--- title: "United States — Missouri (US-MO) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/united-states-missouri/ source_html: /jurisdictions/united-states-missouri/index.html description: "Financial integrity intelligence for United States – Missouri (US-MO): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: fde907241e70dc7733bcefc1f34eb228bd6bd18246546171c7b79d703ff39013 generator: "fe-fleet/md-twin@1.0" --- # United States — Missouri (US-MO) — 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 — Missouri US-MO Domains covered 8 of 8 Sources 137 Role actions 8 Horizon <90d 0 Jurisdiction profile FATF status: Compliant Tier: B Risk direction: Increasing Enablement vs enforcement: Mixed Missouri operates under the federal Bank Secrecy Act/FinCEN AML/CFT/CPF regime, supplemented by state money-transmitter licensing (Missouri Division of Finance) and state consumer-protection enforcement (Missouri Attorney General). More Missouri's Secretary of State does not collect beneficial ownership information at entity formation, and the March 2025 federal Corporate Transparency Act rollback removed the federal backstop for domestically formed entities. Key deficiencies - No state-level beneficial ownership collection at LLC/corporation formation - Federal CTA domestic-reporting-company exemption (March 2025) removes the primary federal transparency backstop for Missouri-formed entities - Crypto ATM/kiosk sector operated with limited state-specific AML tailoring until the Missouri Attorney General's December 2025 investigation - National reduction in IRS-CI examiner capacity for crypto/MSB AML oversight, reducing federal supervisory depth reaching Missouri-licensed money transmitters Recent developments (18m) - FinCEN interim final rule (March 26, 2025) exempted all US domestic reporting companies and their beneficial owners from CTA BOI reporting, narrowing the federal registry to foreign entities only - Missouri Attorney General Catherine Hanaway opened a consumer-protection investigation into crypto ATM operator Bitcoin Depot and four competitors (December 2025) - Bitcoin Depot, the largest US crypto-ATM network, filed for bankruptcy in May 2026 amid multi-state regulatory pressure including the Missouri investigation - DOJ Western District/Eastern District of Missouri secured a 10-year sentence in a $147M health care fraud conspiracy (December 12, 2025), part of a national health-care-fraud money-laundering wave - FATF upgraded the United States' Recommendation 24 (beneficial ownership) rating from Non-Compliant to Largely Compliant in its 2024 Follow-Up Report, a rating now under pressure from the 2025 CTA rollback ahead of the US 5th round mutual evaluation United States federal law that applies in United States – Missouri is covered once, on the [United States](/jurisdictions/us/) page. This page covers United States – Missouri’s own layer: its own law, regulators and enforcement. Brief ## Lead signal #### Lead Signal Missouri's 2025 crypto-kiosk statute, the Virtual Currency Kiosk Consumer Protection Act (RSMo 361.1100), has become the centre of an active enforcement-architecture dispute. GPD Holdings LLC, doing business as CoinFlip, has filed a motion to dismiss the Missouri Attorney General's Merchandising Practices Act suit, arguing that the kiosk statute is the controlling, industry-specific regime and that it displaces the AG's general fraud theory. The dispute arrives alongside pending Missouri Senate Bill 1510, which would amend RSMo 361.1100 to grant the Attorney General sole civil-enforcement authority over kiosk-statute violations, with penalties of up to $10,000 per violation and $1,000 per injunction breach. The bill remains in committee and is not yet enacted. Read full brief #### Lead Signal Missouri's 2025 crypto-kiosk statute, the Virtual Currency Kiosk Consumer Protection Act (RSMo 361.1100), has become the centre of an active enforcement-architecture dispute. GPD Holdings LLC, doing business as CoinFlip, has filed a motion to dismiss the Missouri Attorney General's Merchandising Practices Act suit, arguing that the kiosk statute is the controlling, industry-specific regime and that it displaces the AG's general fraud theory. The dispute arrives alongside pending Missouri Senate Bill 1510, which would amend RSMo 361.1100 to grant the Attorney General sole civil-enforcement authority over kiosk-statute violations, with penalties of up to $10,000 per violation and $1,000 per injunction breach. The bill remains in committee and is not yet enacted. #### Other Developments Federal beneficial-ownership context. FinCEN's 11 August 2026 final rule permanently exempts US-formed entities from Corporate Transparency Act beneficial-ownership reporting. Missouri has no state-level beneficial-ownership registry, so the federal exemption carries no Missouri-specific variance; it is noted here as structural backdrop rather than a state-level development. Statutory architecture under test. The underlying question in the CoinFlip motion is whether a state that has already legislated a kiosk-specific AML and consumer-protection regime, complete with licensing and enhanced-due-diligence requirements, has thereby foreclosed its own attorney general from reaching the same conduct through a broader, generally applicable consumer-fraud statute. This is a structural question about how overlapping state authorities interact, not merely a dispute over one kiosk operator's conduct. #### Cross-Monitor Connections The CoinFlip dispute and pending SB 1510 sit directly at the intersection of consumer-protection enforcement and the crypto/digital-asset typology space, since virtual-currency kiosks are a recognised cash-to-crypto on-ramp relevant to layering and placement typologies. The outcome of the preemption argument could materially affect how other US states structure the relationship between kiosk-specific AML statutes and general consumer-protection enforcement, a question of interest wherever a jurisdiction has layered industry-specific and general-purpose financial-crime authorities. #### Outlook The resolution of CoinFlip's motion to dismiss will determine whether Missouri's AG retains a general fraud-enforcement avenue against kiosk operators alongside the kiosk-specific statute, or whether the 2025 Act operates as an exclusive, displacing regime. SB 1510's progress through the Senate Insurance and Banking Committee is the parallel legislative track to watch: if enacted, it would concentrate civil-enforcement authority over kiosk-statute violations in the Attorney General's office, potentially