--- title: "United States — Hawaii (US-HI) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/united-states-hawaii/ source_html: /jurisdictions/united-states-hawaii/index.html description: "Financial integrity intelligence for United States – Hawaii (US-HI): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: a76dd8fb5ff8bc92029726db210d7f05ef9444eb99e22449a31d13826908bf00 generator: "fe-fleet/md-twin@1.0" --- # United States — Hawaii (US-HI) — 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 — Hawaii US-HI Domains covered 7 of 8 Sources 177 Role actions 8 Horizon <90d 0 Jurisdiction profile FATF status: Compliant Tier: B Risk direction: Increasing Enablement vs enforcement: Mixed Hawaii operates under the federal BSA/AML framework (FinCEN, OFAC) plus state money-transmitter licensing via the DCCA Division of Financial Institutions. More Real-estate laundering exposure is addressed through FinCEN's Honolulu/Maui/Hawaii/Kauai county Geographic Targeting Orders; the broader federal Residential Real Estate Rule was vacated by a federal court in March 2026, leaving GTOs as the primary transparency tool pending appeal. Key deficiencies - Federal Corporate Transparency Act now exempts all domestic (US-formed) reporting companies from beneficial ownership disclosure, removing federal BO visibility for Hawaii-registered LLCs used in real-estate and shell-company structuring - Residential Real Estate Rule (national BO-at-closing reporting requirement) vacated by court order March 19, 2026, with FinCEN/DOJ appeal pending, leaving time-limited GTOs as the sole federal all-cash real estate transparency tool for Hawaii's four counties - High elder and tourist population exposure to crypto-ATM/kiosk-enabled pig-butchering and romance-investment fraud pipelines, per national FinCEN and FBI IC3 typology data - Thin volume of Hawaii-specific (as opposed to national/federal) public enforcement reporting, limiting independent verification of state-level AML effectiveness Recent developments (18m) - FinCEN renewed and later postponed/reissued Residential Real Estate GTOs covering Honolulu, Maui, Hawai'i, and Kaua'i counties (2025) - FinCEN postponed Residential Real Estate Rule reporting requirements to March 1, 2026; rule then vacated by U.S. District Court (E.D. Tex.) March 19, 2026, under appeal - FinCEN alert (March 2025) confirmed domestic reporting companies and their beneficial owners are exempt from Corporate Transparency Act BOI reporting, a nationwide policy reversal affecting Hawaii-formed entities - FinCEN issued CVC kiosk notice (FIN-2025-NTC1, August 2025) addressing elder-targeted crypto-ATM fraud typologies applicable to Hawaii's retiree and tourist population - OFAC designations against Prince Group TCO/Huione Group (Oct 2025) and DPRK IT-worker facilitation networks (March 2026) reshape the national sanctions-evasion and CPF architecture within which Hawaii-domiciled financial institutions and MSBs operate United States federal law that applies in United States – Hawaii is covered once, on the [United States](/jurisdictions/us/) page. This page covers United States – Hawaii’s own layer: its own law, regulators and enforcement. Brief ## Lead signal #### Lead Signal Hawaii's regulation of digital-asset kiosks tightened this cycle with the commencement of Act 224 (HB1642) on October 1, 2026. The statute makes it an unlawful practice under HRS Chapter 481B for an operator to own, operate or manage a digital-financial-asset kiosk that accepts United States currency in exchange for a digital asset. Crypto-to-cash and crypto-to-crypto kiosk transactions remain lawful under the measure, so the prohibition is narrowly targeted at the cash-in leg of kiosk transactions rather than at kiosk operation as such. Each violating transaction is treated as a separate offense, a structural design choice that gives the prohibition cumulative weight against repeat or high-volume non-compliance rather than relying on a single penalty event. Read full brief #### Lead Signal Hawaii's regulation of digital-asset kiosks tightened this cycle with the commencement of Act 224 (HB1642) on October 1, 2026. The statute makes it an unlawful practice under HRS Chapter 481B for an operator to own, operate or manage a digital-financial-asset kiosk that accepts United States currency in exchange for a digital asset. Crypto-to-cash and crypto-to-crypto kiosk transactions remain lawful under the measure, so the prohibition is narrowly targeted at the cash-in leg of kiosk transactions rather than at kiosk operation as such. Each violating transaction is treated as a separate offense, a structural design choice that gives the prohibition cumulative weight against repeat or high-volume non-compliance rather than relying on a single penalty event. The measure sits against a backdrop in which Hawaii has, since mid-2024, taken the position that ordinary digital-currency exchange and custody activity falls outside the state money-transmitter licensing perimeter under HRS Chapter 489D. That determination by the state financial institutions division remains the operative baseline this cycle; nothing in the kiosk measure disturbs it. The result is a regulatory architecture that is permissive at the level of licensing but newly restrictive at the level of a specific cash-handling channel judged to present elevated consumer-protection and fraud risk. #### Other Developments A pending enforcement action from earlier in the year remains part of the state's crypto-adjacent posture. Hawaii's securities regulator issued a cease-and-desist order against BG Wealth Sharing Ltd. and two individual promoters over an alleged crypto investment scheme structured along pyramid lines, with the regulator seeking $50,000 in penalties from each respondent. The order predates this cycle's kiosk development but continues to inform the state's overall enforcement posture toward unregistered or misrepresented crypto investment solicitation. A broader licensing framework proposal did not advance. A bill that would have created Hawaii's first dedicated digital-asset licensing charter, with an effective date no earlier than 2027 and testimony suggesting a date as late as 2028, was deferred by a House committee in March 2026 and did not pass this session. Its failure to advance leaves the 2024 exemption determination as the only governing word on licensing treatment of exchange and custody activity, pending any revival of comprehensive licensing legislation in a future session. #### Cross-Monitor Connections The kiosk cash-deposit prohibition is a consumer-protection and fraud-typology measure as much as a financial-integrity one: cash-funded kiosk transactions are a channel frequently associated with romance-scam and pig-butchering fraud typologies, where victims are directed to deposit cash into a kiosk for onward crypto transfer to a scammer-controlled wallet. By closing the cash-in leg specifically, Hawaii is targeting the point in that typology where a victim's cash becomes irreversible, rather than regulating kiosk operators' broader business model. This has a direct read-across to payments-systems monitoring, since kiosk operators also function as a payment rail for consumers without other access to on-ramp services, and the effective removal of a cash-funding option narrows that rail's accessibility for both licit and illicit use alike. #### Outlook With the kiosk measure now in force and the licensing charter proposal dormant for this session, Hawaii's crypto posture is likely to remain a two-track arrangement through the near term: no state licensing requirement for core exchange and custody activity, paired with narrow, incident-responsive rules such as the kiosk measure for channels judged to carry elevated consumer-risk profiles. Any confirmation of implementing guidance or a first enforcement notice under the new kiosk prohibition would be the next material marker to watch, as would any signal of the digital-asset charter proposal being revived in a subsequent legislative session. Earlier periodic briefs (3) 25 Oct 2026 · fim-2026-10-25 #### Lead Signal Hawaii's regulation of digital-asset kiosks tightened with the commencement of Act 224 (HB1642) on October 1, 2026. The statute makes it an unlawful practice under HRS Chapter 481B for an operator to own, operate or manage a digital-financial-asset kiosk that accepts United States currency in exchange for a digital asset. Crypto-to-cash and crypto-to-crypto kiosk transactions remain lawful under the measure, so the prohibition is narrowly targeted at the cash-in leg of kiosk transactions rather than at kiosk operation as such. Each violating transaction is treated as a separate offense, a structural design choice that gives the prohibition cumulative weight against repeat or high-volume non-compliance rather than relying on a single penalty event. The measure sits against a backdrop in which Hawaii has, since mid-2024, taken the position that ordinary digital-currency exchange and custody activity falls outside the state money-transmitter licensing perimeter under HRS Chapter 489D. That determination by the state financial institutions division remains the operative baseline; nothing in the kiosk measure disturbs it. The result is a regulatory architecture that is permissive at the level of licensing but newly restrictive at the level of a specific cash-handling channel judged to present elevated consumer-protection and fraud risk. #### Other Developments A pending enforcement action from earlier in the year remains part of the state's crypto-adjacent posture. Hawaii's securities regulator issued a cease-and-desist order against BG Wealth Sharing Ltd. and two individual promoters over an alleged crypto investment scheme structured along pyramid lines, with the regulator seeking $50,000 in penalties from each respondent. The order predates the kiosk development but continues to inform the state's overall enforcement posture toward unregistered or misrepresented crypto investment solicitation. A broader licensing framework proposal did not advance. A bill that would have created Hawaii's first dedicated digital-asset licensing charter, with an effective date no earlier than 2027 and testimony suggesting a date as late as 2028, was deferred by a House committee in March 2026 and did not pass this session. Its failure to advance leaves the 2024 exemption determination as the only governing word on licensing treatment of exchange and custody activity, pending any revival of comprehensive licensing legislation in a future session. #### Cross-Monitor Connections The kiosk cash-deposit prohibition is a consumer-protection and fraud-typology measure as much as a financial-integrity one: cash-funded kiosk transactions are a channel frequently associated with romance-scam and pig-butchering fraud typologies, where victims are directed to deposit cash into a kiosk for onward crypto transfer to a scammer-controlled wallet. By closing the cash-in leg specifically, Hawaii is targeting the point in that typology where a victim's cash becomes irreversible, rather than regulating kiosk operators' broader business model. This has a direct read-across to payments-systems monitoring, since kiosk operators also function as a payment rail for consumers without other access to on-ramp services, and the effective removal of a cash-funding option narrows that rail's accessibility for both licit and illicit use alike. #### Outlook With the kiosk measure now in force and the licensing charter proposal dormant for this session, Hawaii's crypto posture is likely to remain a two-track arrangement through the near term: no state licensing requirement for core exchange and custody activity, paired with narrow, incident-responsive rules such as the kiosk measure for channels judged to carry elevated consumer-risk profiles. Any confirmation of implementing guidance or a first enforcement notice under the new kiosk prohibition would be the next material marker to watch, as would any signal of the digital-asset charter proposal being revived in a subsequent legislative session. 