--- title: "United States — Maine (US-ME) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/united-states-maine/ source_html: /jurisdictions/united-states-maine/index.html description: "Financial integrity intelligence for United States – Maine (US-ME): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: b67b8d48017c18c6599f2fb93a0dd834d99166b3e407f866cdae798233c7e2b3 generator: "fe-fleet/md-twin@1.0" --- # United States — Maine (US-ME) — 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 — Maine US-ME Domains covered 8 of 8 Sources 143 Role actions 8 Horizon <90d 0 Jurisdiction profile FATF status: Largely Compliant Tier: B Risk direction: Increasing Enablement vs enforcement: Mixed Maine AML/CFT sits inside the federal BSA/FinCEN architecture (national primary), supplemented by state licensing of money transmitters and virtual-currency businesses through the Bureau of Consumer Credit Protection (BCCP) and depository-institution AML supervision via the Bureau of Financial Institutions. More Maine has been an unusually active state regulator on crypto consumer protection but its authority is now being structurally eroded by federal OCC national-trust-charter preemption and the 2025 federal rollback of domestic beneficial-ownership reporting. Key deficiencies - Loss of state supervisory reach over major crypto/VASP firms that convert to OCC national trust charters, removing Maine BCCP's ability to enforce consumer-protection and AML-adjacent rules against them - No state-level beneficial-ownership backstop for Maine-formed domestic LLCs/corporations after the March 2025 federal interim final rule exempted all U.S. domestic entities from CTA reporting - Crypto ATM/kiosk sector (Bitcoin Depot and peers) operated in Maine with weak fraud controls until a 2025-2026 state settlement, illustrating a lag between deployment of a scam-prone cash-to-crypto channel and enforcement - Federal GTOs for beneficial-ownership disclosure in cash real-estate purchases do not extend to Maine, leaving anonymous LLC purchases of Maine real property outside enhanced federal reporting Recent developments (18m) - Maine BCCP promulgated, then narrowed, a crypto-wallet ownership-verification rule after industry (Coinbase) pressure and a threat of federal intervention - Maine and Nevada settled AML/consumer-protection enforcement actions against crypto-ATM operator Bitcoin Depot, which subsequently filed for bankruptcy in 2026 - Coinbase and Fidelity Digital Assets converted to OCC national trust charters and surrendered/are surrendering their Maine money-transmitter licenses, removing them from BCCP oversight - Federal FinCEN interim final rule (March 2025) exempted all U.S. domestic reporting companies, including Maine-formed entities, from Corporate Transparency Act beneficial-ownership reporting - FATF's March 2024 enhanced follow-up report upgraded the U.S. (the national framework governing Maine) on Recommendation 24 (beneficial ownership) from Non Compliant to Largely Compliant while flagging persistent gaps in timely BO access United States federal law that applies in United States – Maine is covered once, on the [United States](/jurisdictions/us/) page. This page covers United States – Maine’s own layer: its own law, regulators and enforcement. Brief ## Lead signal #### Lead Signal Maine's Bureau of Consumer Credit Protection has closed a two-year investigation into unlicensed virtual-currency kiosk operations by Bitcoin Depot Operating, LLC through a consent agreement effective January 5, 2026. The agreement issues BDO a money-transmitter licence, expiring December 31, 2026, while requiring the company to pay 1.9 million dollars in consumer redress for fraud schemes in which third parties directed victims to send crypto to unhosted wallets. The resolution operationalises two pieces of Maine law that had sat largely untested until now: the 2024 Money Transmission Modernization Act and the 2025 Virtual Currency Kiosk Act, including its unhosted-wallet identification duty under 32 M.R.S. section 6100-UU. That duty survived a 2025 legislative attempt to repeal it, LD 1197, which died in committee on an Ought Not to Pass vote on May 28, 2025, so the identification requirement that the Bitcoin Depot case rests on was never in doubt as a matter of current law, only as a matter of enforcement. Read full brief #### Lead Signal Maine's Bureau of Consumer Credit Protection has closed a two-year investigation into unlicensed virtual-currency kiosk operations by Bitcoin Depot Operating, LLC through a consent agreement effective January 5, 2026. The agreement issues BDO a money-transmitter licence, expiring December 31, 2026, while requiring the company to pay 1.9 million dollars in consumer redress for fraud schemes in which third parties directed victims to send crypto to unhosted wallets. The resolution operationalises two pieces of Maine law that had sat largely untested until now: the 2024 Money Transmission Modernization Act and the 2025 Virtual Currency Kiosk Act, including its unhosted-wallet identification duty under 32 M.R.S. section 6100-UU. That duty survived a 2025 legislative attempt to repeal it, LD 1197, which died in committee on an Ought Not to Pass vote on May 28, 2025, so the identification requirement that the Bitcoin Depot case rests on was never in doubt as a matter of current law, only as a matter of enforcement. #### Other Developments A multistate settlement reaches Maine's payments sector. Maine's Attorney General announced on July 8, 2026 that the state had joined a 45 million dollar multistate settlement with Block, Inc. over deceptive practices on Cash App. The settlement was confirmed through a Tier 1 state index listing; the state-specific allocation of the 45 million dollar total was not located this cycle, leaving the Maine-specific financial consequence of the settlement an open question for now. The statutory architecture behind the kiosk case. Maine's Virtual Currency Kiosk Act requires a kiosk operator to hold a money-transmitter licence, and the Money Transmission Modernization Act's unhosted-wallet identification provision requires kiosk operators to identify the ultimate unhosted-wallet recipient before a transmission is completed. The Bitcoin Depot consent agreement is the first instance this cycle in which both provisions have been applied together against an operator that had been running without a licence for roughly four years, from 2021 to 2025. #### Cross-Monitor Connections The Bitcoin Depot resolution sits at the intersection of this monitor's crypto-asset and AML/CTF tracking: a consumer-fraud pattern built on unhosted-wallet transfers through unlicensed kiosks is precisely the typology that Maine's 2025 kiosk-specific identification duty was designed to interrupt, and its survival through the failed LD 1197 repeal effort means the rule remains available for future enforcement, not just this one case. The Block Inc. Cash App settlement, while framed by Maine's Attorney General primarily as a consumer-protection matter, touches the same payment-company population this monitor tracks for money-transmission and AML exposure, reinforcing that Maine's enforcement activity against payment and crypto intermediaries this year has not been limited to a single sector or a single statute. #### Outlook Watch for two developments. First, Bitcoin Depot's Maine money-transmitter licence expires December 31, 2026; whether it is renewed, and on what terms, will be a signal of whether the consent agreement's conditions were durable or a one-time settlement. Second, the Maine Virtual-Currency Unclaimed Property Act took effect July 29, 2026, bringing virtual currency within the general unclaimed-property abandonment, custody, liquidation and owner-notice regime; this creates a new compliance surface for any crypto-asset operator or custodian holding dormant Maine-linked balances, distinct from the licensing and fraud-redress questions raised by the kiosk case. Earlier periodic briefs (4) 28 Sep 2026 · fim-2026-09-28 #### Lead Signal Maine's Bureau of Consumer Credit Protection has closed out a $1.9 million consent agreement with Bitcoin Depot over kiosk-enabled third-party scam losses, requiring the company to operate going forward as a fully compliant licensed money transmitter under the state's Money Transmission Modernization Act. The settlement is the clearest evidence yet that a small state regulator can move from statute to enforcement outcome within roughly eighteen months, and it lands against the backdrop of the state's emergency Virtual Currency Kiosk Act (PL 2025, c.285), which caps daily kiosk transmission amounts, caps fees and exchange rates, and builds in a consumer redress mechanism that this settlement has now exercised. The architecture matters more than the incident. Maine did not wait for a federal case or a multi-state task force; it legislated a kiosk-specific consumer-protection layer on top of its 2024 money-transmission overhaul, then used that layer within the same year to extract restitution. That sequencing — statute, then swift enforcement — is the structurally significant fact here, more than the dollar figure itself. #### Other Developments Baseline AML/CTF architecture confirmed. Maine's Money Transmission Modernization Act (32 M.R.S. c.79-A, 2024) incorporates the federal Bank Secrecy Act (31 U.S.C. §5311 et seq.) directly into the state licensing regime for money transmission and virtual-currency business activity. This is not a new development so much as a confirmed baseline: state licensure under NMLS runs alongside, rather than replacing, federal FinCEN registration, CTR and SAR obligations for the same entities. Kiosk-fraud Superintendent report status unconfirmed. PL 2025 c.285 required Maine's Superintendent to submit findings and recommendations on kiosk-customer fraud protection by February 1, 2026. Publication status of that report was not located this cycle, leaving a visibility gap on whether the Bitcoin Depot settlement reflects an isolated case or a broader pattern the Superintendent's office has already characterized. Compliance-technology standard remains a gap. No Maine-specific transaction-monitoring or AI/ML standard applicable to kiosk-category money transmitters was identified. The kiosk reforms address fraud typology and consumer redress directly but do not impose a specific technology standard on operators, leaving a model-risk-management gap relative to FinCEN expectations for larger institutions. #### Cross-Monitor Connections The consumer-protection dimension of this settlement — daily transaction caps, fee caps, and unhosted-wallet safeguards — sits squarely in World Payments Monitor's remit on consumer protection and APP fraud, and in the Crypto monitor's consumer-protection module; both should be read as the primary reference points for the non-AML dimensions of this same enforcement action. The AML/CTF baseline finding here, by contrast, is FIM's own to carry: it is the incorporation of BSA obligations into a state money-transmission statute, a structural fact about the regulatory perimeter rather than a consumer-harm finding. #### Outlook Watch for publication of the Superintendent's mandated kiosk-fraud report, which would materially firm up whether Maine's kiosk sector faces a systemic fraud-typology problem beyond the single Bitcoin Depot case. Separately, other states are watching Maine's approach; the CSBS state MTMA legislation tracker suggests kiosk-specific consumer protection statutes of this kind may proliferate across other small-state money-transmission regimes over the coming cycles. No sanctions, beneficial-ownership, conflict-finance, or enabler-jurisdiction signal was identified for Maine this cycle; all activity was concentrated in the crypto/digital-asset and AML/CTF-regime domains. 