--- title: "United States — District of Columbia (US-DC) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/united-states-district-of-columbia/ source_html: /jurisdictions/united-states-district-of-columbia/index.html description: "Financial integrity intelligence for United States – District of Columbia (US-DC): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: 9178334af343be868629615c72923232050b065b257f4b791ee560db23431966 generator: "fe-fleet/md-twin@1.0" --- # United States — District of Columbia (US-DC) — 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 — District of Columbia US-DC Domains covered 8 of 8 Sources 163 Role actions 8 Horizon <90d 0 Jurisdiction profile FATF status: Largely Compliant Tier: A Risk direction: Increasing Enablement vs enforcement: Mixed Federal BSA/USA PATRIOT Act/AML Act 2020 framework administered by FinCEN and OFAC, both headquartered in DC; DC's own DISB supervises DC-licensed MSBs and non-bank financial institutions. More DC-formed LLCs (DCRA registry) carry no independent beneficial-ownership disclosure requirement, inheriting the national CTA framework, which since March 2025 exempts domestic reporting companies from BOI reporting. DC was named directly in FinCEN's residential real estate GTOs; the successor nationwide rule was judicially vacated in March 2026. Key deficiencies - Beneficial-ownership opacity for domestic (including DC-formed) LLCs since the March 2025 CTA domestic-reporting-company exemption - Real estate AML reporting gap following the March 2026 vacatur of the Residential Real Estate Rule and February 2026 GTO expiration - FARA/lobbying-sector disclosure gaps — fee-source and beneficiary-of-services information not required in filings - Stablecoin/crypto AML-CFT supervisory architecture not yet finalized pending GENIUS Act implementing rules Recent developments (18m) - FinCEN interim final rule (March 21/26, 2025) exempting all US domestic reporting companies and their beneficial owners from CTA BOI reporting - FinCEN Residential Real Estate Rule effective date (Dec 1, 2025) postponed to March 1, 2026, then vacated by E.D. Texas court on March 19, 2026 - FinCEN renewal of residential real estate GTOs naming the District of Columbia (effective Oct 10, 2025; expired Feb 28, 2026) - GENIUS Act signed into law July 2025; FinCEN/OFAC joint PPSI AML/CFT and sanctions-compliance NPRM issued April 8, 2026 - OFAC Russian Harmful Foreign Activities Sanctions Regulations designation action effective Nov 21, 2025 - OFAC-Tether coordinated freeze of ~USD 344.2 million in USDT linked to the Central Bank of Iran (April 2026) - FinCEN Section 311 action proposing to sever Huione Group successor entities from the US financial system (Oct 2025, amended 2026) United States federal law that applies in United States – District of Columbia is covered once, on the [United States](/jurisdictions/us/) page. This page covers United States – District of Columbia’s own layer: its own law, regulators and enforcement. Brief ## Lead signal #### Lead Signal District of Columbia financial-integrity exposure this cycle centers on crypto-kiosk enforcement reached through the District's general money-transmission regime rather than through any crypto-specific statute. The District's Department of Insurance, Securities and Banking is reported as a party to a 34-state BSA/AML consent settlement with Coinme Inc., carrying a 2.5 million dollar payment, an independent consultant review, and a requirement that kiosk operations be shut down by 1 January 2027 or face a further 4 million dollar penalty. No District-specific consent-order text was independently located this cycle; the District's participation rests on a national press account from the Conference of State Bank Supervisors and corroborating secondary state-level releases. Read full brief #### Lead Signal District of Columbia financial-integrity exposure this cycle centers on crypto-kiosk enforcement reached through the District's general money-transmission regime rather than through any crypto-specific statute. The District's Department of Insurance, Securities and Banking is reported as a party to a 34-state BSA/AML consent settlement with Coinme Inc., carrying a 2.5 million dollar payment, an independent consultant review, and a requirement that kiosk operations be shut down by 1 January 2027 or face a further 4 million dollar penalty. No District-specific consent-order text was independently located this cycle; the District's participation rests on a national press account from the Conference of State Bank Supervisors and corroborating secondary state-level releases. The legal basis bringing the District into this coordinated action is its general Money Transmitters Act, administered by DISB, which requires licensure for money transmission under D.C. Code § 26-1002(a). The District has no crypto-specific AML overlay, so the general licensing and customer-due-diligence obligations under that statute are the sole hook by which crypto-kiosk misconduct is reached. This structural reliance, rather than the settlement amount itself, is the more durable finding this cycle. #### Other Developments Athena Bitcoin litigation continues in parallel. The District's Attorney General filed suit against Athena Bitcoin, Inc. in September 2025 alleging that 93 percent of District Bitcoin-ATM deposits traced to scam-linked activity and that undisclosed fees ran as high as 26 percent. Secondary mid-2026 reporting indicates the matter remains active, though no settlement or judgment has been located this cycle. The underlying complaint itself is independently confirmed; its continuing-active status for 2026 rests only on a single secondary legal-commentary source. The enabler-jurisdiction reading of the general MTL regime. Because the District lacks a dedicated crypto-asset statute, its standing as an enforcement participant depends entirely on the general money-transmission licensing framework extending to virtual-currency kiosk operators. This is a structural observation about regime design rather than a comment on enforcement intensity: the District is neither more nor less permissive than peer jurisdictions by virtue of this gap, but its crypto-sector exposure is mediated through generic rather than purpose-built law. #### Cross-Monitor Connections The Coinme settlement and the ongoing Athena Bitcoin litigation both concern crypto-asset kiosk operators and their payment-processing conduct, placing this material adjacent to payment-services and fintech-commercial tracking conducted elsewhere in the fleet. Readers tracking the commercial dimension of the Coinme matter, including the related change-of-control activity in that operator's ownership, should cross-reference payment-monitor coverage rather than expect a commercial-structure analysis here. #### Outlook The operative date to watch is 1 January 2027, the deadline by which Coinme must complete the required kiosk shutdown or face the additional 4 million dollar penalty under the multistate settlement terms. Separately, the Athena Bitcoin litigation's resolution, whether by settlement, judgment, or continued pendency, will be the clearer signal of how the District's general consumer-protection and money-transmission statutes are applied to crypto-kiosk misconduct going forward, given the absence of dedicated crypto AML legislation in the District. Earlier periodic briefs (3) 25 Oct 2026 · fim-2026-10-25 #### Lead Signal District of Columbia financial-integrity exposure centers on crypto-kiosk enforcement reached through the District's general money-transmission regime rather than through any crypto-specific statute. The District's Department of Insurance, Securities and Banking is reported as a party to a 34-state BSA/AML consent settlement with Coinme Inc., carrying a 2.5 million dollar payment, an independent consultant review, and a requirement that kiosk operations be shut down by 1 January 2027 or face a further 4 million dollar penalty. No District-specific consent-order text was independently located; the District's participation rests on a national press account from the Conference of State Bank Supervisors and corroborating secondary state-level releases. The legal basis bringing the District into this coordinated action is its general Money Transmitters Act, administered by DISB, which requires licensure for money transmission under D.C. Code § 26-1002(a). The District has no crypto-specific AML overlay, so the general licensing and customer-due-diligence obligations under that statute are the sole hook by which crypto-kiosk misconduct is reached. This structural reliance, rather than the settlement amount itself, is the more durable finding. #### Other Developments Athena Bitcoin litigation continues in parallel. The District's Attorney General filed suit against Athena Bitcoin, Inc. in September 2025 alleging that 93 percent of District Bitcoin-ATM deposits traced to scam-linked activity and that undisclosed fees ran as high as 26 percent. Secondary mid-2026 reporting indicates the matter remains active, though no settlement or judgment has been located. The underlying complaint itself is independently confirmed; its continuing-active status for 2026 rests only on a single secondary legal-commentary source. The enabler-jurisdiction reading of the general MTL regime. Because the District lacks a dedicated crypto-asset statute, its standing as an enforcement participant depends entirely on the general money-transmission licensing framework extending to virtual-currency kiosk operators. This is a structural observation about regime design rather than a comment on enforcement intensity: the District is neither more nor less permissive than peer jurisdictions by virtue of this gap, but its crypto-sector exposure is mediated through generic rather than purpose-built law. #### Cross-Monitor Connections The Coinme settlement and the ongoing Athena Bitcoin litigation both concern crypto-asset kiosk operators and their payment-processing conduct, placing this material adjacent to payment-services and fintech-commercial tracking conducted elsewhere in the fleet. Readers tracking the commercial dimension of the Coinme matter, including the related change-of-control activity in that operator's ownership, should cross-reference payment-monitor coverage rather than expect a commercial-structure analysis here. #### Outlook The operative date to watch is 1 January 2027, the deadline by which Coinme must complete the required kiosk shutdown or face the additional 4 million dollar penalty under the multistate settlement terms. Separately, the Athena Bitcoin litigation's resolution, whether by settlement, judgment, or continued pendency, will be the clearer signal of how the District's general consumer-protection and money-transmission statutes are applied to crypto-kiosk misconduct going forward, given the absence of dedicated crypto AML legislation in the District. 