United States — Arkansas US-AR

Lead Signal

Arkansas has joined thirty-three other state financial regulatory agencies in a multistate settlement with Coinme Inc. (NMLS ID 1185542), a Seattle-based cryptocurrency money transmitter and kiosk operator, resolving findings of violations of Bank Secrecy Act and anti-money laundering requirements. The settlement, worth 2.5 million dollars across the participating states, followed a multistate examination that found Coinme had failed to comply with state net worth requirements, kept poor accounting practices, and ran a deficient Bank Secrecy Act and anti-money laundering program across its network of roughly 6,000 crypto kiosks. Arkansas own allocated share of the settlement is a comparatively modest 48,977.93 dollars, but the structural remedy reaches further than the dollar figure suggests: Coinme must wind down its virtual-currency kiosk operations entirely by January 1, 2027, or face a further 4,000,000 dollar penalty, and must commission an independent review of its Bank Secrecy Act and anti-money laundering program.

The case is best read as an enforcement action against a licensed actor rather than a gap in the licensing perimeter itself. Coinme operated under Arkansas money-transmitter authorisation, and the Arkansas Securities Department states plainly that a Money Transmitter License is required for any person who engages in money transmission activity in the state, a requirement that already reaches virtual-currency transmission and kiosk operation under the Arkansas Uniform Money Services Act. The finding here is about the adequacy of the controls a licensed operator ran, not about whether crypto kiosks sit inside or outside the regulatory boundary.

Other Developments

No additional multistate or enforcement developments were identified for Arkansas outside the Coinme consent order. The broader sanctions, beneficial-ownership, enabler-jurisdiction, conflict-finance, compliance-technology and commercial-activity trackers for the state remain unchanged from the prior baseline.

Cross-Monitor Connections

The Coinme consent order sits directly on the boundary between financial-crime control adequacy and payments-market licensing. The underlying Bank Secrecy Act and anti-money laundering deficiencies identified by the thirty-four-state examination are properly a financial-integrity finding, while the requirement that a licensed money transmitter exit a line of business by a fixed date is a licensing and market-access fact for a payments-focused reading of the same consent order. Both readings trace to the same underlying settlement and should be understood as two lenses on one enforcement event rather than two separate developments.

Outlook

The operative date to track is January 1, 2027, by which Coinme must have ceased Arkansas kiosk operations or face the additional 4,000,000 dollar penalty. The independent program review Coinme must commission is also a forward marker: its findings, once available, would bear on whether the control deficiencies identified in this settlement were specific to Coinme or indicative of a wider supervisory gap across other licensed kiosk operators in the state. Absent a further filing, the Arkansas money-transmitter licensing perimeter itself is not under active review and should be read as stable heading into that date.

Lead Signal

Arkansas regulators moved against a crypto-kiosk operator this cycle in a multistate action that sits squarely inside the financial integrity perimeter for the bound jurisdiction. The Arkansas Securities Department joined 33 other state financial regulatory agencies in a 2.5 million dollar settlement with Coinme Inc., covering BSA and AML program deficiencies at the kiosk operator. The settlement requires Coinme to engage an independent consultant to review its BSA/AML program within six months and to complete remediation within twelve months. This is the single clearest Arkansas-specific development this cycle, and it lands in the crypto and digital-asset domain even though the underlying obligation traces back to Arkansas's general money-services licensing framework.

The other development with direct bearing on the bound jurisdiction's regional exposure is a public warning delivered by a US Ambassador to roughly forty Mexican banks, cautioning that facilitation of cartel-linked financial flows risks financial isolation. That warning sits alongside a standing FinCEN alert on fiscal-fuel-theft, or huachicol, networks that documents cartels using Mexican brokers and correspondent-banking access to move funds internationally, including through stablecoin rails. Arkansas sits within the US correspondent-banking system that is the implicit channel described in that alert, which is why an enabler-jurisdiction signal centered on Mexico carries relevance for a bound jurisdiction that is not itself the named enabler.

Other Developments

A record federal penalty against Bank of America was assessed by FinCEN this cycle, a 1.2 billion dollar civil penalty for willful Bank Secrecy Act violations, including failure to report suspicious transactions linked to Chinese money-laundering networks and to illicit finance along the southwest border. This is a national-level development rather than an Arkansas-specific one, but it sets the enforcement backdrop against which the Coinme settlement and the Mexican-bank warning should be read: federal and multistate authorities are each, independently, escalating pressure on correspondent-banking and money-transmission channels this cycle.

