--- title: "United States — Louisiana (US-LA) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/united-states-louisiana/ source_html: /jurisdictions/united-states-louisiana/index.html description: "Financial integrity intelligence for United States – Louisiana (US-LA): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: d87b688b0879a07c7626f7cf7267358e3a957b38d3e00bbf0951eb457e96c83f generator: "fe-fleet/md-twin@1.0" --- # United States — Louisiana (US-LA) — 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 — Louisiana US-LA Domains covered 8 of 8 Sources 199 Role actions 8 Horizon <90d 0 Jurisdiction profile FATF status: Clean Tier: B Risk direction: Stable Enablement vs enforcement: Mixed Louisiana AML/CTF sits inside the federal BSA/AML framework administered by FinCEN/OFAC, with the state Office of Financial Institutions (OFI) supervising state-chartered banks, money transmitters and sharing OFAC compliance information under a standing MOU. More Louisiana has no independent state beneficial-ownership registry; federal CTA reporting for domestic entities was suspended in March 2025. Key deficiencies - No Louisiana-specific beneficial ownership registry; reliance on now-narrowed federal CTA regime - Gulf Coast refining/port infrastructure (Baton Rouge, Lake Charles, Chalmette, New Orleans) exposed to 'substantially transformed' Russian-origin refined petroleum products not captured by U.S. crude-oil sanctions - Louisiana residential real estate market historically excluded from FinCEN's title-insurance Geographic Targeting Orders, unlike neighboring Texas metros - No state-level AML supervisory capacity independent of federal BSA examination for non-bank sectors Recent developments (18m) - OFAC–Louisiana Office of Financial Institutions MOU formalizing sanctions-compliance information sharing for state-chartered banking organizations - OFAC designation of Rosneft and Lukoil (Oct 2025, effective Nov 21 2025) reshaping global Russian crude flows relevant to Gulf Coast refining exposure - FinCEN's March 2025 interim final rule exempting all U.S.-formed (domestic) entities, including Louisiana LLCs widely used in oil & gas asset holding, from Corporate Transparency Act beneficial-ownership reporting - Nationwide Residential Real Estate Rule (final rule Aug 2024) reporting obligations postponed to March 1, 2026, newly extending non-financed real-estate reporting to Louisiana parishes for the first time - FinCEN Financial Trend Analysis and Advisory on Chinese Money Laundering Networks (Aug 28, 2025) flagging trade-based laundering typologies relevant to Gulf Coast port trade United States federal law that applies in United States – Louisiana is covered once, on the [United States](/jurisdictions/us/) page. This page covers United States – Louisiana’s own layer: its own law, regulators and enforcement. Brief ## Lead signal #### Lead Signal Louisiana has restructured the statutory foundation of money transmission regulation in the state, enacting a replacement act that repeals the prior Sale of Checks and Money Transmission Act and installs a new chapter built on the Model Money Transmission Modernization Act. The new framework, effective 1 July 2026, folds Bank Secrecy Act and anti-money-laundering reporting duties directly into the conditions of state licensure: money transmitters must file reports required under the BSA and other AML laws, retain records for at least five years, and submit quarterly call reports as a matter of licence compliance rather than solely as a federal obligation running in parallel. This is a structural move rather than an enforcement event. By embedding federal AML reporting expectations inside the state licence itself, Louisiana converts what was previously a dual-track compliance posture (state licensure plus independent federal AML duty) into a single licence-conditioned package, and in doing so narrows rather than widens the room for arbitrage between state and federal expectations for money-transmission compliance. Read full brief #### Lead Signal Louisiana has restructured the statutory foundation of money transmission regulation in the state, enacting a replacement act that repeals the prior Sale of Checks and Money Transmission Act and installs a new chapter built on the Model Money Transmission Modernization Act. The new framework, effective 1 July 2026, folds Bank Secrecy Act and anti-money-laundering reporting duties directly into the conditions of state licensure: money transmitters must file reports required under the BSA and other AML laws, retain records for at least five years, and submit quarterly call reports as a matter of licence compliance rather than solely as a federal obligation running in parallel. This is a structural move rather than an enforcement event. By embedding federal AML reporting expectations inside the state licence itself, Louisiana converts what was previously a dual-track compliance posture (state licensure plus independent federal AML duty) into a single licence-conditioned package, and in doing so narrows rather than widens the room for arbitrage between state and federal expectations for money-transmission compliance. A second, related structural change touches the digital-asset perimeter. Act 923 repeals the sunset date that had been due to retire Louisiana's Virtual Currency Businesses Act in mid-2027, and adds a forward-looking provision: if a federal law governing the licensure of virtual-currency business activity takes effect, any conflicting state provision becomes void from the end of the calendar year that federal law takes effect. Read together, the two enactments describe a jurisdiction simultaneously hardening its own money-transmission AML conditions while explicitly building in a mechanism to yield ground to a future federal virtual-currency licensing regime, rather than entrenching a permanently separate state track. #### Other Developments Multistate supervisory alignment. The new Money Transmission Act's adoption of the Model Money Transmission Modernization Act framework is designed to enable multistate supervisory examinations, aligning Louisiana's examination posture with the growing number of states that have adopted the same model law. This reduces the degree to which Louisiana licensure sits apart from the national examination architecture that most other adopting states now share. Grandfathering mechanics. The enactment preserves continuity for incumbents: licensees under the prior Sale of Checks Act framework are not required to re-apply immediately, softening the near-term compliance disruption of the statutory replacement even as the underlying obligations change in substance. #### Cross-Monitor Connections The virtual-currency sunset repeal and federal-preemption trigger in Act 923 sits at the boundary between state money-services regulation and the digital-asset regulatory perimeter tracked separately for crypto-specific developments; the architecture described here is the money-transmission and AML side of that boundary, not an assessment of the digital-asset business models themselves. The embedding of BSA/AML reporting duties into state licensure conditions is also relevant to how payment-services supervision is read at the state level, a connection most directly legible to those tracking payment-industry licensing architecture. #### Outlook The practical question through the remainder of 2026 and into 2027 is less whether Louisiana's new licensing conditions will be enforced as written, since they are now live, and more whether the federal-preemption trigger embedded in Act 923 will ever be activated. That depends entirely on whether Congress or a federal regulator advances a licensure regime for virtual-currency business activity, a development that remains speculative as at this cycle. Louisiana's statute is drafted to yield automatically if that happens; until it does, both enactments stand as the operative state regime, with the Money Transmission Act's AML-reporting conditions already in force and the virtual-currency provisions continuing on an indefinite footing following the sunset repeal. Earlier periodic briefs (7) 25 Oct 2026 · fim-2026-10-25 #### Lead Signal Louisiana has restructured the statutory foundation of money transmission regulation in the state, enacting a replacement act that repeals the prior Sale of Checks and Money Transmission Act and installs a new chapter built on the Model Money Transmission Modernization Act. The new framework, effective 1 July 2026, folds Bank Secrecy Act and anti-money-laundering reporting duties directly into the conditions of state licensure: money transmitters must file reports required under the BSA and other AML laws, retain records for at least five years, and submit quarterly call reports as a matter of licence compliance rather than solely as a federal obligation running in parallel. This is a structural move rather than an enforcement event. By embedding federal AML reporting expectations inside the state licence itself, Louisiana converts what was previously a dual-track compliance posture (state licensure plus independent federal AML duty) into a single licence-conditioned package, and in doing so narrows rather than widens the room for arbitrage between state and federal expectations for money-transmission compliance. A second, related structural change touches the digital-asset perimeter. Act 923 repeals the sunset date that had been due to retire Louisiana's Virtual Currency Businesses Act in mid-2027, and adds a forward-looking provision: if a federal law governing the licensure of virtual-currency business activity takes effect, any conflicting state provision becomes void from the end of the calendar year that federal law takes effect. Read together, the two enactments describe a jurisdiction simultaneously hardening its own money-transmission AML conditions while explicitly building in a mechanism to yield ground to a future federal virtual-currency licensing regime, rather than entrenching a permanently separate state track. #### Other Developments Multistate supervisory alignment. The new Money Transmission Act's adoption of the Model Money Transmission Modernization Act framework is designed to enable multistate supervisory examinations, aligning Louisiana's examination posture with the growing number of states that have adopted the same model law. This reduces the degree to which Louisiana licensure sits apart from the national examination architecture that most other adopting states now share. Grandfathering mechanics. The enactment preserves continuity for incumbents: licensees under the prior Sale of Checks Act framework are not required to re-apply immediately, softening the near-term compliance disruption of the statutory replacement even as the underlying obligations change in substance. #### Cross-Monitor Connections The virtual-currency sunset repeal and federal-preemption trigger in Act 923 sits at the boundary between state money-services regulation and the digital-asset regulatory perimeter tracked separately for crypto-specific developments; the architecture described here is the money-transmission and AML side of that boundary, not an assessment of the digital-asset business models themselves. The embedding of BSA/AML reporting duties into state licensure conditions is also relevant to how payment-services supervision is read at the state level, a connection most directly legible to those tracking payment-industry licensing architecture. #### Outlook The practical question through the remainder of 2026 and into 2027 is less whether Louisiana's new licensing conditions will be enforced as written, since they are now live, and more whether the federal-preemption trigger embedded in Act 923 will ever be activated. That depends entirely on whether Congress or a federal regulator advances a licensure regime for virtual-currency business activity, a development that remains speculative as. Louisiana's statute is drafted to yield automatically if that happens; until it does, both enactments stand as the operative state regime, with the Money Transmission Act's AML-reporting conditions already in force and the virtual-currency provisions continuing on an indefinite footing following the sunset repeal. 18 Oct 2026 · fim-2026-10-18 #### Lead Signal Louisiana has replaced its 1966 Sale of Checks and Money Transmission Act with the Louisiana Money Transmission Act (Act 888/HB1230), effective 1 July 2026 and administered by the Office of Financial Institutions through the Nationwide Multistate Licensing System. Licensees must file reports required under the Bank Secrecy Act and other anti-money-laundering laws, retain books, records and accounts for at least five years, and are subject to possible multistate examinations coordinated through the Conference of State Bank Supervisors and the Money Transmitter Regulators Association. The new regime adopts the CSBS Model Money Transmission Modernization Act, aligning Louisiana with the majority multistate supervisory framework rather than creating a divergent state-specific architecture, a convergence signal rather than an enabler-jurisdiction gap. #### Other Developments Louisiana's Virtual Currency Businesses Act sunset repealed. Act 923 (SB163), effective 1 August 2026, repeals the VCBA's previously scheduled 1 July 2027 sunset date and adds a federal-preemption-trigger clause under which VCBA provisions would become void to the extent preempted by a future federal licensure law. This reinforces the standing crypto-adjacent AML and consumer-protection perimeter in Louisiana as durable infrastructure rather than a time-limited pilot. Cambodia governor warns of possible FATF re-listing. National Bank of Cambodia Governor Chea Serey has been reported, in commentary dated 14 October 2026, as warning that Cambodia could face re-listing on the FATF grey list if online-scam-compound conditions do not improve. Cambodia is not currently grey-listed; this is a warning reported in secondary commentary rather than a primary National Bank of Cambodia or FATF statement, and no primary source for the warning itself was retrieved this cycle. Laos remains on the FATF grey list. Laos (Lao PDR) remains listed among FATF's Jurisdictions under Increased Monitoring per the last confirmed plenary outcome of 19 June 2026; no delisting or further listing change was located this cycle, and no direct FATF plenary statement for an October 2026 session was retrieved, the evidence for continued listing resting on a secondary aggregator. #### Cross-Monitor Connections The Louisiana Money Transmission Act and VCBA sunset repeal are also tracked by the World Payments Monitor under its licensing and stablecoin/digital-money lenses, and by the Crypto Monitor under its crypto-licensing module; all three readings concern the same underlying Louisiana legislative developments viewed through different structural lenses. The Cambodia warning sits adjacent to gambling-sector enforcement questions that Advennt's enabler-jurisdiction framing may separately track where online-scam-compound activity intersects regulated gaming. #### Outlook For Louisiana, the near-term question is how OFI's new examination and BSA/AML recordkeeping authority under the Money Transmission Act will be exercised in practice, including the frequency of multistate examinations coordinated through CSBS/MTRA; no independently-verified statutory pinpoint beyond the核心 recordkeeping provision was retrieved this cycle for the Act's full BSA/AML obligation set. For Cambodia, whether the governor's warning translates into a formal FATF review is the development to watch; for Laos, the next scheduled FATF plenary will determine whether the grey-list status persists. 