=) - [UNITED STATES OF AMERICA FINANCIAL CRIMES ENFORCEMENT NETWORK](https://www.fincen.gov/system/files/2026-03/Canaccord-Consent-Order-No-2026-01.pdf) - [Fincen](https://www.fincen.gov/system/files/schema/code/FinCENReferenceCodes.xsd) - [Key Changes in FinCEN’s Proposed Rule to Refocus AML/CFT Programs on](https://www.fincen.gov/system/files/2026-04/Key-Changes-Program-NPRM.pdf) - [CDD Rule FAQs | FinCEN.gov](https://www.fincen.gov/resources/statutes-and-regulations/cdd-rule-faqs) - [The Value of FinCEN Data | FinCEN.gov](https://www.fincen.gov/resources/law-enforcement/case-examples?field_tags_investigation_target_id=All&page=3) - [Alaska Permanent Fund Corp - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/97517Z:US) - [FinCEN Advisory - FIN-2016-A005 | FinCEN.gov](https://www.fincen.gov/resources/advisories/fincen-advisory-fin-2016-a005) - [Investigations Assisted by Bank Secrecy Act Data | FinCEN.gov](https://www.fincen.gov/investigations-assisted-bank-secrecy-act-data) - [When Are Alaska Permanent Fund Dividend Checks Going Out in 2021? - Bloomberg](https://www.bloomberg.com/news/articles/2021-08-31/alaska-lawmakers-face-crunch-to-pay-checks-from-oil-wealth-kszk7h2e) - [FinCEN PROVIDES HELPFUL ANTI-FRAUD INFORMATION FOR NATIONAL CONSUMER PROTECTION WEEK | FinCEN.gov](https://www.fincen.gov/fincen-provides-helpful-anti-fraud-information-national-consumer-protection-week) - [1 FIN-2021-A002 February 24, 2021](https://www.fincen.gov/system/files/advisory/2021-02-25/Advisory%20EIP%20FINAL%20508.pdf) - [Virtual Asset Service Provider (VASP): Definition, Compliance & Examples](https://www.trmlabs.com/glossary/virtual-asset-service-provider-vasp) - [Jurisdictions under Increased Monitoring - 19 June 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - ["Black and grey" lists](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [High-Risk Jurisdictions subject to a Call for Action - 19 June 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/call-for-action-june-2026.html) - [Jurisdictions under Increased Monitoring - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) - [Outcomes FATF Plenary, 17-19 June 2026](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-june-2026.html) - [Money Laundering Advisory Notice: June 2026 - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/money-laundering-advisory-notice-high-risk-third-countries--2) - [News](https://www.fatf-gafi.org/en/the-fatf/news.html) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions.html) - [High-Risk Jurisdictions subject to a Call for Action - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/Call-for-action-february-2026.html) - [Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov](https://www.fincen.gov/news/news-releases/financial-action-task-force-identifies-jurisdictions-anti-money-laundering-5) - [A Record-Breaking Year for Cybercrime: Key Findings from the FBI’s 2024 IC3 Report | TRM Labs](https://www.trmlabs.com/resources/blog/a-record-breaking-year-for-cybercrime-key-findings-from-the-fbis-2024-ic3-report) - [2026 Crypto Crime Report: Scams](https://www.chainalysis.com/blog/crypto-scams-2026/) - [FinCEN Notice, FIN-2025-NTC1, August 4, 2025](https://www.fincen.gov/system/files/2025-08/FinCEN-Notice-CVCKIOSK.pdf) - [What is Pig Butchering? Crypto Investment Scam - Chainalysis](https://www.chainalysis.com/glossary/pig-butchering/) - [Elder Financial Exploitation: Threat Pattern & Trend ...](https://www.fincen.gov/system/files/shared/FTA_Elder_Financial_Exploitation_508Final.pdf) - [What Is a Crypto Scam? Types & Defense - Chainalysis](https://www.chainalysis.com/glossary/crypto-scam/) - [U.S. Crackdown on Southeast Asian Crypto Scam Centers](https://www.chainalysis.com/blog/asian-scam-centers-crypto-fraud-april-2026/) - [1 1. See 31 U.S.C. § 5312(a)(2); 31 CFR § 1010.100(t). 