25 Aug 2026 · fim-2026-08-21 #### Lead Signal Maine has enacted a pair of statutes that materially tighten the state's crypto-kiosk and money-transmission architecture, and the result is worth reading as structural rather than incidental. Public Law Chapter 542, enacted March 3, 2026, authorizes NMLS registration of cash-dispensing machines and expressly prohibits operating such a machine as a virtual-currency kiosk unless the operator holds a Maine money-transmitter licence, while raising the daily noncompliance fine fivefold, from $5 to $25. Signed weeks later, on April 22, 2026, the Money Transmission Modernization Act (LD 2112) goes further, introducing what is characterized as a first-in-the-nation control: a requirement that crypto companies verify a destination digital wallet actually belongs to the customer before completing a self-transfer, a direct response to the self-transfer fraud scripts that have driven a wave of kiosk-enabled elder fraud. Read together, these two enactments convert Maine's crypto-kiosk sector from a lightly licensed cash-adjacent channel into an obligated-entity space with its own verification control, and they arrive alongside a completed enforcement outcome — a roughly $1.9 million consent agreement between the Maine Bureau of Consumer Credit Protection and Bitcoin Depot, compensating consumers defrauded via its kiosks between 2022 and 2025 and requiring the operator to become a licensed money transmitter. Framed through the AML/CTF regime lens, the same enactments read as an expansion of Maine's obligated-entity perimeter rather than merely a consumer-protection fix. Maine's money-transmitter regime under Title 32, Chapter 80 has historically governed the state's crypto AML posture by default, through the general money-transmission licensing framework rather than a crypto-specific AML statute; LD 2112 and PL Chapter 542 tighten that default framework directly, adding a CDD-adjacent control — wallet-ownership verification — precisely where the obligated-entity population (kiosk operators and exchangers) had previously operated with the least oversight. That is the structural significance financial-integrity analysis assigns to this cycle's Maine material: not a new AML statute, but a hardening of the existing one at its weakest point. #### Other Developments The unhosted-wallet verification duty sits inside the state money-transmission statute, not a separate AML law. This is a notable design choice: rather than layering a bespoke crypto-AML regime on top of Title 32, Chapter 80, Maine amended the money-transmitter statute itself, meaning the new customer-due-diligence-adjacent control inherits the licensing, examination, and enforcement architecture that already governs traditional money transmitters. That has the effect of pulling crypto kiosk operators and exchangers into the same obligated-entity perimeter as any other Maine-licensed money transmitter, with the practical consequence that a kiosk operator who was previously outside meaningful state oversight is now inside a licensing, background-check, and NMLS-processing framework. The Bitcoin Depot consent agreement functions as the enforcement proof-of-concept for the new regime. With claims closed April 1, 2026 and refunds expected from May 2026, the settlement demonstrates the state acting against a named operator under the prior framework, immediately before that framework was tightened. The sequencing — enforcement action followed by statutory tightening — is consistent with a regulator using an enforcement outcome to justify and calibrate the scope of a subsequent legislative fix. #### Cross-Monitor Connections This cycle's Maine crypto-kiosk material connects directly to both the World Payments Monitor and the Crypto monitor tracking the same jurisdiction. World Payments' W1a (Licensing, Authorisation & Market Access) and W10 (Consumer Protection & APP Fraud) domains cover the same LD 2112 and PL Chapter 542 enactments from a payments-market-structure and APP-fraud lens respectively, while the Crypto monitor's crypto_licensing and consumer_protection modules address the identical statutes from a token/VASP-licensing and crypto-consumer-harm lens. All three monitors are drawing on the same underlying Maine statutory changes; the financial-integrity read foregrounds the AML/CTF obligated-entity architecture implication of pulling kiosk operators into the money-transmitter perimeter, which is the framing least visible from a pure payments or pure crypto vantage point. #### Outlook The Maine Bureau of Consumer Credit Protection's rulemaking following LD 2112 and PL Chapter 542 is expected in the fourth quarter of 2026, and the evidence base already signals uneven industry readiness: general industry practice has lagged the new unhosted-wallet-verification and licensing requirements, with some kiosk operators reportedly withdrawing machines from the state rather than comply. That gives the coming cycle two things to watch: whether the finalized rulemaking text hardens or softens the practical compliance bar the statutes established, and whether kiosk-operator attrition in Maine becomes a template other states reference either as a model of successful tightening or as a cautionary tale about liquidity withdrawal from a regulated cash-to-crypto channel. The largest sourcing gap carried into next cycle is the absence of independently retrieved primary statute text for both PL Chapter 542 and LD 2112, relied on this cycle through T3 law-firm secondary reporting. 11 Aug 2026 · fim-2026-08-05 #### Lead Signal On 16 June 2026 the UK designated 70 individuals and entities under expanded Russia sanctions powers, including 27 shadow-fleet vessels used to transport Russian oil and LNG -- one of the more substantial single-day designation packages of the year, targeting shadow-fleet logistics, military procurement, and financial networks together. The same architecture, however, is not moving in a single direction: on 31 March 2026, OFAC removed three Russian-flagged vessels -- FESCO Moneron, FESCO Magadan, and SV Nikolay -- from the SDN list within what was characterised as a routine counter-narcotics delisting batch, a quieter and less-scrutinised move that sits awkwardly beside the UK's expansion. Read architecture-over-incident, the divergence is the story: the overall sanctions perimeter against Russia continues to tighten, but the pace and direction of that tightening is no longer uniform across the US and UK. This sits against continued churn at the multilateral layer: the FATF's June 2026 plenary added Bosnia and Herzegovina and Iraq to its grey list and removed Algeria and Namibia, re-weighting the sanctions and customer-due-diligence risk inputs obliged entities apply to counterparties in those jurisdictions. #### Other Developments Beneficial ownership divergence widens. A May 2026 GAO report found that FinCEN's March 2025 interim final rule, which suspended Corporate Transparency Act beneficial-ownership reporting for US companies and persons, now exempts over 99 percent of previously reportable entities from BOI reporting. This lands as the EU's AML Package advances toward its own 10 July 2026 milestone, at which core beneficial-ownership-register provisions and AMLA's technical standards are due, even though a third of member states missed the July 2025 transposition deadline for BO-register access. Cambodia's enabler-jurisdiction exposure sharpens. Cambodia's National Bank governor has publicly warned of a renewed FATF grey-listing risk tied to scam-compound and casino-linked laundering, a warning punctuated by the arrest and extradition to China of Prince Group chairman Chen Zhi, and the National Bank of Cambodia's forced liquidation of Prince Bank. Fiscal fuel theft surfaces as CJNG's leading non-drug revenue stream. FinCEN issued a supplemental alert on fuel-smuggling and tax-evasion schemes tied to CJNG's huachicoleo operations, identifying it as the cartel's largest non-drug illicit-revenue source, concurrent with an OFAC sanctions action on 30 June 2026 against two Mexican nationals and nine entities. Model-risk supervision is modernised for AI-era transaction monitoring. The Federal Reserve, OCC, and FDIC issued SR 26-2 in April 2026, replacing SR 11-7 after more than a decade, to modernise model-risk-management expectations for AI/ML transaction-monitoring systems -- though generative and agentic AI are explicitly excluded from the new guidance's formal scope. A parallel FinCEN proposal would let the agency's Director weigh a firm's AI/technology adoption as evidence of programme effectiveness in enforcement decisions; its comment period closed 9 June 2026. #### Cross-Monitor Connections The Cambodia enabler-jurisdiction signal, in which Prince Bank was forced into liquidation by a state institution, and the CJNG fiscal-fuel-theft signal both illustrate architecture captured or exploited by illicit enterprise before a correction is imposed -- a pattern with direct read-across to WDM's state-capture lens and to ERM's commodity-flow tracking, given fuel theft's extractive-industry adjacency. The sanctions-architecture divergence between UK expansion and OFAC's quieter delisting is a natural feed to SCEM's conflict-finance tracking, since shadow-fleet logistics and CJNG-linked entities both sit within broader illicit-financing networks monitored from different vantage points. The compliance-technology shift toward AI-adoption-as-evidence-of-effectiveness also intersects with FCW's information-operations lens, insofar as AI-driven detection and AI-driven obfuscation are converging capabilities across both monitoring and evasion. #### Outlook The next material test for the EU AML Package is AMLA's 10 July 2026 deadline to publish its technical-standards package alongside the BO-register provisions; slippage here, layered onto the member states that already missed the July 2025 transposition deadline, would widen rather than narrow the transatlantic beneficial-ownership gap this cycle has already flagged. On sanctions, watch whether OFAC's routine delisting activity continues alongside UK's expansion, since sustained divergence would itself become the analytically significant pattern rather than either single action. Cambodia's grey-listing exposure and Prince Bank's liquidation process are worth tracking for whether enforcement follows the enablement, or whether the correction remains episodic, and whether the SR 26-2 / FinCEN effectiveness-based proposal pairing produces a follow-on rule addressing the generative and agentic AI gap left open this cycle. 