28 Sep 2026 · fim-2026-09-28 #### Lead Signal DC's money-transmission statute has been recodified from the repealed Title 47, Chapter 31 (Consumer Transmission of Money Act) into Title 26, Chapter 10 (Money Transmissions), with DISB confirmed as the designated regulator. The exact repealing instrument and effective date were not independently isolated this cycle, and this gap is carried forward rather than inferred. This is a structural finding for DC's AML/CTF architecture: the regime governing money-services businesses, including virtual-currency kiosk and exchange operators, now sits on a different statutory footing than it did under the prior consumer-transmission statute, even though the substantive licensing requirement for these businesses is unchanged. #### Other Developments FATF grey-list expansion. FATF's June 2026 plenary added Bosnia and Herzegovina and Iraq to its list of jurisdictions under increased monitoring, and removed Algeria and Namibia, bringing the list to 22 jurisdictions. The black list of Iran, North Korea and Myanmar was unchanged. This is Enhanced due diligence territory under the fleet's Countermeasures/Increased monitoring/Enhanced due diligence/Comprehensive sanctions/Sectoral sanctions vocabulary: FATF grey-list status is properly labelled Increased monitoring, not a UK or DC-specific EDD trigger in its own right. OFAC sanctions designation tied to conflict finance. On 16 January 2026, OFAC designated individuals and entities tied to Iran-backed Ansarallah oil-smuggling and financing networks operating via Yemen, Oman and the UAE, continuing a standing sanctions-architecture line against these networks; this action is properly categorised Comprehensive sanctions under the OFAC SDN-listing mechanism. DISB confirms crypto kiosk licensing requirement remains active. DISB's 2022 bulletin and 2023 notice continue to confirm that entities operating Bitcoin Teller Machines or virtual-currency exchange kiosks in DC require a District money transmitter licence, and that DISB is actively monitoring compliance with this requirement. #### Cross-Monitor Connections The DC money-transmission recodification connects directly to world-payments' W1a licensing findings for this jurisdiction, and to crypto's crypto_licensing module, both of which independently confirm DISB's continuing application of the general MTL framework to virtual-currency businesses. The OFAC Houthi-network designation also carries a conflict-finance dimension: oil-smuggling revenue is understood to be funding non-state armed-actor activity, a channel relevant to SCEM-style conflict-finance monitoring beyond this monitor's own D1 sanctions lens. #### Outlook Watch for FATF's October 2026 plenary, the first under UK presidency, for further movement on the grey list. For DC specifically, resolution of the exact repealing instrument and date for the former Title 47, Chapter 31 statute would close a standing gap in the AML/CTF architecture picture; absent that, DISB's active compliance-monitoring posture toward crypto kiosk and exchange operators is expected to continue unchanged. 3 Sep 2026 · fim-2026-08-05 #### Lead Signal OFAC's designation of sitting Cambodian Senator Kok An and 28 associates is this cycle's clearest architecture-level finding: it establishes, at Treasury's own primary-source confidence, that a national legislator directly controlled scam-compound networks operating through casino holdings tied to Crown Resorts and Anco Brothers entities, with the underlying illicit activity built on crypto pig-butchering fraud. The designation sits inside a wider enforcement pattern that is itself only partially effective: Cambodia's casino regulator, the CGMC, reports roughly 91 casino closures and more than 250 raids over nine months, yet Amnesty International's own June 2026 research found more than seventy percent of identified scam compounds had not been reached by that crackdown. Read together, these two findings describe an enabler-jurisdiction architecture where political protection at the senator level, not merely regulatory capacity, is the binding constraint on enforcement reach. #### Other Developments Sanctions enforcement against Russian shadow-fleet infrastructure is shifting from listing to interdiction. The EU's 20th sanctions package added 46 vessels to its shadow-fleet designation list, bringing the total to 632 tankers, and the United Kingdom physically boarded the Russian shadow-fleet tanker Smyrtos in the English Channel on 14 June 2026. The move from a purely list-based instrument to active maritime interdiction raises compliance exposure for insurers, correspondent banks, and trade-finance counterparties financing tanker-adjacent cargo, even where the vessel itself is not their direct counterparty. US and EU beneficial-ownership transparency regimes continue to diverge. FinCEN's March 2025 interim final rule eliminated beneficial-ownership-information reporting for domestic reporting companies and US persons, exempting more than 99 percent of previously covered entities, even after the Eleventh Circuit Court of Appeals held the Corporate Transparency Act constitutional in December 2025. The durable structural backdrop underneath this divergence is three-part: the AML Regulation, directly applicable across Member States; the sixth AML Directive, transposed per Member State; and the AMLA Regulation establishing the Anti-Money Laundering Authority, which has been operational since 1 July 2025 and must submit its first package of 23 Level 2 and Level 3 technical measures to the Commission by 10 July 2026. Where the US narrows domestic coverage, the EU is building toward a hybrid EU-level supervisory perimeter. Narco-finance containment in the Americas shows signs of deterioration. OFAC designated more than 50 Mexican individuals and entities linked to the Cartel de Jalisco Nueva Generacion on 23 July 2026, while the United States separately designated Colombia in its FY2026 Majors List determination as having failed demonstrably to meet international counternarcotics obligations, the first such finding in nearly 30 years. Crypto-rail sanctions evasion is being addressed at the architecture level rather than the transaction level. Chainalysis's 2026 Crypto Crime Report attributes 93.3 billion dollars in ten-month transaction volume to the ruble-backed stablecoin A7A5, a scale that has prompted a US Treasury proposal, floated in April 2026, requiring stablecoin issuers to run risk-based AML and sanctions screening across both primary and secondary market activity. #### Cross-Monitor Connections The Kok An designation is a direct state-capture cross-reference: a sitting senator's direct operational control of scam-compound casino infrastructure is a governance-capture finding as much as a financial-crime one, and the CGMC's incomplete reach into identified compounds is best read alongside that institutional-capacity lens rather than as an AML finding in isolation. The CJNG and Colombia designations connect to conflict-finance tracking of narco-trafficking financial infrastructure in the Americas. The A7A5 stablecoin finding is a natural cross-reference to the extent that ruble-denominated crypto rails intersect with broader Russian sanctions-evasion information architecture, though this cycle's evidence speaks to the financial-flow dimension rather than an information-operations dimension specifically. #### Outlook The most consequential near-term date on the horizon is 10 July 2026, by which AMLA must submit its first RTS/ITS package of 23 Level 2 and Level 3 measures and by which AMLD6's beneficial-ownership register provisions transpose across Member States — a structural step toward the hybrid EU-level supervisory perimeter described above. On the US side, a final FinCEN rule on the narrowed reporting-company definition remains pending for Q4 2026 with uncertain scope. Watch also for whether Cambodia's enforcement posture moves beyond casino closures toward the political-protection layer the Kok An designation exposed, and whether the EU's escalation from listing to physical interdiction of shadow-fleet vessels extends to further boardings. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion The dominant D1 fact this cycle is a correction rather than a new sanction: the record on-chain freeze of Iranian sovereign crypto reserves, initially reported as having occurred on 1 April 2026, is confirmed to have taken place between 23 and 27 April 2026, with the freeze itself executed around 23 April and OFAC's SDN list updated between 24 and 27 April. OFAC designated two TRON-based wallet addresses attributed to the Central Bank of Iran, reported with linkages to the IRGC-Qods Force and Hizballah; Tether coordinated a freeze of approximately USD 344.2 million across both addresses, described as the largest on-chain freeze on record. The three-week date error, corroborated across Chainalysis, CoinDesk and Scorechain reporting rather than a direct OFAC SDN-list publication specific to this action, is itself a data point about the fragility of timeline fidelity in fast-moving crypto-enforcement reporting: a claim of this magnitude sat uncorrected in the corpus until this cycle's verification pass caught the discrepancy. Continue reading Running in parallel, and on an independent calendar, OFAC continued its designation activity under the Russian Harmful Foreign Activities Sanctions Regulations, adding blocked persons effective 21 November 2025 and requiring that any payments due to those persons be routed into blocked accounts under 31 CFR part 587. This is a routine expansion of a mature sanctions architecture rather than a structural shift, but it is administered from the same Washington headquarters that runs the Iran and Huione-adjacent programs, underscoring