FATF grey-list movement remains unconfirmed. Reporting indicates Monaco, Bulgaria, and Cote d'Ivoire are candidates for removal from the FATF list of jurisdictions under increased monitoring at the Plenary concluding in October 2026, but no formal delisting has occurred, and the list published in June 2026 remains the operative one. This is a Probable-confidence development pending confirmation and is not yet an actionable change in designation status for any affected jurisdiction.

Cross-Monitor Connections

The cartel-finance signal connects directly to conflict- and extractive-industry-adjacent typologies tracked elsewhere in the fleet: the same huachicol alert that documents fuel-theft proceeds moving through Mexican brokers also documents those proceeds crossing into stablecoin payment rails, a channel that a crypto-focused monitor would track from the token and settlement-infrastructure side of the same underlying flow. The Coinme settlement likewise sits at a natural seam between financial-integrity enforcement and crypto-sector licensing, since the underlying obligation is an Arkansas money-services licensing requirement applied to a virtual-currency kiosk operator rather than a bespoke crypto AML rule.

Outlook

The Coinme settlement's compliance timeline carries forward: an independent consultant review is due within six months of the October 2026 settlement date, with remediation due within twelve months, so compliance progress on that timeline is a concrete marker to watch as scheduled. The FATF Plenary concluding in October 2026 may formally resolve the Monaco, Bulgaria, and Cote d'Ivoire delisting question; until a formal communique issues, the June 2026 list of monitored jurisdictions remains the reference point. Continued US official attention to Mexican correspondent-banking exposure, if sustained, would mark a structural rather than episodic shift in enabler-jurisdiction posture toward Mexico, though this cycle's evidence supports only a probable, not confirmed, reading of that trajectory.

Lead Signal

The Arkansas Securities Department has moved from standing AML/CTF administrator to active multi-state enforcer. The Department was one of seven lead-state regulators in a 34-state, $2.5 million settlement with Coinme Inc. over a deficient Bank Secrecy Act and anti-money-laundering program at its virtual-currency kiosks. The settlement requires Coinme to cease kiosk operations in participating states, including Arkansas, by 1 January 2027, or face an additional $4 million penalty, and to retain an independent BSA/AML compliance reviewer. Washington State's Department of Financial Institutions entered a corroborating consent order describing the same deficient program and a failure to meet state net-worth requirements, giving the finding two independent Tier-1 regulatory anchors rather than resting on a single state's account.

The action sits inside, rather than alongside, Arkansas's existing regime. The Arkansas Uniform Money Services Act governs virtual-currency money transmission through the Securities Department, and a dedicated virtual-currency-kiosk regime was added to that Act in 2025. The Coinme settlement is best read as the first substantial test of that 2025 kiosk framework in practice: a licensed operator was found short on BSA/AML program adequacy, and the state regulator joined a coordinated multi-state response rather than acting alone.

Other Developments

Commercial activity in the gambling and leisure sector continued alongside the enforcement story. FanDuel, partnered with Oaklawn Racing Casino Resort, and DraftKings, partnered with Southland Casino Hotel, received Arkansas Racing Commission-approved sports-wagering platform vendor licences and launched statewide sports wagering on 20 March 2026. Separately, Saracen Casino Resort completed a roughly $250 million hotel and event-centre expansion in Pine Bluff, adding in the range of 318 to 320 rooms. Neither development discloses full deal economics in the trade press reporting reviewed, and no Tier-1 corporate filing was located to corroborate the capital figure, so both are carried at Probable confidence rather than Confirmed.

The underlying AML/CTF framework for money transmission remains unchanged in substance. The Uniform Money Services Act and its 2025 kiosk provisions continue to operate as the governing structure; the Coinme action is an enforcement event within that structure rather than a change to it.

Cross-Monitor Connections

The Coinme settlement is a crypto-kiosk BSA/AML enforcement action with direct relevance to payments-monitor tracking of money-transmitter licensing and conduct, since Coinme operates as a licensed non-bank payment institution in the kiosk channel. The commercial gambling-sector developments (sportsbook launches, casino capital expansion) are adjacent to financial-integrity's commercial-activity domain principally as context for cash-intensive and wagering-adjacent payment flows in the state, rather than as a standalone illicit-finance signal; no sanctions, beneficial-ownership, or conflict-finance nexus was identified connecting the two threads this cycle.