14 Jul 2026 · fim-2026-07-14 #### Lead Signal The operative status of the largest crypto-automated-teller-machine network in the United States has changed in a manner the prior baseline did not capture. Bitcoin Depot, whose approximately 9,700-kiosk footprint made it the dominant cash-to-crypto conversion channel implicated in elder and romance-scam cashouts, filed for Chapter 11 bankruptcy on 18 May 2026 and took its network offline nationwide. This supersedes the January 2026 Maine and Nevada consumer-protection settlement as the operative fact: the settlement addressed licensing and consumer-protection failures at a single operator, while the subsequent collapse removes that operator from the market entirely, though the underlying cash-to-crypto scam-cashout architecture persists industry-wide at reduced scale. This kiosk-level correction sits inside a wider structural pattern this cycle: federal policy is simultaneously withdrawing beneficial-ownership transparency obligations, preempting state-level crypto oversight, and building a new federal compliance-technology layer for stablecoins. The March 2025 interim final rule exempting all United States domestic entities from Corporate Transparency Act reporting removed the disclosure mechanism the Financial Action Task Force had credited only a year earlier in upgrading the United States to Largely Compliant on Recommendation 24. Concurrently, major virtual-asset firms are converting to Office of the Comptroller of the Currency national trust charters, a federal-preemption pathway that removes them from Maine licensing and from the wallet-verification and consumer-protection reach of the Maine Bureau of Consumer Credit Protection. Read together, these are not three separate incidents but one architecture: federal deregulation and preemption are outpacing, and in places reversing, state-level and internationally credited transparency gains, even as targeted federal enforcement against scam-infrastructure actors continues in parallel. #### Other Developments Sanctions designations targeted scam-compound and procurement infrastructure rather than end-user accounts. OFAC designated 146 individuals and entities tied to the Prince Group Transnational Criminal Organization on 14 October 2025, coordinated with a Department of Justice indictment of Chen Zhi and a record 15 billion dollar civil bitcoin forfeiture connected to Cambodian forced-labor scam compounds that victimized United States consumers, including in Maine; United Kingdom action was coordinated, though the European Union had not mirrored the listing at baseline. One month later, OFAC designated the Democratic Karen Benevolent Army, a Burma-based armed group, its senior leadership, and Chinese organized-crime-linked companies for enabling scam-compound territorial control, part of a Strike Force effort that has seized more than 401 million dollars in cryptocurrency. A Section 311 action severed a laundering hub from the United States financial system. FinCEN designated Huione Group a financial institution of primary money-laundering concern under Section 311, cutting its correspondent-banking access after the entity served as an enabler for Southeast Asian pig-butchering scam infrastructure victimizing United States consumers. A sanctions-removal decision diverges from the coordinated posture seen elsewhere. Treasury removed a Russia-related designation in April 2025 without a parallel European Union or United Kingdom delisting, a documented divergence point bearing on correspondent-banking compliance for any Maine-domiciled institution with cross-border exposure. Maine has no independent backstop against the federal transparency rollback. No state-level beneficial-ownership registry exists to offset the domestic Corporate Transparency Act exemption, and federal residential real-estate Geographic Targeting Orders do not extend to Maine markets, leaving anonymous limited-liability-company real-property purchases outside enhanced federal reporting. A joint rulemaking will set the compliance-technology floor for stablecoin-adjacent money-services businesses. The FinCEN and OFAC joint proposed rule implementing Anti-Money-Laundering and sanctions-compliance-program requirements for Permitted Payment Stablecoin Issuers under the GENIUS Act closed its comment period on 9 June 2026; the final rule will govern screening and freeze-capability expectations for stablecoin-adjacent money-services businesses licensed or domiciled in Maine. Supervisory expectations for kiosk operators were formalized even as the sector contracted. FinCEN issued Notice FIN-2025-NTC1 in August 2025 urging convertible-virtual-currency kiosk operators and financial institutions nationwide, including in Maine, to strengthen suspicious-activity identification given a documented surge in kiosk-facilitated elder and romance-scam losses; separately, the Maine Bureau of Consumer Credit Protection promulgated and then narrowed a wallet-ownership-verification rule after industry pressure and the threat of federal intervention, illustrating the tension between proactive state-level rulemaking and federal or industry pushback. #### Cross-Monitor Connections Two findings this cycle route beyond the financial-integrity lens on their own terms. The Democratic Karen Benevolent Army designation ties an armed non-state actor directly to scam-compound revenue, a conflict-finance signal relevant to SCEM tracking of non-state armed-group financing. Separately, the scale of the Prince Group forfeiture and the embeddedness of its forced-labor scam compounds inside Cambodian territory raise a state-capture question, whether Cambodian authorities have protected or merely failed to interdict this infrastructure, that this cycle does not resolve within a Maine-scoped jurisdiction file but flags for WDM kleptocratic state-capture tracking. Neither connection is asserted here as established; both are surfaced as the analytically significant edges of an otherwise United States domestic-architecture story. #### Outlook Three developments will determine whether this cycle marks a durable inflection or a plateau. FinCEN intends to finalize the domestic Corporate Transparency Act exemption during 2026, which would entrench rather than revisit the current beneficial-ownership blind spot absent any Maine state backstop. The GENIUS Act reaches full implementation by 18 January 2027, and the joint FinCEN and OFAC Permitted Payment Stablecoin Issuer rule is expected to finalize in the third quarter of 2026, together setting a new federal compliance-technology bar that will interact with, and in places supersede, state licensing regimes including the one operated by Maine. Scheduling of the next Financial Action Task Force mutual evaluation of the United States under the 2022 methodology remains unconfirmed, leaving the tension between the March 2024 Recommendation 24 upgrade and the March 2025 domestic exemption analytically unresolved for now. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion This cycle records a coordinated pattern of United States sanctions action against scam-compound infrastructure alongside one point of unilateral divergence. On 14 October 2025, OFAC designated 146 individuals and entities tied to the Prince Group Transnational Criminal Organization, coordinated with a Department of Justice indictment of Chen Zhi and a record 15 billion dollar civil bitcoin forfeiture linked to forced-labor scam compounds in Cambodia that victimized United States consumers, including residents of Maine. United Kingdom authorities coordinated on the action, though the European Union had not mirrored the listing at the point this cycle was assessed, an incomplete multilateral convergence worth tracking rather than treating as settled alignment. One month later, on 12 November 2025, OFAC designated the Democratic Karen Benevolent Army, a Burma-based armed group, together with its senior leadership and Chinese organized-crime-linked companies, for enabling territorial control over scam-compound operations targeting Americans. That designation forms part of a coordinated Scam Center Strike Force effort that has seized more than 401 million dollars in cryptocurrency to date, indicating sustained rather than episodic federal attention to this infrastructure class. Continue reading A parallel and structurally significant action came through FinCEN rather than OFAC. FinCEN designated Huione Group a financial institution of primary money-laundering concern under Section 311, severing its correspondent-banking access. Huione functioned as an enabling node for Southeast Asian pig-butchering scam infrastructure that victimized United States consumers, including in Maine, and the Section 311 mechanism, distinct from an SDN listing, illustrates a second and less frequently examined layer of the sanctions architecture: the capacity to isolate a jurisdiction-adjacent laundering hub from the correspondent-banking system entirely rather than list individual beneficiaries. Against this pattern of targeted, infrastructure-level action sits a documented point of unilateral divergence. Treasury removed a Russia-related sanctions designation in April 2025 without a parallel European Union or United Kingdom delisting, even as counter-terrorism designations against other targets continued. For any Maine-domiciled institution carrying cross-border correspondent-banking exposure, this divergence is not abstract: screening logic calibrated to a single regime risks either over- or under-inclusion relative to partner-jurisdiction lists, and the absence of a parallel EU or UK action means the divergence persists as a live compliance variable rather than a one-off correction. Architecture-over-incident framing is warranted here: the individual delisting is a data point, but the recurring pattern of asynchronous US, EU, and UK sanctions timing across this cycle, from partial Prince Group mirroring to the unmirrored Russia removal, is the durable structural signal for correspondent-banking screening design. The severity read for this domain is elevated and the trajectory is deteriorating, not because enforcement volume has declined, but because the evasion and divergence architecture around scam-compound financing and cross-regime sanctions timing is expanding even as headline designation activity continues. The Maine-specific angle throughout is one of victimization and correspondent-exposure risk rather than facilitation: no Maine-domiciled entity is implicated as an enabler in any of this cycle's designations, but Maine consumers are named victims of the Prince Group and Huione-linked infrastructure, and Maine-domiciled institutions carry the correspondent-banking exposure created by the Russia delisting divergence. #### Outlook The near-term trajectory depends on whether the European Union moves to mirror the Prince Group and Democratic Karen Benevolent Army designations, a step that would tighten the multilateral net around scam-compound financing, and on whether the unmirrored Russia-related delisting is revisited or allowed to stand as a durable US-EU-UK divergence point. Neither outcome is assessed here beyond the possible tier, given the absence this cycle of EU-side primary sourcing confirming or denying mirroring status. Continued Section 311 and Strike Force activity suggests sustained federal appetite for infrastructure-level rather than individual-level sanctions actions, a pattern likely to continue independent of the mirroring question. Judgment: No Maine-specific sanctions-architecture signal found this cycle; single-JID binding did not re-query global trackers. Uncertain #### Beneficial Ownership and Corporate Transparency For Maine, the directly relevant beneficial-ownership development this cycle is domestic and federal rather than European. Following Treasury's March 2025 policy shift, FinCEN's interim final rule redefined reporting company under the Corporate Transparency Act to exclude all United States domestic entities, meaning Maine-formed limited liability companies and corporations, whether used for real-estate holding, timberland investment, or small-business layering, now face zero mandatory federal beneficial-ownership disclosure. Maine has no independent state-level ultimate-beneficial-owner registry to backstop this exemption, and federal residential real-estate Geographic Targeting Orders do not extend to Maine markets, so the state currently has no disclosure mechanism, federal or state, reaching anonymous domestic-entity structures. FinCEN intends to finalize this interim exemption during 2026 following comment, which would entrench rather than reopen the current gap absent any Maine-level legislative response. Continue reading The architecture-over-incident significance of this rollback is sharpened by its interaction with the Financial Action Task Force mutual-evaluation record. The United States was upgraded on Recommendation 24 from Non Compliant to Largely Compliant in March 2024, with the Corporate Transparency Act cited as the primary basis for that upgrade. The March 2025 domestic-entity exemption removed the very transparency mechanism the Financial Action Task Force had credited, one year after the upgrade was issued, a temporal contradiction that no located Financial Action Task Force commentary has yet addressed. The United States remains, as of the March 2024 follow-up, rated 9 Compliant, 23 Largely Compliant, 5 Partially Compliant, and 3 Non Compliant across the 40 Recommendations, still in 4th-round enhanced follow-up with 5th-round scheduling unconfirmed; any future re-rating will directly test whether Recommendation 24 credit survives the domestic rollback. Globally, the