that OFAC's designation machinery operates across sanctions programs as a single institutional capability rather than as siloed regimes. The freeze also demonstrates a specific enforcement architecture worth separating into its constituent layers under a three-level reading: the scheme, in which Iranian sovereign reserves were reportedly held in USDT to gain dollar-liquidity access despite sanctions; the architecture, a public-private coordination model in which a private stablecoin issuer possesses and exercises freeze authority over designated addresses, acting in concert with OFAC designation; and the strategic consequence, a demonstration that on-chain freeze capability can reach state-level sanctioned holdings at a scale exceeding prior public freezes, even where the issuer's own compliance-program obligations under the GENIUS Act are not yet finalised. This three-level separation matters because the capability currently rests on Tether's voluntary cooperation rather than a codified statutory freeze mandate specific to payment-stablecoin issuers, a gap the GENIUS Act's implementing rules are intended to close. FinCEN's proposed Section 311 special measure against Huione Group successor entities, including H-Pay Service PLC, sits at the intersection of sanctions-adjacent and anti-money-laundering authority: the proposed rule would sever the successor network from the US financial system by refining the definition of Huione Group as a financial institution of primary money-laundering concern. The rule remains open as of this cycle, and its architecture-level target, a facilitation network rather than a single account or transaction, is consistent with the broader pattern of this cycle's D1 signal: enforcement directed at connective infrastructure rather than isolated violations. The Treasury Department's Kleptocracy Asset Recovery Rewards Program continues to operate as a standing mechanism from its Washington headquarters, a structural fact rather than an incident, and one that anchors the standing tracker's continuity assessment for the Russian sanctions-evasion architecture this cycle. Read together, the D1 signal this cycle is less about new designations than about the integrity of the reporting on existing ones: the actions themselves are well-evidenced at the level of designation and dollar amount, but the precise timeline, which matters for downstream screening and enforcement-pattern analysis, depended this cycle on vendor and press corroboration rather than primary-source publication. #### Outlook Three threads carry D1 forward. First, the FinCEN Section 311 proceeding against Huione Group successor entities remains open; its finalisation would extend a template for severing digital-asset-native facilitation networks from the US financial system that could be applied to comparable structures elsewhere. Second, the absence this cycle of a primary OFAC SDN-list publication specific to the corrected Iran-freeze date is a collection gap that the next cycle should aim to close, both to firm the date to high confidence and to test whether other crypto-enforcement dates in the corpus carry similar uncertainty. Third, RuHSR designation activity is expected to continue on its own administrative calendar, independent of the Iran- and Huione-related actions, and should be tracked as routine architectural maintenance rather than escalation absent a structural change in scope or authority. None of these are predictions; they are the open questions this cycle's verification pass leaves for the next. Judgment: No DC-specific sanctions activity; sanctions authority is federal. Uncertain #### Beneficial Ownership and Corporate Transparency The D2 posture for US-DC this cycle is defined by two compounding reversals, both now correctly caveated as contested rather than settled. The first and larger is FinCEN's March 2025 interim final rule exempting all US-formed reporting companies, including DC-formed LLCs, and their beneficial owners from Corporate Transparency Act beneficial-ownership-information reporting, described as the single most consequential US corporate-transparency reversal in over a decade. This cycle's verification finding adds a caveat that materially changes the risk-permanence assessment without changing the underlying fact: the exemption is an administrative, interim posture, not a settled statutory endpoint. The CTA itself was upheld as constitutional by the Eleventh Circuit in December 2025, meaning the statute survives even as its principal implementing obligation for domestic entities has been administratively suspended. DC-formed LLCs, which are fully dependent on the national CTA framework given the District's own registry lacks an independent beneficial-ownership disclosure requirement, are disproportionately exposed given DC's dense, LLC-heavy lobbying, consulting and property-holding sector relative to its small resident population. Continue reading The second reversal concerns residential real estate. The nationwide Residential Real Estate Rule, which had required reporting of non-financed transfers of residential property to legal entities, was vacated by an E.D. Texas court on 19 March 2026, after the predecessor Geographic Targeting Orders naming DC had already expired on 28 February 2026. Unlike the CTA exemption, which followed from an administrative rule under an intact statute, the RRE vacatur followed from judicial invalidation, and FinCEN and the Department of Justice have filed a Notice of Appeal in the Fifth Circuit, dated 11 May 2026. The reporting vacuum for anonymous cash real-estate purchases created by the vacatur is therefore contested and could be reversed on appeal, a distinction this cycle's verification pass restores after its initial omission understated the finality of the gap. A third, forward-looking development threatens to convert the currently reversible CTA exemption into something structurally different: a House committee began a party-line process in April 2026 to replace the CTA's beneficial-ownership disclosure requirements outright. If enacted, this would remove the exemption's reversibility-by-rulemaking character and entrench current domestic beneficial-ownership opacity on a permanent statutory footing, a materially different risk posture than an executive-branch rule that a future administration could rescind. Standing behind this US-specific picture is a durable structural fact about the parallel EU architecture, offered here as backdrop rather than as this cycle's development: the EU AML Package comprises three distinct instruments, the directly applicable AML Regulation (Regulation (EU) 2024/1624), the sixth AML Directive requiring Member State transposition, and the AMLA Regulation (Regulation (EU) 2024/1620) establishing the Anti-Money Laundering Authority, whose direct- and indirect-supervision perimeter is shifting cross-border obliged-entity supervision from purely national authorities toward a hybrid EU-level regime. No EU-specific AMLA development was collected for the US-DC jurisdiction this cycle; the architecture is noted as standing context against which the US's divergent, opacity-widening trajectory this cycle can be read, since the CTA rollback moves the United States away from, rather than toward, the interconnection and access standard the EU architecture is built to enforce. #### Outlook The Fifth Circuit's disposition of the Residential Real Estate Rule appeal is the nearest-term determinative event: reversal would restore a federal reporting requirement for anonymous cash real-estate purchases, while affirmance would foreclose it absent new rulemaking. In parallel, the House committee's effort to statutorily narrow the CTA is the development most likely to change the domain's trajectory qualitatively rather than incrementally, since a statutory settlement would remove the reversibility that currently characterises the domestic exemption. Absent either outcome, D2 for US-DC remains structurally worsening: two of the three principal federal beneficial-ownership reporting channels are currently suspended or vacated, and DC's own registry provides no independent backstop. Judgment: DC's own BO disclosure regime continues unaffected by the federal CTA narrowing, which predates this window. Probable #### Enabler Jurisdictions The District of Columbia's relevance to enabler-jurisdiction analysis this cycle turns on a structural gap rather than an enforcement failure: the District has no crypto-specific AML overlay, so when a virtual-currency kiosk operator's conduct required a coordinated multistate response, the District could only participate through its general Money Transmitters Act, administered by the Department of Insurance, Securities and Banking under D.C. Code § 26-1002(a). That statute's licensing and customer-due-diligence requirements became the enforcement hook in a 34-state BSA/AML consent settlement with Coinme Inc., carrying a 2.5 million dollar payment, a mandated independent consultant review, and a kiosk-shutdown deadline of 1 January 2027 backed by a further 4 million dollar penalty for non-compliance. No District-specific consent-order text has been independently located this cycle, so the District's role in this settlement is established through a national press account from the Conference of State Bank Supervisors corroborated by secondary state-level releases, rather than through a primary DISB document. Continue reading This is the archetypal enabler-jurisdiction pattern in miniature: not a jurisdiction that actively courts under-regulated activity, but one whose general-purpose licensing regime is the only available lever when a sector-specific gap exists. The District's position is distinct from jurisdictions that have affirmatively built permissive crypto frameworks; here, the absence of a dedicated statute means enforcement capacity exists only insofar as the general money-transmission definition is read to capture virtual-currency kiosk operation. The fact that DISB is reported as one of 34 participating state regulators indicates that reading has in fact been applied, but the degree to which the District's own due-diligence and supervisory practice toward crypto-kiosk operators differs from its approach to conventional money-service businesses remains undocumented in sources reviewed this cycle. Parallel to the