11 Oct 2026 · fim-2026-10-11 #### Lead Signal Louisiana has moved on two fronts that together tighten the states financial-integrity architecture without producing a single headline enforcement action. Act 923 (SB 163), effective 1 August 2026, repeals the 1 July 2027 sunset date that had been written into the Virtual Currency Businesses Act (VCBA), and adds a clause under which the VCBA licensing regime will become void to the extent a future federal virtual-currency licensure law preempts it. Read together with a companion kiosk-reporting measure, the effect is to convert what had been a time-limited state experiment in crypto licensing into a standing supervisory architecture, while simultaneously building in a mechanism for an orderly handover should Washington ever occupy the field. Alongside this, Louisiana has replaced its 1966 Sale of Checks and Money Transmission Act with a new Money Transmission Act (HB 1230), signed 9 June 2026 and effective 1 July 2026, built on the Conference of State Bank Supervisors Model Money Transmission Modernization Act. The new statute codifies explicit BSA/AML recordkeeping and reporting duties for licensees, alongside quarterly call reports and annual audited financial statements to the Office of Financial Institutions (OFI). Neither development is an enforcement story; both are architecture stories, and the AML-adjacent tightening around money transmission sits usefully alongside the crypto-licensing permanence created by the VCBA sunset repeal. #### Other Developments Virtual-currency kiosk reporting. A companion measure tightens disclosure and reporting duties on virtual-currency-kiosk operators, adding quarterly cancellation/refund reporting and daily transaction-limit disclosure obligations, both effective 1 August 2026 alongside the VCBA sunset repeal. Transitional treatment for incumbent money-transmission licensees. Existing licensees under the old Sale of Checks and Money Transmission Act are not required to meet the new Acts potentially conflicting requirements until license renewal or twelve months from the 1 July 2026 effective date, whichever is later, giving OFI and the roughly 160 affected firms a phased glide path into the new prudential and BSA/AML standards. #### Cross-Monitor Connections The crypto-licensing permanence created by the VCBA sunset repeal is the same underlying fact set that the crypto monitor tracks as a licensing-regime development, and the kiosk-reporting tightening touches consumer-facing conduct obligations that monitor also covers from its own angle; this brief treats both strictly as financial-integrity architecture, foregrounding the AML/CTF and crypto-integrity reading rather than the consumer-protection framing. Similarly, the new Money Transmission Acts BSA/AML recordkeeping duties bear directly on the payments regulatory perimeter that the world-payments monitor tracks for the same instrument; the two monitors are describing the same legislative act from different vantage points, and neither supersedes the other. #### Outlook The transitional window built into the Money Transmission Act runs into 2027, with existing licensees required to reach full compliance by the later of license renewal or twelve months post-effective date, a horizon that falls in Q3 2027 as currently scheduled. Over that period, the practical test will be whether OFI issues implementing guidance that clarifies which net-worth, bonding, and audited-financial-statement standards apply to which cohort of licensees, and whether the VCBAs newly permanent status attracts additional virtual-currency licence applicants now that the prior sunset-driven uncertainty has been removed. No sanctions, beneficial-ownership, or enforcement development was identified for Louisiana this cycle; the signal here is structural tightening of licensing and recordkeeping architecture, consistent with the states mixed enforcement-versus-enablement posture. 28 Sep 2026 · fim-2026-09-28 #### Lead Signal Louisiana's 2026 Regular Session produced two structural moves that together modernise and entrench the state's money-services-business regulatory perimeter. Act 888 (HB 1230), signed June 9, 2026 and effective July 1, 2026, repeals and reenacts Title 6, Chapter 13 in its entirety, replacing the legacy 1966 Sale of Checks and Money Transmission Act with a framework largely adopting the CSBS Model Money Transmission Modernization Act. Existing licensees transition to the new regime at renewal or twelve months from the effective date, whichever is later. In parallel, Act 923 (SB 163) repeals the July 1, 2027 sunset previously placed on Louisiana's Virtual Currency Businesses Act, providing instead that the VCBA is preempted only upon the effective date of any future federal law governing licensure of virtual-currency business activity. The Office of Financial Institutions currently supervises roughly 36 VCBA licensees. #### Other Developments Kiosk-rule amendments to the VCBA arrived via Act 482, effective August 1, 2026, building on 2025's Act 369 kiosk-safeguard provisions; this development is sourced via a T4 aggregator, and the primary enrolled text was not directly retrieved this pass. FinCEN's fiscal fuel-theft alert describes huachicol schemes exploiting the US-Mexico energy trading relationship to generate illicit proceeds for cartels at the expense of Pemex and legitimate energy firms; this is a bounded, episodic advisory rather than a standing structural change, though it continues a pattern of 2025-2026 advisories targeting cartel-linked trade-based laundering channels distinct from narcotics revenue. FATF's grey-list update from the 19 June 2026 Plenary added Bosnia and Herzegovina and Iraq while removing Algeria and Namibia from the list of Jurisdictions under Increased Monitoring; this finding is probable rather than confirmed, sourced from T3 summary reporting not independently cross-checked against FATF's own primary publication this cycle. #### Cross-Monitor Connections The Money Transmission Act's adoption of NMLS-integrated licensing intersects directly with World Payments Monitor's W1a (Licensing, Authorisation & Market Access) tracking of the same instrument, since the statute governs the licensing perimeter for payment companies operating in Louisiana. The VCBA sunset repeal similarly intersects with the crypto monitor's crypto_licensing module, as both trackers are following the same underlying entrenchment of Louisiana's bespoke state-level virtual-currency licensing regime. The FinCEN fiscal fuel-theft alert connects to conflict-finance and commodity-flow tracking relevant to ERM-style monitors, given its focus on a cartel-exploited energy-trading corridor rather than a purely domestic AML finding. #### Outlook The most consequential near-term marker is the Money Transmission Act's transition window, which closes for existing licensees at renewal or twelve months from the July 1, 2026 effective date, whichever is later, meaning full market conformance may not be reached until as late as mid-2027 depending on individual licensees' renewal cycles. On the crypto-licensing side, the VCBA's durability is now tied structurally to the absence of a federal preemption law, so any future federal virtual-currency licensing statute becomes the single trigger to watch for a change in Louisiana's state-level supervisory perimeter. 22 Sep 2026 · fim-2026-08-21 #### Lead Signal Louisiana has enacted a comprehensive money transmission licensing regime, the Louisiana Money Transmission Act (House Bill 1230, enacted as Act 888), effective July 1, 2026, replacing the state's legacy Sale of Checks and Money Transmission Act. The Act adopts the Conference of State Bank Supervisors' Model Money Transmission Modernization Act, mandating NMLS-based licensing, annual license renewal with a nonrefundable fee of up to six thousand dollars, quarterly call reports, five-year recordkeeping, Bank Secrecy Act and anti-money-laundering filing duties, financial-responsibility requirements including tangible net worth and surety bonds, and automatic license-revocation triggers. This is a structural improvement to Louisiana's AML/CTF architecture rather than an incident-driven response: the Act closes a definitional gap by defining money transmission broadly to include selling or issuing payment instruments or stored value, or receiving money or monetary value for transmission, from a person located in Louisiana, closing gaps that previously created enabler risk for unlicensed transmitters operating in or through the state. The structural reading matters more than any single enforcement incident: Louisiana's shift from a legacy statute to a CSBS-aligned modern licensing framework is a jurisdiction voluntarily raising its own money-transmission architecture to match the multistate standard, rather than reacting to a discovered failure. The financial-responsibility requirements, combined with automatic license-revocation triggers, give the regime built-in resilience mechanisms that a purely reactive, enforcement-only posture would lack. #### Other Developments FATF increased monitoring update. FATF's June 2026 update newly identifies Bosnia and Herzegovina and Iraq under increased monitoring. Lao PDR remains listed among jurisdictions whose AML/CFT progress FATF has reviewed since February 2026, under increased monitoring, and Cambodia remains a relevant watch jurisdiction in this fleet's standing tracker architecture. Cambodia's persistent enabler-risk profile. Despite Cambodia's February 2023 exit from the FATF grey list, weaknesses remain with fit-and-proper tests of casinos, lawyers, and accountants. OFAC and FinCEN took unilateral action against the Prince Group transnational criminal organization and the Huione Group in October 2025, indicating that Cambodia's casino and remittance-sector AML supervisory gaps continue to require unilateral rather than multilateral remediation pressure, notwithstanding the formal grey-list exit. Three-pillar balance note. Neither this cycle's Louisiana development nor the FATF and Cambodia items carry a distinct counter-terrorist-financing or counter-proliferation-financing finding; the visible signal is concentrated in the AML pillar, consistent with the broader pattern in which AML enforcement volume structurally outweighs CTF/CPF signal, a bias this brief flags rather than corrects for by inventing balance. #### Cross-Monitor Connections The Louisiana Money Transmission Act's BSA/AML filing duties and recordkeeping obligations are directly relevant to the World Payments Monitor's correspondent-banking and market-access tracking, where the same automatic-revocation and reporting mechanics carry settlement-access implications for licensed non-bank money transmitters. Cambodia's casino-sector supervisory gaps, and the unilateral OFAC/FinCEN enforcement architecture built around Prince Group and Huione Group, connect to conflict-finance and state-capture reasoning tracked elsewhere in this fleet, given the scale of cyber-scam-compound financial flows reportedly running through the affected networks. This is architecture-over-incident: both developments represent standing frameworks rather than one-off actions, and should be read by adjacent monitors as structural inputs rather than episodic alerts. #### Outlook Existing Louisiana money-transmission licensees are not immediately bound by the new regime: they retain the legacy framework until their license renewal date or twelve months after the law's effective date, whichever is earlier, creating a transitional compliance gap running into the third quarter of 2027. Watch for the Office of Financial Institutions' implementing-rule text on NMLS transition mechanics, which was not retrieved this cycle, and for further FATF listing movement given the June 2026 update's new additions of Bosnia and Herzegovina and Iraq alongside Lao PDR's continued increased-monitoring status. The next cycle's highest-value confirmation would be primary-source retrieval of the Office of Financial Institutions' own implementing guidance, alongside continued tracking of whether Bosnia and Herzegovina's and Iraq's new FATF listings produce any downstream correspondent-de-risking signal relevant to US financial institutions with exposure to those markets. 