2.](https://www.fincen.gov/system/files/shared/FinCEN_Alert_Pig_Butchering_FINAL_508c.pdf) - [FinCEN Issues Analysis on Elder Financial Exploitation | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-analysis-elder-financial-exploitation) - [Crypto scams and elder financial exploitation: cracking down on fraud targeting the vulnerable](https://www.elliptic.co/blog/analysis/crypto-scams-and-elder-financial-exploitation-cracking-down-on-fraud-targeting-the-vulnerable) - [Nevada Issues Cease-and-Desist Order to Crypto’s Fortress Trust - Bloomberg](https://www.bloomberg.com/news/articles/2025-10-23/nevada-issues-cease-and-desist-order-to-crypto-s-fortress-trust) - [Alaska Adds “Virtual Currency” to its Regulatory Regime | Elliptic Connect](https://hub.elliptic.co/news/alaska-adds-virtual-currency-to-its-regulatory-regime/) - [Definition of Money Services Business (Money Transmitter/Currency Dealer or Exchanger) | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/definition-money-services-business-money) - [Application of FinCEN’s Regulations to Persons Administering, Exchanging, or Using Virtual Currencies | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/application-fincens-regulations-persons-administering) - [Trump Crypto Feud Heats Up With Cease-And-Desist Letter - Bloomberg](https://www.bloomberg.com/news/articles/2025-06-05/trump-crypto-feud-heats-up-with-cease-and-desist-letter) - [Fact Sheet on MSB Registration Rule | FinCEN.gov](https://www.fincen.gov/fact-sheet-msb-registration-rule) - [Russia's war of aggression against Ukraine: Council sanctions 41 vessels of the Russian shadow fleet - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2025/12/18/russia-s-war-of-aggression-against-ukraine-council-sanctions-41-vessels-of-the-russian-shadow-fleet/) - [SANCTIONS ADVISORY - Guidance for Shipping and ...](https://ofac.treasury.gov/media/934236/download?inline=) - [EU's 20th Russia Sanctions Package](https://www.chainalysis.com/blog/eu-russia-sactions-package-april-2026/) - [Iran-related Designations; International Criminal Court-related Designations; Russia-related Designations Removals; Foreign Sanctions Evaders Determination Removal; Issuance of Iran-related and International Criminal Court-related General Licenses | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20251218) - [Recent Actions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions) - [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [EU adopts 20th package of sanctions against Russia - Finance](https://finance.ec.europa.eu/news/eu-adopts-20th-package-sanctions-against-russia-2026-04-23_en) - [Updated Price Cap Coalition Advisory for the Maritime Oil ...](https://ofac.treasury.gov/media/933506/download?inline=) - [EU Sanctions Russian Propagandists, Military Suppliers, and Officials in New Listings | TRM Labs](https://www.trmlabs.com/resources/blog/eu-sanctions-russian-propagandists-military-suppliers-and-officials-in-new-listings) - [UK forces intercept Russian shadow fleet vessel for the first time in blow to Putin's war chest - GOV.UK](https://www.gov.uk/government/news/uk-forces-intercept-russian-shadow-fleet-vessel-for-the-first-time-in-blow-to-putins-war-chest) - [Russian Tankers Go Dark Out at Sea to Circumvent Sanctions | OCCRP](https://www.occrp.org/en/news/russian-tankers-go-dark-out-at-sea-to-circumvent-sanctions) - [1 Red ALERT Shadow Fleet Sanctions Evasion and Avoidance Network](https://www.nationalcrimeagency.gov.uk/who-we-are/publications/753-red-alert-shadow-fleet-sanctions-evasion-and-avoidance-network/file) - [U.S. Levies Further Sanctions Against Russia’s ‘Shadow Fleet’ | OCCRP](https://www.occrp.org/en/news/us-levies-further-sanctions-against-russias-shadow-fleet) - [Reporter's Notebook: How to Investigate Shadow Fleets | OCCRP](https://www.occrp.org/en/feature/practical-osint-for-investigating-shadow-fleets) - [Russian Tankers Going Dark Raises Flags on Sanctions Evasion - Bloomberg](https://www.bloomberg.com/news/articles/2022-03-27/russian-tankers-going-dark-raises-flags-on-sanctions-evasion) - [Dark Fleet Seeking Russian Protection as US Seizes Oil Tankers - Bloomberg](https://www.bloomberg.com/news/articles/2026-01-14/dark-fleet-seeking-russian-protection-as-us-seizes-oil-tankers) - [European Nations Issue Warning to Russia-Linked Shadow Fleet - Bloomberg](https://www.bloomberg.com/news/articles/2026-01-27/european-nations-issue-warning-to-russia-linked-shadow-fleet) - [European