multistate settlement, the District's Attorney General's litigation against Athena Bitcoin, Inc., filed in September 2025 and alleging that 93 percent of District Bitcoin-ATM deposits were scam-linked with undisclosed fees as high as 26 percent, provides a second data point on how the District's existing general consumer-protection statute, rather than a dedicated financial-crime framework, is the vehicle for addressing kiosk-sector misconduct. Secondary reporting places the litigation as still active through mid-2026, though no settlement or judgment has been confirmed this cycle. Taken together, the Coinme settlement and the Athena Bitcoin litigation show the District reaching crypto-kiosk conduct consistently through generic rather than purpose-built legal instruments, which is the defining structural characteristic of this jurisdiction's current posture in this domain. #### Outlook The most consequential marker ahead is whether the District's reliance on general-purpose statutes proves durable as kiosk-sector volumes and typologies evolve, or whether the Coinme and Athena Bitcoin matters prompt District-specific crypto AML rulemaking. The 1 January 2027 Coinme shutdown deadline and the continuing pendency of the Athena Bitcoin suit are the two concrete events most likely to clarify this trajectory, though as scheduled neither outcome can yet be confirmed from sources reviewed this cycle. Judgment: No DC-specific enabler-jurisdiction finding this cycle. Uncertain #### Conflict Finance and Extractive-Industry Integrity D4 signal for the US-DC jurisdiction is limited this cycle: no direct conflict-finance flow was identified, and the single substantive development is an enabler-side rather than a conflict-flow-side finding. Reporting identifies Trump-linked DC lobbying and advisory firms negotiating multimillion-dollar mineral-sector lobbying contracts on behalf of aid-dependent and scrutiny-adjacent foreign governments, occurring amid reductions in US foreign aid. This is assessed at possible confidence: it rests on a single tier-2 source, is pattern-consistent with DC's broader professional-services enablement architecture tracked more fully under D3, but has not been independently corroborated this cycle. Continue reading The primary domain assignment for this development is D4, given its mineral-sector subject matter and the extractive-industry-corruption-adjacent enablement concern it raises, with D3 as a strong secondary reading given that the mechanism is professional-services lobbying rather than a direct financial flow. Read as a D4 signal specifically, the concern is that reduced US bilateral aid leverage may be coinciding with an increase in direct commercial lobbying relationships between DC-based firms and the same categories of foreign government that aid conditionality would otherwise be used to influence, potentially substituting a private commercial channel for a public policy one in a sector, extractive minerals, historically associated with corruption and conflict-finance risk elsewhere. #### Outlook This is a watch-status domain for the jurisdiction this cycle rather than an active one. The principal open item is corroboration: a second independent source for the mineral-sector lobbying claim would move the assessment from possible to assessed confidence and justify a fuller D4 treatment in a subsequent cycle. Absent that corroboration, or a directly identified conflict-finance flow specific to the jurisdiction, D4 should continue to be read primarily through the D3 enabler-jurisdiction lens. Judgment: No DC-specific conflict-finance finding this cycle. Uncertain #### Crypto / Digital Assets / Financial Innovation The District of Columbia's crypto-sector financial-integrity exposure this cycle is dominated by two parallel matters involving kiosk-based virtual-currency operators. First, the District's Department of Insurance, Securities and Banking is reported as a party to a 34-state BSA/AML consent settlement with Coinme Inc., which includes a 2.5 million dollar payment, a mandated independent consultant review of the firm's compliance program, and a requirement to cease kiosk operations by 1 January 2027 or face an additional 4 million dollar penalty. The settlement reflects a coordinated multistate supervisory response to AML weaknesses identified at a crypto-kiosk operator, though no District-specific consent order has been independently located this cycle; the District's participation rests on a national press account and corroborating secondary state releases rather than a primary DISB document. Continue reading Second, and running in parallel, the District's Attorney General continues litigation against Athena Bitcoin, Inc., filed in September 2025, alleging that 93 percent of District Bitcoin-ATM deposits traced to scam-linked activity, with undisclosed transaction fees reported as high as 26 percent. Secondary reporting from mid-2026 indicates the matter remains active, though this status rests on a single legal-commentary source rather than a primary court filing, and no settlement or judgment has been identified this cycle. Together, these two matters indicate that crypto-kiosk channels, rather than exchange-based or custodial crypto activity, are the locus of financial-integrity concern in the District's digital-asset sector at present. A structural point threads through both matters: the District has no crypto-specific AML statute, so both the multistate settlement and the Athena Bitcoin litigation proceed under general instruments, respectively the Money Transmitters Act (D.C. Code § 26-1002(a)) and the general Consumer Protection Procedures Act (D.C. Code §§ 28-3901 et seq.). For a crypto-asset or payment-company operator assessing District exposure, this means compliance expectations for kiosk operations are shaped by generic money-transmission and consumer-protection standards rather than by a dedicated crypto-asset supervisory framework, a posture that places interpretive weight on how broadly DISB and the Attorney General read those general statutes against virtual-currency conduct. #### Outlook The 1 January 2027 Coinme shutdown deadline is the nearest concrete date against which District crypto-kiosk policy will be tested; failure to meet it triggers the further 4 million dollar penalty under the settlement terms. The Athena Bitcoin litigation's trajectory, whether toward settlement, judgment, or continued pendency, remains the more open question and, absent new filings, its current status as still active cannot be confirmed beyond the mid-2026 secondary reporting available this cycle. Judgment: DISB continues applying its general money-transmission statute to virtual-currency businesses; no new DC-specific development. Uncertain #### Compliance Technology and Active Defence D6 signal this cycle centres on the gap between demonstrated active-defence capability and codified statutory authority, a gap the domain is specifically positioned to track as it closes. The Tether/TRM Labs-anchored T3 Financial Crime Unit is cited as a public-private disruption model that has frozen over USD 450 million in illicit USDT since September 2024, including the corrected April 2026 record freeze of Central Bank of Iran-linked holdings. This model illustrates an active-defence, technology-enabled compliance posture operating ahead of finalised statutory authority: the freeze capability is exercised through voluntary issuer cooperation with OFAC designation activity rather than through a codified, issuer-specific statutory mandate. Continue reading That codified mandate is precisely what the joint FinCEN/OFAC proposed rule, the PPSI AML/CFT and sanctions-compliance NPRM issued 8 April 2026, would establish. The proposed rule would impose formal BSA/AML program and sanctions-compliance-program obligations on payment-stablecoin issuers, shifting the current ad hoc freeze-coordination model onto a codified compliance-technology and governance footing once finalised, with finalisation pending against the 18 July 2026 deadline established by the GENIUS Act. Read as a D6 development specifically, this is the clearest current example in the corpus of a compliance-technology capability, on-chain freeze and monitoring tooling operated jointly by a private issuer and a public regulator, running materially ahead of the governance framework intended to formalise it. This sequencing carries a specific analytical implication for active-defence assessment: the T3 model's effectiveness, evidenced by the scale of funds frozen, should not be read as evidence that the current governance framework is adequate, since the capability currently rests on voluntary cooperation rather than an enforceable, codified compliance-program obligation. The PPSI NPRM's finalisation is therefore the mechanism by which an already-effective operational capability would acquire a correspondingly robust statutory foundation, closing a governance gap rather than creating a new capability. #### Outlook The domain's trajectory depends principally on the PPSI NPRM's finalisation timeline against the 18 July 2026 deadline, and on whether the GENIUS Act's own effective date, triggered by the earlier of 18 months post-enactment or 120 days after final rules issue, arrives before or after that finalisation. Until finalisation, the T3 Financial Crime Unit model should continue to be read as an emerging, watch-status active-defence capability whose statutory grounding remains incomplete rather than as a fully governed compliance-technology regime. Judgment: No RegTech/compliance-technology development specific to DC this cycle. Uncertain #### AML/CTF Regime DC's money-services statute was recodified from the repealed Title 47, Chapter 31 into Title 26, Chapter 10, with DISB designated as the regulator and licensing authority for money-transmission businesses in the District, including virtual-currency kiosk and exchange operators. The exact repealing instrument and effective date were not independently isolated this cycle; this gap is carried forward rather than inferred, consistent with the conservative-confidence principle that a repeal fact confirmed only by the code's own chapter heading, without an isolated repealing instrument, is reported as Probable rather than Confirmed. Continue reading At the global level, FATF's June 2026 plenary added Bosnia