14 Sep 2026 · fim-2026-08-21 #### Lead Signal Hawaii's crypto money-transmission posture remains a structural outlier within the federal AML/CFT architecture. The Hawaii Division of Financial Institutions has determined that digital currency and digital-asset trading and transmission activity is not subject to the state's Money Transmitters Act licensing requirement, a determination that took effect July 1, 2024, following the conclusion of the state's Digital Currency Innovation Lab. Two independent Tier-1 Hawaii state sources corroborate the determination. The practical effect is a narrowing of the state-level AML supervisory perimeter: Hawaii-domiciled or Hawaii-serving digital-asset firms conducting standalone crypto activity face no state AML/CDD licensing overlay, relying solely on federal FinCEN money-services-business registration and program obligations. This state-level enablement signal sits in tension with a 2026 legislative proposal, SB2757 (Digital Asset Charters), which would reintroduce a state chartering framework for digital-asset businesses and explicitly finds that the industry is largely unregulated in the United States. If enacted, SB2757 would close the supervisory gap the 2024 determination opened; as introduced, it has not yet passed. This is an architecture-level story, not an incident: the interesting fact is what the state chose not to require, not any single enforcement action. #### Other Developments Federal stablecoin AML and sanctions rulemaking advances. On April 8, 2026, Treasury issued a joint notice of proposed rulemaking through FinCEN and OFAC to implement the AML/CFT and sanctions provisions of the GENIUS Act for Permitted Payment Stablecoin Issuers. The proposal would establish a stand-alone BSA framework at a new 31 CFR Part 1033, and represents the first sanctions compliance program requirement targeted at a specific category of US person. The comment period closed June 9, 2026. This applies to any Hawaii-domiciled or Hawaii-serving stablecoin issuer irrespective of the state's otherwise light-touch crypto posture, since it is a federal requirement layered on top of, not substituting for, the state gap. FinCEN proposes a structural AML/CFT program overhaul. A separate NPRM would fundamentally reform AML/CFT program requirements for financial institutions, inserting counter-terrorist-financing terminology and effectiveness-based requirements into what has historically been an AML-only program rule. This is a structural development applicable across all US jurisdictions, including Hawaii, and would apply to the federal BSA baseline that Hawaii-based crypto and financial firms currently rely on in the absence of state-level AML licensing for standalone digital-asset activity. FinCEN proposes a whistleblower incentive program. A further NPRM would operationalize financial incentives for reporting BSA, AML, and sanctions violations, with comments due June 1, 2026. No prior FinCEN-administered monetary whistleblower channel existed for BSA or sanctions violations; this would be a new enforcement-support architecture layered onto the existing framework. FATF grey list update (no direct US-HI nexus). The FATF June 2026 Plenary added Iraq and Bosnia and Herzegovina to its grey list and removed Algeria and Namibia, bringing the list to twenty-two jurisdictions under increased monitoring. This is tracked for fleet completeness; no direct nexus to US-HI has been identified this cycle. #### Cross-Monitor Connections The Hawaii crypto money-transmission exemption and the SB2757 charter proposal are the same underlying facts surfaced independently in the World Payments Monitor's licensing and market-access tracking and in the crypto monitor's licensing and stablecoin-regime modules. Where this monitor foregrounds the AML supervisory-perimeter reading, the payments and crypto monitors foreground the market-access and product-classification readings of the identical determination and bill. The federal GENIUS Act stablecoin AML and sanctions NPRM likewise recurs across all three monitors: here as an AML/CFT architecture development, in world-payments as a stablecoin regulatory-framework development, and in the crypto monitor as a stablecoin-regime development. Readers tracking Hawaii's digital-asset posture across monitors should expect to see the same primary sources cited from each analytical angle rather than duplicated independent findings. #### Outlook The near-term marker to watch is whether SB2757 advances beyond its current form; passage would formalize a state chartering regime and close the AML supervisory gap that has existed since the 2024 determination, converting an enablement signal into a more conventional licensing-and-oversight structure. At the federal level, the GENIUS Act stablecoin AML/sanctions NPRM and the broader AML/CFT program-modernization NPRM are both past their comment-period close and moving toward finalization; either would reshape the federal BSA baseline Hawaii firms currently depend on in the absence of state licensing. No US-HI-specific FATF mutual-evaluation status has yet been established to primary-source standard, an open gap for future cycles. 11 Aug 2026 · fim-2026-08-05 #### Lead Signal Hawaii digital-asset regulation is in active flux. Since 1 July 2024, standalone digital-currency and digital-asset activity has not required a Hawaii money-transmitter licence, a position that rests on Department of Commerce and Consumer Affairs / Division of Financial Institutions (DCCA/DFI) interpretive guidance rather than statute. That regulator-interpretation basis is now the target of a 2026 legislative reversal effort: SB 2757 SD1 would create a new Digital Asset Charter licensing and oversight program for digital-asset companies operating in Hawaii, effectively closing the exemption that has stood for two years. The bill advanced out of Senate committee as amended and was referred onward, but its final 2026-session enactment status is unconfirmed as of session close, leaving Hawaii digital-asset licensing posture in a genuinely open state pending further legislative action. #### Other Developments The Hawaii reversal effort sits inside a broader pattern: US states are increasingly narrowing the crypto money-transmitter exemptions many adopted in earlier, more permissive years, even as the federal GENIUS Act framework moves to preempt state authority specifically over stablecoin issuance. That combination, a narrowing state perimeter around general digital-asset activity alongside a narrowing federal-preemption lane specifically for stablecoins, produces a layered and unsettled compliance picture for digital-asset firms operating across multiple states, of which Hawaii SB 2757 SD1 is one concrete instance rather than an isolated event. #### Cross-Monitor Connections This development sits at the boundary between financial-integrity oversight and payments-licensing regulation: the same underlying legislative fact, a state decision to bring digital-asset activity back inside a money-transmitter-style licensing perimeter, is simultaneously a financial-integrity signal about the durability of a jurisdiction AML-adjacent oversight architecture and a payments-market signal about entry conditions for regulated and unregulated digital-asset firms. No further cross-monitor linkage is asserted this cycle beyond that structural overlap. #### Outlook The determinative question for the next cycle is whether SB 2757 SD1 achieves final enactment. Confirmation would mark a concrete narrowing of Hawaii digital-asset perimeter and bring the state into closer alignment with jurisdictions whose exemptions rest on statute rather than surviving purely on regulator interpretation; continued non-enactment would leave the interpretation-based exemption, and its comparative fragility, in place unresolved into the next legislative session. This gap, the final enactment status of SB 2757 SD1, is recorded in the interpreter gaps register pending next-cycle resolution. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion Five distinct sanctions-architecture actions were logged this cycle for the United States sanctions apparatus that governs Hawaii by federal extension, and the analytical unit of interest is the architecture these actions reveal rather than any single designation in isolation. OFAC designated the Prince Group transnational criminal organization and its chairman Chen Zhi on 14 October 2025 alongside a fifteen billion dollar Department of Justice bitcoin forfeiture, a coordinated sanctions-and-forfeiture action against a scam-compound network. The formal designation remains in force, but the enforcement posture toward the principal named individual has since moved outside the United States enforcement chain: Cambodian authorities arrested Chen Zhi, stripped him of Cambodian citizenship, and extradited him to China in January 2026, a status-drift correction held at Assessed confidence rather than treated as settled current fact. The underlying laundering infrastructure, including scam compounds tied to forced labor, persists in Cambodia despite the designation and the approximately one hundred twenty-seven thousand bitcoin forfeiture action. Continue reading A second and structurally stronger tool was applied against Huione Group, designated a foreign financial institution of primary money laundering concern under Section 311 on 16 October 2025. A Section 311 special measure severs correspondent access outright, the most forceful United States financial-integrity instrument short of criminal prosecution, and it disrupted a major crypto-laundering guarantee-platform infrastructure that subsequently went offline. Read together, the Prince Group and Huione actions