European Union AML Package sets the structural direction for beneficial-ownership and corporate-transparency supervision, and it is worth stating that architecture plainly as durable backdrop, even though it does not directly govern Maine. The package comprises three distinct instruments: the directly applicable AML Regulation, known as the AMLR, under Regulation (EU) 2024/1624; the sixth Anti-Money-Laundering Directive, or 6AMLD, which each member state transposes individually rather than applying uniformly; and the AMLA Regulation, Regulation (EU) 2024/1620, which establishes the Anti-Money-Laundering Authority and creates a hybrid EU-level direct and indirect supervisory perimeter over higher-risk obliged entities, shifting supervision away from a purely national-authority model. Maine sits entirely outside this perimeter as a United States sub-national jurisdiction, and 6AMLD transposition tracking is not applicable to it; the relevant point of comparison is structural rather than jurisdictional, since the European trajectory toward centralised, EU-level beneficial-ownership interconnection and direct supervision runs in the opposite direction from the current United States trajectory of federal preemption and disclosure withdrawal documented for Maine this cycle. #### Outlook The trajectory for this domain, as it bears on Maine, is deteriorating and structural rather than episodic. Finalization of the domestic Corporate Transparency Act exemption in 2026 would remove any near-term prospect of federal beneficial-ownership disclosure applying to Maine-formed entities, and no Maine state registry initiative has been identified this cycle to fill the gap. The unresolved Financial Action Task Force Recommendation 24 tension is the key indicator to watch: any Financial Action Task Force commentary addressing the domestic exemption, or confirmation of 5th-round evaluation scheduling, would materially clarify whether the March 2024 upgrade is durable or due for reassessment. Judgment: No Maine-specific beneficial-ownership development found this cycle. Uncertain #### Enabler Jurisdictions and Professional Facilitators The defining development in this domain this cycle is not a permissive jurisdiction opening the door to illicit finance but a federal-preemption mechanism structurally removing a comparatively activist state regulator from the oversight picture. Major virtual-asset firms, including Coinbase, Fidelity Digital Assets, and Paxos, are converting to Office of the Comptroller of the Currency national trust charters, a federal designation that confers preemption immunity against a wide range of state-regulator actions. In practice, this means these firms surrender their Maine money-transmitter licenses and, with them, exit from the Maine Bureau of Consumer Credit Protection wallet-verification and consumer-protection enforcement regime entirely. The conversion wave is reported to have accelerated sharply in early 2026, with eleven firms converting within an 83-day window, a pace that, if independently corroborated, would represent a materially faster erosion of state-level oversight capacity than the prior baseline characterized as a steady-state dynamic; that acceleration detail is treated as assessed rather than confirmed pending independent verification beyond a single source. Continue reading This is an enabler-jurisdiction finding of an unusual type: Maine itself is not the permissive jurisdiction. Rather, the federal charter-conversion mechanism functions as a jurisdiction-shopping tool available to firms operating in Maine and other states, allowing them to exit state oversight without physically relocating. The analytically significant question this raises is one of capacity versus choice: Maine Bureau of Consumer Credit Protection has demonstrated a willingness to regulate proactively, evidenced by its own wallet-verification rulemaking and its participation in the Bitcoin Depot multi-state enforcement action, but that willingness is being structurally outflanked by a federal mechanism operating above the state level, a capacity deficit imposed from outside rather than a policy choice made by Maine regulators themselves. The compounding effect with the domain 2 beneficial-ownership finding is direct: as OCC-chartered firms exit Maine licensing, and as the domestic Corporate Transparency Act exemption removes federal beneficial-ownership disclosure for Maine-formed entities, the aggregate oversight surface reaching virtual-asset activity connected to Maine narrows on two independent axes simultaneously. Neither development alone would be severity-defining, but together they describe a jurisdiction whose state-level enforcement apparatus is being reduced in scope by federal action even as it continues to act within its narrowing remit. #### Outlook The severity read here is high and the trajectory deteriorating, reflecting a structural capacity-deficit dynamic rather than any single enforcement episode. The key open question is whether the reported acceleration in OCC charter conversions is independently corroborated in a subsequent cycle through primary-source corporate-decision-letter documentation; absent that corroboration, the pace of state-oversight erosion remains an assessed rather than a confirmed trajectory. A second indicator to watch is whether Maine Bureau of Consumer Credit Protection responds to this erosion with new rulemaking targeting the entities that remain within its jurisdiction, or whether the narrowing of its own wallet-verification rule after industry pressure, recorded separately in domain 6, signals a broader retreat from proactive posture. Judgment: No Maine-specific enabler-jurisdiction development found this cycle. Uncertain #### Conflict Finance and Extractive-Industry Integrity No Maine-specific conflict-finance or extractive-industry finding was identified this cycle; the domain tracker for this jurisdiction file records a stable trajectory, a monitored severity level, and an empty developments list. Honesty over coverage governs this brief: rather than invent a Maine-specific extractive-industry angle where none exists in the evidence base, this brief re-frames, at reduced length, the one piece of this cycle's evidence that carries a conflict-finance dimension under the applicable analytical filter. OFAC's 12 November 2025 designation of the Democratic Karen Benevolent Army, a Burma-based armed group, together with its senior leadership and Chinese organized-crime-linked companies, was flagged under the conflict-finance filter because the group is assessed to have provided territorial control enabling scam-compound operations, functioning as an armed-actor revenue and protection mechanism rather than a conventional financial-services facilitator. Separately, the scale of the Prince Group Transnational Criminal Organization forfeiture, tied to Cambodian forced-labor scam compounds, raises an unresolved question about the relationship between the compound economy and territorial or state authority in Cambodia, a question this jurisdiction file does not resolve and flags instead for cross-monitor attention. Continue reading Neither finding constitutes a Maine-domiciled conflict-finance or extractive-industry signal in the conventional sense used elsewhere in this domain; both are United States federal actions against foreign armed-actor and criminal-network financing that happen to intersect this cycle's Maine-consumer-victimization narrative rather than any Maine-based extractive or conflict-adjacent financial activity. #### Outlook This domain remains monitored rather than elevated for the Maine jurisdiction file. The armed-actor financing dimension of the Democratic Karen Benevolent Army designation is being tracked for potential escalation through the SCEM cross-monitor channel rather than through this brief, and no independent extractive-industry signal touching Maine has emerged this cycle. Judgment: Not applicable to Maine's sub-national regime; no conflict-finance nexus found this cycle. Probable #### Crypto, Digital Assets, and Financial Innovation Maine's Bureau of Consumer Credit Protection, working with the Attorney General, concluded a two-year investigation into unlicensed virtual-currency-kiosk operations by Bitcoin Depot Operating, LLC. The resulting consent agreement, effective January 5, 2026, issues BDO a money-transmitter licence expiring December 31, 2026, conditioned on the company paying 1.9 million dollars to compensate Maine consumers who were defrauded by third parties directing them to send cryptocurrency to unhosted wallets. The case is the clearest operationalisation yet of Maine's 2024 Money Transmission Modernization Act and its 2025 companion, the Virtual Currency Kiosk Act, which together require kiosk operators to be licensed as money transmitters and to identify the ultimate unhosted-wallet recipient before completing a transmission. That identification duty, codified at 32 M.R.S. section 6100-UU, was the subject of a 2025 repeal attempt, LD 1197, which died in committee on an Ought Not to Pass vote on May 28, 2025 and therefore remains in force exactly as it stood before the bill was introduced. Continue reading A second development reshapes the custody and recovery landscape for digital assets held in Maine: the Virtual-Currency Unclaimed Property Act took effect July 29, 2026, recognising virtual currency as an unclaimed-property type subject to the state's general abandonment, custody, liquidation and owner-notice and recovery rules. For any crypto-asset operator or custodian holding Maine-linked balances that go dormant, this creates a compliance obligation distinct from, and additional to, the licensing and consumer-redress questions raised by the Bitcoin Depot case. Taken together, the kiosk enforcement action and the unclaimed-property statute show a state regime that is moving from dormant statutory authority toward active application across more than one point in the crypto-asset lifecycle: onboarding and transaction-level identification on one hand, and custody and dormancy on the other. #### Outlook The near-term signal to watch is whether Bitcoin Depot's money-transmitter licence, which expires December 31, 2026, is renewed and on what terms; a renewal under unchanged conditions would suggest the consent agreement functioned as a template for bringing a previously unlicensed operator into compliance, while a non-renewal or further condition would suggest continuing concern. Separately, the unclaimed-property regime's interaction with ongoing kiosk and exchange operations in Maine has not yet been tested in practice, and the Bureau's own statutorily-mandated kiosk-fraud report, due February 1, 2026, had not been located as of this cycle's research. Judgment: Maine's BCCP concluded a two-year investigation into unlicensed virtual-currency-kiosk operations by Bitcoin Depot via a consent agreement: BDO receives a money-transmitter licence while paying $1.9M in consumer redress for unhosted-wallet-linked fraud, operationalising the state's 2024 MMTMA and 2025 Virtual Currency Kiosk Act. Probable #### Compliance Technology and Active Defence This cycle records a supervisory-expectation-setting action and a state-level rulemaking retreat operating on the same underlying problem: kiosk-facilitated scam cashouts. FinCEN issued Notice FIN-2025-NTC1 on 4 August 2025, urging convertible-virtual-currency kiosk operators and financial institutions nationwide, including in Maine, to strengthen suspicious-activity identification given a documented surge in kiosk-facilitated elder and romance-scam losses. The Notice sets supervisory expectations that examiners are positioned to apply against any kiosk money-services business operating in Maine, functioning as an active-defence baseline distinct from, and issued prior to, the January 2026 Maine-Nevada settlement and the May 2026 Bitcoin Depot bankruptcy recorded elsewhere in this cycle. Continue reading At the state level, the Maine Bureau of Consumer Credit Protection