11 Aug 2026 · fim-2026-08-05 #### Lead Signal The clearest signal this cycle is a bifurcation in United States financial-integrity architecture: beneficial-ownership transparency is retreating even as supervisory-technology expectations and offshore enforcement intensify. A March 2025 interim final rule issued by FinCEN removed the Corporate Transparency Act beneficial-ownership-information reporting requirement for domestic reporting companies, and a Government Accountability Office review published in May 2026 finds that more than 99 percent of entities previously required to report beneficial ownership are now exempt. This is an Assessed-confidence finding, since the underlying GAO report is relied upon second-hand rather than retrieved directly, but the direction of travel is unambiguous. It sits alongside, not in place of, a parallel intensification of enforcement and supervisory-technology expectations elsewhere in the same architecture: the Federal Reserve, FDIC, and OCC jointly rescinded SR 11-7, OCC 2011-12, and FIL-22-2017 via SR 26-2, effective April 17, 2026, replacing a decade-old model-risk-management framework with an explicitly risk-based, principles-driven standard intended to incentivize AI and machine-learning adoption in AML transaction monitoring. Read together, the domestic transparency floor is falling just as the technology and offshore-enforcement floors are being raised, a divergence that obliged entities and their supervisors will need to reconcile. #### Other Developments Mexico cartel-finance enforcement intensified on multiple fronts. FinCEN expanded its Southwest Border Geographic Targeting Order and issued a supplemental fuel-smuggling alert tied to cartel financing, and separately identified ten Mexico-based gambling establishments as a class of transactions of primary money-laundering concern under a Section 311 finding, proposing to sever their access to the United States financial system over ties to Sinaloa Cartel financing. Mexican financial institutions CIBanco, Intercam, and Vector remain under special-measure wind-down obligations tied to the FEND Off Fentanyl Act. The Sudan gold trade came under new EU sectoral sanctions. The EU Council adopted sanctions banning the purchase, import, and transfer of Sudan-origin gold and the export of mercury and cyanide to Sudan, targeting financing for both factions in the conflict economy of Sudan. Southeast Asian casino-linked laundering infrastructure remains structurally entrenched. The Governor of the National Bank of Cambodia publicly warned of grey-list re-listing risk tied to casino and scam-center anti-money-laundering gaps, following the arrest and extradition of the Prince Group chairman, while the Golden Triangle Special Economic Zone in Laos, in which the Lao state holds a 20 percent equity stake, remains an entrenched laundering hub despite 2018 Magnitsky sanctions on the Zhao Wei-linked operator of the zone. Colombia was designated a major narco-trafficking country under the FY2026 FRAA review , the first such United States finding in nearly thirty years amid record coca cultivation, notably diverging from the continued absence of Colombia from the FATF grey list, a split between unilateral US and multilateral FATF risk assessment that is itself analytically significant. The June 2026 FATF Plenary added Iraq and Bosnia and Herzegovina to the grey list and removed Algeria and Namibia , leaving the grey list at 22 jurisdictions; the black list of Iran, North Korea, and Myanmar is unchanged. The MiCA transitional period closed on July 1, 2026 , requiring unlicensed crypto-asset service providers to cease serving EU clients and automatically converting authorised CASPs into full AML-obliged entities, even as dominant USD stablecoins remain outside the MiCA perimeter. #### Cross-Monitor Connections The Mexico gambling-establishment Section 311 finding and the Golden Triangle Special Economic Zone entry in Laos both connect directly to state-capture and conflict-adjacent gambling infrastructure themes that a payments or gambling-sector monitor would track from the demand side of the same flows this monitor tracks from the supply side. The Sudan gold-sanctions action is a conflict-finance and extractive-industry integrity signal that a commodity-flows monitor would read as a supply-chain sanctions-compliance event rather than a purely financial-integrity one. The SR 26-2 model-risk overhaul is a compliance-technology signal with direct relevance to any monitor tracking AI and machine-learning governance obligations in regulated financial services, since it resets the supervisory baseline against which AI-driven transaction-monitoring systems will be assessed going forward. #### Outlook The domestic United States beneficial-ownership gap and the SR 26-2 supervisory-technology reset are the two developments most likely to define the next several cycles of United States financial-integrity architecture, particularly as a proposed FinCEN AML program-effectiveness rule, whose comment period closed June 9, 2026, with a proposed twelve-month implementation window post-finalization, moves toward finalization and interacts with both. Internationally, watch whether the public re-listing warning from Cambodia translates into a third FATF grey-list placement, and whether the AMLA build-out in Frankfurt, expected to publish its first work programme in the fourth quarter of 2026, begins to close the per-Member-State transposition gaps that remain unquantified in the EU AML Package this cycle. 14 Jul 2026 · fim-2026-07-14 #### Lead Signal Louisiana Gulf Coast refining and port infrastructure remains the point of maximum friction between the United States and European Union sanctions architectures on Russian-origin refined petroleum. Russian crude refined in India or Turkey continues to lose its Russian-origin classification once it is substantially transformed into gasoline, diesel, or naphtha, allowing cargoes to legally discharge at Louisiana, New York, and Houston ports under a customs-classification loophole rather than a security gap. The European Union closed its equivalent loophole under Article 3ma of Regulation 833/2014 on 21 January 2026; the United States has not followed. This divergence persists even after the Office of Foreign Assets Control designated Rosneft PJSC and Lukoil PJSC on the Specially Designated Nationals list, a designation effective 22 October 2025 rather than 21 November 2025 as earlier reported, with the later date instead marking the expiry of a wind-down general licence. A second structural thread is stacking beneficial-ownership opacity. A FinCEN interim final rule dated March 2025 exempted all United States-formed entities and their beneficial owners from Corporate Transparency Act reporting, removing the principal federal ownership-disclosure tool for the Louisiana-formed limited liability companies used across oil and gas, maritime, and real-estate asset holding. A second mitigant that might have partially offset that rollback, the Nationwide Residential Real Estate Rule, was vacated by the United States District Court for the Eastern District of Texas on 19 March 2026; reporting persons in the affected real-estate sector are not currently required to file Real Estate Reports, and Louisiana has no independent state-level beneficial-ownership registry to fall back on. Together these two developments reopen and widen the gap the residential real-estate rule was designed to close, pending an appeal by FinCEN. #### Other Developments A formalised information-sharing channel between the Office of Foreign Assets Control and the Louisiana Office of Financial Institutions became effective 1 April 2025, covering state-chartered banking organisations under Title 6 of the Louisiana Revised Statutes. This is a supervisory-coordination data point rather than an architectural finding in itself, but it establishes a standing bilateral channel for sanctions-compliance information relevant to Louisiana state-chartered banks. Trade-corridor money laundering tied to Chinese networks was the subject of a FinCEN advisory and financial trend analysis issued 28 August 2025, identifying 312 billion dollars in suspicious Bank Secrecy Act-reported activity nationwide across the 2020-2024 period. The advisory implicates Gulf Coast trade corridors as transit points where cartel narcotics cash is placed into the banking system, mirrored through trade-based transactions, and repatriated to China through methods including the growing use of the stablecoin USDT. A forthcoming federal AML and sanctions regime for stablecoin issuers is under consultation. FinCEN and OFAC issued a joint notice of proposed rulemaking in April 2026 that would impose Bank Secrecy Act programme and sanctions-compliance obligations on permitted payment stablecoin issuers, with finalisation expected in the fourth quarter of 2026. This would close a current supervisory gap for any Louisiana-domiciled fintech or payments entity issuing payment stablecoins, a gap presently exploited in the crypto leg of the Chinese money-laundering-network typology described above. A clean compliance-trajectory baseline persists at the national level. The United States remains off both the FATF increased-monitoring list and the high-risk call-for-action list through the 2025 plenary cycle, in which the British Virgin Islands and Bolivia were added and Croatia, Mali, and Tanzania were removed, and Laos and Nepal were added while the Philippines was removed. Louisiana inherits this clean national status; there is no sub-national listing mechanism through which a state could diverge from it. Price-cap maritime-transport mechanics were refined through OFAC General License 124A, issued 22 October 2025, which updated authorised covered services for the transport of price-cap-compliant Russian crude and petroleum products. This mechanic is directly relevant to Gulf Coast refiners and shippers and illustrates a structural difference from the fuller European Union import-ban approach, a divergence that creates persistent compliance friction for Louisiana-linked maritime and trade-finance actors. #### Cross-Monitor Connections The Gulf Coast discharge points for refined Russian-origin petroleum are a shared data point with the Extractive-Resource Monitor commodity-flow and dark-fleet tracking, since the substantial-transformation loophole and the European Union and United States regulatory divergence on it bear directly on assessment of shadow-fleet and refined-product flows. The corrected Rosneft and Lukoil designation date, and the resulting volume of Russian crude reported stranded at sea, is likewise a macro sanctions variable relevant to the Global Macro Monitor tracking of global oil flows. The Louisiana Gulf Coast refining and port sector sits structurally at the intersection of both monitors: a single cargo passing through third-country transformation and Gulf Coast discharge is simultaneously a sanctions-architecture data point for this monitor, a commodity-flow data point for the Extractive-Resource Monitor, and a macro sanctions-transmission data point for the Global Macro Monitor. #### Outlook The near-term trajectory for Louisiana across both the sanctions-architecture and beneficial-ownership domains is one of structural deterioration rather than acute incident. On the sanctions side, the analytically significant watch points are any Treasury or Commerce move to close the substantial-transformation loophole for refined petroleum products, and any further OFAC designations affecting Gulf Coast-linked trading houses; absent either, the divergence identified this cycle is likely to persist and could widen further. On the beneficial-ownership side, the outcome and timeline of the FinCEN appeal of the Eastern District of Texas vacatur is the single largest near-term variable, since it determines whether Louisiana parishes gain, for the first time, the real-estate-adjacent ownership disclosure the Nationwide Residential Real Estate Rule was designed to provide. No legislative reversal of the Corporate Transparency Act domestic-entity exemption, and no Louisiana state-level beneficial-ownership legislation, has been identified as pending. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion Louisiana Gulf Coast refining and port infrastructure sits at the point of maximum structural friction in the current Russian sanctions regime. The mechanism is not a compliance failure at any individual bank or shipper; it is a customs-classification architecture. Russian crude refined in India or Turkey loses its Russian-origin classification once it undergoes substantial transformation into gasoline, diesel, or naphtha, and the resulting refined product can then legally discharge at United States ports, including Louisiana facilities alongside New York and Houston, without triggering the Russian-fossil-fuel import ban. Investigative reporting corroborated at Tier 2, alongside Tier 1 OFAC price-cap alert material, indicates that major commodity trading houses including Trafigura, Vitol, and Gunvor have purchased cargoes discharging at these ports. This is the architecture-over-incident case in its clearest form for Louisiana this cycle: any single cargo discharge is a minor data point, but the persistence of the customs-classification loophole across an entire refining-and-shipping value chain is the analytically significant structural finding. Continue reading That finding takes on added weight because of a widening regulatory divergence. The European Union closed its equivalent loophole under Article 3ma of Regulation 833/2014 on 21 January 2026, banning imports of refined petroleum products derived from Russian-origin crude regardless of where the transformation occurred. The United States has not enacted an equivalent closure. Where the two regimes previously shared a common blind spot, the European Union has now moved and the United States structural gap persists, newly widening the specific divergence that affects Louisiana port exposure. This is a regime-divergence signal under the enabler-jurisdiction and sanctions-architecture filters: the United States is not the only actor with enforcement discretion here, but it is currently the outlier in leaving the mechanism open. Enforcement mechanics moved in this cycle as well, and it matters that they are read as mechanics rather than as the primary architectural signal. OFAC designated Rosneft PJSC and Lukoil PJSC on the Specially Designated Nationals list effective 22 October 2025. A wind-down general licence tied to that designation expired 21 November 2025; earlier reporting had conflated the wind-down deadline with the designation date itself, and the corrected record shows the designation preceded the wind-down expiry by close to a month. Approximately 48 million barrels of Russian crude were left stranded at sea as counterparties worked through the wind-down period. Alongside the designation, OFAC issued General License 124A on 22 October 2025, refining the authorised covered services for maritime transport of price-cap-compliant Russian crude and petroleum products. This general licence mechanic is directly relevant to Gulf Coast refiners and shippers, and it illustrates a structural difference between the United States price-cap-coalition model and the European Union fuller import-ban model; the two approaches diverge in kind, not just in timing, and that divergence is a persistent source of compliance friction for Louisiana-linked trade-finance and correspondent-banking exposure. Read through the three-pillar lens, this cycle Louisiana sanctions-architecture picture is heavily weighted toward the counter-proliferation dimension that AML enforcement volume tends to crowd out in headline reporting. The Rosneft and Lukoil designations generate SDN-list enforcement volume that is easy to report; the substantial-transformation loophole generates no enforcement volume at all, because nothing about the discharge of refined product at a Gulf Coast port is, on its