mooting part of the current jurisdictional dispute by making clear the AG's authority under the kiosk statute itself. Earlier periodic briefs (4) 28 Sep 2026 · fim-2026-09-28 #### Lead Signal Missouri's money-transmission licensing architecture underwent a structural modernization this cycle that reaches directly into the state's crypto-adjacent activity classes. The Money Transmission Modernization Act, codified at RSMo Sections 361.900 through 361.1035, repealed and replaced the state's former Sale of Checks Law effective August 28, 2024, establishing a state-level licensing perimeter beneath federal Bank Secrecy Act and FinCEN obligations for money transmitters domiciled in or serving Missouri, including the payment processors that touch the state's live sports-wagering market. A year later, the Missouri Division of Finance extended that framework explicitly to virtual-currency kiosk operators, deeming them engaged in money transmission and requiring MTMA licensure under RSMo Section 361.1100, effective August 28, 2025. The architecture-over-incident read here is that Missouri has closed, by regulator guidance rather than by enforcement action, a gap that has been exploited nationally in elder-fraud and romance-scam cash-out schemes routed through crypto automated teller machines. No enforcement event grounds this finding; the significant fact is the newly explicit licensing requirement itself, corroborated independently by the Conference of State Bank Supervisors' legislative tracker, which lists Missouri as a Full MTMA introduction state effective the same August 2024 date. #### Other Developments Beneficial-ownership gap remains standing but unconfirmed at Tier 1. Missouri carries no state-level beneficial-ownership register, and limited liability companies file no recurring beneficial-ownership report with the Secretary of State's business registry. The only beneficial-ownership layer applicable to Missouri entities is the federal Corporate Transparency Act, which a March 2025 FinCEN interim final rule narrowed to foreign reporting companies only, removing the filing obligation for domestic reporting companies. This finding rests on a single Tier-4 commercial know-your-business guide rather than an affirmative Tier-1 Missouri source, and is treated as a standing structural gap rather than a new development this cycle. Standing fiscal echo of federal sanctions architecture. The Missouri State Employees' Retirement System's 2022 board vote to divest Russia-linked holdings and bar future purchases of Russian securities remains a standing fiscal-sector echo of federal Office of Foreign Assets Control sanctions architecture; no new development on this front was identified this cycle, and the underlying 2022 decision has not been independently re-verified against a Tier-1 MOSERS filing. #### Cross-Monitor Connections The same Money Transmission Modernization Act finding that grounds this cycle's AML/CFT and crypto-integrity signal is read differently by the crypto and world-payments monitors covering this jurisdiction. The crypto monitor treats the kiosk-licensure extension as a crypto-licensing development in its own right, foregrounding the direct naming of a crypto-adjacent activity class; the world-payments monitor treats the same repeal-and-replace as a licensing and market-access tightening across the payments sector generally, not specific to crypto. Readers tracking the digital-asset dimension of Missouri's payments landscape should consult the crypto monitor for the licensing-regime detail; those tracking payments-sector structure generally should consult world-payments. #### Outlook The principal item to watch is whether Missouri's Division of Finance issues further guidance extending explicit money-transmission licensure to additional crypto-adjacent activity classes beyond kiosk operation, following the pattern set by the August 2025 guidance. On the standing beneficial-ownership gap, the question is whether any Tier-1 Missouri source will affirmatively confirm the absence of a state-level register, which would allow the finding's confidence to be upgraded beyond its current Probable tier. No near-term legislative or enforcement development affecting either the sanctions-architecture echo or the beneficial-ownership gap was identified this cycle. 14 Sep 2026 · fim-2026-09-05 #### Lead Signal On August 7, 2026, OFAC designated crypto exchanges and a weapons-procurement network tied to Iran's IRGC-Qods Force, with further SDN updates following on August 14 and 18, 2026. The action was issued amid attacks on commercial vessels in the Strait of Hormuz and represents architecture-level targeting of digital-asset rails as a sanctions-evasion vector for state-linked weapons procurement, rather than an isolated enforcement incident against a single actor. #### Other Developments FATF's June 2026 Plenary added Iraq and Bosnia and Herzegovina to its grey list while removing Algeria and Namibia, leaving the list at twenty-two jurisdictions. The finding is assessed rather than confirmed: it rests on multiple secondary compliance-industry trackers rather than a direct primary retrieval from fatf-gafi.org this cycle, a sourcing gap noted for follow-up. Cambodia's casino-sector crackdown continued to accelerate, with twenty licences revoked, twenty-nine suspended, and all one hundred ninety-five licensed casinos placed under investigation between July 2025 and July 2026. The enforcement narrative is complicated by a parallel finding from Amnesty International, which documented human-rights abuses at casino compounds that received fresh state approvals during the same crackdown window — a pattern consistent with a state-capture concern rather than a straightforward enforcement success story. FinCEN's Chinese Money Laundering Networks advisory continues to widen in enforcement scope, now spanning Section 311/2313a special-measures authority, sanctions on cartel-linked casinos, and a June 2026 supplemental alert addressing cross-border fiscal fuel theft tied to CJNG. This is a primary-source, Tier 1 finding, though the broader enforcement-drift characterization around it rests on a single secondary synthesis flagged for independent verification. GENIUS Act implementing rulemaking — the joint FinCEN/OFAC proposed rule on AML and sanctions-compliance requirements for payment stablecoin issuers, alongside parallel OCC, FDIC, and NCUA rules — remains at proposal stage past its July 18, 2026 statutory deadline. The Act's January 18, 2027 backstop effective date now governs regardless of whether