illustrate a three-level sanctions-architecture pattern: the scheme, being scam-compound bitcoin laundering; the enabling architecture, being a guarantee-marketplace payment rail and its principal human sponsor; and the strategic consequence, being disruption of the rail without resolution of the underlying compound business model, since the principal individual has since passed out of United States enforcement reach. Proliferation-finance and non-state-actor designations extended the architecture further. OFAC designated six individuals and two entities across the Democratic Peoples Republic of Korea, Vietnam, Laos, and Spain on 12 March 2026 for facilitating a fraudulent remote-employment scheme that generated approximately eight hundred million dollars in 2024 for DPRK weapons programs, a state-directed proliferation-finance architecture with potential exposure for any employer engaged in remote technology hiring. Separately, OFAC designated the Burma-based Democratic Karen Benevolent Army on 12 November 2025, together with four senior leaders and Chinese organized-crime-linked companies, for supporting scam centers that defraud Americans, with no confirmed parallel European Union or United Kingdom listing identified. The fifth architecture point is licensing-timeline divergence. Following the 22 October 2025 Lukoil International GmbH designation, OFAC issued a progression of general licenses, numbered 128B and 128C and 131A through G, extended into mid to late 2026, on a wind-down schedule distinct from European Union and United Kingdom Russian oil-sector sanctions. This divergence, together with the DPRK IT-worker facilitator designations not being fully mirrored across OFAC, OFSI, and European Union lists, creates a persistent reconciliation burden for financial institutions with cross-border correspondent exposure. The coordinated Prince Group and Huione action is the exception in this pattern rather than the rule. The FATF June 2026 Plenary added Bosnia and Herzegovina and Iraq to the grey list and removed Algeria and Namibia, and the Presidency transitioned from Mexico to the United Kingdom effective 1 July 2026 with a stated fraud-epidemic and scam-compound focus directly relevant to elder-fraud and scam-compound exposure. FATF also indicated it will consider further countermeasures on Iran if no progress is made by October 2026 under the new Presidency, shaping enhanced-due-diligence expectations for institutions handling Iran-nexus transactions. The United States, and by extension Hawaii, remains off both FATF lists. #### Outlook The principal forward item is whether the Chen Zhi status drift receives a formal OFAC or Department of Justice update reflecting the January 2026 extradition; absent that update, the Prince Group enforcement narrative should be treated as superseded rather than current. The FATF October 2026 Iran countermeasures review under the new United Kingdom Presidency, and the continuing Lukoil general-license wind-down sequence extending into mid to late 2026, are the two clearest scheduled horizon events. Sanctions-list reconciliation burden arising from OFAC, OFSI, and European Union divergence on the Lukoil and DPRK IT-worker listings is likely to persist as a structural rather than episodic condition, and the incoming FATF Presidency fraud-epidemic focus is worth monitoring as a forward posture shift rather than a single Plenary event. Whether a successor guarantee-marketplace platform emerges to fill the space vacated by Huione is a further item to track. #### Beneficial Ownership and Corporate Transparency Federal beneficial-ownership visibility for domestically formed entities, including Hawaii-registered limited liability companies, has structurally regressed this cycle rather than experienced an isolated policy change. Since 26 March 2025, all United States-formed reporting companies and their beneficial owners are exempt from Corporate Transparency Act reporting to FinCEN under an interim final rule; the rule is not yet finalized, a comment period remains open, and FinCEN intends to issue a final rule in 2026. The exemption is currently operative and restores pre-2024 anonymity conditions for domestic shell structures used in real estate, trade, and offshore wire-transfer layering, an enabler-side condition in which the state entity-formation regime, administered in Hawaii by the Department of Commerce and Consumer Affairs Business Registration Division, now sits inside a federally opaque beneficial-ownership environment. Because Hawaii itself maintains no independent state-level beneficial-ownership register, the entity-formation stage of the corporate lifecycle currently carries no beneficial-ownership collection obligation at either the state or federal level for domestic entities. Continue reading A second structural regression compounds the first. The Residential Real Estate Rule, which would have created a permanent nationwide beneficial-ownership reporting backbone for non-financed residential transfers, was vacated by a United States District Court in the Eastern District of Texas on 19 March 2026, with FinCEN and the Department of Justice appeal pending. The outcome of that appeal will determine whether a permanent nationwide beneficial-ownership backbone for residential real estate is restored or permanently abandoned, and this is treated as a horizon-linked structural item rather than a single incident. With the Residential Real Estate Rule vacated, the county-level Geographic Targeting Orders covering Honolulu, Maui, Hawaii, and Kauai counties, renewed 9 October 2025 and requiring title insurance companies to identify and report natural persons behind all-cash entity real estate purchases above three hundred thousand dollars, become the sole operative federal beneficial-ownership tool for Hawaii real estate. The orders were tied to a 28 February 2026 expiration date, and whether they were renewed, replaced, or allowed to lapse has not been verified as of the 5 July 2026 baseline, a four-month currency gap recorded at Possible confidence pending direct FinCEN confirmation. The architecture-over-incident view treats the Geographic Targeting Order mechanism itself, rather than any single filing under it, as the analytical unit of continuing relevance. Standing architecture: the European Union AML Package operates as three distinct instruments rather than a single measure, a durable structural fact against which any beneficial-ownership signal, including this cycle non-European Union development, should be read. The AML Regulation, known as the AMLR, under Regulation (EU) 2024/1624, is directly applicable across member states without national transposition. The sixth Anti-Money Laundering Directive, the 6AMLD, requires transposition on a per-member-state basis. The AMLA Regulation, Regulation (EU) 2024/1620, establishes the Anti-Money Laundering Authority and creates a direct and indirect supervision perimeter that shifts supervision of high-risk cross-border obliged entities from purely national authorities toward a hybrid European Union-level regime. This architecture has no direct regulatory nexus with Hawaii as a United States sub-national jurisdiction this cycle; the standing tracker for this instrument records the relevance as limited to Hawaii-domiciled institutions with European Union-resident clients or correspondent relationships, and no new European Union AMLA development specific to this jurisdiction was identified this cycle. #### Outlook The Residential Real Estate Rule appeal outcome, expected within the year, is the single clearest structural fork: reinstatement would restore a nationwide beneficial-ownership backbone for residential transfers, while a sustained vacatur would leave the narrower, transaction-specific Geographic Targeting Order mechanism as the only federal tool, itself now of unconfirmed continuity. The Corporate Transparency Act domestic exemption is expected to move from interim to final rule during 2026 following the close of the comment period; whether the final rule preserves, narrows, or reverses the exemption will determine whether the current beneficial-ownership opacity for Hawaii-formed entities is a transitional or durable condition. Direct confirmation of the Hawaii county Geographic Targeting Order post-February-2026 status remains an open verification item for the next cycle. #### Enabler Jurisdictions and Professional Facilitators Hawaii layers a state money-transmitter licensing regime, administered by the Department of Commerce and Consumer Affairs Division of Financial Institutions, atop the full federal Bank Secrecy Act, FinCEN, and OFAC framework that governs virtual-currency and payment businesses operating in the state. This state licensing layer, which operates in addition to federal FinCEN money-services-business registration, is the principal Hawaii-specific regulatory variance from an otherwise fully federal anti-money-laundering and counter-terrorist-financing architecture, and it represents the state-level supervisory perimeter for crypto and money-transmission activity specifically. Continue reading The F3 enabler-jurisdiction filter requires distinguishing a capacity deficit from a political choice when assessing whether a jurisdiction facilitates illicit flows through inaction, and the evidence available this cycle does not permit that distinction for Hawaii specifically. Publicly available Hawaii-specific enforcement and typology reporting remains comparatively thin relative to major mainland financial centers, reducing independent verification of whether state-level supervision effectively addresses tourism-cash-economy and elder-fraud risk factors distinct from national-level federal action applied to Hawaii by extension. This reporting thinness also means the severity rating assigned to the all-cash shell-company real estate layering scheme lacks Hawaii-specific enforcement action or suspicious-activity-report data to substantiate active exploitation as distinct from the national Geographic Targeting Order typology coverage that applies to Hawaii among other jurisdictions. This is a visibility gap rather than a confirmed enforcement failure, and the enabler-jurisdiction reading should be held at that qualified level: Hawaii inherits federal designations, advisories, and licensing requirements in full, and there is no evidence this cycle of a Hawaii-specific policy choice to under-enforce. What is absent is independent, state-specific verification that would allow an assessment of enforcement effectiveness separate from the federal baseline. This absence is itself an analytically significant condition under the enablement-as-signal principle: the lack of visible state-level enforcement action, in a jurisdiction with demonstrated demographic exposure to elder-fraud and cash-economy typologies, is a data point regardless of whether it reflects genuine under-enforcement