and Herzegovina and Iraq to its list of jurisdictions under increased monitoring and removed Algeria and Namibia, bringing the list to 22 jurisdictions; the black list of Iran, North Korea and Myanmar is unchanged. Under the fleet's designation vocabulary this is Increased monitoring, distinct from a Countermeasures call to action and distinct from the EU's own separately-dated high-risk list. The next FATF plenary, scheduled for October 2026, will be the first under UK presidency, and is a date to watch for further list movement. For DC specifically, the AML/CTF regime operates through the general money-transmitter licensing framework rather than a bespoke AML statute: DISB-licensed money-services businesses, including crypto kiosk operators, are subject to standard US federal AML/BSA obligations layered on top of DC's own licensing regime, and DISB's active compliance-monitoring posture toward BTM operators is the clearest DC-specific enforcement signal in this domain this cycle. #### Outlook Watch the October 2026 FATF plenary under the new UK presidency for further grey-list movement. For DC, resolution of the exact repealing instrument and date for the former Title 47, Chapter 31 statute would close a standing gap in the jurisdiction's AML/CTF architecture picture; DISB's active monitoring of money-services businesses, including crypto kiosk and exchange operators, is expected to continue unchanged in the interim. Judgment: No change to DC's federally-derived AML/CTF baseline this cycle. Uncertain Judgment: No commercial activity among integrity-infrastructure firms located this cycle for DC. Uncertain Regulatory horizon No dated horizon items this cycle. 3 items tracked without a confirmed date. 3 pending date · baseline fim-2026-07-06 Role action cards MLRO ### DC DISB is reported as one of 34 state regulators in a BSA/AML consent settlement with crypto-kiosk operator Coinme Inc. A multistate consent settlement reaching crypto-kiosk AML weaknesses, with a mandated independent consultant review and a shutdown deadline of 1 January 2027, signals continued multistate supervisory coordination against this typology. The District's parallel Athena Bitcoin litigation over scam-linked kiosk deposits reinforces that kiosk-channel due diligence is an area of active attention. 2 evidence refs Compliance ### The District reaches crypto-kiosk misconduct solely through its general Money Transmitters Act, with no dedicated crypto AML overlay. Firms operating crypto kiosks or similar virtual-currency services in the District should note that licensing and due-diligence obligations flow from the generic money-transmission statute rather than a purpose-built crypto framework, meaning compliance expectations are shaped by how broadly DISB applies existing general requirements. 2 evidence refs Legal ### Athena Bitcoin, Inc. litigation alleging scam-linked kiosk deposits and undisclosed fees remains reported as active through mid-2026. The underlying complaint, alleging 93 percent of District Bitcoin-ATM deposits were scam-linked with fees up to 26 percent, is independently confirmed; its continuing-active status for 2026 rests on secondary legal commentary rather than a primary filing, and no settlement or judgment has been located this cycle. 1 evidence refs Board ### DC's participation in a 34-state 2.5 million dollar Coinme settlement, alongside ongoing Athena Bitcoin litigation, marks episodic crypto-kiosk enforcement activity in the District this cycle. These are episodic enforcement events rather than a structural regulatory shift; the District has made no crypto-specific rulemaking move, continuing instead to rely on its general money-transmission and consumer-protection statutes. 3 evidence refs Risk ### Crypto-kiosk channels, rather than exchange or custodial crypto activity, are the concentrated point of financial-integrity exposure in the District's digital-asset sector this cycle. Both the Coinme multistate settlement and the Athena Bitcoin litigation concentrate risk in physical kiosk-based virtual-currency conversion, an exposure concentration distinct from other digital-asset business models operating in the District. 2 evidence refs Audit ### No District-specific primary consent-order text for the Coinme settlement has been independently located this cycle. The District's participation in the multistate settlement rests on national CSBS reporting and secondary state-level releases rather than a DISB-issued primary document, a documentation gap worth noting for audit-trail completeness. 1 evidence refs Standing trackers (T1–T6) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture no_change T2 · EU AML Package / AMLA no_change T3 · FATF Grey List no_change T4 · Beneficial-Ownership Register Status no_change T5 · Crypto & Digital-Asset Integrity no_change T6 · Sanctions Regime Divergence no_change Registers ### Enforcement actions - 27 Apr 2026 - 21 Nov 2025 - 1 Oct 2025 - 26 Mar 2025 - 9 Oct 2025 - Roman Storm convicted on operating an unlicensed money-transmission business; jury deadlocked on money-laundering/sanctions-violation conspiracy counts. 2024-08 - 14 Jan 2025 - 7 Oct 2026 - OFAC designated two wallets attributed to the Central Bank of Iran with linkages to the IRGC-Qods Force and Hizballah; Tether coordinated with OFAC and US law enforcement to freeze approximately USD 344.2 million in USDT across both addresses. 1 Apr 2026 - OFAC issued a designation action under the Russian Harmful Foreign Activities Sanctions Regulations effective 12:01 a.m. EST November 21, 2025, requiring payments to blocked persons to be made into blocked accounts. 21 Nov 2025 - FinCEN proposed severing H-Pay Service PLC and other Huione Group successor entities from the US financial system under a Section 311 special-measures action, and issued a proposed amendment refining the definition of 'Huione Group' as a financial institution of primary money laundering concern. 1 Oct 2025 - FinCEN issued an interim final rule revising the CTA's 'reporting company' definition to exclude all US-formed entities, formally exempting domestic reporting companies and their beneficial owners from BOI filing obligations nationwide, including for DC-formed entities. 26 Mar 2025 - FinCEN renewed residential real estate Geographic Targeting Orders requiring title insurers to identify natural persons behind shell companies used in non-financed purchases, explicitly naming the District of Columbia among covered jurisdictions, effective October 10, 2025. 9 Oct 2025 ### Sanctions changes - 21 Nov 2025 - 27 Apr 2026 - 16 Jan 2026 - 23 Apr 2026 - 30 Jun 2026 - 19 Jun 2026 - 23 Apr 2026 - 17 Jul 2026 - 10 Jul 2026 - 23 Jul 2026 - 23 Jul 2026 - 16 Jan 2026 - OFAC designated additional persons/property under the Russian Harmful Foreign Activities Sanctions Regulations effective November 21, 2025, requiring routing of payments to blocked persons into blocked accounts. 21 Nov 2025 - OFAC designated two Central Bank of Iran-linked digital-currency wallets with ties to IRGC-Qods Force and Hizballah, triggering a coordinated Tether freeze of ~USD 344.2 million in USDT. 1 Apr 2026 - FATF's June 2025 plenary added the British Virgin Islands and Bolivia to its Jurisdictions Under Increased Monitoring list and removed Croatia, Mali, and Tanzania; FinCEN issued a corresponding advisory directing US financial institutions (including DC-licensed MSBs) to apply risk-based due diligence per 31 CFR 1010.610. 13 Jun 2025 ### Regulatory horizon (register) - AMLA direct supervision of selected obliged entities begins - GENIUS Act stablecoin AML/sanctions final rules deadline - DOJ appeal of Residential Real Estate Rule vacatur - Congressional effort to narrow Corporate Transparency Act further - US 5th-round FATF mutual evaluation follow-up report ### Active schemes - [CRITICAL] Reopened LLC/BO anonymity via CTA domestic exemption - [HIGH] Anonymous-shell residential real estate laundering, DC market - DC lobbying/FARA network as sanctions-evasion enabler - Stablecoin sanctions-evasion window pending GENIUS Act rules - Cambodia casino-linked crypto pig-butchering scam-compound network (Kok An / Crown Resorts) - Russian shadow-fleet tanker sanctions-evasion network Sources - [US Congressional Committee Chips Away at Corporate Transparency Act | OCCRP](https://www.occrp.org/en/news/us-congressional-committee-chips-away-at-corporate-transparency-act) - [https://amluae.com/fatf-grey-list-countries-update-19th-june-2026/](https://amluae.com/fatf-grey-list-countries-update-19th-june-2026/) - [https://acrioncompliance.com/blogs/acrion-regulation-watch-fatf-updates-grey-list-following-june-2026-plenary/](https://acrioncompliance.com/blogs/acrion-regulation-watch-fatf-updates-grey-list-following-june-2026-plenary/) - [https://klealegal.com/newsroom/amld6-eu-aml-package-entity-management](https://klealegal.com/newsroom/amld6-eu-aml-package-entity-management) - [https://financialregulations.eu/blog/eu-aml-package-amla-amlr-guide](https://financialregulations.eu/blog/eu-aml-package-amla-amlr-guide) - [https://eucrim.eu/news/new-anti-money-laundering-directive-amld-6/](https://eucrim.eu/news/new-anti-money-laundering-directive-amld-6/) - [https://ofac.treasury.gov/recent-actions](https://ofac.treasury.gov/recent-actions) - [https://home.treasury.gov/news/press-releases/sb0469](https://home.treasury.gov/news/press-releases/sb0469) - [https://www.federalregister.gov/documents/2026/07/30/2026-15356/notice-of-ofac-sanctions-action](https://www.federalregister.gov/documents/2026/07/30/2026-15356/notice-of-ofac-sanctions-action) - [https://www.steptoe.com/en/news-publications/international-compliance-blog/weekly-sanction-update-july-20-2026.html](https://www.steptoe.com/en/news-publications/international-compliance-blog/weekly-sanction-update-july-20-2026.html) - [https://sanctionsnews.bakermckenzie.com/category/ofac/](https://sanctionsnews.bakermckenzie.com/category/ofac/) - [https://www.hklaw.com/en/insights/publications/2026/06/what-happened-to-fincens-corporate-transparency-act](https://www.hklaw.com/en/insights/publications/2026/06/what-happened-to-fincens-corporate-transparency-act) - [https://www.milliganlawless.com/corporate-transparency-act/corporate-transparency-act-update-2026/](https://www.milliganlawless.com/corporate-transparency-act/corporate-transparency-act-update-2026/) - [https://www