rulemaking is completed, extending a compliance-timeline overhang across the stablecoin-issuance sector. #### Cross-Monitor Connections The GENIUS Act rulemaking delay and the OFAC crypto-exchange designations both sit at the direct intersection of this monitor's sanctions and crypto-integrity domains and the World Payments Monitor's stablecoin and digital-money tracking: a federal AML/sanctions-compliance regime for payment stablecoin issuers is now guaranteed to bind by January 2027 independent of rulemaking completion, a structural fact relevant to any payments-side assessment of stablecoin-issuer risk. Cambodia's casino-sector crackdown, and the state-capture question raised by Amnesty International's findings, is architecture-relevant to any monitor tracking state-capture or enabler-jurisdiction dynamics in Southeast Asia; the coexistence of licence revocations with fresh approvals for scam-linked complexes is an enforcement-versus-enablement divergence that should be read as a structural signal, not resolved as either a clean crackdown or a clean failure. #### Outlook The January 18, 2027 GENIUS Act backstop is now the operative date to track regardless of rulemaking progress; failure to finalize implementing rules before that date would leave stablecoin issuers operating under a binding but procedurally incomplete compliance regime. The FATF grey list is on its standard triannual Plenary cycle; whether Iraq and Bosnia and Herzegovina begin action plans that could shorten their listing period is the primary watch item there. In Cambodia, the credibility of the casino-sector crackdown will be tested by whether further licence actions target the specific complexes Amnesty International identified as having received fresh state approval, or whether the divergence between enforcement rhetoric and approval practice persists. 11 Aug 2026 · fim-2026-08-05 #### Lead Signal The most structurally significant development this cycle is the advancement of the GENIUS Act rulemaking cascade in the United States, which for the first time formally extends Bank Secrecy Act anti-money-laundering and sanctions-compliance architecture to payment stablecoin issuers at the federal level. FinCEN and OFAC issued a joint proposed rule on April 8, 2026 implementing BSA/AML and sanctions-compliance requirements for Permitted Payment Stablecoin Issuers, with the comment period closing June 9, 2026, and the FDIC has advanced a parallel custodial-safeguarding proposal; both race toward the Act's July 18, 2026 statutory deadline. This is assessed at High confidence on two independent Tier 1 primary sources. The architecture-over-incident read is that this is not an isolated rulemaking but a structural first: stablecoin issuers, previously outside the BSA obliged-entity perimeter, are being brought inside it via customer due-diligence, sanctions-screening and custodial-safeguarding obligations modeled on bank and money-services-business programs, even though the sector's compliance-program maturity remains comparatively nascent. The parallel European track reinforces the structural read: the EU's AML Regulation already designates crypto-asset service providers as obliged entities, meaning the two largest AML jurisdictions are converging, on different timelines, toward treating digital-asset issuers as first-class subjects of AML supervision rather than a peripheral category. #### Other Developments The Russian shadow-fleet sanctions-enforcement divergence persists as a structural rather than episodic feature this cycle. At least 623 tankers have been designated by one sanctions regime or another, yet 111 continued loading despite designation, and the United States has added no new OFAC vessel designations targeting Russian or Iranian tankers since January 2025, even as the European Union prepares a twentieth sanctions package understood to extend toward a full maritime-services ban. This finding rests on Tier 3 sourcing only this cycle; no Tier 1 OFAC.gov or EU Council primary record was independently retrieved for the specific vessel-count figures, a gap logged accordingly. Separately, OFAC did act against the Iran-linked shadow fleet, designating eight entities and nine vessels for transporting Iranian oil, and issued fresh designations tied to Houthi military capability, indicating that US sanctions activity has not paused generally, only specifically with respect to new Russian/Iranian tanker designations. The EU AML Package's architecture continues to unfold across three distinct instruments carrying diverging timelines. The AML Regulation and the sixth AML Directive, together with the Regulation establishing the Anti-Money Laundering Authority, must be tracked separately: AMLA has been operational since July 1, 2025 and faces a July 10, 2026 deadline to submit roughly twenty-three regulatory and implementing technical standards to the Commission; AMLD6's beneficial-ownership register provisions are due for transposition by the same July 2026 date; and the AMLR, the directly-applicable regulation, together with full AMLD6 application, does not bite until July 10, 2027, at which point AMLD4 and AMLD5 are repealed. This staggered structure means supervisory perimeters across the EU will diverge temporarily between 2026 and 2027, and this cycle's sourcing for the timeline is Tier 4 only, capping confidence at Assessed despite multi-source corroboration. Cambodia's own regulator has surfaced grey-list risk explicitly , with National Bank of Cambodia Governor Chea Serey warning that continued casino and scam-centre laundering activity risks a third FATF grey-listing for the jurisdiction. This is an enablement signal worth foregrounding under the three-pillar framing: it is the regulator's own acknowledgment, not an external finding, and it sits alongside a reported 47.8 percent year-on-year fall in tourism arrivals, suggesting the casino/scam-centre nexus is beginning to carry an economic cost that may or may not translate into enforcement follow-through. In Mexico, formal financial infrastructure continues to be implicated in cartel finance. A FinCEN alert, corroborated at Tier 1, ties CJNG, Sinaloa, and Gulf Cartel fuel-theft (huachicol) smuggling to United States fuel distributors, Mexican trading companies, logistics providers, and shell entities. This is a formal, government-issued advisory rather than press reporting, and it names bank and cross-sector obligations under existing BSA advisory framework. #### Cross-Monitor Connections The GENIUS Act cascade is directly relevant to World Payments Monitor coverage