face, unlawful. That asymmetry is itself the signal: an absence of enforcement action against Gulf Coast refiners and shippers receiving refined Russian-origin product is not evidence of clean flows, it is evidence that the loophole is functioning as designed at the customs-classification level, defeating the sanctions strategic intent while remaining legal. A final piece of this cycle architecture is coordination infrastructure rather than substantive policy change. OFAC and the Louisiana Office of Financial Institutions formalised a sanctions-compliance information-sharing memorandum of understanding, effective 1 April 2025, covering state-chartered banking organisations under Title 6 of the Louisiana Revised Statutes. This is a standing supervisory channel, not itself an architectural finding, but it is the mechanism through which any future tightening of the substantial-transformation loophole, or any future designation affecting Gulf Coast-linked entities, would be expected to reach Louisiana state-chartered banks in the first instance. #### Outlook The single most analytically significant watch point for Louisiana sanctions-architecture exposure is whether Treasury or Commerce moves to close the substantial-transformation loophole for refined petroleum products, either unilaterally or in coordination with the European Union. Absent such a move, the divergence identified this cycle is structural rather than transitional and should be expected to persist. A secondary watch point is further OFAC designation activity affecting Gulf Coast-linked trading houses beyond Rosneft and Lukoil; the correction of the designation date this cycle underscores the importance of precise sequencing when assessing wind-down exposure and stranded-cargo risk. No coordinated United States, European Union, or United Kingdom move to redefine substantial transformation for refined petroleum products has been identified as pending. Judgment: No Louisiana-specific sanctions signal identified this cycle; single-JID scope did not extend to federal/OFAC channels. Uncertain #### Beneficial Ownership and Corporate Transparency Louisiana sits outside the European Union AML Package perimeter entirely: the state is a subdivision of the United States, and the AML Regulation, the sixth Anti-Money Laundering Directive, and the AMLA Regulation attach to European Economic Area member states, not to United States jurisdictions. The developments directly relevant to Louisiana beneficial-ownership exposure this cycle are domestic federal ones, and they move in the opposite direction from the European Union trajectory. Louisiana has no independent state-level beneficial-ownership registry: entity formation runs through the Louisiana Secretary of State with no ownership-disclosure requirement attached, so state-level transparency has always depended entirely on the federal regime layered on top of it. That federal regime narrowed substantially in March 2025, when a FinCEN interim final rule exempted all United States-formed entities, and their beneficial owners, from Corporate Transparency Act reporting; the rule preserved obligations only for foreign-formed entities registered to do business in states including Louisiana. The effect for Louisiana-formed limited liability companies used across the oil and gas, maritime, and real-estate sectors is that ownership is now effectively unverifiable absent a criminal subpoena. Continue reading A second, more recent development compounds the first. The Nationwide Residential Real Estate Rule, which would have extended non-financed residential real-estate reporting to Louisiana parishes for the first time from an expected March 2026 go-live, was vacated by the United States District Court for the Eastern District of Texas on 19 March 2026. Reporting persons in the affected real-estate sector are not currently required to file Real Estate Reports with FinCEN. FinCEN has appealed, but the rule is not currently in effect, which means the multi-year gap left by the historical exclusion of Louisiana from FinCEN residential real-estate Geographic Targeting Orders, previously expected to see partial remediation this year, remains open. The two developments stack: the entity-level disclosure tool and the real-estate-level disclosure tool were both narrowed or reversed within roughly twelve months of each other, and neither Louisiana nor the federal government currently has an alternative mechanism in place to substitute for either. The active-scheme register for this cycle names Louisiana LLC beneficial-ownership opacity explicitly, at an elevated preliminary severity rating, with the observable red flag being single-purpose LLCs formed for oil and gas or real-estate asset holding with no beneficial-owner disclosure obligation following the domestic-entity exemption. That indicator is most visible at onboarding, when a corporate customer typology presents no beneficial-owner information because none is legally required, rather than because verification failed; the distinction matters for how the gap should be read operationally within the institutions exposed to it. Globally, the European Union AML Package sets the structural direction against which this domestic picture should be read, even though it does not apply to Louisiana directly. The package is properly understood as three distinct instruments rather than one: the AML Regulation, directly applicable across European Economic Area member states without transposition; the sixth Anti-Money Laundering Directive, transposed individually by each member state; and the AMLA Regulation, which establishes the Anti-Money Laundering Authority and shifts supervision of a defined set of high-risk, cross-border obliged entities from purely national authorities toward a hybrid European Union-level regime through a direct and indirect supervision perimeter. That architecture is a durable structural fact, not a single-cycle development, and it stands as the backdrop against which the Louisiana rollback reads as a genuine divergence rather than a shared global trend: the European Union is centralising and layering beneficial-ownership-adjacent supervision upward, while the United States federal regime relevant to Louisiana is narrowing the population of entities subject to ownership disclosure at all. One structural constant frames both pictures. The United States remains off both FATF increased-monitoring and high-risk call-for-action lists through the 2025 plenary cycle, and Louisiana inherits this clean national status with no sub-national listing mechanism through which a state could diverge from it. The country-level compliance trajectory therefore gives no early-warning signal of the state-level opacity increase described above; the FATF list mechanism operates at a level of resolution that does not capture sub-national stacking of this kind. #### Outlook The single largest near-term variable for Louisiana beneficial-ownership exposure is the outcome and timeline of the FinCEN appeal of the Eastern District of Texas vacatur, which has not yet been established. A successful appeal, or a narrower successor rule, would restore some measure of the real-estate-adjacent disclosure that was expected to reach Louisiana parishes for the first time this year; an unsuccessful appeal would leave the gap permanently open absent new legislation. No legislative reversal of the Corporate Transparency Act domestic-entity exemption, and no Louisiana state-level beneficial-ownership registry proposal, has been identified as pending, which means the entity-level half of the stacked gap currently has no visible near-term remediation path at all. Judgment: No Louisiana-specific beneficial-ownership registry development identified; federal CTA status not re-examined under single-JID scope. Uncertain #### Enabler Jurisdictions and Professional Facilitators The professional-facilitator picture for Louisiana this cycle centres on a single but substantial finding: a FinCEN advisory and financial trend analysis on Chinese money-laundering networks, issued 28 August 2025, which identifies 312 billion dollars in suspicious Bank Secrecy Act-reported activity nationwide across the 2020-2024 period and explicitly implicates Gulf Coast trade corridors as transit points within the laundering cycle. The typology described is not Louisiana-specific in origin, but Louisiana Gulf Coast port and logistics infrastructure functions as one of the enabling channels through which the network operates, which is precisely the enabler-jurisdiction filter test: does existing infrastructure facilitate a flow that originates and terminates elsewhere. The advisory describes a three-stage architecture: placement of Mexican cartel narcotics cash into the United States banking system, layering through trade-based mirror transactions routed through Gulf Coast trade-goods shipments, and repatriation of value to China exploiting Chinese capital controls, increasingly through the stablecoin USDT rather than traditional correspondent-banking rails. Continue reading Read architecturally rather than episodically, the significance of this finding for Louisiana is that it identifies port and logistics infrastructure, not any named Louisiana entity or institution, as the facilitating layer. This is consistent with the architecture-over-incident principle: no enforcement action against a Louisiana-based facilitator has been identified this cycle, and the absence of such action is itself worth noting rather than treated as evidence of a clean corridor. The FinCEN advisory is a federal-level typology document rather than a state-specific enforcement record, and Louisiana financial institutions, together with those in other Gulf Coast states, are the intended audience for the red-flag indicators it sets out, most notably high-volume trade-goods shipments through port corridors mirroring trade-based money-laundering settlement patterns, and placement of narcotics cash followed by mirror transactions and USDT-based repatriation. Applying the enabler-jurisdiction filter four-dimension test to Louisiana Gulf Coast port infrastructure in this context, the relevant questions are less about legal framework, since federal Bank Secrecy Act examination authority already covers Louisiana financial institutions and money-service businesses operating there, and more about enforcement intensity, and about whether the facilitation is a matter of capacity constraint or of choice. On the present record, nothing indicates that Louisiana authorities or Louisiana-based institutions are declining to act; the gap identified is a national one in typology visibility and enforcement reporting, of which Louisiana Gulf Coast infrastructure is simply a named component. The systemic significance of the corridor is nonetheless real: Gulf Coast trade-goods volume gives the mirror-transaction layering stage of the typology a plausible, high-volume, legitimate-looking cover, which is the same property that makes port and logistics infrastructure attractive to trade-based launderers more generally. The professional-facilitator dimension proper, meaning identified lawyers, accountants, company-formation agents, or trust and company service providers operating in or through Louisiana, has not generated a distinct finding this cycle beyond the structural beneficial-ownership opacity already discussed under the corporate-transparency domain. The absence of such a finding should not be read as an absence of facilitator risk; it is more likely a reflection of the collection gap noted this cycle in Louisiana-specific federal financial-crime prosecution reporting, which remains sparse across the Eastern, Middle, and Western Districts of Louisiana within the review window, limiting confidence in assessing true Louisiana-specific enforcement intensity against the national baseline. For Louisiana financial institutions, the customer-typology exposure implied by this advisory spans money-service businesses, trade-finance desks, and correspondent-banking relationships, the same three categories flagged in the underlying evidence base for this finding. Money-service businesses operating in or through Louisiana Gulf Coast metropolitan areas sit closest to the placement stage of the typology; trade-finance and correspondent-banking relationships tied to Gulf Coast import-export activity sit closer to the layering and mirror-transaction stage. Neither exposure is unique to Louisiana, but the concentration of port and logistics infrastructure in the Gulf Coast corridor makes the exposure more concentrated there than in inland jurisdictions with comparable population and banking-sector size. #### Outlook The most direct near-term watch point is whether any Gulf Coast-specific enforcement action, prosecution, or supervisory finding emerges that names a Louisiana-based or Louisiana-transiting facilitator within the Chinese money-laundering-network typology described this cycle; none has been identified to date. A second watch point is whether the crypto leg of that typology, specifically USDT-based repatriation, intersects with the forthcoming GENIUS Act stablecoin AML and sanctions rule discussed under the digital-assets domain, since that rule would for the first time impose federal AML obligations directly on the payment stablecoin issuers whose products are implicated in the repatriation stage of the network. Judgment: Louisiana's adoption of the multistate Model Money Transmission Modernization Act reduces rather than expands regulatory-arbitrage space for money transmission. Probable #### Conflict Finance and Extractive-Industry Integrity Read through the conflict-finance filter, the substantial-transformation loophole discussed under the sanctions-architecture domain is not only a customs-classification gap; it is an active channel of continued revenue to the Russian war economy. Major commodity trading houses, including Trafigura, Vitol, and Gunvor, have purchased cargoes of petroleum refined from Russian-origin crude in India or Turkey and discharged them at United States Gulf Coast ports, including Louisiana facilities, generating continued oil-revenue transmission to the Kremlin notwithstanding the nominal United States import ban on Russian fossil fuels. The tracing exercise the conflict-finance filter requires, source, channel, and deployment, maps cleanly here: the source is Russian crude extraction, the channel is third-country refining followed by Gulf Coast discharge legitimised by the substantial-transformation customs rule, and the deployment is Russian state and war-economy revenue, sanctions notwithstanding. Continue reading The persistence of this channel despite