.amnesty.org/en/latest/news/2026/04/cambodia-casinos-get-state-approval-despite-links-to-human-rights-abuse-at-scamming-compounds/](https://www.amnesty.org/en/latest/news/2026/04/cambodia-casinos-get-state-approval-despite-links-to-human-rights-abuse-at-scamming-compounds/) - [https://wearenotforsale.org/human-trafficking/cambodia-scam-compounds-casinos-trafficking/](https://wearenotforsale.org/human-trafficking/cambodia-scam-compounds-casinos-trafficking/) - [https://www.ggrasia.com/72-cambodian-casinos-shut-amid-year-long-crackdown-on-scam-centres-reports](https://www.ggrasia.com/72-cambodian-casinos-shut-amid-year-long-crackdown-on-scam-centres-reports) - [https://www.khmertimeskh.com/501934605/casino-regulator-tightens-oversight-amid-online-scam-crackdown/](https://www.khmertimeskh.com/501934605/casino-regulator-tightens-oversight-amid-online-scam-crackdown/) - [https://unchainedcrypto.com/treasury-sanctions-cambodian-senator-kok-an-over-pig-butchering-crypto-scam-network/](https://unchainedcrypto.com/treasury-sanctions-cambodian-senator-kok-an-over-pig-butchering-crypto-scam-network/) - [https://www.bloomberg.com/features/2024-golden-triangle-special-economic-zone/](https://www.bloomberg.com/features/2024-golden-triangle-special-economic-zone/) - [https://www.steptoe.com/en/news-publications/international-compliance-blog/weekly-sanctions-update-july-27-2026.html](https://www.steptoe.com/en/news-publications/international-compliance-blog/weekly-sanctions-update-july-27-2026.html) - [https://www.fticonsulting.com/insights/articles/trade-money-laundering](https://www.fticonsulting.com/insights/articles/trade-money-laundering) - [https://www.wttlonline.com/stories/colombia-designated-major-trafficker-in-fraa-review,14278](https://www.wttlonline.com/stories/colombia-designated-major-trafficker-in-fraa-review,14278) - [https://www.logisticsmiddleeast.com/analysis/how-far-can-europe-go-against-russias-shadow-fleet](https://www.logisticsmiddleeast.com/analysis/how-far-can-europe-go-against-russias-shadow-fleet) - [https://www.swp-berlin.org/10.18449/2026C20/](https://www.swp-berlin.org/10.18449/2026C20/) - [https://www.chainalysis.com/blog/crypto-sanctions-2026/](https://www.chainalysis.com/blog/crypto-sanctions-2026/) - [https://www.newstrail.com/the-compliance-gap-behind-crypto-laundering-networks-in-2026/](https://www.newstrail.com/the-compliance-gap-behind-crypto-laundering-networks-in-2026/) - [https://www.coindesk.com/policy/2026/04/08/u-s-treasury-to-propose-demands-that-stablecoin-firms-be-set-to-police-bad-transactions](https://www.coindesk.com/policy/2026/04/08/u-s-treasury-to-propose-demands-that-stablecoin-firms-be-set-to-police-bad-transactions) - [https://uk.practicallaw.thomsonreuters.com/w-039-9590](https://uk.practicallaw.thomsonreuters.com/w-039-9590) - [https://www.ukfinance.org.uk/policy-and-guidance/guidance/guidance-failure-prevent-fraud-offence-eccta-2023](https://www.ukfinance.org.uk/policy-and-guidance/guidance/guidance-failure-prevent-fraud-offence-eccta-2023) - [https://disb.dc.gov/page/banking-licensing-requirements-fintech-companies](https://disb.dc.gov/page/banking-licensing-requirements-fintech-companies) - [https://code.dccouncil.gov/us/dc/council/code/sections/26-1001](https://code.dccouncil.gov/us/dc/council/code/sections/26-1001) - [https://disb.dc.gov/sites/default/files/dc/sites/disb/page_content/attachments/bulletin-disb-cryptocurrency-money-transmission-approved.pdf](https://disb.dc.gov/sites/default/files/dc/sites/disb/page_content/attachments/bulletin-disb-cryptocurrency-money-transmission-approved.pdf) - [https://www.lexology.com/library/detail.aspx?g=99ff4962-762f-4839-b286-c39d7fb72e08](https://www.lexology.com/library/detail.aspx?g=99ff4962-762f-4839-b286-c39d7fb72e08) - [DC Law Library](https://code.dccouncil.gov/us/dc/council/code/titles/47/chapters/31) - [DC Law Library](https://code.dccouncil.gov/us/dc/council/code/sections/26-1001) - [DC DISB](https://disb.dc.gov/sites/default/files/dc/sites/disb/publication/attachments/notice_disb_%20bitcoin_atms_03_16_23.pdf) - [FATF](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-june-2026.html) - [U.S. Treasury / OFAC](https://ofac.treasury.gov/recent-actions/20260116) - [Wikimedia Foundation](https://en.wikipedia.org/wiki/D.C._Lottery) - [https://www.csbs.org/newsroom/state-financial-regulators-reach-25-million-settlement-crypto-kiosk-operator](https://www.csbs.org/newsroom/state-financial-regulators-reach-25-million-settlement-crypto-kiosk-operator) - [https://www.thegeorgiavirtue.com/georgia-crime/coinme-to-shut-down-cryptocurrency-kiosks-in-georgia-following-multistate-settlement/](https://www.thegeorgiavirtue.com/georgia-crime/coinme-to-shut-down-cryptocurrency-kiosks-in-georgia-following-multistate-settlement/) - [https://www.gibsondunn.com/mid-year-developments-in-anti-money-laundering-in-2026/](https://www.gibsondunn.com/mid-year-developments-in-anti-money-laundering-in-2026/) - [https://oag.dc.gov/sites/default/files/2025-09/Athena%20Complaint.pdf](https://oag.dc.gov/sites/default/files/2025-09/Athena%20Complaint.pdf) - [Harbor Compliance](https://www.harborcompliance.com/how-to-form-an-llc-in-district-of-columbia) - [U.S. Department of the Treasury](https://home.treasury.gov/news/press-releases/sb0603) - [DC Department of Licensing and Consumer Protection](https://dlcp.dc.gov/page/corporations-division-business-registration-faqs) - [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) - [CHARTER THE BANK SECRECY ACT ADVISORY GROUP](https://www.fincen.gov/system/files/shared/charter.pdf) - [United States Department of the Treasury Financial Crimes Enforcement Network - Home | FinCEN.gov](https://www.fincen.gov/) - [DEPARTMENT OF THE TREASURY BANK SECRECY ACT ADVISORY GROUP](https://www.fincen.gov/system/files/shared/bsaag_members.pdf) - [Treasury Convenes Law Enforcement, Financial Institutions in the Washington, D.C. Area for Counter-Fentanyl Exchange | FinCEN.gov](https://www.fincen.gov/news/news-releases/treasury-convenes-law-enforcement-financial-institutions-washington-dc-area) - [Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Countering 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-3) - [Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering and Combating the Financing of Terrorism and Counter-Proliferation Deficiencies | FinCEN.gov](https://www.fincen.gov/index.php/news/news-releases/financial-action-task-force-identifies-jurisdictions-anti-money-laundering-and-1) - [Treasury Anti-Money Laundering Regulations | FinCEN.gov](https://www.fincen.gov/treasury-anti-money-laundering-regulations) - [Home](https://www.fatf-gafi.org/en/home.html) - [Anti-Money Laundering Programs for Money Services Businesses | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/federal-register-notices/anti-money-laundering-programs-money) - [FinCEN Removes Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Persons, Sets New Deadlines for Foreign Companies | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-removes-beneficial-ownership-reporting-requirements-us-companies-and-us) - [FinCEN Not Issuing Fines or Penalties in Connection with Beneficial Ownership Information Reporting Deadlines | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-not-issuing-fines-or-penalties-connection-beneficial-ownership) - [Beneficial Ownership Information Reporting | FinCEN.gov](https://www.fincen.gov/boi) - [FinCEN Issues Notice to Financial Institution Customers on Beneficial Ownership Information Requirements | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-notice-financial-institution-customers-beneficial-ownership) - [Beneficial Ownership Information Reporting Rule Fact Sheet | FinCEN.gov](https://www.fincen.gov/beneficial-ownership-information-reporting-rule-fact-sheet) - [FinCEN Issues Final Rule for Beneficial Ownership Reporting to Support Law Enforcement Efforts, Counter Illicit Finance, and Increase Transparency | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-final-rule-beneficial-ownership-reporting-support-law-enforcement) - [Frequently Asked Questions | FinCEN.gov](https://www.fincen.gov/boi-faqs) - [Small Entity Compliance Guide | FinCEN.gov](https://www.fincen.gov/boi/small-entity-compliance-guide) - [Interim Final Rule: Questions and Answers | FinCEN.gov](https://www.fincen.gov/boi/ifr-qa) - [Fact Sheet: Beneficial Ownership Information Access and Safeguards Final Rule | FinCEN.gov](https://www.fincen.gov/news/news-releases/fact-sheet-beneficial-ownership-information-access-and-safeguards-final-rule) - [How Anonymous Companies Are Used to Launder Money in US Real Estate | Global Witness](https://www.globalwitness.org/en/campaigns/corruption-and-money-laundering/anonymous-companies-used-to-launder-money-in-us-real-estate/) - [FinCEN Issues Advisory on Kleptocracy and Foreign Public Corruption | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-advisory-kleptocracy-and-foreign-public-corruption) - [‘A Kleptocrat’s dream’: US real estate a safe haven for billions in dirty money, report says - ICIJ](https://www.icij.org/investigations/fincen-files/a-kleptocrats-dream-us-real-estate-a-safe-haven-for-billions-in-dirty-money-report-says/) - [US real estate key vehicle for money laundering, and as the ‘FinCEN files’ reveal, anonymous companies are at the heart of it | Global Witness](https://www.globalwitness.org/en/press-releases/us-real-estate-key-vehicle-for-money-laundering/) - [US lawmakers move to end anonymous shell companies in national defense spending bill - ICIJ](https://www.icij.org/inside-icij/2020/11/us-lawmakers-move-to-end-anonymous-shell-companies-in-national-defense-spending-bill/) - [How anonymous companies help launder money in US real estate | Global Witness](https://globalwitness.org/en/campaigns/corruption-and-money-laundering/on-the-house/) - [Congress passes historic anti-corruption provision, culminating decade-long fight to end anonymous companies in the US | Global Witness](https://globalwitness.org/en/press-releases/congress-passes-historic-anti-corruption-provision-culminating-decade-long-fight-to-end-anonymous-companies-in-the-us/) - [FinCEN Alert Russian Elites High Value Assets](https://www.fincen.gov/system/files/2022-03/FinCEN%20Alert%20Russian%20Elites%20High%20Value%20Assets_508%20FINAL.pdf) - [The era of anonymous companies in the US is nearly over | Global