Outlook

The operative date to track is 1 January 2027, when Coinme's Arkansas kiosk operations must cease absent further relief, or the firm faces the additional $4 million penalty. Whether Coinme exits the Arkansas kiosk market, restructures its compliance program sufficiently to continue, or triggers the escalated penalty will be the clearest near-term indicator of how the 2025 kiosk regime is enforced in practice going forward. The commercial gambling-sector expansion (sportsbook launches, casino capital projects) is expected to continue generating transaction volume in a cash-intensive sector, though no further financial-integrity-specific finding attaches to it as scheduled.

Lead Signal

The United States sanctions architecture expanded this cycle through a codified set of Cuba Sanctions Regulations at 31 CFR Part 516, which took effect on 30 September 2026. The new regulations consolidate and extend the restrictions originally imposed through Executive Order 14404 into a standalone regulatory text, widening exposure for foreign financial institutions that deal, directly or indirectly, with blocked Cuba-related persons. This is a structural development rather than an isolated enforcement episode: it moves prior executive-order authority into codified regulatory form, which is the kind of architectural consolidation that tends to outlast any single administration and that correspondent banks and cross-border payment firms should read as a durable feature of the sanctions landscape rather than a transient measure. Arkansas carries no state-specific sanctions-regime element of its own; the state operates within the federal sanctions perimeter that this new instrument modifies.

Alongside the Cuba measure, OFAC designated the Los Mayos faction network of the Sinaloa Cartel on 29 September 2026 under its Counter Narcotics and Non-Proliferation authorities. The designation targets the financial architecture supporting cartel narcotics operations and forms part of mandatory ongoing coverage of Mexico-linked illicit-finance typologies. Read together, the two developments describe an active week for US sanctions-list expansion across two distinct typological registers: codified country-based sanctions and targeted narco-finance designations.

Other Developments

Cross-bloc sanctions divergence widens. The new Cuba Sanctions Regulations are a unilateral US measure with no identified equivalent in EU or UK sanctions frameworks as of this cycle. This widens an existing structural divergence between the US autonomous-sanctions track and the sanctions postures of other major financial centres, a divergence relevant to institutions operating correspondent relationships across multiple sanctions regimes simultaneously.

Arkansas AML/CTF perimeter unchanged. No Arkansas-specific sanctions or conflict-finance development was identified this cycle. The state's money-services licensing framework continues to operate as the standing structural backdrop against which federal sanctions obligations, including those arising from the new Cuba regulations and the Sinaloa Cartel designation, are given effect at the state level.

Cross-Monitor Connections

The Sinaloa Cartel designation connects directly to conflict-finance and extractive-industry integrity tracking of narcotics-linked financial networks in Mexico, a jurisdiction carrying mandatory ongoing coverage given the scale of cross-border narco-finance flows into the US financial system. The Cuba Sanctions Regulations, as a codified country-based instrument, is relevant to any cross-monitor tracking of state-level sanctioned-jurisdiction exposure, particularly where correspondent banking relationships create indirect exposure pathways for US-regulated institutions.

Outlook

The Cuba Sanctions Regulations took effect on 30 September 2026 and institutions with any correspondent or indirect exposure to Cuba-related persons should treat the codified text, rather than the superseded executive order, as the operative authority going forward. The cross-bloc divergence this creates is likely to persist as scheduled absent a coordinated EU or UK measure, and continued OFAC designation activity targeting Sinaloa Cartel faction networks should be expected to continue incrementally as the agency works through the broader cartel-finance architecture. No change to Arkansas's own AML/CTF perimeter is indicated for the near term.

Lead Signal

Arkansas's 2023 Data Centers Act, which restricts local-government regulation of cryptocurrency-mining operations, survived a coordinated 2026 legislative reversal attempt. Eight resolutions sponsored by a state senator during the April 2026 fiscal session sought to roll back swaths of the 2023 law, including a measure that would have required digital-asset miners to register as licensed money transmitters. The Senate passed all eight resolutions, but six House companion resolutions fell short of the two-thirds threshold required for passage, and none became law this session. The practical effect is that Arkansas's permissive mining framework remains in place unchanged, and crypto miners in the state continue to sit outside the money-transmitter licensing perimeter that already governs virtual-currency transmission businesses.