the October 2025 Rosneft and Lukoil designations is itself the analytically significant point. Designating the two dominant Russian oil majors on the Specially Designated Nationals list is an incident-level action against named entities; it does not, on the present record, close the customs-classification mechanism through which non-designated intermediaries in India and Turkey can continue to refine and re-export Russian-origin crude in a form that no longer carries Russian-origin classification. The European Union move to close its equivalent loophole on 21 January 2026 is the clearest evidence available this cycle that the mechanism is understood, internationally, as closeable; the persistence of the open United States version of the same mechanism, discharging in part at Louisiana ports, is a choice rather than a capacity constraint, at least at the level of legal authority available to Treasury and Commerce. The active-scheme register names this channel explicitly, rating it at a high preliminary severity with active current status, and sets out a single primary red flag indicator observable in trade documentation: refined petroleum cargoes re-classified as non-Russian-origin after third-country processing, discharging at Gulf Coast ports. That indicator is, by construction, difficult for a trade-finance desk to escalate on documentary grounds alone, since the re-classification is the legally operative fact under current customs rules rather than a documentary anomaly; the indicator functions more as a flag for enhanced due diligence on counterparty and vessel history than as a basis for a suspicious-activity filing in isolation. The jurisdiction risk tracker for Louisiana characterises this posture as mixed between enforcement and enablement rather than purely one or the other: enforcement activity is real and visible at the designation level, while enablement is structural and largely invisible at the level of individual transactions, since nothing about a Gulf Coast refined-product discharge is, on its face, unlawful. That mixed characterisation is the appropriate one for a conflict-finance channel that operates through a legal loophole rather than through evasion of a rule that is otherwise being enforced. For Gulf Coast and Louisiana-specific extractive-industry integrity purposes, the relevant customer typologies are trade-finance and correspondent-banking relationships tied to the refined-product import trade, the same typologies flagged under the sanctions-architecture domain. No Louisiana-specific extractive-industry corruption finding distinct from this sanctions-adjacent oil-revenue channel has been identified this cycle; the Gulf Coast conflict-finance exposure identified here is a downstream financial-flow issue rather than an upstream resource-governance issue of the kind more typically associated with this domain in mineral-extraction contexts elsewhere. The role of Louisiana in this channel is a function of its refining and port capacity rather than of any distinct policy choice by state authorities; the state has no independent authority over customs classification or sanctions administration, both of which sit with federal agencies. This is consistent with the pattern, seen also in the beneficial-ownership domain, of Louisiana state-level exposure being driven almost entirely by federal architecture rather than by state-level decisions. #### Outlook The most consequential near-term development for this domain would be any coordinated United States, European Union, or United Kingdom move to redefine substantial transformation for refined petroleum products, which would close the specific mechanism sustaining continued Russian war-economy oil revenue through Gulf Coast discharge points; no such move has been identified as pending. Absent that, further OFAC designations affecting Gulf Coast-linked trading houses would be the next most significant watch point, since they would attack specific intermediaries within the channel rather than the customs-classification mechanism itself. The structural gap between incident-level designation activity and the architecture-level customs mechanism is likely to persist as the defining feature of this domain for Louisiana through the next several cycles. Judgment: No conflict-finance signal identified for Louisiana this cycle. Uncertain #### Crypto / Digital Assets / Financial Innovation Louisiana's Act 923 (SB163), effective 1 August 2026, makes a structural change to the state's virtual-currency licensing architecture rather than introducing a new enforcement posture toward digital-asset businesses. The amendment repeals the 1 July 2027 sunset date that had previously been written into the Virtual Currency Businesses Act, removing what had been a built-in expiry for the state's bespoke virtual-currency licensing regime. In its place, the amendment adds a forward-looking federal-preemption clause: if a federal law governing the licensure of virtual-currency business activity becomes effective, any Louisiana VCBA provision that conflicts with it becomes null and void from the end of the calendar year in which that federal law takes effect. Continue reading The significance of this pairing is architectural. Rather than simply extending the state regime indefinitely, Louisiana has built an automatic stand-down mechanism tied to a hypothetical future federal licensing framework for virtual-currency business activity. This reads as a deliberate acknowledgment that federal action in this space remains a live possibility, and as an attempt to avoid locking the state into a permanently separate licensing track that would need a future legislative session to unwind if Washington moves first. For virtual-currency business operators licensed in Louisiana, the near-term effect is continuity: the VCBA continues in force with no sunset date now on the books, so existing and prospective licensees should not expect the state regime to lapse on its own. This digital-asset development sits alongside, but is legally distinct from, Louisiana's simultaneous overhaul of its conventional money-transmission statute, which separately embeds Bank Secrecy Act and anti-money-laundering reporting conditions into state money-transmitter licensure. The two enactments were not evidenced here as textually unified, but both reflect a legislative session in which Louisiana revisited the statutory architecture governing money-services and virtual-currency businesses operating in the state, in each case moving toward closer alignment with, or anticipatory deference to, broader multistate or federal frameworks rather than toward a more isolated state-specific regime. #### Outlook The operative question is whether and when a federal licensure framework for virtual-currency business activity materializes, since that is the trigger condition written into Act 923. Until such a federal law is enacted and takes effect, the Louisiana VCBA continues to operate on an indefinite basis following the sunset repeal, with no indication in the material available of any near-term change to its substantive licensing conditions. The preemption clause itself is best read as a contingent structural placeholder: it does not change how virtual-currency businesses are regulated in Louisiana today, but it does pre-commit the state to yielding specific conflicting provisions if federal legislation advances, which is itself a notable signal about how Louisiana's legislature is positioning the state relative to anticipated federal movement in digital-asset licensure. Judgment: Louisiana's VCBA sunset repeal and federal-preemption trigger (Act 923/SB163) is an architecture change affecting how state crypto licensing yields to a future federal licensing/AML framework. Probable #### Compliance Technology and Active Defence Signal in this domain for Louisiana this cycle is limited to a single forward-looking regulatory proposal rather than to any active-defence technology deployment, enforcement action, or supervisory finding specific to Louisiana. FinCEN has proposed a rule to strengthen and modernise financial institutions Anti-Money-Laundering and Countering-the-Financing-of-Terrorism programme requirements, expected to be finalised by the end of 2026, which would require effective, risk-based programmes incorporating government-wide priorities in place of static, reactive Bank Secrecy Act compliance. This would apply to Louisiana-regulated banks and money-service businesses on the same basis as institutions nationwide; no Louisiana-specific implementation detail, pilot, or timeline distinct from the national rulemaking has been identified. Continue reading No compliance-technology deployment, screening-system upgrade, or active-defence initiative specific to Louisiana financial institutions has been identified this cycle, and this absence should be read honestly as a genuine information gap rather than padded into a fuller narrative than the evidence supports. The proposed rule is, at this stage, a national regulatory-horizon item in the consultation-to-proposed stage rather than an operational development, and its risk direction on implementation is assessed as improving. In the interim, Louisiana-regulated institutions remain subject to the existing, largely reactive Bank Secrecy Act compliance-programme standard, and the gap between that standard and the more proactive posture the proposed rule envisages is itself the most concrete near-term compliance-technology signal available for this jurisdiction file. #### Outlook The principal watch point is the finalisation of the FinCEN AML and CFT programme modernisation rule, expected by the end of 2026; finalisation would mark the first substantive compliance-technology-relevant development specific to this domain for Louisiana-regulated institutions since the current review window opened. No other near-term development in this domain has been identified as pending. Judgment: No RegTech/guidance development identified for Louisiana this cycle. Uncertain #### AML/CTF Regime Louisiana's new Money Transmission Act, replacing the former Sale of Checks and Money Transmission Act with a chapter built on the Model Money Transmission Modernization Act, took effect 1 July 2026 and embeds Bank Secrecy Act and anti-money-laundering reporting duties directly into the conditions of state money-transmitter licensure. Licensees must file reports required under the BSA and other anti-money-laundering laws, maintain certain records for at least five years, and submit quarterly call reports. This is best read as a state-licensing variance layered on top of the federal AML baseline rather than as a new federal AML instrument in its own right: the underlying BSA reporting obligation already applies to money transmitters as a matter of federal law, and what has changed is that Louisiana has now made demonstrable compliance with that obligation a condition of holding a state money-transmission licence, giving state examiners a direct supervisory lever over AML compliance that previously sat more exclusively with federal authorities and self-regulatory examination. Continue reading The architectural significance of this move is that it closes a potential gap between state licensure and federal AML expectations. A money transmitter could, in principle, hold a state licence while falling out of compliance with BSA reporting without that lapse being visible to, or actionable by, the state licensing authority under the prior statute. By writing BSA/AML reporting, five-year recordkeeping, and quarterly call reporting into the licence conditions themselves, Louisiana gives its state regulator standing to treat an AML reporting failure as a licensing matter, not solely a federal enforcement matter. This is consistent with the broader national trend toward multistate alignment under the Model Money Transmission Modernization Act framework, which several other states have also adopted, and which is explicitly designed to enable multistate supervisory examinations rather than leave each state's money-transmission AML expectations idiosyncratic. The new statute also sits in relation to Louisiana's separate handling of its virtual-currency licensing regime, where Act 923 removed a sunset date and added a provision under which conflicting state virtual-currency provisions would yield to a future federal virtual-currency licensing law. Taken together, the two enactments describe a state regulatory posture that is simultaneously tightening its own AML-linked licensing conditions for conventional money transmission while explicitly preserving a pathway to defer to federal authority on virtual-currency licensure specifically, should that federal authority materialize. #### Outlook With the Money Transmission Act's AML-linked licensing conditions now in force, the practical focus for licensees is operational: ensuring quarterly call reporting, five-year recordkeeping, and BSA-required filings are demonstrably in place for licence maintenance rather than solely for federal compliance purposes. No enforcement action under the new provisions was identified in the material reviewed. Because the law converges Louisiana toward the national Model Money Transmission Modernization Act baseline, how it is administered by the Louisiana Office of Financial Institutions over coming examination cycles will be a reasonable marker of how multistate AML-linked licensing conditions are applied in practice, though no examination or guidance record beyond the statute and secondary commentary was available this cycle. Judgment: The new Louisiana Money Transmission Act (HB1230/Act888) embeds BSA/AML reporting duties directly into the conditions of state money-transmitter licensure, a state-licensing variance against the federal AML baseline. Probable Judgment: No financial-integrity-sector commercial event with a Louisiana party identified this cycle. Uncertain Regulatory horizon In Force Pending 2027-Q3 · ±half_year ### Louisiana Money Transmission Act transitional compliance deadline Existing money-transmission licensees must meet new net-worth, bonding, audited-financial-statement and BSA/AML recordkeeping standards by the later of license renewal or 12 months post-effective date. [Louisiana Office of Financial Institutions Source](https://www.consumerprotectioninsights.com/2026/07/louisiana-enacts-new-money-transmission-act-largely-adopting-model-money-transmission-modernization-act/) 1 dated · 2 pending date · baseline fim-2026-07-05 Role action cards MLRO ### Louisiana has made Bank Secrecy Act and anti-money-laundering reporting a condition of state money-transmitter licensure rather than a purely parallel federal obligation. Money transmitters licensed in Louisiana now face a state licensing authority with a direct supervisory lever over BSA reporting, five-year recordkeeping, and quarterly call reporting, meaning an AML reporting lapse could now also be treated as a state licensing matter. 