or simply thin public reporting. The two federally targeted tools that do apply specifically to Hawaii, the county-level Geographic Targeting Orders governing all-cash real estate purchases and the national crypto-convertible-virtual-currency kiosk fraud typology guidance, both depend for their practical effectiveness on state-level supervisory follow-through that is not independently documented in public sources. The kiosk fraud typology in particular carries elevated relevance given Hawaii demographic profile, a substantial retiree population and a tourism-dependent economy that create the same convertible-virtual-currency kiosk cash-conversion exposure documented nationally in FinCEN Notice FIN-2025-NTC1. Without Hawaii-specific data on kiosk-related suspicious-activity-report filings or state licensing examination outcomes, it is not possible to assess whether the Division of Financial Institutions supervisory perimeter is translating federal guidance into effective state-level monitoring, or whether Hawaii money-transmitter licensees are meeting the same red-flag-indicator expectations FinCEN has articulated at the national level. #### Outlook Resolution of this visibility gap would require either a direct Hawaii-specific enforcement action or suspicious-activity-report volume disclosure that could substantiate or revise the current severity assessment on the real estate layering scheme, or a comparative study benchmarking Hawaii Division of Financial Institutions examination and enforcement activity against equivalent mainland state regulators. Absent either, this domain is likely to remain assessed primarily through the lens of federal action applied to Hawaii by extension, with the state-specific enabler-jurisdiction question held open pending better source coverage in subsequent cycles. #### Conflict Finance and Extractive-Industry Integrity The principal conflict-finance-adjacent signal this cycle is the OFAC designation of the Democratic Karen Benevolent Army, a Burma-based armed group, on 12 November 2025, alongside four senior leaders and Chinese organized-crime-linked companies, for supporting cyber scam centers that defraud Americans nationwide. Read through the F4 conflict-finance filter, the source of funds is scam-compound proceeds, the channel is the armed group financial network, and the deployment sustains a non-state armed actor operating in Myanmar; this is a conflict-finance architecture in which the revenue stream is cyber-enabled fraud rather than a traditional extractive-industry or commodity-trafficking channel. No confirmed parallel European Union or United Kingdom OFSI listing was identified, an enforcement-architecture divergence in a domain where the United States, European Union, and United Kingdom sanctions regimes do not consistently mirror underlying designations. Continue reading This finding is not Hawaii-specific and has no direct jurisdictional nexus to this cycle sub-national baseline beyond the general observation that scam-compound revenue streams of this kind can intersect with the same crypto-laundering and kiosk-fraud typologies tracked elsewhere in this cycle for Hawaii demographic exposure. Signal for this domain is limited this cycle relative to the other five domains; no extractive-industry, mineral-trafficking, or direct war-economy financing development specific to this jurisdiction pass was identified in the underlying research. #### Outlook Given the limited and largely non-jurisdiction-specific signal this cycle, the principal forward item is whether a parallel European Union or United Kingdom listing of the Democratic Karen Benevolent Army network emerges, which would narrow the current sanctions-architecture divergence. No Hawaii-specific conflict-finance development is anticipated in the near term absent a materially different research scope in subsequent cycles. #### Crypto / Digital Assets / Financial Innovation Hawaii's digital-asset posture this cycle is defined by the commencement of Act 224 (HB1642) on October 1, 2026, which makes it an unlawful practice under HRS Chapter 481B for an operator to own, operate or manage a digital-financial-asset kiosk that accepts United States currency in exchange for a digital asset. The prohibition is narrow by design: crypto-to-cash and crypto-to-crypto kiosk transactions remain lawful, so the measure targets the specific cash-in channel rather than kiosk operation in general. Each violating transaction is treated as a separate offense, which gives the prohibition escalating force against sustained non-compliance rather than a one-time exposure. Continue reading This sits alongside, and does not disturb, Hawaii's 2024 determination that ordinary digital-currency exchange and custody activity falls outside the state money-transmitter licensing definition under HRS Chapter 489D. No state licence is required for standalone virtual-currency transmission as a result, and that baseline remains the operative state posture. The combination produces a jurisdiction that is permissive on licensing but has now carved out a targeted restriction where a particular transaction channel was judged to carry elevated consumer-risk characteristics, a pattern consistent with a jurisdiction responding to specific incident typologies (notably kiosk-enabled cash scams) rather than pursuing comprehensive digital-asset licensing. A broader move toward comprehensive licensing did not materialise this session. A bill proposing Hawaii's first dedicated digital-asset licensing charter, with an effective date no earlier than 2027 (and testimony suggesting as late as 2028), was deferred by a House committee in March 2026 and did not pass. Its deferral leaves the 2024 exemption determination as the governing word on licensing treatment for now, with no confirmed primary regulatory notice yet located addressing Act 224's commencement or any implementing guidance issued since. Separately, an enforcement action from earlier in 2026 continues to inform the state's posture toward crypto investment solicitation: Hawaii's securities regulator ordered a company and two individual promoters to cease soliciting investors in connection with an alleged crypto pyramid scheme, seeking $50,000 in penalties from each respondent. While dated outside this cycle's narrow window, it remains part of the continuity of Hawaii's crypto-enforcement record and underscores that enforcement attention in this jurisdiction has concentrated on investment-fraud typologies and consumer-facing cash channels rather than on licensing-perimeter disputes. #### Outlook The near-term trajectory for Hawaii's digital-asset regime is likely to remain incremental rather than structural: the exchange/custody licensing exemption appears stable, the kiosk cash-ban is newly in force, and the comprehensive charter proposal is dormant pending a possible revival in a future legislative session. The most consequential near-term marker would be confirmation of any implementing guidance or a first enforcement notice issued under Act 224, which would indicate how actively the new kiosk prohibition is being supervised in practice. #### AML/CTF Regime The federal AML/CTF regime applicable to US-HI saw two structural rulemaking developments this cycle, both flowing from FinCEN rather than any Hawaii-specific action. First, FinCEN issued a notice of proposed rulemaking that would fundamentally reform the requirements for financial institutions' AML/CFT programs, inserting counter-terrorist-financing terminology and effectiveness-based requirements into what has historically been an AML-only program rule under the Bank Secrecy Act. This is an architecture-level change: it does not respond to a single incident but rewrites the baseline expectation for how institutions design and evidence the adequacy of their compliance programs, a change that would apply uniformly to Hawaii-domiciled financial institutions as it would nationwide. Second, FinCEN proposed a whistleblower program that would operationalize financial incentives for reporting BSA, AML, and sanctions violations, with the comment period closing June 1, 2026. No FinCEN-administered monetary whistleblower channel for BSA or sanctions violations existed prior to this proposal, making it a new enforcement-support mechanism rather than an incremental adjustment to an existing one. Continue reading Separately, and at a global rather than jurisdictional level, the FATF's June 2026 Plenary updated its grey list, adding Iraq and Bosnia and Herzegovina and removing Algeria and Namibia, bringing the total under increased monitoring to twenty-two jurisdictions. No direct nexus between this update and US-HI has been identified this cycle; it is carried in this brief for fleet-wide completeness rather than as a Hawaii-specific finding. Notably, no US-HI-specific or US federal mutual-evaluation status has been established to primary-source standard this cycle, which remains an open evidentiary gap rather than a confirmed null finding. Taken together, the AML/CTF architecture governing US-HI this cycle is being reshaped almost entirely at the federal layer, through the BSA program-modernization NPRM and the whistleblower NPRM, with no genuine subnational divergence identified beyond the crypto money-transmission licensing gap tracked separately under the crypto and digital-assets domain. The absence of state-specific AML/CTF rulemaking in Hawaii this cycle is itself consistent with the state's broader pattern of relying on federal frameworks rather than layering additional state requirements. #### Outlook Both FinCEN NPRMs are past their comment-period close and moving toward potential finalization; either would materially change the compliance-program and enforcement-exposure baseline for financial institutions operating in or through Hawaii. The next cycle should also look for progress toward closing the US federal mutual-evaluation gap noted in this cycle's evidence, and for any indication that Hawaii's legislature intends to layer state-specific AML requirements onto the federal baseline, which nothing in this cycle's evidence currently suggests is under consideration. Baseline-Tracked Domains with No Current-Cycle Escalation (1 of 8) - D8 Commercial Activity: Standing coverage — no activity this cycle. Regulatory horizon Proposed 2027-Q1 · ±multi_year ### Hawaii Digital Asset Charter program (SB2757) Would end Hawaii's current unregulated-at-state-level posture for digital asset companies and introduce a charter, tiered assessment fees and consumer-protection/reserve requirements. [Source](https://data.capitol.hawaii.gov/sessions/session2026/bills/SB2757_SD2_.pdf) Consultation 2027-Q1 · ±half_year ### Hawaii Digital Asset Charters Act (SB2757) A new state charter/licensing regime for digital-asset companies would begin 2027-01-01, with transitional relief for firms that participated in the now-closed Digital Currency Innovation Lab. [Hawaii DCCA Division of Financial Institutions Source](https://data.capitol.hawaii.gov/sessions/session2026/bills/SB2757_SD2_.PDF) 2 dated · 3 pending date · baseline fim-2026-07-05 Role action cards MLRO ### A narrow cash-deposit prohibition for crypto kiosks took effect in Hawaii on October 1, 2026. The new prohibition closes a cash-funding channel often associated with kiosk-enabled investment-fraud typologies, though it does not alter the absence of a state money-transmitter licensing requirement for exchange or custody activity. 