Other Developments

Virtual-currency transmission continues to be regulated through Arkansas's general money-services framework rather than a bespoke crypto statute. The Uniform Money Services Act, enacted as Act 532 of 2021, brought virtual-currency transmission under the same licensing regime as traditional money transmission, and 2025 amendments added kiosk-specific fee caps, transaction limits, and disclosure rules, including a 72-hour window for fraud refunds on new virtual-currency-kiosk customer transactions. This dual-track structure, permissive on mining, conventional-MSB on transmission, is the standing shape of Arkansas's digital-asset regulatory perimeter and did not otherwise change this cycle.

Cross-Monitor Connections

The failed 2026 mining-regulation resolutions and the standing Uniform Money Services Act framework are directly relevant to the crypto monitor's licensing and on-chain-activity-regime modules for this jurisdiction, since both track the same underlying instruments from a token- and infrastructure-specific lens. The vendor-licensing and consumer-facing elements of the kiosk amendments also connect to the world-payments monitor's consumer-protection and licensing modules, which track the same 72-hour refund provision and money-transmitter perimeter from a payments-infrastructure lens.

Outlook

The University of Arkansas Extension's summary and the Association of Arkansas Counties' coverage both frame the 2026 session's outcome as a near-miss rather than a settled defeat for mining-regulation advocates, since the measures passed the Senate cleanly and fell short only in the House. A regulatory-horizon item anticipates that these resolutions could be reintroduced in a future legislative session, which if passed would bring Arkansas crypto miners within general money-transmitter licensing and associated BSA/AML obligations, closing a gap relative to states that already impose such registration. Until then, the permissive 2023 framework and the standing money-services regime for virtual-currency transmission remain the operative Arkansas baseline.

Lead Signal

The joint FinCEN and OFAC notice of proposed rulemaking, published April 8, 2026, is this cycle's structural lead signal: for the first time by statute, permitted payment stablecoin issuers operating under the GENIUS Act would be treated as BSA financial institutions and required to maintain sanctions-compliance programs. This is an architecture-level change, not an enforcement incident. It closes a gap that has long separated stablecoin issuance from the AML/CFT obligations imposed on banks and money services businesses, and it arrives against a backdrop of documented stablecoin-enabled sanctions evasion that made the gap analytically indefensible.

The timing is notable for what it enables going forward rather than what it punishes now: no enforcement action accompanies the NPRM, and the proposal itself is the signal. Firms that issue or facilitate permitted payment stablecoins should treat this as the year's clearest indication that digital-asset AML architecture in the United States is converging with, rather than diverging from, the bank and MSB compliance baseline.

Other Developments

FATF's June 2026 plenary reshuffled the grey list. Iraq and Bosnia and Herzegovina were added to increased monitoring while Algeria and Namibia were removed, leaving twenty-two jurisdictions under enhanced follow-up. The reshuffle is a routine but consequential recalibration of where cross-border AML risk is formally recognized, and it was corroborated independently by both FATF's own plenary outcomes publication and the U.S. Treasury's readout.

Sanctions architecture around African conflict commodities escalated in tandem across three governments. The UK, EU, and US each imposed new sanctions on Sudan's conflict-gold economy and on DRC and Rwanda conflict-mineral networks, naming entities including Sudamin and the Gasabo Gold Refinery. The three governments moved on overlapping but not identical target sets and timelines, illustrating the now-familiar pattern of autonomous-listing divergence even where the underlying policy objective is shared.

OFAC designated 29 individuals and entities tied to Cambodia's scam economy, anchored by a sitting senator, Kok An, in April 2026. The designation is the clearest evidence yet that Southeast Asia's cyber-fraud and human-trafficking scam economy has state-connected roots rather than being a purely criminal-network phenomenon.

Laos's Golden Triangle special economic zone continues to enable scam-centre displacement. King's Romans Casino remains a laundering node despite periodic crackdowns, a pattern that has persisted across multiple cycles without structural resolution, corroborated across Tier 2 and Tier 3 investigative sources though without a fresh Tier 1 government or UNODC document this cycle.