1 evidence refs Compliance ### Louisiana replaced its money-transmission statute wholesale, adopting the Model Money Transmission Modernization Act and enabling multistate examinations. Compliance functions overseeing Louisiana money-transmission licences should expect examination practices to converge with other Model Money Transmission Modernization Act states, and should note that existing Sale-of-Checks-Act licensees are not required to re-apply immediately. 1 evidence refs Legal ### Act 923 adds a federal-preemption trigger to Louisiana's virtual-currency licensing statute, voiding conflicting state provisions if a federal virtual-currency licensing law takes effect. Legal teams advising virtual-currency business operators in Louisiana should note that the state's licensing regime, while continuing indefinitely following the sunset repeal, is explicitly structured to yield to a future federal licensure framework rather than persist as a permanently separate track. 1 evidence refs Board ### Louisiana has tightened its money-transmission AML-linked licensing architecture while building in deference to any future federal virtual-currency licensing regime. The two enactments together signal a state regulatory posture oriented toward convergence with national and federal frameworks rather than toward a distinct, isolated Louisiana regime, which is a relevant consideration for institutions weighing the durability of state-specific compliance programs. 2 evidence refs Risk ### Louisiana's embedding of BSA/AML reporting duties into state licensure closes a prior gap between state licence status and federal AML compliance visibility. Risk functions should register that an AML reporting failure by a Louisiana-licensed money transmitter can now more directly expose the institution to a state licensing consequence, not solely a separate federal enforcement track. 1 evidence refs Operations ### Quarterly call reporting and five-year recordkeeping are now explicit licence-maintenance conditions for Louisiana money transmitters. Operations teams responsible for regulatory filings should confirm quarterly call-report submission and five-year record retention processes are in place to support licence maintenance, not only federal filing obligations. 1 evidence refs Audit ### Louisiana's statutory replacement changes the evidentiary basis examiners may rely on for licence-condition compliance. Internal audit scope for Louisiana money-transmission licensure should now account for BSA/AML reporting, recordkeeping, and quarterly call reporting as licence-condition audit points, reflecting the new statute's incorporation of these duties. 2 evidence refs Scenario sketches ### Illustrative pathway: AMLA direct supervision and cross-border obliged-entity evasion response As an illustrative orientation only, consider how the transition from purely national anti-money-laundering supervision toward a hybrid regime, in which the Anti-Money Laundering Authority exercises direct or indirect supervision over certain cross-border obliged entities alongside the directly applicable AML Regulation and per-state transposition of the sixth AML Directive, could reshape incentives for entities seeking to layer funds across supervisory boundaries. A structural shift of this kind could, hypothetically, alter where an illicit actor perceives the weakest supervisory link to sit, potentially shifting attention toward obliged entities and jurisdictions that remain under purely national supervision rather than those drawn into direct EU-level oversight. This is an illustrative sketch of a possible structural dynamic, not an observed development and not a prediction of how any specific entity or jurisdiction will behave. 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 T6 · Sanctions Regime Divergence no_change Registers ### Enforcement actions - 1 Apr 2025 - 22 Oct 2025 - 28 Aug 2025 - 26 Mar 2025 - 19 Mar 2026 - FinCEN amended the June 2025 special-measure order against CIBanco to permit fund transmittals for the Mexican government's court-ordered liquidation. 16 Apr 2026 - Largest-ever civil money penalty against a broker-dealer for BSA violations including 160+ unfiled SARs and an unscaled monitoring program. 1 Mar 2026 - OFAC designated 29 individuals and entities tied to Cambodia's cyber-fraud and human-trafficking scam-compound economy. 23 Apr 2026 - 2026-01 - 2026 - OFAC and the Louisiana Office of Financial Institutions executed a Memorandum of Understanding formalizing bilateral information sharing on OFAC sanctions compliance and enforcement for banking organizations supervised by the state agency under Title 6 of the Louisiana Revised Statutes. 1 Apr 2025 - OFAC designated Russia's two largest oil producers, Rosneft and Lukoil, sanctioning their operations and stranding tens of millions of barrels of Russian crude at sea, with direct relevance to Gulf Coast refining and trading counterparties that historically handled Russian-linked or Russian-derived crude and refined products. 21 Nov 2025 - FinCEN issued an Advisory and accompanying Financial Trend Analysis directing all U.S. financial institutions, including Louisiana state and nationally chartered banks, to enhance detection of Chinese money laundering network (CMLN) activity tied to cartel drug proceeds, trade-based laundering, and real estate purchases. 28 Aug 2025 - FinCEN issued an interim final rule revising the definition of 'reporting company' under the Corporate Transparency Act to exempt all U.S.-formed entities and their beneficial owners from BOI reporting, retaining obligations only for foreign-formed entities registered to do business in U.S. states including Louisiana. 26 Mar 2025 ### Sanctions changes - 22 Oct 2025 - 22 Oct 2025 - 16 Jan 2026 - 2 Jun 2026 - 24 Apr 2026 - 23 Apr 2026 - 24 Jul 2026 - 13 Jul 2026 - 19 Jun 2026 - OFAC designated Rosneft PJSC and Lukoil PJSC, Russia's two largest oil producers, marking the U.S. administration's most aggressive move to date against core Russian energy revenue, with knock-on effects for Gulf Coast refiners and traders historically active in Russian-linked crude/product flows. 21 Nov 2025 - OFAC issued General License 124A refining the Russian oil price-cap framework, updating authorized covered services for maritime transport of Russian crude and petroleum products purchased at or below the price cap, directly relevant to Gulf Coast/Louisiana refiners and shippers engaging with price-cap-compliant cargoes. 22 Oct 2025 ### Regulatory horizon (register) - AMLA Work Programme / build-out - Louisiana Money Transmission Act — existing-licensee transition window - Louisiana Money Transmission Act — existing-licensee transition window - Louisiana Money Transmission Act transition period - Louisiana Money Transmission Act transitional compliance deadline - Nationwide Residential Real Estate Rule reporting go-live - GENIUS Act stablecoin AML/sanctions rule finalization - FinCEN AML/CFT program modernization rule finalization ### Active schemes - [HIGH] Refined Russian crude laundered via Gulf Coast/Louisiana ports - [HIGH] Chinese money laundering networks using Gulf trade corridors - Beneficial ownership opacity in Louisiana LLCs post-CTA rollback Sources - [FinCEN Notice on the Use of Counterfeit U.S. Passport ...](https://www.fincen.gov/system/files/shared/FinCEN_Notice_Counterfeit_US_Passport_FINAL508.pdf) - [FATF](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-june-2026.html) - [ComplyAdvantage](https://complyadvantage.com/insights/fatf-plenary-june-2026-outcomes/) - [AMLUAE](https://amluae.com/fatf-grey-list-countries-update-19th-june-2026/) - [Logistics Middle East](https://www.logisticsmiddleeast.com/analysis/how-far-can-europe-go-against-russias-shadow-fleet) - [Wikipedia](https://en.wikipedia.org/wiki/Scam_centers_in_Cambodia) - [Ukraine Defense Intelligence (GUR)](https://war-sanctions.gur.gov.ua/en/transport/shadow-fleet) - [U.S. Department of the Treasury / OFAC](https://home.treasury.gov/news/press-releases/sb0367) - [Zavia (UBO Data)](https://zavia.ai/eu-beneficial-ownership-in-2026-amlr-amld6-amla-explained/) - [Norton Rose Fulbright](https://www.nortonrosefulbright.com/en/knowledge/publications/644c5392/the-new-eu-amlcft-regime-has-arrived-are-you-ready) - [Klea Legal](https://klealegal.com/newsroom/amld6-eu-aml-package-entity-management) - [FinCEN](https://www.fincen.gov/system/files/2025-08/FinCEN-Advisory-CMLN-508.pdf) - [Procopio](https://www.procopio.com/resource/latest-cta-update) - [Casino Guardian](https://www.casinoguardian.co.uk/2026/01/27/cambodia-intensifies-crackdown-on-illegal-online-gambling-amid-fatf-scrutiny/) - [Chainalysis](https://www.chainalysis.com/blog/crypto-sanctions-2026/) - [Substack (D. Whitehouse)](https://drdavidwhitehouse.substack.com/p/why-is-cambodia-not-on-faft-grey) - [U.S. Department of the Treasury](https://home.treasury.gov/news/press-releases/sb0179) - [Federal Register / FinCEN](https://www.federalregister.gov/documents/2026/04/16/2026-07416/imposition-of-special-measure-prohibiting-certain-transmittals-of-funds-involving-cibanco-sa) - [Illicit Edge](https://illicitedge.com/chinese-money-laundering-networks-serving-mexico-based-drug-cartels/) - [Washington Trade & Tariff Letter](https://www.wttlonline.com/stories/colombia-designated-major-trafficker-in-fraa-review,14278) - [EU AML/CFT Global Facility](https://www.global-amlcft.eu/colombia-aml-cft/) - [Scorechain](https://www.scorechain.com/blog/ofac-iran-crypto-sanctions-june-2026) - [TRM Labs](https://www.trmlabs.com/resources/blog/ofac-sanctions-crypto-addresses-associated-with-the-central-bank-of-iran-freezes-usd-344-million) - [Guidehouse](https://guidehouse.com/insights/financial-services/2026/ai-based-transaction-monitoring) - [Unit21](https://www.unit21.ai/blog/fincen-proposed-rule-2026-faqs-what-compliance-teams-need-to-know) - [UK Home Office (gov.uk)](https://www.gov.uk/government/publications/offence-of-failure-to-prevent-fraud-introduced-by-eccta) - [FiscalTec](https://fiscaltec.com/uk-fraud-sanctions-compliance-2026-eccta-ofsi-full-guide/) - [https://www.fincen.gov/boi](https://www.fincen.gov/boi) - [https://www.databricks.com/blog/model-risk-management-2026-bankers-guide-revised-interagency-guidance](https://www.databricks.com/blog/model-risk-management-2026-bankers-guide-revised-interagency-guidance) - [https://www.fincen.gov/news/news-releases/fincen-issues-expanded-southwest-border-geographic-targeting-order](https://www.fincen.gov/news/news-releases/fincen-issues-expanded-southwest-border-geographic-targeting-order) - [https://www.fincen.gov/news/news-releases/fincen-combats-financial-support-sinaloa-cartel-finding-transactions-involving](https://www.fincen.gov/news/news-releases/fincen-combats-financial-support-sinaloa-cartel-finding-transactions-involving) - [https://agbrief.com/news/cambodia/26/01/2026/cambodia-battles-to-avoid-third-fatf-grey-list-placement-amid-scam-crackdown/](https://agbrief.com/news/cambodia/26/01/2026/cambodia-battles-to-avoid-third-fatf-grey-list-placement-amid-scam-crackdown/) - [https://newlinesinstitute.org/global-security-mil-priorities/cybercrimes-human-trafficking-and-cryptocurrency-in-southeast-asias-special-economic-zones/](https://newlinesinstitute.org/global-security-mil-priorities/cybercrimes-human-trafficking-and-cryptocurrency-in-southeast-asias-special-economic-zones/) - [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.consilium.europa.eu/en/press/press-releases/2026/07/13/sudan-council-strengthens-eu-sanctions-regime-by-targeting-gold-trade/](https://www.consilium.europa.eu/en/press/press-releases/2026/07/13/sudan-council-strengthens-eu-sanctions-regime-by-targeting-gold-trade/) - [https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-june-2026.html](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-june-2026.html) - [https://shuftipro.com/blog/mica-regulation-eu-crypto-rules/](https://shuftipro.com/blog/mica-regulation-eu-crypto-rules/) - [https://www.mondaq.com/unitedstates/financial-services/1808274/louisiana-enacts-comprehensive-money-transmission-law-mirroring-laws-in-other-states](https://www.mondaq.com/unitedstates/financial-services/1808274/louisiana-enacts-comprehensive-money-transmission-law-mirroring-laws-in-other-states) - [https://infobytes.orrick.com/2026-06-18/louisiana-enacts-money-transmission-regulatory-and-licensing-framework/](https://infobytes.orrick.com/2026-06-18/louisiana-enacts-money-transmission-regulatory-and-licensing-framework/) - [https://natlawreview.com/article/louisiana-enacts-comprehensive-money-transmission-law-mirroring-laws-other-states](https://natlawreview.com/article/louisiana-enacts-comprehensive-money-transmission-law-mirroring-laws-other-states) - [https://www.legis.la.gov/Legis/ViewDocument.aspx?d=1461907](https://www.legis.la.gov/Legis/ViewDocument.aspx?d=1461907) - [https://www.sheppard.com/insights/blogs/louisiana-enacts-comprehensive-money-transmission-law-mirroring-laws-in-other-states](https://www.sheppard.com/insights/blogs/louisiana-enacts-comprehensive-money-transmission-law-mirroring-laws-in-other-states) - [https://www.discern.com/resources/louisiana-financial-services-compliance](https://www.discern.com/resources/louisiana-financial-services-compliance) - [https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) - [https://www.fatf-gafi.org/en/countries/detail/Lao-People-s-Democratic-Republic.html](https://www.fatf-gafi.org/en/countries/detail/Lao-People-s-Democratic-Republic.html) - [https://www.knowyourcountry.com/country-reports/cambodia/](https://www.knowyourcountry.com/country-reports/cambodia/) - [https://thediplomat.com/2025/07/fatf-is-behind-the-curve-on-cambodias-cyber-scam-compounds/](https://thediplomat.com/2025/07/fatf-is-behind-the-curve-on-cambodias-cyber-scam-compounds/) - [https://ofi.la.gov/](https://ofi.la.gov/) - [Louisiana State Legislature](https://www.legis.la.gov/Legis/ViewDocument.aspx?d=1481521) - [National Law Review](https://natlawreview.com/article/louisiana-enacts-new-money-transmission-act-largely-adopting-model-money) - [Louisiana State Legislature](https://legis.la.gov/Legis/ViewDocument.aspx?d=1481806) - [FinCEN](https://www.fincen.gov/system/files/2026-06/FinCEN-Alert-Fiscal-Fuel-Theft.pdf) - [AML UAE](https://amluae.com/fatf-grey-list-countries-update-19th-june-2026/) - [Citizen