Witness](https://globalwitness.org/en/campaigns/anonymous-company-holders/the-era-of-anonymous-companies-in-the-us-is-nearly-over/) - [New US rule targeting real estate money laundering slated for early 2024 - ICIJ](https://www.icij.org/investigations/pandora-papers/new-u-s-rule-targeting-real-estate-money-laundering-slated-for-early-2024/) - [T3 Financial Crime Unit: A Model for Public-private Disruption in the Age of Stablecoins | TRM Labs](https://www.trmlabs.com/resources/blog/t3-financial-crime-unit-a-model-for-public-private-disruption-in-the-age-of-stablecoins) - [FinCEN -Financial Crimes Enforcement Network | FinCEN.gov](https://www.fincen.gov/fincen-financial-crimes-enforcement-network) - [About FinCEN | FinCEN.gov](https://www.fincen.gov/about-fincen) - [Advisories | FinCEN.gov](https://www.fincen.gov/resources/advisoriesbulletinsfact-sheets/advisories) - [1 Financial Crimes Enforcement Network (FinCEN)](https://www.fincen.gov/system/files/2026-05/FinCEN-Year-in-Review-2025.pdf) - [Financial Fraud Enforcement Task Force (FFETF) | FinCEN.gov](https://www.fincen.gov/financial-fraud-enforcement-task-force-ffetf) - [News | FinCEN.gov](https://www.fincen.gov/news) - [FinCEN Exchange | FinCEN.gov](https://www.fincen.gov/resources/fincen-exchange) - [History of Anti-Money Laundering Laws | FinCEN.gov](https://www.fincen.gov/resources/history-anti-money-laundering-laws) - [Application of the Definition of Money Transmitter to Brokers and Dealers in Currency and Other Commodities | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/application-definition-money-transmitter-brokers-and) - [Enforcement Actions for Failure to Register as a Money Services Business | FinCEN.gov](https://www.fincen.gov/enforcement-actions-failure-register-money-services-business) - [Interagency Interpretive Guidance on Providing Banking Services to Money Services Businesses Operating in the United States | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/interagency-interpretive-guidance-providing-banking) - [F I N C E N G U I D A N C E 1](https://www.fincen.gov/system/files/2019-05/FinCEN%20CVC%20Guidance%20FINAL.pdf) - [Advisory on Illicit Activity Involving Convertible Virtual ...](https://www.fincen.gov/system/files/advisory/2019-05-10/FinCEN%20Advisory%20CVC%20FINAL%20508.pdf) - [The Anti-Money Laundering Act of 2020 | FinCEN.gov](https://www.fincen.gov/resources/statutes-and-regulations/anti-money-laundering-act-2020) - [FinCEN Penalizes Peer-to-Peer Virtual Currency Exchanger for Violations of Anti-Money Laundering Laws | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-penalizes-peer-peer-virtual-currency-exchanger-violations-anti-money) - [Trump-linked firms make millions from aid-deprived nations | Global Witness](https://globalwitness.org/en/campaigns/transition-minerals/revealed-trump-linked-firms-cash-in-on-mineral-lobbying-deals-as-us-cuts-aid/) - [Park Strategies, LLC Settles Potential Civil ...](https://ofac.treasury.gov/media/33081/download?inline=) - [Home | Office of Foreign Assets Control](https://ofac.treasury.gov/) - [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [DEPARTMENT OF THE TREASURY WASHINGTON, D.C. OFFICE OF FOREIGN ASSETS CONTROL](https://ofac.treasury.gov/media/934706/download?inline=) - [Sanctions List Service | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-list-service) - [Recent Actions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/sanctions-list-updates) - [India Hires US Lobbying Firm With Trump Ties as Tariffs Loom - Bloomberg](https://www.bloomberg.com/news/articles/2025-08-25/india-hires-dc-lobbying-firm-with-trump-ties-as-tariffs-loom) - [U.S. DEPARTMENT OF THE TREASURY OFFICE OF FOREIGN ASSETS CONTROL](https://ofac.treasury.gov/media/933941/download?inline=) - [Cambodian Minister’s Lobbying Spotlights US Anti-Scam Legislation | OCCRP](https://www.occrp.org/en/news/cambodian-ministers-lobbying-spotlights-us-anti-scam-legislation) - [Mutual Evaluation of the United States](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationoftheunitedstates.html) - ["Black and grey" lists](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [Assessments](https://www.fatf-gafi.org/en/calendars/assessments.html) - [Consolidated assessment ratings](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Assessment-ratings.html) - [United States](https://www.fatf-gafi.org/en/countries/detail/United-States.html) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions.html) - [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) - [Mutual Evaluations](https://www.fatf-gafi.org/en/publications/Mutualevaluations.html) - [Countries / Jurisdictions](https://www.fatf-gafi.org/en/countries.html) - [FATF changes its grey listing criteria to further focus on risk](https://www.fatf-gafi.org/en/publications/Fatfgeneral/FATF-grey-listing-criteria.html) - [1 Fact Sheet: FinCEN Issues Final Rule to](https://www.fincen.gov/system/files/shared/RREFactSheet.pdf) - [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) - [Residential Real Estate Rule | FinCEN.gov](https://www.fincen.gov/rre) - [Residential Real Estate Frequently Asked Questions | FinCEN.gov](https://www.fincen.gov/rre-faqs) - [Exemptive Relief Order to Delay the Effective Date of the ...](https://www.fincen.gov/system/files/2025-09/RRE-Rule-Exemptive-Relief-Order-508.pdf) - [FinCEN Renews Real Estate Geographic Targeting Orders | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-renews-real-estate-geographic-targeting-orders-0) - [Real Estate Report Filing Instructions Financial Crimes Enforcement Network](https://www.fincen.gov/system/files/2025-12/RRE-Filing-Instructions.pdf) - [Quick Reference Guide Residential Real Estate Reporting](https://www.fincen.gov/system/files/2025-12/General-Fact-Sheet.pdf) - [FinCEN Requests Comments on Proposed Form for Compliance with Residential Real Estate Rule | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-requests-comments-proposed-form-compliance-residential-real-estate-rule) - [1 Residential Real Estate Reporting Frequently Asked Questions](https://www.fincen.gov/system/files/shared/RREFAQs.pdf) - [Fincen](https://www.fincen.gov/system/files/schema/code/FinCENReferenceCodes.xsd) - [FinCEN TD Bank Consent Order, Number 2024-02](https://www.fincen.gov/system/files/enforcement_action/2024-10-10/FinCEN-TD-Bank-Consent-Order-508FINAL.pdf) - [FinCEN Recognizes Law Enforcement Cases Significantly Impacted by Bank Secrecy Act Filings | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-recognizes-law-enforcement-cases-significantly-impacted-bank-secrecy-act) - [FinCEN Recognizes the Significant Impact of Bank Secrecy Act Data on Law Enforcement Efforts | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-recognizes-significant-impact-bank-secrecy-act-data-law-enforcement) - [Statement | FinCEN.gov](https://www.fincen.gov/news/news-releases/statement) - [FinCEN Alert, FIN-2024-Alert005, December 18, 2024](https://www.fincen.gov/system/files/2024-12/Alert-FinCEN-Scams-FINAL508.pdf) - [STATE CONTACT INFORMATION FOR MSBs](https://www.fincen.gov/system/files/shared/msbstatecontactsfinal.pdf) - [DEPARTMENT OF THE TREASURY WASHINGTON, D.C. OFFICE OF FOREIGN ASSETS CONTROL](https://ofac.treasury.gov/media/935516/download?inline=) - [Frequently Asked Questions | Office of Foreign Assets Control](https://ofac.treasury.gov/faqs/search?faq-search=cisada&page=11) - [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) - [Sanctions Compliance Guidance for the Virtual Currency](https://ofac.treasury.gov/media/913571/download) - [Questions on Virtual Currency](https://ofac.treasury.gov/faqs/topic/1626) - [Publication of Sanctions Compliance Guidance for the Virtual Currency Industry and Updated Frequently Asked Questions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20211015) - [OFAC Consolidated Frequently Asked Questions | Office of Foreign Assets Control](https://ofac.treasury.gov/faqs/all-faqs) - [PPSI-AMLCFT-NPRM.pdf](https://www.fincen.gov/system/files/2026-04/PPSI-AMLCFT-NPRM.pdf) - [Treasury Proposes Rule to Implement the GENIUS Act’s Requirements to Counter Illicit Finance | FinCEN.gov](https://www.fincen.gov/news/news-releases/treasury-proposes-rule-implement-genius-acts-requirements-counter-illicit) - [Elliptic's 2026 regulatory and policy outlook: US sets the pace](https://www.elliptic.co/blog/elliptics-2026-regulatory-and-policy-outlook-us-sets-the-pace) - [Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2025-26) - [Fact Sheet: Proposed Rule to Implement the GENIUS Act’s Anti-](https://www.fincen.gov/system/files/2026-04/FactSheet-PPSI-program-NPRM.pdf) - [Treasury Seeks Public Comment on Implementation of the GENIUS Act | FinCEN.gov](https://www.fincen.gov/news/news-releases/treasury-seeks-public-comment-implementation-genius-act) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [Crypto regulatory affairs: OCC sets out proposed GENIUS Act rules](https://www.elliptic.co/blog/crypto-regulatory-affairs-occ-sets-out-proposed-genius-act-rules) - [Treasury Proposes Rule to Implement the GENIUS Act's Requirements to Counter Illicit Finance | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20260408_33) - [U.S. Senate Advances GENIUS Act: Long Awaited Stablecoin Framework Edges Closer to Reality - Chainalysis](https://www.chainalysis.com/blog/senate-advances-genius-stablecoin-act/) - [UPDATED: Notice Regarding National Small Business United v. Yellen, No. 5:22-cv-01448 (N.D. Ala.) | FinCEN.gov](https://www.fincen.gov/news/news-releases/updated-notice-regarding-national-small-business-united-v-yellen-no-522-cv-01448) - [Corporate Transparency Act](https://www.fincen.gov/system/files/shared/Corporate_Transparency_Act.pdf) - [FinCEN 31 CFR Part 1010.380, RIN 1506-AB49](https://www.fincen.gov/sites/default/files/federal_register_notices/2025-03-21/CTAIFR3-21-25-FINAL508.pdf) - [The Economic Crime and Corporate Transparency Act 2023 (Financial Penalty) Regulations 2024](https://www.legislation.gov.uk/uksi/2024/445) - [1 UT Neutral citation number: [2026] UKUT 00130 (TCC)](https://assets.publishing.service.gov.uk/media/69bbf7864b1db2e4ba9b649e/Rowland_v_HMRC_Final_Decisison_for_release_to_the_parties.pdf) - [US Congressional Committee Chips Away at Corporate Transparency Act | OCCRP](https://www.occrp.org/en/news/us-congressional-committee-chips-away-at-corporate-transparency-act) - [DC Department of