of state-level stablecoin qualification regimes, since the federal rulemaking's BSA/AML and sanctions provisions interact with the substantially-similar state-qualification test that determines whether state money-transmission frameworks can serve as an alternative federal-recognition pathway for stablecoin issuers. The Mexican fuel-theft finding connects to conflict-finance and extractive-industry-integrity coverage of cartel revenue diversification beyond narcotics, a theme relevant to any monitor tracking non-drug transnational-criminal-organization revenue streams. The Houthi and Iran-linked designations connect to conflict-finance coverage of Iran/Russia/Hezbollah material support sustaining Houthi military capability, a financing architecture that OFAC designation activity has so far not visibly degraded. #### Outlook The next several cycles carry two hard deadlines worth tracking closely: the GENIUS Act's July 18, 2026 statutory deadline for implementing regulations, against which the FinCEN/OFAC and FDIC proposals are racing, and AMLA's July 10, 2026 deadline to submit its full slate of technical standards, which will determine how much operational specificity EU obliged entities have before the 2027 AMLR/AMLD6 full-application date. Cambodia's grey-list trajectory is a further watch item: whether the central bank's own warning translates into enforcement action before the next FATF Plenary will be a meaningful test of the capacity-versus-choice tension identified this cycle. Illustrative scenario material accompanying this brief should be read strictly as analytical orientation, not as prediction. 14 Jul 2026 · fim-2026-07-14 #### Lead Signal The defining development this cycle is a structural rollback rather than a single enforcement episode. The FinCEN interim final rule of March 26, 2025 exempted all United States-formed domestic reporting companies and their beneficial owners from Corporate Transparency Act beneficial ownership information reporting, narrowing the federal BOI registry to foreign entities registering to do business in the United States. For Missouri, where the Secretary of State does not collect beneficial ownership information at LLC or corporation formation, removal of the federal backstop converts a previously mitigated state-level transparency gap into an unmitigated national exposure. The consequence is now measurable against an external benchmark: the United States was upgraded on FATF Recommendation 24 from Non-Compliant to Largely Compliant in the March 2024 Follow-Up Report, a rating explicitly credited to Corporate Transparency Act implementation, and that credited upgrade is now assessed to be at re-rating risk ahead of the 5th round mutual evaluation. The composite jurisdiction risk trajectory for Missouri is accordingly assessed as increasing, reflecting the compounding effect of the federal rollback and the capacity-deficit beneficial-ownership regime at state level, partially offset by state-level enforcement activity documented elsewhere this cycle. #### Other Developments A convergent, not divergent, sanctions architecture emerged on October 14, 2025, when OFAC designated the Prince Group Transnational Criminal Organization, its chairman, and 146 associated targets for operating pig-butchering scam networks that laundered funds through cryptocurrency, alongside a Department of Justice seizure of approximately 127,271 bitcoin, valued near 15 billion dollars. The United Kingdom OFSI dually designated related entities, Byex Exchange and Jin Bei Group, the same day, an instance of coordinated timing rather than the regime fragmentation sometimes assumed in the standing US-UK sanctions divergence assessment. The same day, FinCEN finalized a Section 311 special measure designating Huione Group a foreign financial institution of primary money-laundering concern, severing it from the United States financial system after linkage to more than 4 billion dollars in laundered proceeds between 2021 and 2025, including funds traced to North Korean cyber-heist activity. The crypto ATM kiosk sector multi-year growth is giving way to consolidation. National kiosk count rose from 4,128 in January 2019 to 37,342 in January 2025, operating for years as a largely unregulated cash-to-crypto conversion channel for scam proceeds. The Missouri Attorney General opened a consumer-protection investigation into Bitcoin Depot and four competitor operators on December 17, 2025; that pressure, layered onto a Connecticut licence suspension and litigation in Massachusetts and Iowa, contributed to the Bitcoin Depot Chapter 11 bankruptcy filing on May 18, 2026, removing approximately 9,700 kiosks, the largest single operator footprint, from the national scam-conversion pipeline. Separately, the Treasury Department published state-equivalency principles for the GENIUS Act stablecoin framework on April 3, 2026, a determination against which Missouri money-transmitter licensees, including crypto ATM operators, will need to certify. Compliance architecture is moving in two directions at once. The FinCEN proposed reform of AML/CFT program requirements, with a comment period that closed June 9, 2026, would shift financial institutions toward a risk-based, less prescriptive compliance posture, reducing reliance on check-the-box SAR filing in favor of institutional risk assessment; the risk direction on implementation remains assessed as uncertain pending a final rule. Running counter to that proactive-compliance thesis is a national reduction in IRS Criminal Investigation examiner capacity for crypto and money-services-business AML oversight, a capacity deficit that narrows federal supervisory depth reaching Missouri-licensed money transmitters. A national health-care-fraud money-laundering wave continues to generate individual prosecutions. The Department of Justice secured a 10-year sentence in a 147 million dollar health-care-fraud conspiracy on December 12, 2025, one data point within a broader trend documented in the FinCEN 2026 National Money Laundering Risk Assessment, which found a 330 percent increase in health-care-fraud-related Suspicious Activity Report filings between 2020 and 2025, indicating sustained proceeds-layering via business-entity structures rather than an isolated case. #### Cross-Monitor Connections The Huione Group Section 311 designation carries a state-linked financial network dimension: proceeds traced to North Korean cyber-heist activity routing through the platform warrant assessment by the state-capture-focused monitor for a state-capture dimension rather than