Portal](https://citizenportal.ai/articles/7758570/Louisiana/2026-Legislature-LA/Commerce-Committee-advances-bill-to-remove-sunset-on-state-virtual-currency-licensing) - [https://ofi.la.gov/wp-content/uploads/2026/07/NonDep_2026VCBASunsetLegislation_SB163.pdf](https://ofi.la.gov/wp-content/uploads/2026/07/NonDep_2026VCBASunsetLegislation_SB163.pdf) - [https://legis.la.gov/Legis/ViewDocument.aspx?d=1481806](https://legis.la.gov/Legis/ViewDocument.aspx?d=1481806) - [https://www.consumerprotectioninsights.com/2026/07/louisiana-enacts-new-money-transmission-act-largely-adopting-model-money-transmission-modernization-act/](https://www.consumerprotectioninsights.com/2026/07/louisiana-enacts-new-money-transmission-act-largely-adopting-model-money-transmission-modernization-act/) - [Sheppard Mullin](https://www.sheppard.com/insights/blogs/louisiana-enacts-comprehensive-money-transmission-law-mirroring-laws-in-other-states) - [Louisiana Legislature](https://www.legis.la.gov/Legis/ViewDocument.aspx?d=1481521) - [ChecklyNx](https://checklynx.com/en/resources/knowledge-base/fatf-grey-list) - [The Star (Malaysia)](https://www.thestar.com.my/aseanplus/aseanplus-news/2026/10/14/a-test-of-accountability-on-cambodia039s-online-scam-challenge-comment) - [https://legis.la.gov/Legis/ViewDocument.aspx?d=1478935](https://legis.la.gov/Legis/ViewDocument.aspx?d=1478935) - [Civil Penalties and Enforcement Information | Office of Foreign Assets Control](https://ofac.treasury.gov/civil-penalties-and-enforcement-information) - [About OFAC | Office of Foreign Assets Control](https://ofac.treasury.gov/about-ofac) - [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) - [Basic Information on OFAC and Sanctions](https://ofac.treasury.gov/faqs/topic/1501) - [Federal Register/Vol. 90, No. 54/Friday, March 21, 2025/Rules ...](https://ofac.treasury.gov/media/934131/download) - [MEMORANDUM OF UNDERSTANDING US Department of ...](https://ofac.treasury.gov/media/934276/download?inline=) - [Counter Narcotics Trafficking Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/counter-narcotics-trafficking-sanctions) - [1 1. See 31 U.S.C. § 5312(a)(2); 31 C.F.R. § 1010.100(t).](https://www.fincen.gov/system/files/2026-05/FinCEN-Alert-IRGC.pdf) - [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) - [United States Department of the Treasury Financial Crimes Enforcement Network - Home | FinCEN.gov](https://www.fincen.gov/) - [FinCEN GEOGRAPHIC TARGETING ORDER, April 14, 2025](https://www.fincen.gov/system/files/shared/RRE-GTO-Order-April-14-2025-FINAL508.pdf) - [FREQUENTLY ASKED QUESTIONS Issued: October 9, 2025](https://www.fincen.gov/system/files/2025-10/RRE-GTO-FAQs.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) - [Geographic Targeting Order Covering TITLE INSURANCE COMPANY October 9, 2025](https://www.fincen.gov/system/files/2025-10/RRE-GTO-Order.pdf) - [FinCEN Renews Real Estate Geographic Targeting Orders | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-renews-real-estate-geographic-targeting-orders-0) - [GEOGRAPHIC TARGETING ORDER The Director of the ...](https://www.fincen.gov/sites/default/files/shared/Real%20Estate%20GTO%20GENERIC_111518_FINAL.pdf) - [Real Estate Geographic Targeting Order](https://www.fincen.gov/sites/default/files/shared/508_Real%20Estate%20GTO%20Order%20FINAL%20GENERIC%2011.4.2020.pdf) - [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) - [Geographic Targeting Orders Involving Certain Real Estate ...](https://www.fincen.gov/sites/default/files/shared/508_FAQ_April2023REGTO.pdf) - [FinCEN GEOGRAPHIC TARGETING ORDER, Frequently ...](https://www.fincen.gov/sites/default/files/shared/Real%20Estate%20GTO_FAQ_4.29.22_for%20Press%20Release.pdf) - [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-2) - [Alerts/Advisories/Notices/Bulletins/Fact Sheets | FinCEN.gov](https://www.fincen.gov/resources/advisoriesbulletinsfact-sheets) - [FinCEN Exchange | FinCEN.gov](https://www.fincen.gov/resources/financial-crime-enforcement-network-exchange) - [FinCEN Issues Proposed Rule to Strengthen and Modernize Financial Institutions’ AML/CFT Programs | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-proposed-rule-strengthen-and-modernize-financial-institutions) - [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) - [1 Financial Crimes Enforcement Network (FinCEN)](https://www.fincen.gov/system/files/2026-05/FinCEN-Year-in-Review-2025.pdf) - [1 Financial Crimes Enforcement Network](https://www.fincen.gov/system/files/2025-10/SAR-FAQs-October-2025.pdf) - [1 Fact Sheet: FinCEN Issues Final Rule to](https://www.fincen.gov/system/files/shared/RREFactSheet.pdf) - [Shadow Bankers – Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/shadow-bankers) - [Sanctions and terrorism: How the cartels use crypto to launder the proceeds of narcotics trafficking](https://www.elliptic.co/blog/sanctions-and-terrorism-how-the-cartels-use-crypto-to-launder-the-proceeds-of-narcotics-trafficking) - [Sinaloa Cartel Money Laundering Network SINALOA CARTEL (CDS) March 2025](https://ofac.treasury.gov/system/files/2025-03/20250331_sinaloa_money_laundering.pdf) - [Drug Cartel Money Laundering Shifts to Crypto and the Gig ...](https://www.bloomberg.com/news/features/2026-02-11/drug-cartel-money-laundering-shifts-to-crypto-and-the-gig-economy) - [1 The U.S. Department of the Treasury’s (Treasury)](https://www.fincen.gov/system/files/2025-08/FinCEN-Advisory-CMLN-508.pdf) - [Cartels are using cryptoassets to move drug proceeds. Blockchain intelligence can stop them.](https://www.elliptic.co/blog/how-cartels-use-cryptoassets-to-move-drug-proceeds) - [FinCEN Alert on Bulk Cash Smuggling and Repatriation by ...](https://www.fincen.gov/sites/default/files/shared/BCS-Alert-FINAL-508C.pdf) - [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-Oil-Smuggling-FINAL-508C.pdf) - [FinCEN Issues Advisory and Financial Trend Analysis on Chinese Money Laundering Networks | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-advisory-and-financial-trend-analysis-chinese-money-laundering) - [FOR IMMEDIATE RELEASE October 2, 2014 CONTACT: Steve Hudak 703-905-3770](https://www.fincen.gov/system/files/shared/20141002.pdf) - [US DOJ Announces Largest Ever Seizure of Funds Related to Crypto Scams | TRM Labs](https://www.trmlabs.com/resources/blog/us-doj-announces-largest-ever-seizure-of-funds-related-to-crypto-scams) - [State of Louisiana Office of the Attorney General - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/1342023D:US) - [Canaccord-Consent-Order-No-2026-01. ...](https://www.fincen.gov/system/files/2026-03/Canaccord-Consent-Order-No-2026-01.pdf) - [Questions swirl around US plans for record $15B Prince Group crypto seizure - ICIJ](https://www.icij.org/investigations/coin-laundry/questions-swirl-around-us-plans-for-record-15b-prince-group-crypto-seizure/) - [News | FinCEN.gov](https://www.fincen.gov/news) - [SAR Activity Review](https://www.fincen.gov/system/files/shared/sar_tti_02.pdf) - [Advisories | FinCEN.gov](https://www.fincen.gov/resources/advisoriesbulletinsfact-sheets/advisories) - [2026 Crypto Crime Report: Scams](https://www.chainalysis.com/blog/crypto-scams-2026/) - [Press Releases | FinCEN.gov](https://www.fincen.gov/news/press-releases) - [Important Information for Casinos | FinCEN.gov](https://www.fincen.gov/resources/financial-institutions/casinos) - [Casino or Card Club Risk-Based Compliance Indicators | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/casino-or-card-club-risk-based-compliance-indicators) - [Frequently Asked Questions Casino Recordkeeping, Reporting, and Compliance Program Requirements | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/frequently-asked-questions-casino-recordkeeping-reporting-0) - [Suspicious Activity Reporting in the Gaming Industry](https://www.fincen.gov/sites/default/files/shared/GamingIndustry508March2012.pdf) - [FinCEN Form 102a SAR- Casinos and Card Clubs Instructions 1](https://www.fincen.gov/system/files/shared/fin102a_instructions_only.pdf) - [PPSI-AMLCFT-NPRM.pdf](https://www.fincen.gov/system/files/2026-04/PPSI-AMLCFT-NPRM.pdf) - [Definition of Money Services Business (Casinos as Money Services Businesses) | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/definition-money-services-business-casinos) - [Guidance | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance?field_tags_financial_institution_target_id=659&page=0) - [Casinos | FinCEN.gov](https://www.fincen.gov/resources/financial-institutions/casinos?page=2) - [Casino or Card Club Compliance Program Assessment | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/casino-or-card-club-compliance-program-assessment) - [CONSENT ORDER IMPOSING CIVIL MONEY PENALTY](https://www.fincen.gov/system/files?file=enforcement_action%2F2023-04-05%2FCBOT_Enf_Action_121621_508_FINAL.pdf) - [FinCEN Consent Order Imposing Civil Money Penalty, ...](https://www.fincen.gov/system/files/enforcement_action/2023-04-05/USAA_Consent_Order_Final_508_2.pdf) - [FIN-2025-G001 Issued: September 5, 2025](https://www.fincen.gov/system/files/2025-09/Crossborderguidance-508C.pdf) - [CIP TIN Exemption Order final508.pdf](https://www.fincen.gov/system/files/2025-08/CIP-TIN-Exemption-Order-final508.pdf) - [1 ORDER](https://www.fincen.gov/system/files/2025-06/CIP-TIN-Exemption-Order-final508.pdf) - [Enforcement Actions | FinCEN.gov](https://www.fincen.gov/news/enforcement-actions) - [Interagency Statement on Sharing Bank Secrecy Act Resources | FinCEN.gov](https://www.fincen.gov/news/news-releases/interagency-statement-sharing-bank-secrecy-act-resources) - [Federal Register/Vol. 91, No. 69/Friday, April 10, 2026/ ...](https://ofac.treasury.gov/media/935481/download?inline=) - [Frequently Asked Questions | FinCEN.gov](https://www.fincen.gov/boi-faqs) - [Beneficial Ownership Information Reporting Rule Fact Sheet | FinCEN.gov](https://www.fincen.gov/beneficial-ownership-information-reporting-rule-fact-sheet) - [Fact Sheet: Beneficial Ownership Information Reporting Notice of Proposed Rulemaking (NPRM) | FinCEN.gov](https://www.fincen.gov/news/news-releases/fact-sheet-beneficial-ownership-information-reporting-notice-proposed-rulemaking) - [Beneficial Ownership Information Reporting | FinCEN.gov](https://www.fincen.gov/boi) - [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?twclid=2-5rnrr590r1kru5w3p1iak11ok) - [Beneficial Ownership Reporting Outreach and Education Toolkit | FinCEN.gov](https://www.fincen.gov/boi/toolkit) - [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) - [Updated: March 2025 1 Financial Crimes Enforcement Network](https://www.fincen.gov/system/files/shared/BOI-FAQs-QA-508C.pdf) - [U.S. Beneficial Ownership Information Registry Now Accepting Reports | FinCEN.gov](https://www.fincen.gov/news/news-releases/us-beneficial-ownership-information-registry-now-accepting-reports) - [Financial Crimes Enforcement Network U.S. Department of the Treasury](https://www.fincen.gov/system/files/shared/BOI_Small_Compliance_Guide.v1.1-FINAL.pdf) - [Financial Institutions | FinCEN.gov](https://www.fincen.gov/resources/financial-institutions) - [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) - [Definition of Money Transmitter (Merchant Payment Processor) | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/definition-money-transmitter-merchant-payment) - [Administrative Rulings | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings?field_tags_financial_institution_target_id=All&page=1) - [Requests by Law Enforcement for Financial Institutions to Maintain Accounts | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/requests-law-enforcement-financial-institutions-maintain) - [Law Enforcement Overview | FinCEN.gov](https://www.fincen.gov/resources/law-enforcement) - [Financial Crimes Enforcement Network](https://www.fincen.gov/system/files/guidance/guidance04262005.pdf) - [Whether a Certain Operation Protecting On-line Personal Financial Information is a Money Transmitter | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/whether-certain-operation-protecting-line) - [Publication of Alert on Possible Evasion of the Russian Oil Price Cap | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20230417) - [Possible Evasion of the Russian Oil Price Cap OFAC ALERT](https://ofac.treasury.gov/media/931641/download) - [American purchases of laundered Russian oil worth at least $180 million to the Kremlin | Global Witness](https://www.globalwitness.org/en/campaigns/fossil-gas/american-purchases-laundered-russian-oil-worth-least-180-million-kremlin/) - [American purchases of laundered Russian oil worth at least $180 million to the Kremlin | Global Witness](https://globalwitness.org/en/campaigns/fossil-fuels/american-purchases-of-laundered-russian-oil-worth-at-least-180-million-to-the-kremlin/) - [American sanctions fail to screen out Russian-origin petroleum products | Global Witness](https://www.globalwitness.org/en/campaigns/fossil-gas/transformative-loophole-american-sanctions-fail-screen-out-russian-origin-petroleum-products/) - [DEPARTMENT OF THE TREASURY WASHINGTON, D.C. February 3, 2023](https://ofac.treasury.gov/media/931036/download) - [1216 | Office of Foreign Assets Control](https://ofac.treasury.gov/faqs/1216) - [Frequently Asked Questions - Recently Updated | Office of Foreign Assets Control](https://ofac.treasury.gov/faqs/updated/2025-12-17) - [Russian Harmful Foreign Activities Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions) - [Russian Oil at Risk of Being Stranded at Sea as US Sanctions Hit - Bloomberg](https://www.bloomberg.com/news/articles/2025-11-20/russian-oil-at-risk-of-being-stranded-at-sea-as-us-sanctions-hit) - [STATE CONTACT INFORMATION FOR MSBs](https://www.fincen.gov/system/files/shared/msbstatecontactsfinal.pdf) - [Money Services Business Definition | FinCEN.gov](https://www.fincen.gov/money-services-business-definition) - [Money Services Businesses | FinCEN.gov](https://www.fincen.gov/resources/financial-institutions/money-services-businesses?page=32) - [Financial Institution Definition | FinCEN.gov](https://www.fincen.gov/financial-institution-definition) - [Important Information for MSBs | FinCEN.gov](https://www.fincen.gov/resources/financial-institutions/money-services-businesses?field_date_release_value=&field_date_release_value_1=&page=22&type=All) - [Money Services Businesses Home | FinCEN.gov](https://www.fincen.gov/money-services-businesses-home) - [Money Services Business (MSB) Registration | FinCEN.gov](https://fincen.gov/money-services-business-msb-registration) - [FinCEN Initiatives | FinCEN.gov](https://www.fincen.gov/fincen-initiatives) - [1 BY OPIATE TRAFFICKERS AND MIGRANT SMUGGLERS The Hawala System](https://www.unodc.org/documents/data-and-analysis/AOTP/Hawala_Digital.pdf) - [Money Laundering and Terrorist Financing Risks Arising from Migrant