had itself moved proactively on the same problem, promulgating a wallet-ownership-verification rule intended to interdict romance and pig-butchering scam cashouts at the point of kiosk transaction. That rule was subsequently narrowed following industry pressure, reported specifically as pressure from Coinbase, and the threat of federal intervention. This sequence illustrates a recurring tension in the compliance-technology and active-defence domain: a state regulator identifies a proactive, transaction-level control mechanism, moves to implement it, and then narrows that mechanism under pressure from the regulated industry and the prospect of federal preemption, the same preemption dynamic recorded structurally in domain 3 through OCC national trust charter conversions. Read together, the FinCEN Notice and the Maine rule-narrowing episode describe a compliance-technology environment in which supervisory expectations for red-flag identification are rising in principle, through federal guidance, while the specific, proactive state-level control most directly responsive to the kiosk-scam problem was weakened in practice. This is not necessarily a contradiction: federal guidance sets a floor for suspicious-activity identification broadly, while the narrowed Maine rule concerned a more specific verification mechanism; but the juxtaposition is analytically significant because it shows active-defence rulemaking facing headwinds precisely where it is most transaction-specific and industry-facing. #### Outlook The trajectory for this domain is watch rather than clearly deteriorating or improving, reflecting the countervailing pull between rising federal supervisory expectations and narrowed state-level proactive rulemaking. The indicator to track is whether Maine Bureau of Consumer Credit Protection attempts a revised or alternative version of its wallet-verification mechanism, and whether FinCEN examiners begin citing the August 2025 Notice in subsequent kiosk-related supervisory or enforcement actions touching Maine-operating money-services businesses. Judgment: No RegTech/active-defence development found for Maine this cycle; D6 is exempt from the substantive-finding floor. Uncertain #### AML/CTF Regime Maine's AML/CTF posture for crypto-adjacent activity runs through its general money-transmitter regime under Title 32, Chapter 80, rather than through a freestanding crypto-AML statute, and this cycle's developments tighten that regime at exactly the obligated-entity population — kiosk operators and virtual-currency exchangers — that had previously carried the lightest oversight. The Money Transmission Modernization Act (LD 2112), signed April 22, 2026, and Public Law Chapter 542, signed March 3, 2026, jointly narrow the scope for unlicensed operation: PL Chapter 542 requires a Maine money-transmitter licence before a cash-dispensing machine may be operated as a virtual-currency kiosk, while LD 2112 introduces a customer-due-diligence-adjacent control requiring verification that a destination digital wallet actually belongs to the customer receiving funds. Read through the AML/CTF lens specifically, that verification duty functions analogously to a beneficiary-verification check within a payment chain: it is not a traditional CDD/KYC-at-onboarding control, but a transaction-time control aimed at a specific typology (scripted self-transfer fraud) that the traditional onboarding-stage CDD regime does not reach. Continue reading This is an important distinction for AML program design: a money transmitter that has already onboarded a customer through standard identity verification can still be the unwitting instrument of a self-transfer fraud, because the fraud operates by manipulating the customer into transferring their own funds to a wallet the customer believes is theirs. Maine's new verification duty inserts a control at the transaction stage rather than relying solely on onboarding-stage CDD, which is a meaningful architectural choice regardless of the confidence level attached to the specific enacting statute's text. The Bitcoin Depot consent agreement adds a compliance-program dimension to this cycle's AML/CTF picture: the settlement requires the operator to become a licensed money transmitter, which brings it inside Maine's AML-adjacent supervisory perimeter (examination rights, licensing conditions, and the new wallet-verification duty) for the first time. Viewed architecturally, the settlement functions less as a one-off financial penalty and more as an onboarding event into the state's obligated-entity population, which is the more durable outcome from an AML/CTF program-design perspective than the dollar figure of the settlement itself. The state's overall AML/CTF trajectory this cycle is assessed as a watch item rather than a settled improvement: the developments are structural and are expected to persist, but Maine's underlying obligated-entity architecture is unchanged in its basic form — the money-transmitter licence remains the operative AML instrument, and what has changed is the scope of who must hold that licence and what additional transaction-level control they must apply, not the creation of a new supervisory body or reporting regime. Consistent with the three-pillar balance principle, this cycle's Maine evidence sits almost entirely on the AML side of the ledger; no counter-terrorist-financing-specific or counter-proliferation-financing-specific finding was identified for the state's crypto-kiosk sector, and that absence should be read as a research gap rather than a clean CTF finding, particularly given that crypto kiosks have historically been flagged elsewhere as a channel of interest for CTF-adjacent typologies. No independent evidence was identified this cycle regarding STR/CTR-equivalent thresholds or a designated-reporting-entity list beyond the money-transmitter licence category; the AML/CTF read here is therefore built entirely from the licensing and consumer-protection statutes rather than from a dedicated AML supervisory filing. #### Outlook Maine Bureau of Consumer Credit Protection rulemaking expected in the fourth quarter of 2026 will determine whether the wallet-verification duty is implemented as a specific technical standard or left as a principles-based obligation for licensees to satisfy through their own procedures. That implementation choice will materially affect the practical AML/CTF compliance lift for licensed money transmitters operating kiosks or exchanges in Maine. Analysts should also watch whether Maine's approach becomes a template referenced in other states' money-transmission modernization efforts, given that the underlying fraud typology is not unique to Maine. Judgment: Maine's AML/CTF architecture for crypto-adjacent and money-transmission businesses runs through MMTMA licensing (32 M.R.S. ch. 79-A) layered under federal BSA/FinCEN MSB registration; there is no Maine-specific FIU or state SAR regime distinct from federal BSA reporting. Probable #### Commercial Activity Two commercial-regulatory events mark this cycle for Maine. First, Bitcoin Depot Operating, LLC's consent agreement with the Bureau of Consumer Credit Protection, effective January 5, 2026, combines a grant of money-transmitter licensure with a 1.9 million dollar consumer-redress payment, resolving roughly four years of unlicensed virtual-currency-kiosk operation in the state. The commercial substance of the agreement is notable in its structure: rather than purely punitive, it pairs a licensing pathway into the regulated market with a redress obligation tied to specific identified consumer harm, giving the company a route to continued lawful operation in Maine conditioned on the licence remaining in force through December 31, 2026. Continue reading Second, Maine's Attorney General announced on July 8, 2026 that the state had joined a 45 million dollar multistate settlement with Block, Inc. over deceptive practices on its Cash App product. The settlement was confirmed through a Tier 1 state announcement, though the state-specific dollar allocation to Maine within the larger multistate total has not been located this cycle. Both events touch payment and crypto-adjacent intermediaries operating in Maine and both proceeded through regulatory or prosecutorial settlement rather than contested litigation to judgment, consistent with a state posture of resolving financial-intermediary compliance gaps through negotiated licensing and redress terms rather than exclusively through penalty. #### Outlook The unresolved item from the Block Inc. settlement, Maine's specific share of the 45 million dollar total, is the most immediate open question; its eventual disclosure would sharpen the picture of how Maine's consumer-protection enforcement against large payment platforms compares in scale to the more narrowly targeted Bitcoin Depot resolution. More broadly, both cases this cycle suggest Maine's financial-intermediary enforcement, across both crypto-kiosk and mainstream payment-app channels, is currently active rather than dormant, a posture worth tracking for whether it extends to other payment companies operating in the state. Judgment: Maine AG joined a $45M multistate settlement with Block Inc. over Cash App deceptive practices (announced July 8, 2026); Maine-specific allocation not located this cycle. Bitcoin Depot's consent agreement and MTL licensure is also a D8 commercial/regulatory event. Probable Regulatory horizon No dated horizon items this cycle. 3 items tracked without a confirmed date. 3 pending date · baseline financial-integrity-2026-07-05 Role action cards MLRO ### Maine resolved a two-year unlicensed-kiosk investigation via consent agreement combining licensure with $1.9M consumer redress. The Bitcoin Depot consent agreement confirms active application of Maine's unhosted-wallet identification duty and money-transmitter licensing requirement against a previously unlicensed crypto-kiosk operator, a reportable-activity pattern relevant to any MLRO overseeing kiosk or crypto-adjacent payment channels with Maine exposure. 2 evidence refs Compliance ### Maine's unhosted-wallet identification rule survived a 2025 repeal attempt and is now the basis of an active enforcement resolution. LD 1197's failure in committee confirms the continued force of 32 M.R.S. section 6100-UU; compliance functions overseeing crypto-kiosk or money-transmission licensees with Maine exposure should treat this identification duty as a stable control-framework requirement, not a contested one. 3 evidence refs Board ### Maine joined a $45 million multistate settlement with Block, Inc. over Cash App practices, alongside a separate $1.9 million crypto-kiosk redress resolution. Two separate financial-intermediary enforcement resolutions in one state within the same reporting period signal an active state-level enforcement posture against payment and crypto-adjacent firms, a reputational and financial-crime-risk consideration for institutions with Maine-exposed payment or crypto operations. 2 evidence refs CTO ### Maine's new unclaimed-property regime for virtual currency, in force since July 29, 2026, creates a custody and dormancy compliance surface for crypto infrastructure. Crypto-asset operators and custodians with Maine-linked account holders now need technical processes to detect and report dormant virtual-currency balances under the state's abandonment, custody and liquidation rules, a new data and platform requirement layered onto existing wallet-identification infrastructure. 1 evidence refs Risk ### Active enforcement against both a crypto-kiosk operator and a major payment app signals rising episodic enforcement risk in Maine's financial-intermediary sector. The combination of the Bitcoin Depot consent agreement and the Block Inc./Cash App multistate settlement indicates Maine's enforcement posture this period is episodic but concentrated on payment and crypto intermediaries, raising exposure-concentration considerations for institutions with operations spanning both sectors in the state. 