Ships Keep Russia’s Shadow Fleet Afloat | OCCRP](https://www.occrp.org/en/investigation/european-ships-keep-russias-shadow-fleet-afloat) - [Secretary of State for Defence on Russian Shadow Fleet interdiction - GOV.UK](https://www.gov.uk/government/speeches/secretary-of-state-for-defence-on-russian-shadow-fleet-interdiction) - [Office of Foreign Assets Control / Alaska Division of Banking and Securities](https://ofac.treasury.gov/media/31246/download) - [FATF](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [FinCEN](https://www.fincen.gov/system/files/2025-08/FinCEN-Notice-CVCKIOSK.pdf) - [ICIJ](https://www.icij.org/investigations/pandora-papers/millions-in-covid-relief-funds-went-to-shadowy-companies-at-a-wyoming-storefront-that-hundreds-of-thousands-of-firms-used-as-an-address/) - [ICIJ](https://www.icij.org/investigations/coin-laundry/amid-a-scam-crackdown-crypto-giants-keep-fueling-bitcoin-atms/) - [OFAC](https://ofac.treasury.gov/faqs/1155) - [OCCRP](https://www.occrp.org/en/news/us-levies-further-sanctions-against-russias-shadow-fleet) - [European Commission](https://finance.ec.europa.eu/news/eu-adopts-20th-package-sanctions-against-russia-2026-04-23_en) - [FinCEN](https://www.fincen.gov/boi-faqs) - [FinCEN](https://www.fincen.gov/system/files/2026-03/Canaccord-Consent-Order-No-2026-01.pdf) - [Elliptic](https://hub.elliptic.co/news/alaska-adds-virtual-currency-to-its-regulatory-regime/) - [UK Government (Ministry of Defence / National Crime Agency)](https://www.gov.uk/government/news/uk-forces-intercept-russian-shadow-fleet-vessel-for-the-first-time-in-blow-to-putins-war-chest) Coverage gaps fim-int-2026-07-07-G001: Alaska-specific enforcement actions… fim-int-2026-07-07-G001: Alaska-specific enforcement actions, such as state Division of Banking and Securities orders or US Attorney (District of Alaska) financial-crime prosecutions, are sparse and would strengthen enforcement-intensity claims currently inferred from the federal baseline. [resolved] fim-int-2026-07-07-G002: Post-implementation compliance data… fim-int-2026-07-07-G002: Post-implementation compliance data for the March 2026 Residential Real Estate Rule as applied to Alaska and Anchorage transactions is not yet available to confirm the prior GTO blind spot has closed in practice. [resolved] fim-int-2026-07-07-G003: No Alaska Division of Banking and S… fim-int-2026-07-07-G003: No Alaska Division of Banking and Securities enforcement action against crypto-ATM kiosk operators has been identified; state-level supervisory data would clarify whether FinCEN's kiosk guidance is translating into local action. [resolved] fim-int-2026-07-07-G004: EU AMLA equivalence determinations … fim-int-2026-07-07-G004: EU AMLA equivalence determinations or correspondent-banking guidance specifically addressing US institutions, including any Alaska-domiciled banks with EU counterparty exposure, have not been located this cycle. [resolved] fim-int-2026-07-07-G005: FATF October 2026 Plenary outcomes … fim-int-2026-07-07-G005: FATF October 2026 Plenary outcomes are not yet available; current enhanced-due-diligence implications for Alaska institutions rest solely on the June 2026 Plenary listing. [resolved] fim-int-2026-08-21-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-08-21-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): No direct Tier-1 statutory text of SB 86/SB 249 was reviewed this cycle; findings rest on secondary legal-alert corroboration only. [resolved] fim-int-2026-08-21-G002: Tier D jurisdictions Laos, Mexico, … fim-int-2026-08-21-G002: Tier D jurisdictions Laos, Mexico, and Colombia were not independently resolved this cycle given the US-AK-bound research scope. [resolved] fim-int-2026-09-28-G001: Tier D watch jurisdictions (Cambodi… fim-int-2026-09-28-G001: Tier D watch jurisdictions (Cambodia, Laos, Mexico, Colombia) and the standing Yemen/Houthi CTF/CPF check were not actively re-searched this cycle; pooled research budget was concentrated on the bound jurisdiction US-AK. [resolved] fim-int-2026-09-28-G002: D1-D4 and D6 yielded