Smuggling](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Migrant-smuggling.html) - [Comprehensive Update on Terrorist Financing Risks FATF REPORT July 2025](https://www.fatf-gafi.org/content/dam/fatf-gafi/publications/Comprehensive-Update-on-Terrorist-Financing-Risks-2025.pdf.coredownload.inline.pdf) - [Stories on Human Trafficking](https://www.unodc.org/unodc/en/frontpage/index.html?tag=Human+Trafficking) - [Financial Flows from Human Trafficking](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Human-trafficking.html) - [International Narcotics Control Strategy Report Volume II Money Laundering](https://syntheticdrugs.unodc.org/uploads/syntheticdrugs/res/library/cybercrime_html/US_International_Narcotics_Control_Strategy_Report_Money_Laundering.pdf) - [UNODC in South-Eastern Europe](https://www.unodc.org/southeasterneurope/en/all-stories.html) - [How the finance sector can help prevent human trafficking](https://www.unodc.org/unodc/en/frontpage/2025/March/how-the-finance-sector-can-help-prevent-human-trafficking.html) - [December 2024 Anti-money laundering and counter-terrorist financing measures](https://www.fatf-gafi.org/content/dam/fatf-gafi/mer/Comms%20MER%20Oman%202024.pdf.coredownload.inline.pdf) - [Latest NEWS & STORIES](https://www.unodc.org/unodc/human-trafficking/latest-news.html) - [United States District Court for the Eastern District of Louisiana - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/1050L:US) - [United States Bankruptcy Court for the Eastern District of Louisiana - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/1264189D:US) - [United States District Court for the Western District of Louisiana - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/1052L:US) - [1264189D: United States Bankruptcy Court for the Eastern District of Louisiana Stock Price Quote - - Bloomberg](https://www.bloomberg.com/quote/1264189D:US) - [United States Bankruptcy Court for the Middle District of Louisiana - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/1264236D:US) - [Michael B North, United States District Court for the Eastern District of Louisiana: Profile and Biography - Bloomberg Markets](https://www.bloomberg.com/profile/person/18710520) - [Eldon E Fallon, United States District Court for the Eastern District of Louisiana: Profile and Biography - Bloomberg Markets](https://www.bloomberg.com/profile/person/3046248) - [Meredith S Grabill, United States Bankruptcy Court for the Eastern District of Louisiana: Profile and Biography - Bloomberg Markets](https://www.bloomberg.com/profile/person/21011553) - [1051L: United States District Court for the Middle District of Louisiana Stock Price Quote - - Bloomberg](https://www.bloomberg.com/quote/1051L:US) - [1264236D: United States Bankruptcy Court for the Middle District of Louisiana Stock Price Quote - - Bloomberg](https://www.bloomberg.com/quote/1264236D:US) - [Suspicious Activity Reporting](https://www.fincen.gov/sites/default/files/shared/neilanderaml.pdf) - [Emerging money laundering and terrorist financing risks from April 2025](https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/emerging-money-laundering-and-terrorist-financing-risks-from-april-2025) - [Frequently Asked Questions Casino Record keeping, Reporting, and Compliance Program Requirements | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/frequently-asked-questions-casino-record-keeping-reporting) - [Recognizing Suspicious Activity - Red Flags for Casinos and Card Clubs | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/recognizing-suspicious-activity-red-flags-casinos-and-card) - [Suspicious Activity Reporting in the Gaming Industry](https://www.fincen.gov/system/files/shared/GamingIndustry508March2012.pdf) - [Casino Industry Currency Transaction Reporting](https://www.fincen.gov/sites/default/files/shared/CasinoIndustryCTRFilings.pdf) - [FinCEN Notice on the Use of Counterfeit U.S. Passport ...](https://www.fincen.gov/system/files/shared/FinCEN_Notice_Counterfeit_US_Passport_FINAL508.pdf) - [U.S. Department of the Treasury / OFAC](https://ofac.treasury.gov/media/934276/download?inline=) - [Louisiana Office of Financial Institutions](http://www.ofi.state.la.us/) - [Global Witness](https://www.globalwitness.org/en/campaigns/fossil-gas/american-purchases-laundered-russian-oil-worth-least-180-million-kremlin/) - [FinCEN](https://www.fincen.gov/news/news-releases/fincen-issues-advisory-and-financial-trend-analysis-chinese-money-laundering) - [FinCEN](https://www.fincen.gov/news/news-releases/fincen-removes-beneficial-ownership-reporting-requirements-us-companies-and-us?twclid=2-5rnrr590r1kru5w3p1iak11ok) - [Bloomberg](https://www.bloomberg.com/news/articles/2025-11-20/russian-oil-at-risk-of-being-stranded-at-sea-as-us-sanctions-hit) - [FinCEN](https://www.fincen.gov/news/news-releases/fincen-renews-residential-real-estate-geographic-targeting-orders-0) - [FinCEN (relaying FATF plenary outcomes)](https://www.fincen.gov/news/news-releases/financial-action-task-force-identifies-jurisdictions-anti-money-laundering-3) Coverage gaps fim-int-2026-07-07-G001: The outcome and expected timeline o… fim-int-2026-07-07-G001: The outcome and expected timeline of FinCEN's appeal of the Eastern District of Texas vacatur of the Residential Real Estate Rule has not been established, leaving the risk_direction_on_implementation for that horizon item genuinely uncertain. [resolved] fim-int-2026-07-07-G002: Publicly available Tier 1-3 reporti… fim-int-2026-07-07-G002: Publicly available Tier 1-3 reporting on Louisiana-specific federal financial-crime prosecutions (USAO Eastern/Middle/Western Districts of Louisiana) within the review window remains sparse, limiting confidence in assessing true Louisiana-specific enforcement intensity versus baseline national posture. [resolved] fim-int-2026-07-07-G003: The EU's Article 3ma refined-petrol… fim-int-2026-07-07-G003: The EU's Article 3ma refined-petroleum loophole closure (21 January 2026) is currently corroborated only by a Tier 3 law-firm client alert; a primary EU Official Journal or Council citation would strengthen the regime-divergence assessment beyond Assessed confidence. [resolved] fim-int-2026-07-07-G004: No Louisiana-specific data on payme… fim-int-2026-07-07-G004: No Louisiana-specific data on payment stablecoin issuer presence or activity has been identified, limiting assessment of Louisiana's direct exposure to the pending GENIUS Act PPSI AML/sanctions rule. [resolved] fim-int-2026-07-14-G001: No T1 EU institutional source was d… fim-int-2026-07-14-G001: No T1 EU institutional source was directly queried this cycle for AMLA/AMLR/6AMLD dates; reliance on T4 legal-secondary summaries. [resolved] fim-int-2026-07-14-G002: Full 27-member-state 6AMLD transpos… fim-int-2026-07-14-G002: Full 27-member-state 6AMLD transposition delta table is not available this cycle. [resolved] fim-int-2026-07-14-G003: AMLA's selection criteria for the ~… fim-int-2026-07-14-G003: AMLA's selection criteria for the ~40 directly-supervised entities are not yet finalised. [resolved] fim-int-2026-07-14-G004: D6 (Compliance Technology) coverage… fim-int-2026-07-14-G004: D6 (Compliance Technology) coverage is thin this cycle, limited to a single illustrative FinCEN enforcement action and one pending NPRM; no broader AI/ML supervisory-guidance sweep was completed. [resolved] fim-int-2026-07-14-G005: No direct T1 OFAC press release URL… fim-int-2026-07-14-G005: No direct T1 OFAC press release URL was retrieved this cycle for the 2 June 2026 Iranian crypto-exchange designation; sourcing rests on T2 vendor corroboration only. [resolved] fim-int-2026-08-05-G001: No Louisiana (US state)-specific AM… fim-int-2026-08-05-G001: No Louisiana (US state)-specific AML/CFT finding was available this cycle; FIM's taxonomy operates at national/supranational level and did not surface a Louisiana sub-national finding. [resolved] fim-int-2026-08-05-G002: The AMLR/6AMLD per-Member-State EEA… fim-int-2026-08-05-G002: The AMLR/6AMLD per-Member-State EEA transposition delta table was not retrieved this cycle; per-Member-State divergence remains unquantified. [resolved] fim-int-2026-08-05-G003: No dedicated UK FCA/JMLSG D6 guidan… fim-int-2026-08-05-G003: No dedicated UK FCA/JMLSG D6 guidance was retrieved this cycle despite ECCTA fraud-strategy developments; D6 UK coverage remains thin. [resolved] fim-int-2026-08-05-G004: Colombia's FRAA determination exact… fim-int-2026-08-05-G004: Colombia's FRAA determination exact publication date was not established from available sources this cycle. [resolved] fim-int-2026-08-20-G001: No official Louisiana OFI implement… fim-int-2026-08-20-G001: No official Louisiana OFI implementing-rule text retrieved for the Money Transmission Act's NMLS transition mechanics. [resolved] fim-int-2026-08-20-G002: Mexico and Colombia (Tier D watch j… fim-int-2026-08-20-G002: Mexico and Colombia (Tier D watch jurisdictions) yielded no fresh material within the pooled search budget this cycle. [resolved] fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): No US-LA-specific D1 (Sanctions Architecture) finding was identified this cycle. [resolved] fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', 'value': 'D3'}): No US-LA-specific D3 (Enabler Jurisdictions) finding was identified this cycle. [resolved] fim-int-2026-09-28-G003: Tier D Cambodia and Colombia covera… fim-int-2026-09-28-G003: Tier D Cambodia and Colombia coverage was thin this cycle; only stale pre-2026 material was surfaced. [resolved] fim-int-2026-10-11-G001: No primary confirmation of transiti… fim-int-2026-10-11-G001: No primary confirmation of transitional compliance deadline details for existing Sale-of-Checks-Act licensees under the new Money Transmission Act beyond secondary-source reporting. [resolved] fim-int-2026-10-11-G002: Exact Act number assigned to SB 287… fim-int-2026-10-11-G002: Exact Act number assigned to SB 287 (virtual-currency kiosk amendments) not cross-verified against the enrolled act text this cycle. [resolved] fim-int-2026-10-11-G003: D1 sanctions, D2 beneficial ownersh… fim-int-2026-10-11-G003: D1 sanctions, D2 beneficial ownership and FATF grey-list applicability are not applicable in a subnational US regime and were not researched this cycle. [resolved] fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', 'value': 'D3'}): No Mexico-specific or Colombia-specific Tier-D material was located this cycle within the available search budget. [open] fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): No independently-verified statutory pinpoint beyond La. R.S. 6:1037 was retrieved for the full set of BSA/AML obligations imposed by the new Louisiana Money Transmission Act. [open] fim-int-2026-10-25-G001: Mandatory Tier D (Cambodia/Laos/Mex… fim-int-2026-10-25-G001: Mandatory Tier D (Cambodia/Laos/Mexico/Colombia) sweep was not executed; run was single-JID bound to US-LA per the union envelope contract, and T1/T3/T6 standing trackers could not be independently assessed for this cycle. [open] FIM-GAP-001 (D2): Louisiana was never included among the met… FIM-GAP-001 (D2): Louisiana was never included among the metropolitan areas covered by FinCEN's residential real-estate Geographic Targeting Orders (which covered California, Texas, Florida, New York and others), leaving Louisiana's cash real-estate market without the shell-company beneficial-ownership disclosure that neighboring Gulf Coast states received for years, until the nationwide RRE Rule takes effect in March 2026. FIM-GAP-002 (D2): FinCEN's March 2025 interim final rule exe… FIM-GAP-002 (D2): FinCEN's March 2025 interim final rule exempting all U.S.-formed entities from Corporate Transparency Act beneficial-ownership reporting removed the principal federal transparency tool for the thousands of single-purpose LLCs used in Louisiana's oil & gas, maritime, and real-estate sectors, with no Louisiana state-level registry to substitute. FIM-GAP-003 (D3): Publicly available reporting from Tier 1-3… FIM-GAP-003 (D3): Publicly available reporting from Tier 1-3 sources on Louisiana-specific federal financial-crime prosecutions (U.S. Attorney's Offices for the Eastern, Middle, and Western Districts of Louisiana) within the 18-month window was sparse; this baseline relies principally on national FinCEN/OFAC architecture and one cross-jurisdictional investigative finding (Global Witness) with direct Louisiana relevance, rather than a dense set of Louisiana-specific enforcement actions. ## Evidence #### Confidence-tiered claims Signed 9 June 2026, effective 1 July 2026, replacing the 1966 Sale of Checks and Money Transmission Act and adopting the CSBS Model Money Transmission Modernization Act. [[Source 1]](#sec-sources) Probable · 1 source Act 923 (SB 163), effective 1 August 2026, repeals the 1 July 2027 VCBA sunset and provides for the VCBA to become void to the extent preempted by future federal virtual-currency licensure law. [[Source 1]](#sec-sources) Probable · 1 source Licensees must file BSA/AML-required reports, retain records at least 5 years, and are subject to possible multistate examinations coordinated via CSBS/MTRA. [[Source 1]](#sec-sources) Probable · 1 source Remains listed among FATF's Jurisdictions under Increased Monitoring per last-known 19 June 2026 plenary; no change this cycle. [[Source 1]](#sec-sources) Probable · 1 source Governor Chea Serey warned Cambodia could face re-listing on the FATF grey list if online-scam-compound conditions do not improve. [[Source 1]](#sec-sources) Uncertain · 1 source Act 923 (SB163), eff. Aug 1 2026, repeals the VCBA's July 1 2027 sunset date and adds a federal-preemption-trigger clause. [[Source 1]](#sec-sources) Probable · 1 source Louisiana's new money-transmission regime adopts the CSBS Model Money Transmission Modernization Act, aligning with the majority multistate supervisory framework rather than diverging from it. [[Source 1]](#sec-sources) Probable · 1 source Licensees must file reports required under the BSA and other AML laws, maintain five-year records, and submit quarterly call reports; effective 2026-07-01. [[Source 1]](#sec-sources) Probable · 1 source Repeals the Sale of Checks and Money Transmission Act; enacts Chapter 13 of Title 6 (R.S. 6:1031-1072), adopting the Model Money Transmission Modernization Act and enabling multistate supervisory examinations. [[Source 1]](#sec-sources) Probable · 1 source Act 923 (SB163, eff. 2026-08-01) repeals the VCBA's July 1, 2027 sunset date and provides that any VCBA provision in conflict with a future federal virtual-currency-licensing law becomes null and void from the end of the calendar year that federal law takes effect. [[Source 1]](#sec-sources) Probable · 1 source