treatment as purely private criminal architecture. The convergent scale of the Prince Group and Huione Group actions, together exceeding 15 billion dollars in seizure and 4 billion dollars in laundered proceeds, is also a macro-scale sanctions-as-variable event relevant to the tracking of sanctions-architecture effects by the macro-focused monitor. Conflict-finance and extractive-industry exposure for Missouri remains an open question rather than a confirmed null: no Tier 1-2 sourced Missouri-specific scheme was identified this cycle, a gap flagged for re-verification rather than asserted as a settled absence, and any future finding in this domain would warrant cross-reference to the conflict-finance and commodity-flow monitors consistent with standing filter practice. #### Outlook Three developments define the near-term horizon. The FinCEN AML/CFT program reform rule remains in consultation, with a year-scale uncertainty band on its expected 2027 effective date; how the transition toward risk-based compliance interacts with the concurrent IRS-CI capacity reduction will determine whether Missouri-licensed institutions experience a net gain or loss in supervisory depth. The GENIUS Act state-equivalency determination process, also on a year-scale horizon, will require the Missouri money-transmitter regime, including its crypto ATM licensees, to be assessed against the federal stablecoin framework, a process assessed as improving on the risk direction on implementation. Most consequential for the federal AML architecture affecting this jurisdiction is the United States 5th round FATF mutual evaluation progress reporting, an in-force, multi-year-band horizon item in which the March 2025 Corporate Transparency Act domestic exemption is expected to be a central scrutiny point, with the national beneficial-ownership rating trajectory, worsening per this cycle assessment, a variable that Missouri inherits in full as a constituent of the federal system. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion Missouri carries no independent sanctions authority and inherits the federal OFAC sanctions architecture in full as a US state; there is no Missouri-specific divergence in how sanctions screening obligations apply to state-chartered or state-licensed institutions. This cycle most consequential sanctions-architecture development nonetheless has direct relevance to Missouri-based financial institutions and crypto-asset operators through the counterparty-screening obligations those entities carry. On October 14, 2025, OFAC designated the Prince Group Transnational Criminal Organization, its chairman Chen Zhi, and 146 associated targets under the sanctions authority governing pig-butchering scam networks that laundered proceeds through cryptocurrency; the Department of Justice concurrently seized approximately 127,271 bitcoin, valued at roughly 15 billion dollars, a scale that places the action among the largest crypto-linked forfeitures on record. The United Kingdom Office of Financial Sanctions Implementation dually designated Byex Exchange and Jin Bei Group, both linked to the Prince Group network, the same day. Continue reading Applying a three-level sanctions-architecture reading, the scheme is pig-butchering fraud converting victim funds into crypto assets; the architecture is the Prince Group transnational criminal organization structure operating in conjunction with affiliated exchanges; and the strategic consequence is that the convergent, same-day US-UK designation evidences coordinated sanctions architecture rather than the regime fragmentation that the standing divergence assessment sometimes anticipates between the two jurisdictions differing legal bases for listing. This convergence reading is itself the analytically significant finding, more so than either designation taken in isolation. The same day, FinCEN finalized a Section 311 special measure designating Huione Group a foreign financial institution of primary money-laundering concern, severing the platform from the United States financial system. Huione Group has been linked to more than 4 billion dollars in laundered proceeds between 2021 and 2025, including funds traced to North Korean cyber-heist activity and crypto-investment-scam proceeds. This linkage introduces a state-capture dimension worth flagging explicitly rather than treating the designation as purely private criminal architecture: proceeds tied to a state-directed cyber-heist program routing through a commercial laundering platform sit at the intersection of financial-crime and state-capture analysis, and the cross-monitor flag generated this cycle identifies this as warranting assessment by the state-capture-focused monitor rather than resolution within the financial-integrity frame alone. For Missouri-domiciled banks, payment companies, and crypto-asset operators, both actions generate immediate screening obligations under existing OFAC and BSA Section 311 authorities; the control-gap signal on both is assessed as covered, meaning the obligation exists and is not itself a newly identified gap. The more significant analytical point is architectural: the scale of laundered and seized proceeds in both actions illustrates that crypto-enabled evasion infrastructure now reaches Missouri-exposed exchanges and money-services businesses at a scale that a purely jurisdiction-bounded assessment would understate. Missouri has no confirmed Russia-sanctions-evasion nexus case identified this cycle, and the state has no direct transit-corridor exposure to Russian sanctions-evasion architecture; the standing Russian evasion tracker for this jurisdiction remains stable on that basis, with the March 2025 Corporate Transparency Act domestic exemption noted only as a generic, not Russia-specific, enabling condition that reduces federal visibility into Missouri LLC beneficial ownership more broadly. Sanctions-regime divergence generally remains a standing area of monitoring for this jurisdiction, though Missouri-based institutions are subject uniformly to federal OFAC sanctions with no independent state authority, so any future divergence signal would necessarily be a national rather than state-level finding. #### Outlook The near-term sanctions-architecture outlook for Missouri-exposed institutions is shaped less by any anticipated new designation than by the durability of the convergence pattern demonstrated this cycle. If the coordinated US-UK designation timing observed in the Prince Group and Huione Group actions persists, Missouri financial institutions and crypto-asset operators