2 evidence refs Compliance ### Hawaii's licensing exemption for crypto exchange and custody remains unchanged while a narrow kiosk prohibition is now in force. Firms operating kiosks accepting US currency for digital assets in Hawaii now face an enforceable prohibition on that specific transaction type, while the broader licensing exemption for exchange and custody activity continues to apply. 2 evidence refs Legal ### A proposed comprehensive digital-asset licensing charter failed to advance in the 2026 session. The deferral of the charter bill leaves the 2024 exemption determination as the governing licensing position, with no confirmed timeline for comprehensive licensing legislation. 1 evidence refs Board ### Hawaii's narrow, incident-responsive approach to crypto regulation continued this cycle rather than shifting to comprehensive licensing. The state's regulatory posture toward digital assets remains permissive on core licensing while responsive to specific consumer-risk incidents, a pattern likely to continue absent revival of the stalled charter proposal. 2 evidence refs CTO ### Kiosk operators in Hawaii must now technically exclude cash-to-crypto transactions from their product flow. Kiosk platforms serving Hawaii need configuration changes to block cash-in digital-asset purchases while continuing to support crypto-to-cash and crypto-to-crypto flows, which remain lawful. 1 evidence refs Risk ### A kiosk-channel fraud-typology risk in Hawaii is now addressed by a targeted statutory prohibition. The narrowing of the cash-in kiosk channel reduces one vector associated with scam-driven crypto fund transfers, though no primary regulatory guidance on enforcement practice has yet been located. 1 evidence refs Audit ### No Tier-1 primary regulatory notice has yet been located confirming Act 224's commencement or implementing guidance. The evidentiary record for this cycle's kiosk-ban finding rests on secondary reporting rather than a primary regulator publication, which should be noted when assessing documentation sufficiency for this finding. 1 evidence refs Scenario sketches ### Illustrative shift from national supervision toward a hybrid EU-level AML perimeter As an illustrative orientation only, the gradual move in some multilateral frameworks from purely national anti-money-laundering supervision toward a hybrid model combining national and supranational direct or indirect oversight of cross-border obliged entities could, over time, reshape how evasion typologies migrate between jurisdictions with different supervisory reach. This is a structural, architecture-level illustration of how a supervisory perimeter shift could alter the landscape for obliged entities operating across borders; it describes a possible structural mechanism, not an observed fact about any specific jurisdiction in this cycle. Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact. 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 watch Act 224 cash-to-crypto kiosk ban took effect 2026-10-01; 2024 DFI money-transmitter exemption remains operative. T6 · Sanctions Regime Divergence no_change Registers ### Enforcement actions - 9 Oct 2025 - 14 Oct 2025 - 16 Oct 2025 - 12 Mar 2026 - 4 Aug 2025 - 17 Jun 2026 - 30 Jun 2026 - 25 Jun 2025 - 8 May 2026 - FinCEN renewed and reissued Geographic Targeting Orders requiring title insurers to identify and report the natural persons behind legal entities used in non-financed, all-cash residential real estate purchases above $300,000 across Hawaii's four counties among other US metros. 9 Oct 2025 - OFAC designated the Prince Group TCO and 146 associated targets, alongside a $15 billion DOJ bitcoin forfeiture action, for running forced-labor 'pig butchering' scam compounds in Cambodia that victimized Americans nationwide, including potentially Hawaii residents given the scheme's broad US targeting. 14 Oct 2025 - FinCEN imposed a Section 311 special measure designating Huione Group a foreign financial institution of primary money laundering concern, severing its access to the US financial system and thereby affecting US financial institutions', including Hawaii-based institutions', counterparty and correspondent screening obligations. 16 Oct 2025 - OFAC sanctioned facilitators of North Korean IT-worker fraud schemes generating nearly $800 million in 2024 for DPRK weapons programs, using cryptocurrency to move illicit earnings — a scheme typology (fraudulent remote employment) with potential exposure for Hawaii's remote-hiring technology and services sector. 12 Mar 2026 - FinCEN issued Notice FIN-2025-NTC1 urging increased vigilance regarding cryptocurrency ATM/kiosk fraud, citing a 99% increase in FBI IC3 complaints involving CVC kiosks and reminding financial institutions of BSA reporting obligations applicable to Hawaii-licensed money transmitters operating such kiosks. 4 Aug 2025 ### Sanctions changes - 14 Oct 2025 - 12 Nov 2025 - 12 Mar 2026 - 10 Dec 2025 - 23 Apr 2026 - 1 Jul 2026 - 30 Jun 2026 - 1 Jul 2026 - 23 Apr 2026 - 30 Jun 2026 - 28 May 2026 - 29 Jul 2026 - 30 Jul 2026 - 23 Jul 2026 - 24 Jul 2026 - 3 Aug 2026 - 1 May 2025 - OFAC designated Prince Group TCO, Chen Zhi, and associated entities for operating pig-butchering scam networks; expanded on October 30, 2025 to add 25 additional bitcoin addresses to Chen Zhi's SDN listing. 14 Oct 2025 - OFAC designated the Democratic Karen Benevolent Army (DKBA), a Burma-based armed group, plus four senior leaders and companies linked to Chinese organized crime, for supporting cyber scam centers targeting Americans. 12 Nov 2025 - OFAC designated six individuals and two entities (Amnokgang Technology Development Company, Quangvietdnbg) spanning DPRK, Vietnam, Laos, and Spain for facilitating North Korean IT-worker fraud and currency-conversion schemes. 12 Mar 2026 - Following the October 22, 2025 designation of Lukoil, OFAC issued a series of general licenses (GL 128B/C, 131A-G) authorizing wind-down, divestment negotiation, and maintenance of Lukoil International GmbH entities and retail service stations outside Russia, with authorizations progressively extended into mid-to-late 2026. 10 Dec 2025 ### Regulatory horizon (register) - UK Economic Crime and Corporate Transparency Act 2023 — failure-to-prevent-fraud offence - Hawaii Digital Asset Charters Act (SB2757) - Hawaii Act 224 digital financial asset kiosk cash-deposit prohibition - Hawaii Digital Asset Charter program (SB2757) - Appeal outcome on vacated Residential Real Estate Rule - Status of Hawaii-county real estate GTOs after Feb 2026 expiration - GENIUS Act stablecoin implementing regulations finalization - FATF October 2026 review of Iran countermeasures under new UK Presidency ### Active schemes - All-cash shell-company real estate layering, Hawaii counties - [HIGH] Crypto-ATM kiosk pig-butchering pipeline targeting Hawaii residents - [HIGH] Post-Corporate-Transparency-Act-exemption domestic shell company beneficial-ownership opacity Sources - [High-Risk Jurisdictions subject to a Call for Action - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/Call-for-action-february-2026.html) - [https://cca.hawaii.gov/blog/digital-currency-innovation-lab-concludes/](https://cca.hawaii.gov/blog/digital-currency-innovation-lab-concludes/) - [https://governor.hawaii.gov/newsroom/dcca-release-hawaii-digital-currency-innovation-lab-to-conclude/](https://governor.hawaii.gov/newsroom/dcca-release-hawaii-digital-currency-innovation-lab-to-conclude/) - [https://data.capitol.hawaii.gov/sessions/session2026/bills/SB2757_SD1_.PDF](https://data.capitol.hawaii.gov/sessions/session2026/bills/SB2757_SD1_.PDF) - [https://www.federalregister.gov/documents/2026/04/10/2026-07033/anti-money-laundering-and-countering-the-financing-of-terrorism-programs](https://www.federalregister.gov/documents/2026/04/10/2026-07033/anti-money-laundering-and-countering-the-financing-of-terrorism-programs) - [https://www.mayerbrown.com/en/insights/publications/2026/04/fincens-proposed-whistleblower-program-a-sea-change-in-aml-and-sanctions-enforcement](https://www.mayerbrown.com/en/insights/publications/2026/04/fincens-proposed-whistleblower-program-a-sea-change-in-aml-and-sanctions-enforcement) - [https://amluae.com/fatf-grey-list-countries-update-19th-june-2026/](https://amluae.com/fatf-grey-list-countries-update-19th-june-2026/) - [https://www.fatf-gafi.org/en/countries/detail/Lao-People-s-Democratic-Republic.html](https://www.fatf-gafi.org/en/countries/detail/Lao-People-s-Democratic-Republic.html) - [https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) - [https://www.fincen.gov/system/files/2026-06/FinCEN-Alert-Fiscal-Fuel-Theft.pdf](https://www.fincen.gov/system/files/2026-06/FinCEN-Alert-Fiscal-Fuel-Theft.pdf) - [https://home.treasury.gov/news/press-releases/sb0125](https://home.treasury.gov/news/press-releases/sb0125) - [https://consilient.com/illegal-gold-mining-money-laundering-fatf-unodc](https://consilient.com/illegal-gold-mining-money-laundering-fatf-unodc) - [https://data.capitol.hawaii.gov/sessions/session2026/CommReports/SB2757_SD1_SSCR2274_.htm](https://data.capitol.hawaii.gov/sessions/session2026/CommReports/SB2757_SD1_SSCR2274_.htm) - [https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [Office of the Governor, State of Hawaii](https://data.capitol.hawaii.gov/sessions/session2026/bills/GM1326_.pdf) - [Hawaii State Legislature](https://data.capitol.hawaii.gov/sessions/session2026/bills/HB1642_CD1_.pdf) - [Honolulu Star-Advertiser](https://www.staradvertiser.com/2026/08/02/hawaii-news/kokua-line-why-are-crypto-kiosks-still-around/) - [TokenPost](https://www.tokenpost.com/news/regulation/25991) - [Hawaii Dept. of Commerce & Consumer Affairs, Division of Financial Institutions](https://cca.hawaii.gov/dfi/mt-faq/) - [Office of the Governor, State of Hawaii / DCCA](https://governor.hawaii.gov/newsroom/dcca-release-hawaii-digital-currency-innovation-lab-to-conclude/) - [US Department of the Treasury](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [Decrypt](https://decrypt.co/375560/hawaii-to-ban-cash-deposits-at-crypto-atms-from-october) - [Troutman Pepper Locke](https://www.troutman.com/insights/digital-assets-blockchain-newsletter-october-16-2026/) - [Hoodline](https://hoodline.com/2026/05/hawaii-slaps-bg-wealth-with-cease-and-desist-over-alleged-crypto-pyramid/) - [Mondaq / Greenberg Traurig](https://www.mondaq.com/unitedstates/fin-tech/1427532/hawaiis-money-transmitters-modernization-act-will-no-longer-apply-to-cryptocurrency-activities) - [Astraea Law](https://astraea.law/insights/state-by-state-crypto-licensing-map-2025) - [Fact Sheet on MSB Registration Rule | FinCEN.gov](https://www.fincen.gov/fact-sheet-msb-registration-rule) - [FinCEN Notice, FIN-2025-NTC1, August 4, 2025](https://www.fincen.gov/system/files/2025-08/FinCEN-Notice-CVCKIOSK.