FinCEN issued a supplemental advisory on cartel fiscal fuel-theft trade-based money laundering exploiting the US-Mexico energy trading relationship, extending its prior cartel-related advisory work.

Colombia's status remains stable rather than newly deteriorating. It is not FATF grey-listed and continues in GAFILAT's enhanced follow-up process, having been re-rated Largely Compliant on Recommendations 10 and 12; this is a standing-status confirmation rather than a fresh development.

Cross-Monitor Connections

The Sudan and DRC/Rwanda sanctions escalation is a direct conflict-finance and extractive-industry integrity story with an obvious commodity-flow dimension that a commodity-focused monitor would track from the supply side while this monitor tracks it from the financial-flow side. The Cambodia and Laos enabler-jurisdiction findings connect to state-capture analysis: a scam economy anchored by a sitting senator is not merely a criminal-network problem but a governance one, and the persistence of the Golden Triangle SEZ despite periodic crackdowns points to a capacity or willingness deficit in the host jurisdiction rather than a purely episodic enforcement gap. The FinCEN/OFAC stablecoin NPRM, meanwhile, sits at the boundary between financial-integrity architecture and the broader digital-payments regulatory landscape being built around permitted payment stablecoins, a boundary other monitors tracking payments infrastructure and product innovation should be watching in parallel.

Outlook

The regulatory horizon carries three items worth tracking into the next cycle. The EU AMLR's beneficial-ownership core provisions and AMLA's technical standards fall due in the third quarter of 2026, a year ahead of the AMLR's full application date, and roughly a third of Member States have already missed the prior 2025 register-access transposition deadline, triggering infringement proceedings; the compliance-gap window this creates for cross-border beneficial-ownership verification is worth monitoring closely. The UK's Economic Crime and Corporate Transparency Act failure-to-prevent-fraud offence is in force and live for large organizations meeting its size threshold, with documentation practices around reasonable prevention procedures still uneven. Both the UK's next National Risk Assessment and the EU's next Supra-National Risk Assessment are expected in the 2026-2027 window, though this has not been independently verified this cycle. Scenario framing below is illustrative orientation only, not a prediction of how any of these threads resolve.

Lead Signal

The Financial Integrity Monitor record for Arkansas this cycle is dominated by a structural rollback of the federal beneficial-ownership disclosure regime rather than by any single enforcement episode, and the architecture-over-incident principle applies with unusual clarity here. The FinCEN interim final rule, effective 26 March 2025, exempted all domestically formed reporting companies, including Arkansas-formed LLCs and corporations, from the Corporate Transparency Act requirement to report beneficial-ownership information, restricting the surviving disclosure obligation to foreign-formed entities registering to do business in a US state or tribal jurisdiction. The US House Financial Services Committee, chaired by an Arkansas representative, advanced the Repealing Big Brother Overreach Act out of committee on 22 April 2026 with the effect of codifying that exemption by statute; the bill has not been enacted and Senate action remains pending. Taken together, these two developments restore a pre-2024 opacity baseline for the ownership of Arkansas-formed entities and place the United States 2024 upgrade to largely compliant on FATF Recommendation 24 at material re-assessment risk, since that upgrade was explicitly tied to the Corporate Transparency Act mechanism now narrowed.

The distinguishing Arkansas-specific feature of this cycle is not that the state is unusually exposed to illicit finance in isolation, but that its own congressional delegation functions as a principal architect of the federal-level rollback, illustrating an enabler-jurisdiction dynamic driven by political choice rather than by capacity deficit. This is read alongside a federal preliminary injunction, issued 9 December 2024 and still in force, that enjoins enforcement of the Arkansas own foreign-adversary farmland disclosure statute pending constitutional litigation, meaning the one state-level transparency mechanism Arkansas had built, and which federal agencies were beginning to replicate nationally, currently cannot be enforced.

Other Developments

The Syngenta Arkansas farmland precedent now sits on uncertain enforcement footing. A Swiss-domiciled agribusiness under PRC state-linked ownership held Arkansas farmland through layered corporate subsidiaries without timely disclosure of the ultimate foreign beneficial owner, and a divestiture order with a 280,000 dollar civil penalty followed in October 2023. The underlying Arkansas Act 636 disclosure statute, however, has been enjoined by federal preliminary injunction since December 2024 on preemption grounds, so the precedent illustrating multi-tier corporate opacity over sensitive US farmland now depends on the outcome of ongoing constitutional litigation rather than on a settled enforcement mechanism.