2 evidence refs Audit ### Maine's kiosk enforcement rests on secondary-source corroboration for some elements, with the Bureau's own mandated fraud report not yet located. Audit functions reviewing documentation adequacy for the Bitcoin Depot matter should note that the Bureau's statutorily-mandated February 1, 2026 kiosk-fraud report was not located this cycle, and the Maine-specific allocation within the Block Inc. settlement total remains undocumented, both representing gaps in the available evidentiary record. 2 evidence refs Scenario sketches ### AMLA transition reshaping cross-border supervisory and evasion dynamics Illustrative scenario for analytical orientation only: as the EU moves from purely national AML supervision toward AMLA direct and indirect supervision of cross-border obliged entities under the AMLA Regulation, alongside the directly-applicable AMLR and per-state 6AMLD transposition, evasion actors accustomed to exploiting divergent national supervisory intensity could face a narrower set of jurisdictional gaps within the EU perimeter, potentially displacing some layering activity toward non-EEA venues with lighter, more fragmented state-level oversight. This is architecture-over-incident illustration, not an observed development in any specific jurisdiction including Maine. 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 No Maine-specific or Russia/Houthi-Yemen-linked material found this cycle under single-JID binding. T2 · EU AML Package / AMLA no_change Not applicable — US-ME is outside the EEA/AMLR/6AMLD/AMLA perimeter. T3 · FATF Grey List no_change United States is not FATF grey-listed; no change at the US-ME sub-national level. T4 · Beneficial-Ownership Register Status no_change No Maine-specific BO-register development found this cycle; federal CTA status unchanged at state level. T5 · Crypto & Digital-Asset Integrity material_change Bitcoin Depot consent agreement (licensing + $1.9M redress) operationalises Maine's unhosted-wallet / virtual-currency-kiosk regime. T6 · Sanctions Regime Divergence no_change No Maine-specific sanctions-divergence signal found this cycle. Registers ### Enforcement actions - 5 Jan 2026 - 14 Oct 2025 - 12 Nov 2025 - 4 Aug 2025 - 25 Jun 2025 - 23 Jun 2026 - 30 Jun 2026 - 5 Jan 2026 - 5 Jan 2026 - 8 Jul 2026 - Maine and Nevada settled enforcement actions against Bitcoin Depot requiring payment of fines and compliance with state consumer-protection and licensing rules, part of a multi-state crackdown (alongside Connecticut's AML-related license suspension and a Massachusetts AG lawsuit) on crypto-ATM scam facilitation. 1 Feb 2026 - FinCEN designated Huione Group as a financial institution of primary money-laundering concern, severing its access to the U.S. financial system. Huione served as a key laundering and scam-infrastructure enabler for Southeast Asian pig-butchering operations that victimize U.S. consumers, including in states such as Maine where CVC kiosks are a common scam-cashout channel. 14 Oct 2025 - OFAC designated the Burma-based DKBA armed group along with senior leaders and companies linked to Chinese organized crime for supporting cyber-scam centers targeting Americans, part of the coordinated U.S. Scam Center Strike Force response protecting U.S. consumers (including Maine residents) from pig-butchering fraud. 12 Nov 2025 - FinCEN issued a Notice urging financial institutions and CVC kiosk operators to strengthen suspicious-activity identification and reporting given a documented surge in kiosk-facilitated elder and romance-scam losses. 4 Aug 2025 ### Sanctions changes - 14 Oct 2025 - 12 Nov 2025 - 2 Apr 2025 - 15 Jun 2026 - 16 Jun 2026 - 23 Jun 2026 - 8 Jul 2026 - 16 Jun 2026 - 31 Mar 2026 - OFAC designated 146 individuals and entities tied to the Prince Group Transnational Criminal Organization, coinciding with a DOJ indictment of Chen Zhi and a record $15 billion civil forfeiture of bitcoin tied to forced-labor pig-butchering scam compounds in Cambodia that victimized U.S. consumers including in Maine. 14 Oct 2025 - OFAC designated the Democratic Karen Benevolent Army (DKBA), a Burma-based armed group controlling scam-compound territory, along with senior leaders and Chinese organized-crime-linked companies. 12 Nov 2025 - Treasury issued a Russia-related designation removal (April 2, 2025) alongside continued counter-terrorism designations, reflecting an evolving and partially diverging U.S. sanctions posture toward Russia relative to EU/UK positions during the window. 2 Apr 2025 ### Regulatory horizon (register) - UK ECCTA 2023 failure-to-prevent-fraud offence enforcement status - FinCEN/OFAC PPSI AML/CFT and Sanctions NPRM - UK ECCTA 2023 failure-to-prevent-fraud offence enforcement status - Maine kiosk-fraud Superintendent report - Maine Virtual-Currency Unclaimed Property Act in force - GENIUS Act full implementation deadline for stablecoin issuers - FinCEN/OFAC joint PPSI AML/CFT rule finalization - FinCEN plans to finalize CTA domestic-exemption interim rule - FATF U.S. next enhanced follow-up / 5th round evaluation ### Active schemes - Crypto-ATM cash-to-crypto scam pipeline - OCC national trust charter preemption of state crypto oversight - Domestic LLC beneficial-ownership blind spot post-CTA rollback Sources - [Money Services Business (MSB) Registration | FinCEN.gov](https://www.fincen.gov/resources/money-services-business-msb-registration) - [FATF](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-june-2026.html) - [US Department of the Treasury](https://home.treasury.gov/news/press-releases/sb0547) - [FinCEN](https://www.fincen.gov/news/news-releases/fincen-issues-supplemental-alert-fuel-smuggling-and-tax-evasion-schemes-southern) - [Holland & Knight](https://www.hklaw.com/en/insights/publications/2026/06/what-happened-to-fincens-corporate-transparency-act) - [Zavia](https://zavia.ai/eu-beneficial-ownership-in-2026-amlr-amld6-amla-explained/) - [Baker McKenzie](https://sanctionsnews.bakermckenzie.com/uk-expands-russia-sanctions-to-further-target-shadow-fleet-military-procurement-and-financial-networks/) - [OFAC](https://ofac.treasury.gov/recent-actions/20260720) - [AGB (Asia Gaming Brief)](https://agbrief.com/news/cambodia/26/01/2026/cambodia-battles-to-avoid-third-fatf-grey-list-placement-amid-scam-crackdown/) - [eco.com](https://eco.com/support/en/articles/15192006-mica-compliant-stablecoins-2026-full-list-with-issuers) - [Stout](https://www.stout.com/en/insights/article/modernizing-aml-transaction-monitoring-model-risk-management) - [UK Government (Home Office)](https://www.gov.uk/government/publications/offence-of-failure-to-prevent-fraud-introduced-by-eccta/economic-crime-and-corporate-transparency-act-2023-guidance-to-organisations-on-the-offence-of-failure-to-prevent-fraud-accessible-version) - [https://infobytes.orrick.com/2026-03-13/maine-enacts-law-restricting-cash-dispensing-machines-from-use-as-virtual-currency-kiosks/](https://infobytes.orrick.com/2026-03-13/maine-enacts-law-restricting-cash-dispensing-machines-from-use-as-virtual-currency-kiosks/) - [https://wgme.com/news/i-team/maine-consumers-scammed-through-bitcoin-atms-could-get-refunds-under-19m-deal](https://wgme.com/news/i-team/maine-consumers-scammed-through-bitcoin-atms-could-get-refunds-under-19m-deal) - [https://www.maine.gov/pfr/consumercredit/consumer/virtual_currencies.html](https://www.maine.gov/pfr/consumercredit/consumer/virtual_currencies.html) - [https://www.jdsupra.com/topics/digital-currency/money-transmitter](https://www.jdsupra.com/topics/digital-currency/money-transmitter) - [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://ofac.treasury.gov/recent-actions](https://ofac.treasury.gov/recent-actions) - [https://www.justice.gov/usao-ma/pr/seven-chinese-nationals-charged-alleged-roles-multi-million-dollar-money-laundering](https://www.justice.gov/usao-ma/pr/seven-chinese-nationals-charged-alleged-roles-multi-million-dollar-money-laundering) - [https://www.themainewire.com/2026/08/chinese-national-indicted-for-money-laundering-conspiracy-in-maryland-has-extensive-ties-to-maine-cannabis/](https://www.themainewire.com/2026/08/chinese-national-indicted-for-money-laundering-conspiracy-in-maryland-has-extensive-ties-to-maine-cannabis/) - [https://www.bangordailynews.com/2026/01/05/state/state-police-courts/maine-settlement-bitcoin-depot/](https://www.bangordailynews.com/2026/01/05/state/state-police-courts/maine-settlement-bitcoin-depot/) - [https://www.federalregister.gov/documents/2025/08/22/2025-16080/imposition-of-special-measures-prohibiting-certain-transmittals-of-funds-involving-cibanco-sa](https://www.federalregister.gov/documents/2025/08/22/2025-16080/imposition-of-special-measures-prohibiting-certain-transmittals-of-funds-involving-cibanco-sa) - [https://illicitedge.com/chinese-money-laundering-networks-serving-mexico-based-drug-cartels/](https://illicitedge.com/chinese-money-laundering-networks-serving-mexico-based-drug-cartels/) - [https://sigma.world/news/cambodia-anti-gambling-drive-fatf-grey-list/](https://sigma.world/news/cambodia-anti-gambling-drive-fatf-grey-list/) - [https://www.cov.com/en/news-and-insights/insights/2026/04/fincen-and-ofac-propose-aml-cft-and-sanctions-framework-for-permitted-payment-stablecoin-issuers-five-things-to-know](https://www.cov.com/en/news-and-insights/insights/2026/04/fincen-and-ofac-propose-aml-cft-and-sanctions-framework-for-permitted-payment-stablecoin-issuers-five-things-to-know) - [https://www.stevens-bolton.com/insights/102jnnd/guidance-on-the-new-offence-of-failure-to-prevent-fraud-under-the-eccta-2023/](https://www.stevens-bolton.com/insights/102jnnd/guidance-on-the-new-offence-of-failure-to-prevent-fraud-under-the-eccta-2023/) - [https://www.maine.gov/pfr/consumercredit/enforcement/bitcoindepot/20260105_bitcoindepot_press.pdf](https://www.maine.gov/pfr/consumercredit/enforcement/bitcoindepot/20260105_bitcoindepot_press.pdf) - [https://www.maine.gov/pfr/consumercredit/news/news_item.shtml?id=13338763](https://www.maine.gov/pfr/consumercredit/news/news_item.shtml?id=13338763) - [https://legislature.maine.gov/bills/getPDF.asp?amp=&=&item=3&paper=SP0905&snum=131](https://legislature.maine.gov/bills/getPDF.asp?amp=&=&item=3&paper=SP0905&snum=131) - [https://www1.maine.gov/pfr/consumercredit/laws_rules/laws.html](https://www1.maine.gov/pfr/consumercredit/laws_rules/laws.html) - [https://www.csbs.org/state-pending-enacted-mtma-legislation](https://www.csbs.org/state-pending-enacted-mtma-legislation) - [https://mainemorningstar.com/briefs/state-consumer-finance-agency-recovers-nearly-2-million-that-mainers-lost-to-bitcoin-kiosk-scams/](https://mainemorningstar.com/briefs/state-consumer-finance-agency-recovers-nearly-2-million-that-mainers-lost-to-bitcoin-kiosk-scams/) - [Maine Bureau of Consumer Credit Protection](https://www.maine.gov/pfr/consumercredit/enforcement/enforcement_item.shtml?id=13337498) - [Maine Bureau of Consumer Credit Protection](https://www.maine.gov/pfr/consumercredit/news/news_item.shtml?id=13338763) - [Maine Office of the Attorney General](https://www.maine.gov/ag/news-and-library/press-releases/attorney-general-aaron-m-frey-announces-largest-big-tech-settlement) - [Maine Office of the Attorney General](https://www.maine.gov/ag/news-and-library/press-releases?id=13341312) - [CryptoSlate](https://cryptoslate.com/crypto-laws/jurisdiction/united-states/maine/) - [Enforcement Actions | FinCEN.gov](https://www.fincen.gov/news/enforcement-actions) - [Enforcement Actions for Failure to Register as a Money Services Business | FinCEN.gov](https://www.fincen.gov/enforcement-actions-failure-register-money-services-business) - [A Money Services Business Guide Financial Crimes Enforcement Network](https://www.fincen.gov/system/files/shared/prevention_guide.pdf) - [United States Department of the Treasury Financial Crimes Enforcement Network - Home | FinCEN.gov](https://www.fincen.gov/) - [Important Information for MSBs | FinCEN.gov](https://www.fincen.gov/resources/financial-institutions/money-services-businesses) - [MSB Registrant Search | FinCEN.gov](https://www.fincen.gov/resources/msb-state-selector) - [Guidance | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance) - [1 Financial Crimes Enforcement Network](https://www.fincen.gov/system/files/2025-10/SAR-FAQs-October-2025.pdf) - [FinCEN Announces Data-Driven Border Operation to Address Potential Money Laundering | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-announces-data-driven-border-operation-address-potential-money-laundering) - [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) - [Fact Sheet on MSB Registration Rule | FinCEN.gov](https://www.fincen.gov/fact-sheet-msb-registration-rule) - [Application of the Definition of Money Transmitter to Brokers and Dealers in Currency and Other Commodities | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/application-definition-money-transmitter-brokers-and) - [Special Measures | FinCEN.gov](https://www.fincen.gov/resources/statutes-and-regulations/special-measures) - [1 FinCEN Advisory United States Department of the Treasury](https://www.fincen.gov/system/files/advisory/advissu7.pdf) - [Fact Sheet for the Industry on MSB Suspicious Activity Reporting Rule | FinCEN.gov](https://www.fincen.gov/fact-sheet-industry-msb-suspicious-activity-reporting-rule) - [PPSI-AMLCFT-NPRM.pdf](https://www.fincen.gov/system/files/2026-04/PPSI-AMLCFT-NPRM.pdf) - [Definition of Money Services Business (Money Transmitter/Currency Dealer or Exchanger) | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/definition-money-services-business-money) - [Application of FinCEN’s Regulations to Persons Administering, Exchanging, or Using Virtual Currencies | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/application-fincens-regulations-persons-administering) - [Fact Sheet: Proposed Rule to Strengthen and Modernize ...](https://www.fincen.gov/system/files/shared/Program-NPRM-FactSheet-508.pdf) - [2025 TRM Wrapped: Celebrating a Year of Private-Public Disruption | TRM Blog](https://www.trmlabs.com/resources/blog/2025-trm-wrapped) - [Serious Economic and Organised Crime Mission Statement | The Crown Prosecution Service](https://www.cps.gov.uk/serious-economic-and-organised-crime-mission-statement) - [Press Releases | FinCEN.gov](https://www.fincen.gov/news/press-releases) - [News | FinCEN.gov](https://www.fincen.gov/news) - [What We Do | FinCEN.gov](https://www.fincen.gov/about-fincen/what-we-do) - [USA PATRIOT Act | FinCEN.gov](https://www.fincen.gov/resources/statutes-and-regulations/usa-patriot-act) - [Definition of Money Transmitter (Merchant Payment Processor) | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/definition-money-transmitter-merchant-payment) - [Money Services Business (MSB) Registration | FinCEN.gov](https://www.fincen.gov/resources/money-services-business-msb-registration) - [Whether a Company that Provides Online Real-Time Deposit, Settlement, and Payment Services for Banks, Businesses and Consumers is a Money Transmitter rather | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/whether-company-provides-online-real-time) - [Money Services Businesses | FinCEN.gov](https://www.fincen.gov/money-services-businesses) - [Financial Crimes Enforcement Network Registration of Money Services Business](https://www.fincen.gov/system/files/shared/FinCENRMSB_ElectronicFilingInstructions.pdf) - [Application of Money Services Business Regulations to a Company that Offers Escrow Services to a Buyer and Seller in a Given Internet Sale of Goods or Services | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/application-money-services-business-1) - [FinCEN Notice, FIN-2025-NTC1, August 4, 2025](https://www.fincen.gov/system/files/2025-08/FinCEN-Notice-CVCKIOSK.pdf) - [USSS Pig Butchering Investigation Leads to $5M+ Seizure of Victim Funds](https://www.trmlabs.com/resources/case-studies/usss) - [Pig butchering scam](https://www.trmlabs.com/glossary/pig-butchering-scam) - [U.S. Launches New Strike Force to Combat $10 Billion Scam Industry](https://www.chainalysis.com/blog/ofac-targets-pig-butchering-scams-november-2025/) - [1 1. See 31 U.S.C. § 5312(a)(2); 31 CFR § 1010.100(t). 2.](https://www.fincen.gov/system/files/shared/FinCEN_Alert_Pig_Butchering_FINAL_508c.pdf) - [Elder Financial Exploitation: Threat Pattern & Trend ...](https://www.fincen.gov/system/files/shared/FTA_Elder_Financial_Exploitation_508Final.pdf) - [What is Pig Butchering? Crypto Investment Scam - Chainalysis](https://www.chainalysis.com/glossary/pig-butchering/) - [2024 Pig Butchering Crypto Scam Revenue Grows 40% YoY as Industry Increases Sophistication](https://www.chainalysis.com/blog/2024-pig-butchering-scam-revenue-grows-yoy/) - [FinCEN Alert, FIN-2024-Alert005, December 18, 2024](https://www.fincen.gov/system/files/2024-12/Alert-FinCEN-Scams-FINAL508.pdf) - [What Is a Crypto Scam? Types & Defense - Chainalysis](https://www.chainalysis.com/glossary/crypto-scam/) - [Trump administration curbs state oversight of crypto industry - ICIJ](https://www.icij.org/investigations/coin-laundry/trump-administration-curbs-state-oversight-of-crypto-industry/) - [Amid a scam crackdown, crypto giants keep fueling bitcoin ATMs - ICIJ](https://www.icij.org/investigations/coin-laundry/amid-a-scam-crackdown-crypto-giants-keep-fueling-bitcoin-atms/) - [Crypto ATM operator Bitcoin Depot files for bankruptcy - ICIJ](https://www.icij.org/investigations/coin-laundry/crypto-atm-operator-bitcoin-depot-files-for-bankruptcy/) - [Historic U.S.–U.K. Operation Targets Southeast Asia’s Scam Compounds with Record $15 Billion Bitcoin Seizure | TRM Labs](https://www.trmlabs.com/resources/blog/historic-u-s--u-k-operation-targets-southeast-asias-scam-compounds-with-record-15-billion-bitcoin-seizure) - [How Chainalysis Helped Uncover an NCA Officer’s Theft of Seized Bitcoin](https://www.chainalysis.com/blog/nca-officer-theft-of-seized-bitcoin-july-2025/) - [Now Live: The 2025 Crypto Crime Report | TRM Labs](https://www.trmlabs.com/resources/blog/now-live-the-2025-crypto-crime-report) - [Massachusetts sues Bitcoin Depot, alleging the crypto ATM operator knowingly facilitated crypto scams - ICIJ](https://www.icij.org/investigations/coin-laundry/massachusetts-sues-bitcoin-depot-alleging-the-crypto-atm-operator-knowingly-facilitated-crypto-scams/) - [Settlement Agreement between the U.S. Department of the Treasury's Office of Foreign Assets Control and Bittrex, Inc. | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20221011) - [Request for Administrative Ruling on the Application of FinCEN’s Regulations to a Virtual Currency Payment System | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/request-administrative-ruling-application) - [Settlement Agreement between the U.S. Department of the Treasury’s Office of Foreign Assets Control and Binance Holdings, Ltd. | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20231121) - [Bitcoin Depot Goes Bankrupt, Signaling Demise of Crypto ATMs - Bloomberg](https://www.bloomberg.com/news/articles/2026-05-18/bitcoin-depot-goes-bankrupt-signaling-demise-of-crypto-atms) - [FinCEN Announces $29 Million Enforcement Action Against Virtual Asset Service Provider Bittrex for Willful Violations of the Bank Secrecy Act | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-announces-29-million-enforcement-action-against-virtual-asset-service) - [UNITED STATES OF AMERICA FINANCIAL CRIMES ENFORCEMENT NETWORK](https://www.fincen.gov/system/files?file=enforcement_action%2F2023-04-05%2FCBOT_Enf_Action_121621_508_FINAL.pdf) - [Cryptocurrency Exchange Compliance: The Ultimate Guide](https://www.chainalysis.com/blog/cryptocurrency-exchange-compliance-a-guide-to-security-and-compliance-for-crypto-businesses/) - [Wallet screening](https://www.trmlabs.com/glossary/wallet-screening) - [The Complete Crypto Compliance Program Guide for Financial Institutions | TRM Labs](https://www.trmlabs.com/guides/crypto-compliance-program-guide-for-financial-institutions) - [TRM Wallet Screening | Protect Against High-Risk Wallets](https://www.trmlabs.com/blockchain-intelligence-platform/wallet-screening) - [Crypto Compliance Solution - Chainalysis](https://www.chainalysis.com/solution/crypto-compliance/) - [Hosted vs unhosted wallets: Compliance risks and practical solutions](https://www.elliptic.co/blog/hosted-vs-unhosted-wallets) - [What is crypto AML compliance?](https://www.elliptic.co/blockchain-basics/what-is-crypto-aml-compliance) - [Application of FinCEN’s Regulations to Persons Issuing Physical or Digital Negotiable Certificates of Ownership of Precious Metals | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/application-fincens-regulations-persons) - [1 Fact Sheet: Proposed Rule to Implement GENIUS Act Customer](https://www.fincen.gov/system/files/2026-06/GENIUS-CIP-NPRM-FactSheet.pdf) - [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) - [Beneficial Ownership Information Reporting | FinCEN.gov](https://www.fincen.gov/boi) - [Frequently Asked Questions | FinCEN.gov](https://www.fincen.gov/boi-faqs) - [Interim Final Rule: Questions and Answers | FinCEN.gov](https://www.fincen.gov/boi/ifr-qa) - [Fact Sheet: Beneficial Ownership Information Access and Safeguards Final Rule | FinCEN.gov](https://www.fincen.gov/news/news-releases/fact-sheet-beneficial-ownership-information-access-and-safeguards-final-rule) - [Beneficial Ownership Information Reporting Rule Fact Sheet | FinCEN.gov](https://www.fincen.gov/beneficial-ownership-information-reporting-rule-fact-sheet) - [Small Entity Compliance Guide | FinCEN.gov](https://www.fincen.gov/boi/small-entity-compliance-guide) - [Reference Materials | FinCEN.gov](https://www.fincen.gov/boi/Reference-materials) - [1 Notice to Customers: Beneficial Ownership Information Reference Guide](https://www.fincen.gov/system/files/shared/BOI-Notice-to-Customers-508FINAL.pdf) - [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) - [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) - [Application of Money Services Business regulations to the rental of computer systems for mining virtual currency | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/application-money-services-business-0) - [FinCEN Issues Notice on the Use of Convertible Virtual Currency Kiosks for Scam Payments and Other Illicit Activity | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-notice-use-convertible-virtual-currency-kiosks-scam-payments-and) - [Request for Administrative Ruling on the Application of FinCEN’s Regulations to a Virtual Currency Trading Platform | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/request-administrative-ruling-application-0) - [Application of FinCEN’s Regulations to Virtual Currency Mining Operations | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/application-fincens-regulations-virtual-0) - [United States' progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/united-states-fur-2024.html) - [Mutual Evaluations](https://www.fatf-gafi.org/en/publications/Mutualevaluations.html) - [Assessments](https://www.fatf-gafi.org/en/calendars/assessments.html) - [Mutual Evaluation of the United States](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationoftheunitedstates.html) - [Consolidated assessment ratings](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Assessment-ratings.html) - [United States](https://www.fatf-gafi.org/en/countries/detail/United-States.html) - [Outcomes FATF Plenary, 22-24 October 2025](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-FATF-plenary-october-2025.html) - [FATF Annual Report 2024-2025](https://www.fatf-gafi.org/en/publications/Fatfgeneral/FATF-Annual-report-2024-2025.html) - [Publications](https://www.fatf-gafi.org/en/publications.html) - [Report on the State of Effectiveness and Compliance with the FATF Standards](https://www.fatf-gafi.org/en/publications/Fatfgeneral/Effectiveness-compliance-standards.html) - [What the GENIUS Act PPSI Rule Means for Stablecoin Issuers | TRM Labs](https://www.trmlabs.com/resources/blog/what-the-genius-act-ppsi-rule-means-for-stablecoin-issuers) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [Crypto regulatory affairs: OCC