should expect list-screening obligations to track closely across both regimes rather than diverge, reducing arbitrage opportunity for evasion intermediaries seeking to exploit jurisdictional gaps between OFAC and OFSI list architecture. The unresolved question, flagged rather than settled this cycle, is whether the scale of proceeds moving through crypto-enabled laundering platforms such as Huione Group reveals a persistent structural vulnerability in crypto-exchange counterparty screening that will recur in future cycles absent a broader platform-level intervention, as opposed to a single, now-resolved node removal. This is illustrative framing of an open question, not a forecast of a specific future designation. Judgment: No US-MO-specific sanctions development this cycle. Uncertain #### Beneficial Ownership and Corporate Transparency The directly relevant beneficial-ownership development for Missouri this cycle is a federal one: the FinCEN interim final rule of March 26, 2025 exempted all entities created in the United States, including those previously known as domestic reporting companies, and their beneficial owners, from Corporate Transparency Act beneficial ownership information reporting. The rule narrows the federal BOI registry to foreign entities registering to do business in the United States, removing the primary federal transparency backstop for Missouri-formed LLCs and corporations. This matters more in Missouri than in states with their own beneficial-ownership collection regimes, because the Missouri Secretary of State does not collect beneficial ownership information at LLC or corporation formation and permits layered ownership structures, including LLCs owning LLCs, alongside registered-agent nominee arrangements that obscure ultimate control. Before March 2025, the federal CTA registry served as a backstop against this state-level gap; its narrowing converts a previously mitigated capacity deficit into an unmitigated national exposure for any entity formed in Missouri. Continue reading The consequence is measurable against an external compliance benchmark. The United States was upgraded on FATF Recommendation 24, the beneficial-ownership recommendation, from Non-Compliant to Largely Compliant in the March 2024 Follow-Up Report, a rating explicitly credited to Corporate Transparency Act implementation. The March 2025 domestic-reporting exemption directly undermines the basis for that credited upgrade, and the rating is now assessed to be at re-rating risk ahead of the United States 5th round mutual evaluation, a process in which the domestic exemption is expected to be a central scrutiny point. Missouri, as a constituent of the federal system, inherits this national rating trajectory in full regardless of any state-level policy choice of its own. A separate but related signal comes from enforcement data rather than registry design. The Department of Justice secured a 10-year sentence in a Missouri-based 147 million dollar health-care-fraud conspiracy on December 12, 2025. The FinCEN 2026 National Money Laundering Risk Assessment situates this individual prosecution within a national trend: a 330 percent increase in health-care-fraud-related Suspicious Activity Report filings between 2020 and 2025. The architecture-level finding is the trend, not the individual case: sustained proceeds-layering through business-entity structures, the same category of structure whose beneficial ownership the CTA exemption now leaves undisclosed at the federal level for domestically formed entities. The composite jurisdiction risk trajectory for Missouri is assessed as increasing this cycle, reflecting the compounding effect of the federal CTA rollback and the capacity-deficit beneficial-ownership regime at state level, partially offset by state-level consumer-protection enforcement activity documented elsewhere in this profile. Globally, the EU AML Package sets the structural direction for beneficial-ownership and corporate-transparency architecture, though it is not the directly relevant regulatory perimeter for Missouri or the United States more broadly. That package comprises three distinct instruments: the directly applicable AML Regulation, Regulation (EU) 2024/1624, the sixth AML Directive requiring transposition by individual EU member states, and the AMLA Regulation, Regulation (EU) 2024/1620, establishing the Anti-Money Laundering Authority, which is shifting supervision of high-risk cross-border obliged entities from purely national authorities toward a hybrid EU-level direct and indirect supervisory perimeter. This structural shift is standing background against which any future EU beneficial-ownership signal should be read; it does not itself alter Missouri regulatory exposure, and no AMLA supervisory perimeter or 6AMLD transposition status applies to a US sub-national jurisdiction. #### Outlook The most consequential near-term event for Missouri beneficial-ownership exposure is not a Missouri-specific proceeding but the United States 5th round FATF mutual evaluation progress reporting, an in-force horizon item carrying a multi-year uncertainty band in which the March 2025 domestic exemption is expected to be a central point of scrutiny. Whether the currently interim exemption status converts into a final rule on materially different terms, or whether the Missouri Secretary of State moves to close the formation-stage beneficial-ownership gap independently of federal action, remain open questions this cycle leaves unresolved rather than answered. Judgment: No US-MO-specific BO development this cycle. Uncertain #### Enabler Jurisdictions and Professional Facilitators Missouri exemplifies a capacity-deficit enabler condition rather than a deliberate permissiveness choice, and this cycle sharpens the consequence of that condition rather than introducing a new one. The Missouri Secretary of State does not collect beneficial ownership information at LLC or corporation formation, permitting layered ownership structures and registered-agent nominee arrangements that obscure ultimate control. Applying the enabler-jurisdiction filter capacity-versus-choice distinction, the Missouri gap reads as a resourcing and design deficiency rather than a strategic decision to attract opaque capital; what changed this cycle is not Missouri own posture but the removal of the federal backstop that had previously offset it. The FinCEN interim final rule of March 26, 2025 exempted all United States-formed domestic reporting companies and their beneficial owners from Corporate Transparency Act reporting, narrowing