no Alaska-spec… fim-int-2026-09-28-G002: D1-D4 and D6 yielded no Alaska-specific delta this cycle; per the nested-jurisdiction model, sanctions/BO/enabler/conflict-finance administration sits at the US federal layer and no independent state variance was evidenced. [resolved] fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): Specific numeric caps (civil penalty figure, surety bond amount, transaction limits) rest on T3 law-firm secondary summaries not yet cross-checked against the enrolled statute's own section numbers. [resolved] fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): Could not confirm whether DBS has issued implementing regulations or NMLS filing guidance for the 2026-10-01 commencement. [resolved] fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): Whether DBS has adopted implementing regulations under SB86 since its 2026-06-30 enactment was not located this cycle. [resolved] fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): Whether AK's $500,000 virtual-currency surety-bond requirement (AS 06.55.104(f), pre-SB86) survives unchanged or was revised under the reenacted AS 06.55 was not confirmed this cycle. [resolved] fim-int-2026-10-18-G001: Tier D watch jurisdictions (KH, LA,… fim-int-2026-10-18-G001: Tier D watch jurisdictions (KH, LA, MX, CO) were not re-swept this cycle; the pooled research budget was allocated entirely to US-AK. [resolved] fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): Specific net-worth/surety dollar thresholds for SB86's money-transmission licensing requirements were not located this cycle. [resolved] fim-int-2026-10-25-G001: No primary Department of Banking an… fim-int-2026-10-25-G001: No primary Department of Banking and Securities bulletin confirming Alaska's own order-entry date in the Coinme consent order was located; the 2026-10-07/08 dates rest on Georgia and Washington's own releases. [resolved] fim-int-2026-10-25-G002: D1-D4 and D6 domains showed thin co… fim-int-2026-10-25-G002: D1-D4 and D6 domains showed thin coverage for Alaska this cycle; no state-specific signal was located. [resolved] fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): D1-D4 and D6 analytical domains returned thin or no coverage for US-AK nested jurisdiction this cycle; this subnational dispatch is delta-only against the parent US layer, which is out of scope here. [open] FIM-GAP-001 (D2): Alaska/Anchorage residential real estate i… FIM-GAP-001 (D2): Alaska/Anchorage residential real estate is absent from FinCEN's title-insurance Geographic Targeting Order coverage list (which spans CA, CO, CT, FL, HI, IL, MD, MA, NV, NY, TX, WA, VA and DC), leaving non-financed shell-company real estate purchases in Alaska unreported pending the March 2026 nationwide RRE Rule. FIM-GAP-002 (D2): The March 2025 CTA interim final rule exem… FIM-GAP-002 (D2): The March 2025 CTA interim final rule exempts all domestically formed entities, including Alaska LLCs, from federal beneficial-ownership reporting, removing the principal mechanism for federal visibility into the ownership of Alaska-registered shells previously flagged by investigative reporting as attractive to out-of-state and international clients. FIM-GAP-003 (D3): Alaska's corporate registry (Division of C… FIM-GAP-003 (D3): Alaska's corporate registry (Division of Corporations, Business and Professional Licensing) imposes no beneficial-ownership disclosure requirement at LLC/corporation formation and no independent state-level AML statute exists beyond incorporation of BSA obligations for licensed MSBs, leaving registered-agent and company-formation services largely self-regulated. FIM-GAP-004 (D3): Publicly indexed Alaska-specific enforceme… FIM-GAP-004 (D3): Publicly indexed Alaska-specific enforcement actions (state DBS orders, DOJ prosecutions, FinCEN actions naming Alaska entities) are sparse; this baseline draws primarily on national-level federal actions with inferred Alaska applicability plus investigative-journalism identification of Alaska as a secondary corporate-formation and crypto-ATM hub, rather than Alaska-specific prosecutions. ## Evidence #### Confidence-tiered claims SB 86 (Ch. 48 SLA 26) and SB 249 (Ch. 50 SLA 26) both become effective 2026-10-01, bringing virtual currency business activity and kiosk operation within Alaska's licensed-activity perimeter. [[Source 1]](#sec-sources) Probable · 1 source Requires a separately-scoped licence covering virtual currency business activity (exchanging, transferring, storing, or administering virtual currency on behalf of another). [[Source 1]](#sec-sources) Probable · 1 source Kiosk operators must hold a money-transmitter licence and obtain DBS prior approval for each physical kiosk location, maintain written anti-fraud and BSA/AML-consistent policies, and file quarterly/annual reports including suspicious-transaction counts. [[Source 1]](#sec-sources) Probable · 1 source Raises the maximum civil penalty for continuing licensing violations to $10,000 per day. [[Source 1]](#sec-sources) Probable · 1 source Establishes a regulatory framework for virtual currency kiosks in Alaska to enhance consumer protection and prevent fraud and money laundering. [[Source 1]](#sec-sources) Probable · 1 source AS 06.55.150 requires a person engaging in virtual-currency business activity to, from, or within Alaska to hold a money-transmission licence, unless exempt under AS 06.55.802. [[Source 1]](#sec-sources) Probable · 1 source Existing AK money-services licensees may continue operating under their current (pre-SB86) licenses until the earlier of their next renewal or 2028-07-01. [[Source 1]](#sec-sources) Probable · 1 source DBS is AK's designated money-transmission licensor and requires BSA/SAR compliance; no separate state FIU exists. [[Source 1]](#sec-sources) Probable · 1 source co_led_34_state_2.5m_bsa_aml_settlement_against_coinme [[Source 1]](#sec-sources) Probable · 1 source AS_06.55_amended_to_cover_virtual_currency_via_SB86_SB249 [[Source 1]](#sec-sources) Probable · 1 source 2500000_usd_consent_order_kiosk_shutdown [[Source 1]](#sec-sources) Probable · 1 source kiosk_operators_must_hold_money_transmission_license_effective_2026-10-01 [[Source 1]](#sec-sources) Probable · 1 source no_state_level_registry_beyond_federal_CTA_baseline [[Source 1]](#sec-sources) Uncertain · 1 source 34-state BSA/AML Consent Order (Alaska co-lead) requiring national kiosk shutdown by 2027-01-01 and $2.5 million in penalties/costs; additional $4 million penalty if deadline missed. [[Source 1]](#sec-sources) Probable · 1 source Virtual-currency kiosk operators must hold a money-transmission licence, obtain prior Division approval per kiosk location, cap transactions at $1,000/day and $10,000/30 days per user, cap fees, post fraud warnings, and maintain a written anti-fraud/BSA-referencing AML policy. [[Source 1]](#sec-sources) Probable · 1 source Expands 'money transmission' to cover virtual-currency exchange, transfer, storage and administration; adopts NMLS-based multistate licensing; raises maximum civil penalty to $10,000/day. Most provisions effective 2027-07-01; existing licensees may continue under current licences until renewal or 2028-07-01. [[Source 1]](#sec-sources) Probable · 1 source Alaska DBS joined a 34-regulator multistate consent order against Coinme Inc. for deficient BSA/AML program; $2.5M penalty/costs, kiosk shutdown, independent BSA/AML review required. [[Source 1]](#sec-sources) Probable · 1 source 2026-10-01 [[Source 1]](#sec-sources) Probable · 1 source Coinme Inc. (NMLS #1185542) — multistate consent order, 2026-10-07, over deficient BSA/AML kiosk program [[Source 1]](#sec-sources) Probable · 1 source Virtual-currency-kiosk operators must hold a money-transmission license, obtain prior departmental approval per location, cap fees, post fraud warnings, file periodic reports, and maintain written anti-fraud and BSA/AML-consistent policies, effective 2026-10-01. [[Source 1]](#sec-sources) Probable · 1 source Rewrites AS 06.55 to add virtual-currency exchange/transfer/storage/administration to the licensed activity definition; most provisions commence 2027-07-01, existing licensees may continue to 2028-07-01. [[Source 1]](#sec-sources) Probable · 1 source