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) - [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) - [Enforcement Actions | FinCEN.gov](https://www.fincen.gov/news/enforcement-actions) - [Enforcement Actions for Failure to Register as a Money Services Business | FinCEN.gov](https://www.fincen.gov/enforcement-actions-failure-register-money-services-business) - [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) - [Definition of Money Transmitter (Merchant Payment Processor) | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/definition-money-transmitter-merchant-payment) - [FinCEN Issues Report on Informal Value Transfer Systems | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-report-informal-value-transfer-systems) - [Fincen](https://www.fincen.gov/sites/default/files/shared/msbstatecontactsfinal.pdf) - [Important Information for MSBs | FinCEN.gov](https://www.fincen.gov/resources/financial-institutions/money-services-businesses) - [Hawaiian Financial Federal Credit Union - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/7620955Z:US) - [American Savings Bank FSB/Honolulu HI - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/394927Z:US) - [Bank of Hawaii Investment Services Group - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/0346103D:US) - [United States Department of the Treasury Financial Crimes Enforcement Network - Home | FinCEN.gov](https://www.fincen.gov/) - [Hawaii Federal Credit Union - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/0434074D:US) - [Hawaii Bankers Association - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/0084543Z:US) - [Hawaii USA Federal Credit Union - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/7342554Z:US) - [Financial Institution Definition | FinCEN.gov](https://www.fincen.gov/financial-institution-definition) - [44768 A Federal Register Vol. 72, No. 153 Thursday, Aug ...](https://www.fincen.gov/sites/default/files/shared/31_CFR_Part_103_312_EDD_Rule.pdf) - [Virtual Asset Service Provider (VASP): Definition, Compliance & Examples](https://www.trmlabs.com/fr/glossary/virtual-asset-service-provider-vasp) - [Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2025-26) - [MSB Registrant Search | FinCEN.gov](https://www.fincen.gov/resources/msb-state-selector) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [TRM Labs Resources | Crypto Investigations, Compliance, and Policy Insights](https://www.trmlabs.com/resources) - [Questions on Virtual Currency](https://ofac.treasury.gov/faqs/topic/1626) - [Training and Certifications](https://www.trmlabs.com/training-and-certifications) - [Trump administration curbs state oversight of crypto industry - ICIJ](https://www.icij.org/investigations/coin-laundry/trump-administration-curbs-state-oversight-of-crypto-industry/) - [Advanced Crypto Investigator](https://www.trmlabs.com/training-and-certifications/advanced-crypto-investigator) - [USSS Pig Butchering Investigation Leads to $5M+ Seizure of Victim Funds](https://www.trmlabs.com/resources/case-studies/usss) - [US Seizes Bitcoin Worth $15 Billion in 'Pig-Butchering' Case](https://www.bloomberg.com/news/articles/2025-10-14/cambodian-corporate-chairman-charged-in-15-billion-crypto-fraud) - [2026 Crypto Crime Report: Scams](https://www.chainalysis.com/blog/crypto-scams-2026/) - [DOJ Seizes $15 Billion in Bitcoin](https://www.chainalysis.com/blog/southeast-asia-crypto-scam-network-mining-pig-butchering-october-2025/) - [U.S. Launches New Strike Force to Combat $10 Billion Scam Industry](https://www.chainalysis.com/blog/ofac-targets-pig-butchering-scams-november-2025/) - [Pig butchering scam](https://www.trmlabs.com/glossary/pig-butchering-scam) - [1 1. See 31 U.S.C. § 5312(a)(2); 31 CFR § 1010.100(t). 2.](https://www.fincen.gov/system/files/shared/FinCEN_Alert_Pig_Butchering_FINAL_508c.pdf) - [APAC-based Law Enforcement Freezes $47 Million in Pig Butchering Funds](https://www.chainalysis.com/blog/apac-law-enforcement-freezes-pig-butchering-funds-august-2025/) - [Prince Group targeted with $15B crypto seizure and sanctions for pig butchering operations](https://www.elliptic.co/blog/prince-group-targeted-with-crypto-sanctions-for-global-pig-butchering-operations) - [US Charges North Koreans in Plot to Dupe More Than 100 Firms - Bloomberg](https://www.bloomberg.com/news/articles/2025-06-30/us-charges-north-koreans-in-plot-to-defraud-more-than-100-firms) - [Confessions of a Laptop Farmer: How an American Helped North Korea’s Wild Remote Worker Scheme](https://www.bloomberg.com/news/features/2025-07-24/north-korea-infiltrated-america-by-taking-remote-us-it-jobs) - [Beyond IT Worker Fraud: OFAC's Latest DPRK Designations Show Broader Sanctions and National Security Risk | TRM Blog](https://www.trmlabs.com/resources/blog/beyond-it-worker-fraud-ofacs-latest-dprk-designations-show-broader-sanctions-and-national-security-risk) - [Watch North Korea’s Hidden Remote IT Scheme - Bloomberg](https://www.bloomberg.com/news/videos/2025-12-16/inside-north-korea-s-secret-remote-it-workforce-video) - [Publication of North Korea Information Technology Workers Advisory | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20220516) - [US Sanctions Target North Korean Fake-Tech-Worker Scheme - Bloomberg](https://www.bloomberg.com/news/articles/2025-07-08/us-sanctions-target-north-korean-fake-tech-worker-scheme) - [UK supports US charges against North Korean cyber actors | National Cyber Security Centre - NCSC.GOV.UK](https://www.ncsc.gov.uk/news/uk-supports-us-charges-against-north-korean-cyber-actors) - [OFAC Targets DPRK IT Workers Using Crypto](https://www.chainalysis.com/blog/ofac-targets-north-korean-it-workers-crypto-march-2026/) - [Video: The Secret North Korean Workforce Inside US Companies - Bloomberg](https://www.bloomberg.com/news/articles/2025-12-16/video-the-secret-north-korean-workforce-inside-us-companies) - [US Imposes Sanctions Over North Korean Fraud Targeting US Firms - Bloomberg](https://www.bloomberg.com/news/articles/2026-03-12/us-imposes-sanctions-over-north-korean-fraud-targeting-us-firms) - [1 The U.S. Department of the Treasury’s (Treasury) Financial](https://www.fincen.gov/system/files/2026-03/FinCEN-Advisory-Health-Care-Fraud.pdf) - [SAR Filing Leads to Identification of Elaborate Ponzi Schemes | FinCEN.gov](https://www.fincen.gov/resources/law-enforcement/case-examples/sar-filing-leads-identification-elaborate-ponzi-schemes) - [DOJ Uses Organized Crime Statute in $263 Million Cryptocurrency Theft, Money Laundering and Home Invasion Conspiracy | TRM Labs](https://www.trmlabs.com/resources/blog/doj-uses-organized-crime-statute-in-263-million-cryptocurrency-theft-money-laundering-and-home-invasion-conspiracy) - [Canaccord-Consent-Order-No-2026-01. ...](https://www.fincen.gov/system/files/2026-03/Canaccord-Consent-Order-No-2026-01.pdf) - [1 (BILLINGCODE: 4810-02-P) DEPARTMENT OF THE TREASURY](https://www.fincen.gov/system/files/2026-06/HPay-NPRM.pdf) - [Law enforcement, banks warn of money laundering gaps in major US crypto bill - ICIJ](https://www.icij.org/investigations/coin-laundry/law-enforcement-banks-warn-of-money-laundering-gaps-in-major-us-crypto-bill/) - [Financial Fraud Enforcement Task Force (FFETF) | FinCEN.gov](https://www.fincen.gov/financial-fraud-enforcement-task-force-ffetf) - [Advisories | FinCEN.gov](https://www.fincen.gov/resources/advisoriesbulletinsfact-sheets/advisories) - [Press Releases | FinCEN.gov](https://www.fincen.gov/news/press-releases) - [Attorney Sentenced in Fraud Case | FinCEN.gov](https://www.fincen.gov/resources/law-enforcement/case-examples/attorney-sentenced-fraud-case) - [United States Attorney's Office for the District of Hawaii - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/1339169D:US) - [Summary of Nominated Cases State and Local – San Jose Police Department](https://www.fincen.gov/system/files/shared/Summary%20of%20LEAP%20Nominated%20Cases.pdf) - [Elliot Enoki, United States Attorney's Office for the District of Hawaii: Profile and Biography - Bloomberg Markets](https://www.bloomberg.com/profile/person/17798212) - [U.S. Convicts Two for Laundering $150 Million from Marijuana Sales | OCCRP](https://www.occrp.org/en/news/us-convicts-two-for-laundering-150-million-from-marijuana-sales) - [Nigerian Pension Reformer Bought US and UAE Properties Before Money Laundering Conviction | OCCRP](https://www.occrp.org/en/scoop/nigerian-pension-reformer-bought-us-and-uae-properties-before-money-laundering-conviction) - [Definition of Money Services Business (Money Transmitter/Currency Dealer or Exchanger) | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/definition-money-services-business-money) - [Special Measures | FinCEN.gov](https://www.fincen.gov/resources/statutes-and-regulations/special-measures) - [Application of Money Services Business Regulations to a Company Acting as an Independent Sales Organization and Payment Processor | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/application-money-services-business) - [Application of the Definition of Money Transmitter to Brokers and Dealers in Currency and Other Commodities | FinCEN.gov](https://fincen.gov/index.php/resources/statutes-regulations/guidance/application-definition-money-transmitter-brokers-and) - [Title 18b | FinCEN.gov](https://www.fincen.gov/title-18b) - [1 (BILLING CODE 4810-2P) DEPARTMENT OF THE TREASURY 31 CFR Part 103](https://www.fincen.gov/system/files/shared/ChaptXFinalRule.pdf) - [Chapter X | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/chapter-x) - [The Bank Secrecy Act | FinCEN.gov](https://www.fincen.gov/resources/statutes-and-regulations/bank-secrecy-act) - [Definition of Money Services Business (Debt Management Company) | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/definition-money-services-business-debt) - [Nevada Issues Cease-and-Desist Order to Crypto’s Fortress Trust - Bloomberg](https://www.bloomberg.com/news/articles/2025-10-23/nevada-issues-cease-and-desist-order-to-crypto-s-fortress-trust) - [DEPARTMENT OF THE TREASURY WASHINGTON, D.C. OFFICE OF FOREIGN ASSETS CONTROL](https://ofac.treasury.gov/media/933791/download?inline=) - [1198 | Office of Foreign Assets Control](https://ofac.treasury.gov/faqs/1198) - [Hawaii Tries a New Twist on US Board Gender Quotas: Must Have Men - Bloomberg](https://www.bloomberg.com/news/articles/2023-02-08/hawaii-tries-a-new-twist-on-us-board-gender-quotas-must-have-men) - [844 | Office of Foreign Assets Control](https://ofac.treasury.gov/faqs/844) - [DEPARTMENT OF THE TREASURY