the federal registry to foreign entities registering to do business domestically. A capacity deficit that was tolerable while a federal backstop existed becomes, in its absence, an unmitigated national exposure for every Missouri-formed entity. Continue reading A second enabler pattern this cycle concerns enforcement lag rather than registry design. Crypto ATM kiosks proliferated nationally, including in Missouri, for years as a largely unregulated cash-to-crypto conversion channel: national kiosk count grew from 4,128 in January 2019 to 37,342 in January 2025, with commission structures of 15 to 50 percent per transaction financially disincentivizing operators from suppressing fraud volume. The Missouri Attorney General did not open a tailored consumer-protection investigation into the sector, targeting Bitcoin Depot and four competitor operators, until December 17, 2025, consistent with a multi-year national enforcement lag against a sector whose retail-site proliferation, at gas stations and convenience stores, occurred largely without tailored money-services-business oversight. That state-level action, layered onto a Connecticut licence suspension and Massachusetts and Iowa litigation, subsequently contributed to the Bitcoin Depot Chapter 11 bankruptcy filing on May 18, 2026, an enforcement-consequence outcome discussed further in the crypto and digital-assets domain of this profile. Read together, these two patterns describe an enabler condition with two faces: a persistent, capacity-driven state-formation gap now compounded by federal backstop removal, and a multi-year enforcement lag against a specific higher-velocity retail scheme that state action has begun, but not fully, to close. Neither reflects Missouri exercising deliberate choice to enable illicit finance; both reflect a structural gap between formation-stage transparency design and the speed at which enforcement capacity was mobilized against an emergent retail typology. This distinction, between capacity deficit and political choice, is the analytically load-bearing element of the enabler-jurisdiction filter as applied to Missouri, and it differentiates this jurisdiction profile from enabler jurisdictions where permissiveness reflects an affirmative regulatory choice rather than a resourcing gap. The professional-facilitator dimension of this filter, concerning registered agents and formation intermediaries who structure the layered LLC and nominee arrangements referenced above, remains a standing area for deeper examination in future cycles; this baseline cycle documents the structural conditions that make such facilitation possible without identifying a specific facilitator network operating in Missouri. #### Outlook The enabler-jurisdiction profile for Missouri this cycle is trending toward deterioration on the beneficial-ownership axis and improvement on the crypto-kiosk axis simultaneously, a genuinely mixed trajectory rather than a uniform direction. Whether the Missouri Secretary of State moves independently to introduce formation-stage beneficial-ownership collection, closing the gap the federal rollback has widened, is not addressed by any development identified this cycle and remains an open question for future monitoring. Judgment: No US-MO-specific enabler-jurisdiction development this cycle. Uncertain #### Conflict Finance and Extractive-Industry Integrity No Missouri-specific conflict-finance, extractive-industry-integrity, or counter-proliferation-financing mechanism was identified in Tier 1-2 sourced reporting within this cycle research window. This domain is accordingly carried forward on a watch basis rather than assessed as materially active, consistent with the fixed-set domain convention that treats a quiet domain as a standing entry rather than an omission. The absence of a finding is explicitly flagged for re-verification rather than asserted as a confirmed null: a targeted search of FinCEN and Department of Justice Missouri-district press releases was noted as a step that would help confirm whether this reflects a genuine absence of conflict-finance exposure in the jurisdiction or a visibility gap in the sources reviewed this cycle. Continue reading This honest-absence framing matters analytically. Financial-integrity assessment of extractive-industry and conflict-finance exposure typically requires either a documented physical-commodity nexus or a documented armed-group financing channel; Missouri economy does not present an obvious extractive-industry profile of the kind that has generated Tier 1 findings in other jurisdictions this monitor covers, and no cross-border commodity-flow or armed-conflict financing signal touching Missouri-domiciled entities surfaced in this cycle research. That absence is worth stating plainly rather than filling with adjacent material, consistent with the principle that a concise, honest account of a quiet domain is preferable to inflated coverage. #### Outlook No specific forward-looking development in this domain was identified this cycle. Future cycles should test whether the targeted Missouri-district federal press-release search identified as a gap in this cycle research would surface a conflict-finance or extractive-industry signal not visible in the broader source set reviewed to date. Judgment: Not applicable to US-MO this cycle. Uncertain #### Crypto / Digital Assets / Financial Innovation Missouri's crypto-kiosk regulatory architecture is in active dispute this cycle. GPD Holdings LLC, operating as CoinFlip, has moved to dismiss the Missouri Attorney General's Merchandising Practices Act suit, arguing that the Virtual Currency Kiosk Consumer Protection Act (RSMo 361.1100), enacted in 2025, is the industry-specific regime that governs crypto-kiosk conduct and therefore displaces the AG's broader fraud-based theory. This is a live test of a pattern relevant well beyond Missouri: a state legislature enacts a sector-specific AML and consumer-protection statute, complete with its own licensing, due-diligence, and penalty structure, and the regulated industry then argues that statute is the exclusive remedy, foreclosing use of a state's general consumer-protection toolkit against the same conduct. Where a kiosk-specific regime was advanced with industry input, as reporting on Missouri's 2025 statute suggests, the resulting question is whether that regime functions as a genuine AML control or as a liability shield against broader enforcement. Continue reading Running in parallel, Missouri Senate Bill 1510 would amend RSMo 361.1100 to grant the Attorney