Insurance, Securities and Banking](https://disb.dc.gov/page/anti-money-laundering) - [FinCEN, US Department of the Treasury](https://www.fincen.gov/boi) - [FinCEN, US Department of the Treasury](https://www.fincen.gov/rre) - [FinCEN, US Department of the Treasury](https://www.fincen.gov/news/news-releases/fincen-renews-residential-real-estate-geographic-targeting-orders-0) - [Office of Foreign Assets Control, US Department of the Treasury](https://ofac.treasury.gov/media/934706/download?inline=) - [TRM Labs](https://www.trmlabs.com/resources/blog/t3-financial-crime-unit-a-model-for-public-private-disruption-in-the-age-of-stablecoins) - [Financial Action Task Force](https://www.fatf-gafi.org/en/countries/detail/United-States.html) - [Global Witness](https://globalwitness.org/en/campaigns/corruption-and-money-laundering/anonymous-companies-used-to-launder-money-in-us-real-estate/) - [OCCRP](https://www.occrp.org/en/news/cambodian-ministers-lobbying-spotlights-us-anti-scam-legislation) - [Elliptic](https://www.elliptic.co/blog/elliptics-2026-regulatory-and-policy-outlook-us-sets-the-pace) - [FinCEN / OFAC, US Department of the Treasury](https://www.fincen.gov/system/files/2026-04/PPSI-AMLCFT-NPRM.pdf) Coverage gaps fim-int-2026-07-06-G001: No direct-read verification of the … fim-int-2026-07-06-G001: No direct-read verification of the DC DISB AML supervisory examination or MSB-licensing enforcement statistics was available this cycle to independently corroborate sub-national supervisory effectiveness. [resolved] fim-int-2026-07-06-G002: No primary OFAC SDN-list publicatio… fim-int-2026-07-06-G002: No primary OFAC SDN-list publication URL specific to the corrected 23-27 April 2026 Central Bank of Iran wallet designation was collected this cycle; only T3 vendor/press corroboration is available. [resolved] fim-int-2026-07-06-G003: No FARA filing-level data (fee amou… fim-int-2026-07-06-G003: No FARA filing-level data (fee amounts, full client identity, engagement scope) was available to substantiate the scale of DC lobbying-sector sanctions-adjacent engagement beyond the single cited OCCRP case. [resolved] fim-int-2026-07-06-G004: The outcome of the Fifth Circuit ap… fim-int-2026-07-06-G004: The outcome of the Fifth Circuit appeal of the Residential Real Estate Rule vacatur is not yet available; next-cycle evidence on the appellate ruling would resolve the current 'uncertain' risk-direction rating. [resolved] fim-int-2026-07-06-G005: No independent corroboration beyond… fim-int-2026-07-06-G005: No independent corroboration beyond a single T2 source (Global Witness) exists for the DC lobbying-firm mineral-sector deals claim; a second independent source would move this from Possible to Assessed confidence. [resolved] fim-int-2026-07-14-G001: No 2026 mutual-evaluation or enforc… fim-int-2026-07-14-G001: No 2026 mutual-evaluation or enforcement update was located for Colombia this cycle; Colombia's GAFILAT enhanced-follow-up status could not be refreshed. [resolved] fim-int-2026-07-14-G002: No Central Asia or non-PNG Pacific … fim-int-2026-07-14-G002: No Central Asia or non-PNG Pacific jurisdiction findings were located this cycle. [resolved] fim-int-2026-07-14-G003: No FinCEN AI/ML transaction-monitor… fim-int-2026-07-14-G003: No FinCEN AI/ML transaction-monitoring model-risk guidance refresh was located, leaving D6 supervisory-expectations coverage thin. [resolved] fim-int-2026-08-05-G001: GAO's May 2026 report and the under… fim-int-2026-08-05-G001: GAO's May 2026 report and the underlying Eleventh Circuit opinion were not independently retrieved as Tier 1 primary documents this cycle. [resolved] fim-int-2026-08-05-G002: No dated 2026 Lao government or mul… fim-int-2026-08-05-G002: No dated 2026 Lao government or multilateral enforcement action specific to the Golden Triangle SEZ was located this cycle. [resolved] fim-int-2026-08-05-G003: The underlying OFAC SDN listing for… fim-int-2026-08-05-G003: The underlying OFAC SDN listing for the 50+ CJNG-linked designations was not independently re-verified as a Tier 1 source this cycle. [resolved] fim-int-2026-08-05-G004: The exact issuance date of the FY20… fim-int-2026-08-05-G004: The exact issuance date of the FY2026 Majors List 'failed demonstrably' determination for Colombia could not be independently confirmed this cycle. [resolved] fim-int-2026-08-05-G005: No UK/EU Hong Kong-sanctions action… fim-int-2026-08-05-G005: No UK/EU Hong Kong-sanctions action was identified to confirm whether the US unilateral E.O. 13936 delisting is mirrored or diverges from allied sanctions regimes. [resolved] fim-int-2026-09-05-G001: Tier D watch jurisdictions (KH, LA,… fim-int-2026-09-05-G001: Tier D watch jurisdictions (KH, LA, MX, CO) were not independently re-verified this cycle; research budget was allocated to the bound jurisdiction US-DC. [resolved] fim-int-2026-09-05-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): DISB's virtual-currency MTL guidance rests on a single T1 primary source with only T3 secondary corroboration; no second independent T1-T2 source has verified the finding this cycle. [resolved] fim-int-2026-09-28-G001: Exact repealing instrument and effe… fim-int-2026-09-28-G001: Exact repealing instrument and effective date for DC Code Title 47, Chapter 31 not independently isolated this cycle. [resolved] fim-int-2026-09-28-G002: D2 beneficial ownership, D3 enabler… fim-int-2026-09-28-G002: D2 beneficial ownership, D3 enabler jurisdictions, D4 conflict finance beyond the Houthi note, and D6 compliance technology were not actively researched this cycle given the bound-JID search budget. [resolved] fim-int-2026-09-28-G003: Tier D jurisdictions (KH, LA, MX, C… fim-int-2026-09-28-G003: Tier D jurisdictions (KH, LA, MX, CO) were not actively refreshed this cycle. [resolved] fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): No independent DC DISB press release or consent-order text located for the Coinme settlement this cycle; status rests on national CSBS and two secondary state releases. [open] fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', 'value': 'D2'}): No DC-specific beneficial-ownership registry development was found; this domain is substantially inherited from the US federal parent layer. [open] fim-int-2026-10-25-G001: No DC-specific OFAC/OFSI/EU-Council… fim-int-2026-10-25-G001: No DC-specific OFAC/OFSI/EU-Council/UN sanctions designation touching a DC-headquartered entity was located this cycle; sanctions authority is exclusively federal, limiting D1 coverage for a sub-national dispatch. [open] fim-int-2026-10-25-G002: No DISB bulletin superseding Notice… fim-int-2026-10-25-G002: No DISB bulletin superseding Notice 24-BB-001 was located; whether DISB has updated its crypto money-transmission guidance since August 2024 remains unconfirmed this cycle. [open] FIM-GAP-001 (D2): The March 2025 CTA interim final rule exem… FIM-GAP-001 (D2): The March 2025 CTA interim final rule exempted all US-formed entities, including DC-formed LLCs, from beneficial-ownership reporting, reversing the principal US corporate-transparency reform and restoring the anonymity structure long flagged by ICIJ, Global Witness, and Transparency International as enabling kleptocratic and criminal asset-laundering. FIM-GAP-002 (D2): The nationwide Residential Real Estate Rul… FIM-GAP-002 (D2): The nationwide Residential Real Estate Rule, which would have required reporting on non-financed residential transfers to legal entities/trusts (covering DC), was vacated by a federal court on March 19, 2026, while the GTOs it was meant to replace had already expired February 28, 2026 — leaving no operative federal reporting mechanism for anonymous cash real estate purchases pending appeal. FIM-GAP-003 (D3): FARA filings by DC-based lobbying and lega… FIM-GAP-003 (D3): FARA filings by DC-based lobbying and legal-advisory firms are not required to disclose the source of six-figure-and-above fees or the precise nature of engagements, limiting visibility into whether foreign-official or sanctions-adjacent clients are using DC's professional-services sector to influence sanctions or enforcement outcomes. FIM-GAP-004 (D3): DC does not have an independent FATF mutua… FIM-GAP-004 (D3): DC does not have an independent FATF mutual evaluation; it is assessed only as part of the US national MER, and the seed-referenced DISB AML page requires direct-read verification not completed in this research pass (staleness_flag set true). ## Evidence #### Confidence-tiered claims 34-state BSA/AML consent settlement (DC DISB a party), $2.5M payment, independent consultant review, kiosk shutdown required by 2027-01-01 or additional $4M penalty. [[Source 1]](#sec-sources) Probable · 1 source DC AG CPPA suit (filed Sept 2025) alleging 93% of DC Bitcoin-ATM deposits were scam-linked and fees up to 26% undisclosed; remains active per mid-2026 secondary reporting, no settlement/judgment found this cycle. [[Source 1]](#sec-sources) Probable · 1 source DC's general money-transmission licensing regime, administered by DISB, is the legal basis bringing DC into the multistate coordinated action against an under-supervised crypto-kiosk channel. [[Source 1]](#sec-sources) Probable · 1 source DC Code 29-102.01/29-102.11 beneficial-ownership disclosure (>10% threshold) remains in force independently of FinCEN's August 14, 2026 final rule narrowing federal CTA reporting to foreign entities. [[Source 1]](#sec-sources) Probable · 1 source Final rule effective 14 August 2026 permanently removes the requirement for U.S. companies and U.S. persons to report beneficial ownership information to FinCEN, narrowing federal CTA reporting to foreign entities. [[Source 1]](#sec-sources) Probable · 1 source DISB continues to apply the general Money Transmitters Act (DC Code 26-1001 et seq.) to virtual-currency businesses per its standing Notice 24-BB-001 (Aug 9, 2024); no new DC-specific crypto AML development this cycle. [[Source 1]](#sec-sources) Uncertain · 1 source Ongoing litigation against a Bitcoin-kiosk (BTM) operator, alongside Massachusetts, over consumer-protection/AML-adjacent conduct. [[Source 1]](#sec-sources) Probable · 1 source Municipal beneficial-ownership filing requirement, administered by DLCP, in force since 2020-01-01, distinct from federal CTA/FinCEN BOI regime; unchanged this cycle. [[Source 1]](#sec-sources) Probable · 1 source