WASHINGTON, D.C, 20220 SETTLEMENT AGREEMENT](https://ofac.treasury.gov/media/13891/download?inline=) - [MSB Examination Manual](https://www.fincen.gov/system/files/shared/MSB_Exam_Manual.pdf) - [Frequently Asked Questions - Recently Updated | Office of Foreign Assets Control](https://ofac.treasury.gov/faqs/updated) - [OFFICE OF FOREIGN ASSETS CONTROL Executive Order ...](https://ofac.treasury.gov/media/934336/download?inline=) - [Russia-related Designations; Issuance of Russia-related General Licenses and new and amended Frequently Asked Questions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20240223) - [From trading bans to total embrace, a global guide to crypto regulation](https://www.icij.org/investigations/coin-laundry/cryptocurrency-regulations-global-explainer/) - [The Complete Crypto Compliance Program Guide for Financial Institutions | TRM Labs](https://www.trmlabs.com/guides/crypto-compliance-program-guide-for-financial-institutions) - [Hong Kong Crypto Exchanges Face Challenges to Get Full Licenses - Bloomberg](https://www.bloomberg.com/news/articles/2024-08-22/hong-kong-crypto-exchanges-face-challenges-to-get-full-licenses) - [Crypto regulatory affairs: Hong Kong plans to create panel for licensed crypto exchanges to facilitate regulatory consultation](https://www.elliptic.co/blog/crypto-regulatory-affairs-hong-kong-plans-to-create-panel-for-licensed-crypto-exchanges-to-facilitate-regulatory-consultation) - [Crypto: Regulation - Bloomberg](https://www.bloomberg.com/crypto/regulation) - [Hong Kong Pledges More Licenses for Crypto Exchanges by Year-End - Bloomberg](https://www.bloomberg.com/news/articles/2024-10-28/hong-kong-pledges-more-licenses-for-crypto-exchanges-by-year-end) - [UAE Readies National Crypto Licensing in Push to Embrace Fintech](https://www.bloomberg.com/news/articles/2022-02-17/uae-readies-national-crypto-licensing-in-push-to-embrace-fintech) - [Crypto regulatory affairs: Hong Kong regulator names 11 crypto firms progressing through licensing process](https://www.elliptic.co/blog/hong-kong-regulator-names-eleven-crypto-firms-progressing-through-licensing-process) - [Hong Kong Regulator Releases Blueprint for Crypto Framework](https://www.elliptic.co/blog/hong-kong-regulator-releases-blueprint-for-new-crypto-framework) - [Introduction to Cryptocurrency Exchange Compliance - Chainalysis](https://www.chainalysis.com/blog/introduction-to-cryptocurrency-exchange-compliance-crypto-businesses-2024/) - [Request for Administrative Ruling on the Application of FinCEN’s Regulations to a Virtual Currency Payment System | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/request-administrative-ruling-application) - [Application of Money Services Business regulations to the rental of computer systems for mining virtual currency | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/application-money-services-business-0) - [Application of FinCEN’s Regulations to Virtual Currency Mining Operations | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/application-fincens-regulations-virtual-0) - [Definition of Money Services Business (Money Transmitter/Currency Dealer or Exchanger) | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/definition-money-services-business-money-0) - [Request for Administrative Ruling on the Application of FinCEN’s Regulations to a Virtual Currency Trading Platform | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/request-administrative-ruling-application-0) - [FinCEN Issues Guidance on Virtual Currencies and Regulatory Responsibilities | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-guidance-virtual-currencies-and-regulatory-responsibilities) - [Administrative Rulings | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings?field_tags_financial_institution_target_id=All&page=1) - [Money Services Business (MSB) Registration | FinCEN.gov](https://www.fincen.gov/resources/money-services-business-msb-registration) - [A Record-Breaking Year for Cybercrime: Key Findings from the FBI’s 2024 IC3 Report | TRM Labs](https://www.trmlabs.com/resources/blog/a-record-breaking-year-for-cybercrime-key-findings-from-the-fbis-2024-ic3-report) - [Elder Financial Exploitation: Threat Pattern & Trend ...](https://www.fincen.gov/system/files/shared/FTA_Elder_Financial_Exploitation_508Final.pdf) - [FBI Report Shows People Lost US$1.4 Billion to Cyber Criminals | OCCRP](https://www.occrp.org/en/news/fbi-report-shows-people-lost-us14-billion-to-cyber-criminals) - [FinCEN Issues Analysis on Elder Financial Exploitation | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-analysis-elder-financial-exploitation) - [What is Pig Butchering? Crypto Investment Scam - Chainalysis](https://www.chainalysis.com/glossary/pig-butchering/) - [1 FIN-2022-A002 June 15, 2022 Advisory on Elder Financial Exploitation](https://www.fincen.gov/system/files/advisory/2022-06-15/FinCEN%20Advisory%20Elder%20Financial%20Exploitation%20FINAL%20508.pdf) - [FinCEN Alert, FIN-2024-Alert005, December 18, 2024](https://www.fincen.gov/system/files/2024-12/Alert-FinCEN-Scams-FINAL508.pdf) - [What Is a Crypto Scam? Types & Defense - Chainalysis](https://www.chainalysis.com/glossary/crypto-scam/) - [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) - [FinCEN Renews and Expands Real Estate Geographic Targeting Orders | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-renews-and-expands-real-estate-geographic-targeting-orders) - [FinCEN Renews Real Estate Geographic Targeting Orders | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-renews-real-estate-geographic-targeting-orders) - [FinCEN Reissues Real Estate Geographic Targeting Orders for 12 Metropolitan Areas | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-reissues-real-estate-geographic-targeting-orders-12-metropolitan-areas-2) - [FinCEN Renews Real Estate Geographic Targeting Orders for 12 Metropolitan Areas | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-renews-real-estate-geographic-targeting-orders-12-metropolitan-areas) - [FinCEN Reissues Real Estate Geographic Targeting Orders and Expands Coverage to 12 Metropolitan Areas | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-reissues-real-estate-geographic-targeting-orders-and-expands-coverage-12) - [RRE GTO FAQs](https://www.fincen.gov/system/files/2025-10/RRE-GTO-FAQs.pdf) - [Residential Real Estate Newsroom | FinCEN.gov](https://www.fincen.gov/rre-newsroom) - [Residential Real Estate Rule | FinCEN.gov](https://www.fincen.gov/rre) - [Geographic Targeting Order Covering TITLE INSURANCE COMPANY October 9, 2025](https://www.fincen.gov/system/files/2025-10/RRE-GTO-Order.pdf) - [Interagency Statement on Sharing Bank Secrecy Act Resources | FinCEN.gov](https://www.fincen.gov/news/news-releases/interagency-statement-sharing-bank-secrecy-act-resources) - [CONSENT ORDER IMPOSING CIVIL MONEY PENALTY](https://www.fincen.gov/sites/default/files/enforcement_action/2023-04-05/CBOT_Enf_Action_121621_508_FINAL.pdf) - [The 2010 Version of the Bank Secrecy Act/Anti-Money Laundering Examination Manual | FinCEN.gov](https://www.fincen.gov/news/news-releases/2010-version-bank-secrecy-actanti-money-laundering-examination-manual) - [Bank of America Reaches Anti-Money-Laundering Consent Agreement With OCC](https://www.bloomberg.com/news/articles/2024-12-23/bofa-reaches-anti-money-laundering-consent-agreement-with-occ) - [FinCEN Consent Order Imposing Civil Money Penalty, ...](https://www.fincen.gov/sites/default/files/enforcement_action/2022-03-17/USAA%20Consent%20Order_Final_508%20Compliant.pdf) - [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) - [– 1 – UNITED STATES OF AMERICA FINANCIAL CRIMES ENFORCEMENT NETWORK](https://www.fincen.gov/system/files/enforcement_action/2023-04-05/Assessment_CONA_508_0.pdf) - [PPSI-AMLCFT-NPRM.pdf](https://www.fincen.gov/system/files/2026-04/PPSI-AMLCFT-NPRM.pdf) - [FinCEN Number 2023-03, CONSENT ORDER IMPOSING ...](https://www.fincen.gov/sites/default/files/enforcement_action/2023-09-29/SHBA_9-28_FINAL_508.pdf) - [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) - [Whether a Company that Provides Online Real-Time Deposit, Settlement, and Payment Services for Banks, Businesses and Consumers is a Money Transmitter rather | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/whether-company-provides-online-real-time) - [Application of FinCEN’s Regulations to Virtual Currency Software Development and Certain Investment Activity | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/application-fincens-regulations-virtual) - [Jurisdictions under Increased Monitoring - 19 June 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - ["Black and grey" lists](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [High-Risk Jurisdictions subject to a Call for Action - 19 June 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/call-for-action-june-2026.html) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions.html) - [Outcomes FATF Plenary, 17-19 June 2026](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-june-2026.html) - [Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov](https://www.fincen.gov/news/news-releases/financial-action-task-force-identifies-jurisdictions-anti-money-laundering-5) - [Jurisdictions under Increased Monitoring - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) - [Countries / Jurisdictions](https://www.fatf-gafi.org/en/countries.html) - [News](https://www.fatf-gafi.org/en/the-fatf/news.html) - [High-Risk Jurisdictions subject to a Call for Action - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/Call-for-action-february-2026.html) - [FinCEN, U.S. Department of the Treasury](https://www.fincen.gov/news/news-releases/fincen-renews-residential-real-estate-geographic-targeting-orders-0) - [FinCEN, U.S. Department of the Treasury](https://www.fincen.gov/rre) - [FinCEN, U.S. Department of the Treasury](https://www.fincen.gov/system/files/2025-08/FinCEN-Notice-CVCKIOSK.pdf) - [FinCEN, U.S. Department of the Treasury](https://www.fincen.gov/system/files/2026-06/HPay-NPRM.pdf) - [FinCEN, U.S. Department of the Treasury](https://www.fincen.gov/) - [Hawaii Department of Commerce and Consumer Affairs, Division of Financial Institutions](https://cca.hawaii.gov/dfi/) - [Elliptic](https://www.elliptic.co/blog/prince-group-targeted-with-crypto-sanctions-for-global-pig-butchering-operations) - [Chainalysis](https://www.chainalysis.com/blog/ofac-targets-north-korean-it-workers-crypto-march-2026/) - [Bloomberg](https://www.bloomberg.com/news/articles/2026-03-12/us-imposes-sanctions-over-north-korean-fraud-targeting-us-firms) - [Financial Action Task Force](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [International Consortium of Investigative Journalists (ICIJ)](https://www.icij.org/investigations/coin-laundry/trump-administration-curbs-state-oversight-of-crypto-industry/) Coverage gaps fim-int-2026-07-07-G001: Current enforcement and custody sta… fim-int-2026-07-07-G001: Current enforcement and custody status of Chen Zhi following the January 2026 extradition to China, and whether OFAC has updated the SDN record or issued a follow-on statement, has not been confirmed by Research and requires verification before treating the Prince Group enforcement narrative as current. [resolved] fim-int-2026-07-07-G002: Whether the Hawaii county Geographi… fim-int-2026-07-07-G002: Whether the Hawaii county Geographic Targeting Orders were renewed, replaced, or allowed to lapse following the 28 February 2026 expiration date is unverified as of the 5 July 2026 baseline and needs a direct FinCEN source check. [resolved] fim-int-2026-07-07-G003: The final, non-interim status of th… fim-int-2026-07-07-G003: The final, non-interim status of the Corporate Transparency Act domestic reporting company exemption, expected to be resolved via a 2026 final rule following the public comment period, has not yet been confirmed. [resolved] fim-int-2026-07-07-G004: Hawaii-specific suspicious-activity… fim-int-2026-07-07-G004: Hawaii-specific suspicious-activity-report volume or state-level enforcement outcomes that would substantiate the ELEVATED severity rating on the all-cash real estate layering scheme, as distinct from national Geographic Targeting Order typology coverage, have not been located. [resolved] fim-int-2026-07-07-G005: Direct primary-source confirmation … fim-int-2026-07-07-G005: Direct primary-source confirmation of any Hawaii-domiciled financial institution counterparty exposure to Lukoil-affiliated entities or to the designated Prince Group or Huione Group networks has not been established; current assessment relies on national extension of federal action rather than jurisdiction-specific evidence. [resolved] fim-int-2026-07-07-G006: Publication-gate quality indicators… fim-int-2026-07-07-G006: Publication-gate quality indicators on the underlying baseline record (schema_valid false, jurisdiction_source_floor_met false, tier_a_b_national_primary_pct 0.0) suggest unresolved source-quality or schema issues upstream that would benefit from resolution before this jurisdiction record is treated as publication-ready. [resolved] fim-int-2026-07-14-G001: No direct primary-source retrieval … fim-int-2026-07-14-G001: No direct primary-source retrieval of the underlying OFAC Kok An network press release; findings rest on Chainalysis secondary reporting. [resolved] fim-int-2026-07-14-G002: No primary Amnesty International re… fim-int-2026-07-14-G002: No primary Amnesty International report text retrieved this cycle; the 24-of-86-compound finding rests on Al Jazeera's summary of the report. [resolved] fim-int-2026-07-14-G003: No direct EU Council text for the 2… fim-int-2026-07-14-G003: No direct EU Council text for the 21st sanctions package (crypto-evasion focus) was retrieved this cycle. [resolved] fim-int-2026-07-14-G004: No direct federalreserve.gov SR 26-… fim-int-2026-07-14-G004: No direct federalreserve.gov SR 26-2 primary text retrieved this cycle; both corroborating sources are Tier-4 secondary analysis. [resolved] fim-int-2026-07-14-G005: UK National Risk Assessment refresh… fim-int-2026-07-14-G005: UK National Risk Assessment refresh timing is unconfirmed; carried as a placeholder horizon item pending a primary HM Treasury source. [resolved] fim-int-2026-07-14-G006: Per-Member-State 6AMLD transpositio… fim-int-2026-07-14-G006: Per-Member-State 6AMLD transposition status was not separately established for any individual EEA jurisdiction this cycle. [resolved] fim-int-2026-07-14-G007: DeFi-specific (non-VASP/CASP) enfor… fim-int-2026-07-14-G007: DeFi-specific (non-VASP/CASP) enforcement coverage was thin this cycle; only centralised-exchange/stablecoin-issuer-level developments were surfaced. [resolved] fim-int-2026-07-14-G008: Sub-Saharan Africa and Central Asia… fim-int-2026-07-14-G008: Sub-Saharan Africa and Central Asia regional AML/CFT coverage was not separately surfaced this cycle and should be prioritised next cycle. [resolved] fim-int-2026-08-05-G001: No EU AML Package (AMLR/6AMLD/AMLA)… fim-int-2026-08-05-G001: No EU AML Package (AMLR/6AMLD/AMLA) source was searched this cycle; D2 tracker status reflects a coverage gap, not confirmed stability. [resolved] fim-int-2026-08-05-G002: No conflict-finance (D4) source was… fim-int-2026-08-05-G002: No conflict-finance (D4) source was searched this cycle. [resolved] fim-int-2026-08-05-G003: Tier D jurisdictions (Cambodia, Lao… fim-int-2026-08-05-G003: Tier D jurisdictions (Cambodia, Laos, Mexico, Colombia) were not searched this cycle. [resolved] fim-int-2026-08-05-G004: Final 2026-session enactment status… fim-int-2026-08-05-G004: Final 2026-session enactment status of Hawaii SB 2757 SD1 (Digital Asset Charter) is unconfirmed. [resolved] fim-int-2026-08-05-G005: UK ECCTA 2023 failure-to-prevent-fr… fim-int-2026-08-05-G005: UK ECCTA 2023 failure-to-prevent-fraud offence's current implementation stage was not confirmed by a fresh primary source this cycle. [resolved] fim-int-2026-08-20-G001: Tier D jurisdictions (KH, MX, CO) d… fim-int-2026-08-20-G001: Tier D jurisdictions (KH, MX, CO) deep-dive deferred this cycle due to pooled union web-search budget prioritizing the bound JID; flagged as awaiting_primary_source, not a confirmed null. [resolved] fim-int-2026-08-20-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-08-20-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): No US-HI-specific FATF mutual-evaluation status (D7) established this cycle; US federal-level mutual evaluation status not confirmed to primary-source standard. [resolved] fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): No independent T1 confirmation of final enacted status for any 2026 Hawaii gambling or digital-asset bill was retrieved this cycle. [resolved] fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', 'value': 'D2'}): D2, D3, D6 and D7 domains had thin or no coverage this cycle; no material developments identified beyond standing status. [resolved] fim-int-2026-10-04-G001: No DFI supervisory letter interpret… fim-int-2026-10-04-G001: No DFI supervisory letter interpreting Act 224's scope for mixed-function (bidirectional) kiosks ahead of the October 1, 2026 effective date was located this cycle. [open] fim-int-2026-10-04-G002: Domains D1-D4 and D6 carry only thi… fim-int-2026-10-04-G002: Domains D1-D4 and D6 carry only thin or standing coverage for US-HI this cycle; no fresh T1 instrument was found touching sanctions, beneficial ownership, enabler-jurisdiction, or conflict-finance architecture for this sub-national jurisdiction in the window. [open] fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): No Tier-1 Hawaii DCCA/DFI primary notice was located confirming Act 224's commencement or any implementing guidance issued since the October 1, 2026 effective date. [open] fim-int-2026-10-25-G002: D1 (Sanctions), D2 (Beneficial Owne… fim-int-2026-10-25-G002: D1 (Sanctions), D2 (Beneficial Ownership), D3 (Enabler Jurisdictions), D4 (Conflict Finance) and D6 (Compliance Technology) domain findings specific to Hawaii were not located this cycle given the narrow single-jurisdiction search scope. [open] FIM-GAP-001 (D2): Since March 2025, all US-formed ('domestic… FIM-GAP-001 (D2): Since March 2025, all US-formed ('domestic reporting') companies and their beneficial owners are exempt from Corporate Transparency Act reporting to FinCEN, eliminating federal beneficial-ownership visibility for Hawaii-registered LLCs — a structure type commonly used in real-estate and trade-based layering. FIM-GAP-002 (D2): The federal Residential Real Estate Rule —… FIM-GAP-002 (D2): The federal Residential Real Estate Rule — intended to provide a permanent nationwide BO-reporting backbone for non-financed residential transfers — was vacated by a US District Court on March 19, 2026, and the underlying GTOs covering Hawaii's four counties were themselves tied to a February 28, 2026 expiration linked to that rule's implementation. FIM-GAP-003 (D3): Publicly available enforcement and typolog… FIM-GAP-003 (D3): Publicly available enforcement and typology reporting specific to Hawaii (as distinct from national-level federal actions applied to Hawaii by extension) is comparatively thin relative to major financial centers (New York, California, Florida), limiting independent verification of state-level AML/CFT effectiveness and DCCA Division of Financial Institutions supervisory outcomes. ## Evidence #### Confidence-tiered claims Owning, operating, or managing a digital financial asset transaction kiosk that accepts United States currency from a customer in exchange for a digital financial asset, effective October 1, 2026; each violating transaction is a separate offense. [[Source 1]](#sec-sources) Probable · 1 source No state-level crypto AML regime exists; money-transmitter licensing (HRS Ch. 489D) was determined inapplicable to digital-currency companies in 2024, leaving crypto firms state-unregulated and subject only to federal BSA/FinCEN requirements. [[Source 1]](#sec-sources) Probable · 1 source AML/CTF supervision for US-HI follows the federal BSA/FinCEN framework; no state-level AML instrument applies to crypto or payment firms beyond the general Money Transmitters Act, which is held inapplicable to crypto. [[Source 1]](#sec-sources) Probable · 1 source Crypto-ATM kiosks were disproportionately used in elder-targeted romance, impersonation and tech-support scams; DC/Iowa AG investigations found up to 90% of kiosk transactions fraudulent prior to Act 224. [[Source 1]](#sec-sources) Probable · 1 source Sanctions and beneficial-ownership registry authority in the United States sits exclusively at the federal level; no US-HI-specific development was found in the window. [[Source 1]](#sec-sources) Probable · 1 source Makes it an unlawful practice under HRS Chapter 481B for an operator to own, operate or manage a digital-financial-asset kiosk accepting US currency in exchange for a digital asset, effective 2026-10-01; crypto-to-cash and crypto-to-crypto kiosk transactions remain lawful [[Source 1]](#sec-sources) Probable · 1 source Hawaii DCCA securities regulator issued a cease-and-desist order against BG Wealth Sharing Ltd. and two promoters over an alleged crypto pyramid scheme, seeking $50,000 in penalties from each respondent [[Source 1]](#sec-sources) Probable · 1 source DFI determined effective 2024-07-01 that ordinary digital-currency exchange/custody activity falls outside the HRS Chapter 489D money-transmitter definition; no state licence is required for standalone virtual-currency transmission [[Source 1]](#sec-sources) Probable · 1 source Proposed Hawaii's first dedicated digital-asset licensing charter, with an effective date no earlier than 2027-01-01 (DFI testimony suggested as late as 2028); deferred by House committee on 2026-03-17 and did not pass in the 2026 session [[Source 1]](#sec-sources) Uncertain · 1 source