gives US banks go-ahead on riskless crypto transfers](https://www.elliptic.co/blog/crypto-regulatory-affairs-occ-gives-us-banks-go-ahead-on-riskless-crypto-transfers) - [U.S. Senate Advances GENIUS Act: Long Awaited Stablecoin Framework Edges Closer to Reality - Chainalysis](https://www.chainalysis.com/blog/senate-advances-genius-stablecoin-act/) - [Treasury Proposes Rule to Implement the GENIUS Act’s Requirements to Counter Illicit Finance | FinCEN.gov](https://www.fincen.gov/news/news-releases/treasury-proposes-rule-implement-genius-acts-requirements-counter-illicit) - [What the GENIUS and Market Structure Bills Mean for Crypto Compliance](https://www.chainalysis.com/blog/genius-act-market-structure-bills-crypto-compliance-july-2025/) - [Crypto regulatory affairs: US Congress pushes for Clarity Act passage](https://www.elliptic.co/blog/crypto-regulatory-affairs-us-congress-pushes-for-clarity-act-passage) - [What banks need to know about GENIUS Act stablecoin compliance](https://www.elliptic.co/blog/genius-act-stablecoin-compliance-for-banks) - [Crypto regulatory affairs: US Crypto Week delivers as GENIUS Act becomes law, CLARITY Act moves to Senate](https://www.elliptic.co/blog/crypto-regulatory-affairs-us-crypto-week-delivers-as-genius-act-becomes-law-clarity-act-moves-to-senate) - [Administrative Ruling on Whether a Company that Offers a Payment Mechanism Based on Payable-Through Drafts to its Commercial Customers is a Money Transmitter | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/administrative-ruling-whether-company-offers) - [Registration and De-Registration of Money Services Businesses | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/registration-and-de-registration-money-services-businesses) - [International Consortium of Investigative Journalists (ICIJ)](https://www.icij.org/investigations/coin-laundry/trump-administration-curbs-state-oversight-of-crypto-industry/) - [International Consortium of Investigative Journalists (ICIJ)](https://www.icij.org/investigations/coin-laundry/crypto-atm-operator-bitcoin-depot-files-for-bankruptcy/) - [Financial Crimes Enforcement Network (FinCEN), U.S. Department of the Treasury](https://www.fincen.gov/boi) - [Financial Action Task Force (FATF)](https://www.fatf-gafi.org/en/publications/Mutualevaluations/united-states-fur-2024.html) - [Chainalysis](https://www.chainalysis.com/blog/ofac-targets-pig-butchering-scams-november-2025/) - [Financial Crimes Enforcement Network (FinCEN), U.S. Department of the Treasury](https://www.fincen.gov/news/news-releases/fincen-issues-notice-use-convertible-virtual-currency-kiosks-scam-payments-and) - [Financial Crimes Enforcement Network (FinCEN) / Office of Foreign Assets Control, U.S. Department of the Treasury](https://www.fincen.gov/system/files/2026-04/PPSI-AMLCFT-NPRM.pdf) Coverage gaps fim-int-2026-07-05-G001: Primary-source Maine BCCP consent-o… fim-int-2026-07-05-G001: Primary-source Maine BCCP consent-order/docket documentation for the Bitcoin Depot settlement was not independently retrieved this cycle beyond a challenge-cited state webpage, limiting corroboration of the exact settlement date and terms. [resolved] fim-int-2026-07-05-G002: Independent primary-source verifica… fim-int-2026-07-05-G002: Independent primary-source verification (OCC corporate-decision letters) of the reported acceleration in national trust charter conversions (eleven firms in an 83-day window) is absent, preventing an upgrade of that claim's confidence beyond Assessed. [resolved] fim-int-2026-07-05-G003: No FATF commentary or statement add… fim-int-2026-07-05-G003: No FATF commentary or statement addressing the effect of the March 2025 domestic CTA exemption on the March 2024 Recommendation 24 upgrade has yet been located, leaving the flagged temporal contradiction analytically unresolved. [resolved] fim-int-2026-07-05-G004: EU-level mirroring (or non-mirrorin… fim-int-2026-07-05-G004: EU-level mirroring (or non-mirroring) status of the OFAC Prince Group and DKBA designations was not confirmed this cycle, limiting the sanctions-regime-divergence assessment to the documented US-UK coordination only. [resolved] fim-int-2026-07-14-G001: No independent FinCEN.gov or OFAC.g… fim-int-2026-07-14-G001: No independent FinCEN.gov or OFAC.gov primary-source retrieval was performed this cycle for the Huione/H-Pay and Prince Group actions; the sole evidence base is a tier-3 trade-press summary. [resolved] fim-int-2026-07-14-G002: No dedicated UAE trade-finance TBML… fim-int-2026-07-14-G002: No dedicated UAE trade-finance TBML case document was located this cycle to substantiate the standing transshipment-enforcement gap beyond a single tier-4 vendor summary. [resolved] fim-int-2026-07-14-G003: No fresh 2026 Colombia-specific TBM… fim-int-2026-07-14-G003: No fresh 2026 Colombia-specific TBML action was located to update the Black-Market Peso Exchange reference architecture. [resolved] fim-int-2026-07-14-G004: Per-EEA-Member-State 6AMLD transpos… fim-int-2026-07-14-G004: Per-EEA-Member-State 6AMLD transposition status (not yet transposed / partly transposed / fully transposed) could not be established for any individual Member State this cycle. [resolved] fim-int-2026-07-14-G005: No fresh FinCEN AI/model-risk guida… fim-int-2026-07-14-G005: No fresh FinCEN AI/model-risk guidance or FCA JMLSG RegTech guidance was located to expand D6 coverage beyond the single AMLA SupTech data-quality item. [resolved] fim-int-2026-08-05-G001: No primary FATF or MONEYVAL mutual-… fim-int-2026-08-05-G001: No primary FATF or MONEYVAL mutual-evaluation report was directly retrieved for Bosnia and Herzegovina's grey-listing basis this cycle; only a Treasury readout was cited. [resolved] fim-int-2026-08-05-G002: No Tier-1 EU primary source (Europe… fim-int-2026-08-05-G002: No Tier-1 EU primary source (European Commission or AMLA official publication) was retrieved this cycle to corroborate the AMLA technical-standards timeline; all sourcing is Tier 3/4. [resolved] fim-int-2026-08-05-G003: Laos-specific corridor and cash-con… fim-int-2026-08-05-G003: Laos-specific corridor and cash-control reporting yielded no material findings this cycle despite Tier-D active search. [resolved] fim-int-2026-08-05-G004: Colombia's FATF/GAFILAT mutual-eval… fim-int-2026-08-05-G004: Colombia's FATF/GAFILAT mutual-evaluation posture was not updated beyond the standing 2023 follow-up report; no new movement was found this cycle. [resolved] fim-int-2026-08-05-G005: No direct Federal Reserve primary b… fim-int-2026-08-05-G005: No direct Federal Reserve primary bulletin for SR 26-2 was retrieved this cycle; sourcing relies on Tier-3 and Tier-4 secondary analysis. [resolved] fim-int-2026-08-20-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-08-20-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): EU AML Package / AMLA (T2) transposition status not actively searched this cycle; coverage gap rather than confirmed no-change. [resolved] fim-int-2026-08-20-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-08-20-G002 ({'scheme': 'financial_integrity', 'value': 'D2'}): Global beneficial-ownership register status (T4) not actively searched this cycle. [resolved] fim-int-2026-08-20-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-08-20-G003 ({'scheme': 'financial_integrity', 'value': 'D1'}): Sanctions regime divergence (T6) and Tier D jurisdictions (KH, LA, MX, CO) not actively searched this cycle; recorded as awaiting_primary_source. [resolved] fim-int-2026-08-20-G004 ({'scheme': 'financial_integrity', '… fim-int-2026-08-20-G004 ({'scheme': 'financial_integrity', 'value': 'D5'}): Primary statute text for Maine PL Chapter 542 and LD 2112 not independently retrieved this cycle; relied on T3 law-firm secondary sourcing. [resolved] fim-int-2026-09-05-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G001 ({'scheme': 'financial_integrity', 'value': 'D3'}): No Tier-1/Tier-2 source confirmed the Maryland (U.S. v. Tao) or Dixfield mortgage-fraud follow-on cases directly; both rest on single Tier-3 sourcing. [resolved] fim-int-2026-09-05-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G002 ({'scheme': 'financial_integrity', 'value': 'D3'}): No FATF plenary Tier-1 statement confirming or denying Cambodia's grey-list re-listing risk was located this cycle. [resolved] fim-int-2026-09-05-G003: Domains D1, D2, D4 and D6 returned … fim-int-2026-09-05-G003: Domains D1, D2, D4 and D6 returned thin coverage for the US-ME dispatch this cycle; no material developments found. [resolved] fim-int-2026-09-28-G001: Tier D jurisdiction watch (Cambodia… fim-int-2026-09-28-G001: Tier D jurisdiction watch (Cambodia, Laos, Mexico, Colombia) was not researched this cycle; pooled web-search budget allocated to US-ME per this run's jurisdiction binding. [open] fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', 'value': 'D6'}): No Maine-specific AI/ML transaction-monitoring standard for kiosk-category money transmitters was located this cycle beyond FinCEN model-risk guidance. [open] fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): Whether the 'like-kind virtual currency reserve' requirement for MMTMA licensees is still in the current statute text was not independently re-verified this cycle. [open] fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', 'value': 'D8'}): Maine's specific dollar allocation under the $45M multistate Block Inc./Cash App settlement was not located this cycle. [open] fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', 'value': 'D1'}): D1/D2/D3/D4 Maine-specific findings were not located this cycle under the single-JID binding; Tier D jurisdictions (KH/LA/MX/CO) and global T1 Russia/Houthi trackers were not independently re-searched. [open] FIM-GAP-001 (D2): Maine has no state-level beneficial-owners… FIM-GAP-001 (D2): Maine has no state-level beneficial-ownership registry to backfill the federal CTA domestic-entity exemption enacted in March 2025, leaving Maine-formed LLCs and corporations with zero mandatory beneficial-ownership disclosure to any government registry. FIM-GAP-002 (D3): Federal OCC national trust charter convers… FIM-GAP-002 (D3): Federal OCC national trust charter conversions are removing major crypto/VASP firms from Maine Bureau of Consumer Credit Protection oversight entirely, eliminating the state's ability to enforce consumer-complaint resolution, AML-adjacent wallet-verification rules, or licensing conditions against those firms. FIM-GAP-003 (D3): Independently published, Maine-specific AM… FIM-GAP-003 (D3): Independently published, Maine-specific AML enforcement records beyond the ICIJ investigative reporting on crypto-ATM settlements and OCC preemption are sparse; primary-source documentation directly from Maine BCCP (consent orders, docket filings) was not located in this baseline pass. ## Evidence #### Confidence-tiered claims Maine BCCP consent agreement (effective 2026-01-05): BDO receives money-transmitter licence (expiring Dec 31, 2026) and pays $1.9M in consumer redress for unhosted-wallet-linked crypto-kiosk scams, resolving unlicensed operation 2021-2025. [[Source 1]](#sec-sources) Probable · 1 source LD 1197, which would have repealed Maine's unhosted-wallet identification requirement (32 M.R.S. §6100-UU), died in committee (Ought Not to Pass, May 28, 2025) — the rule remains in force. [[Source 1]](#sec-sources) Probable · 1 source Maine's AML/CTF architecture for crypto-adjacent and money-transmission businesses runs through MMTMA licensing (BCCP) layered under federal BSA/FinCEN MSB registration; no Maine-specific FIU or state SAR regime exists. [[Source 1]](#sec-sources) Probable · 1 source $45 million multistate settlement announced 2026-07-08 over deceptive practices on Cash App; Maine joined as a party; Maine-specific allocation not located this cycle. [[Source 1]](#sec-sources) Probable · 1 source Virtual currency recognized as an unclaimed-property type, with abandonment, custody, liquidation, owner-notice and recovery rules, effective July 29, 2026. [[Source 1]](#sec-sources) Probable · 1 source