A cartel cash-to-crypto laundering network was designated with a typology bearing directly on Arkansas transit geography. OFAC designated more than a dozen individuals and entities tied to the Sinaloa Cartel Los Chapitos faction on 20 May 2026 for converting bulk US cash fentanyl proceeds into stablecoins for cross-border transfer to Mexico. The underlying scheme, corroborated by FinCEN financial trend analysis, involves interior cash collection, bulk stablecoin conversion, layering across decentralized exchanges, and centralized-exchange off-ramping, with Arkansas positioned within the interior cash-collection and transit corridor.

Sanctions-regime divergence between the United States and its European partners continued to widen. OFAC delisted Tornado Cash from the SDN List effective 21 March 2025 following the Fifth Circuit Van Loon ruling, an action the European Union and United Kingdom have not mirrored. Conversely, the Council of the European Union sanctioned the ruble-pegged A7A5 stablecoin and the payment processor Payeer effective 23 October 2025, without an equivalent OFAC instrument-level designation, creating a compliance-mapping gap for Arkansas-domiciled money-services businesses with European counterparties.

Forward federal digital-asset rulemaking is advancing on two tracks relevant to any Arkansas-chartered entity entering stablecoin issuance. The FinCEN own proposed rule, issued April 2026, applies Bank Secrecy Act and sanctions-compliance obligations to Permitted Payment Stablecoin Issuers under the GENIUS Act, ahead of a statutory implementation deadline of 18 January 2027. Separately, FinCEN closed the comment period on 9 June 2026 for a proposed reform of Bank Secrecy Act program requirements under the AML Act of 2020 that would shift supervisory expectations toward risk-based, outcome-focused compliance programs.

Structural gaps persist in the Arkansas own oversight architecture. Unlike more than eighteen other US states, Arkansas has not enacted crypto-ATM consumer-protection legislation, leaving kiosk-based cash-to-crypto conversion less regulated against a national backdrop of approximately 333 million dollars in crypto-ATM fraud losses between January and November 2025. No standalone Arkansas-specific state-level Bank Secrecy Act or OFAC enforcement action was independently identified this cycle, an absence-of-evidence signal limiting assessment of state-level supervisory quality. Separately, the USDA and Treasury CFIUS announced a partnership with state lawmakers on 8 July 2025 extending nationally a farmland-ownership restriction model piloted by the Arkansas own 2023 statute, expanding CFIUS review of agricultural-sector foreign transactions even as the original Arkansas mechanism remains enjoined.

Cross-Monitor Connections

The political-economy dynamic in which an Arkansas congressional office is a principal driver of the federal beneficial-ownership rollback warrants cross-reference to the state-capture-adjacent lens used by the kleptocratic state-capture monitor, since the mechanism at work is legislative choice by domestic political actors rather than external capture of a weak state apparatus. The cartel cash-to-crypto laundering typology connecting interior US cash-collection corridors to Mexican deployment sits at the intersection of sanctions architecture and digital-asset channels, and the same bulk-conversion and cross-exchange layering tradecraft documented here recurs in other conflict-finance and commodity-flow-adjacent laundering typologies tracked elsewhere in the suite. The widening US-EU sanctions divergence on Tornado Cash and the A7A5 stablecoin is relevant to any monitor tracking correspondent-banking and crypto-exchange screening obligations across jurisdictions with materially different list architectures, since firms operating across both blocs must now reconcile two sanctions regimes that no longer move in step on digital-asset instruments.

Outlook

The forward calendar for Arkansas is dominated by federal rather than state-specific rulemaking. The FinCEN Permitted Payment Stablecoin Issuer rule is expected to finalize ahead of the 18 January 2027 statutory deadline, the FinCEN Bank Secrecy Act program-reform rule is expected around September 2026, and the CLARITY Act market-structure legislation and the Repealing Big Brother Overreach Act both face uncertain resolution in the fourth quarter of 2026. The single most consequential open question remains whether the FATF flags the domestic-company beneficial-ownership exemption as a re-emergent deficiency at the next US follow-up assessment, a determination that would carry reputational and correspondent-banking consequences well beyond Arkansas itself. Any forward scenario framing offered elsewhere in this cycle record is illustrative orientation only, not a prediction.