General sole authority to bring civil actions for violations of the kiosk statute, with civil penalties of up to $10,000 per violation and $1,000 for each breach of an injunction. The bill remains pending in the Senate Insurance and Banking Committee and has not been enacted. If passed, it would clarify and concentrate enforcement authority specifically within the kiosk statute itself, a development that could bear on, without necessarily resolving, the question raised by CoinFlip's motion to dismiss. At the federal layer, FinCEN's 11 August 2026 final rule permanently exempting US-formed entities from Corporate Transparency Act beneficial-ownership reporting is noted as structural context; Missouri has no state-level beneficial-ownership registry, so this federal development carries no Missouri-specific variance and does not alter the kiosk-statute dispute described above. #### Outlook The trajectory of Missouri's crypto-kiosk enforcement architecture depends on two linked but distinct processes: the court's ruling on CoinFlip's preemption-style motion to dismiss, which will determine whether the kiosk statute operates as an exclusive regime displacing general consumer-protection enforcement, and the Senate's handling of SB 1510, which would separately strengthen and concentrate the AG's enforcement authority under the kiosk statute itself. The underlying motion-to-dismiss document has not been independently retrieved this cycle; this sub-brief's account rests on a single T3 press report of the filing, and the compliance status of other Missouri kiosk operators under general consumer-protection scrutiny remains unestablished. Judgment: Missouri's RSMo 361.1100 kiosk statute and pending SB 1510 AG-enforcement bill remain the operative state-level crypto/AML-adjacent instruments; no movement confirmed this cycle. Probable #### Compliance Technology and Active Defence Two counter-directional signals define this domain for Missouri this cycle, and the analytical value lies precisely in their tension rather than in either alone. The FinCEN proposed rule to fundamentally reform AML/CFT program requirements, with a comment period that closed June 9, 2026, would shift financial institutions, including Missouri-licensed money transmitters, toward a risk-based, less prescriptive compliance posture, moving away from check-the-box Suspicious Activity Report filing volume toward institutional risk assessment as the primary compliance benchmark. This is presented as a proactive-compliance thesis: a shift that, if implemented as proposed, could allow better-resourced institutions to concentrate detection effort on genuinely higher-risk activity rather than filing volume for its own sake. The risk direction on implementation is assessed as uncertain pending a final rule, reflecting genuine ambiguity in whether the reform practical effect will strengthen or dilute oversight depth once translated into supervisory practice. Continue reading Running counter to that thesis is a national reduction in IRS Criminal Investigation examiner capacity for crypto and money-services-business AML oversight. This capacity reduction is a national rather than Missouri-specific development, but it narrows federal supervisory depth reaching Missouri-licensed money transmitters precisely at a moment when the proposed program-reform rule would ask institutions to exercise more, not less, independent risk judgment. A risk-based compliance model depends on credible supervisory verification that institutions own risk assessments are sound; a contemporaneous reduction in the federal examiner capacity available to perform that verification is a capacity-deficit signal that operates independently of, and in tension with, any individual enforcement action. This signal is more thinly sourced within this cycle profile than the program-reform NPRM itself, and is assessed accordingly at a lower confidence tier, Possible rather than Assessed or High. For Missouri-licensed money-services businesses and crypto-asset operators, the practical implication is that the compliance-technology and active-defence environment is genuinely uncertain in direction, not merely under-described. Institutions cannot yet assume that a shift toward risk-based program design will be accompanied by commensurate supervisory capacity to test the quality of the risk assessments institutions themselves will be expected to produce. This tension, between a stated policy direction toward proactive, risk-based compliance and a resourcing trend running the opposite way, is the defining structural finding for this domain this cycle, and it applies with equal force to Missouri banks, payment companies, and crypto-asset operators subject to the federal AML program framework. #### Outlook The FinCEN AML/CFT program reform rule sits on a year-scale uncertainty band with an expected 2027 effective date; its final terms, and whether examiner capacity is restored or further reduced in parallel, will determine whether Missouri-licensed institutions experience the reform as a genuine compliance-burden reduction or as a supervisory-depth gap dressed in risk-based language. This is illustrative framing of a genuinely open question, not a prediction of the rule eventual terms. Judgment: No RegTech/guidance development identified for US-MO this cycle. Uncertain #### AML/CTF Regime Missouri's money-transmission licensing perimeter, the state-level layer beneath federal Bank Secrecy Act and FinCEN obligations for money transmitters, was modernized this cycle through the repeal-and-replace of the state's former Sale of Checks Law. The Money Transmission Modernization Act, codified at RSMo Sections 361.900 through 361.1035, became effective August 28, 2024, confirmed directly on the Missouri Revisor of Statutes' own statute page, which marks the prior sections as repealed pursuant to 2024 Senate Bill 1359. The enacted bill text itself, retrieved from the Missouri Senate's own records, confirms the repeal-and-enactment language directly. Continue reading This modernization is independently corroborated by the Conference of State Bank Supervisors' legislative tracker, which lists Missouri as a Full MTMA introduction state effective the same August 28, 2024 date, situating Missouri's reform within a broader multi-state harmonization effort coordinated through the Model Money Transmission Act framework rather than as an idiosyncratic state-specific change. The practical AML/CTF significance for licensees, including payment processors and money-transmitters serving Missouri's live regulated sports-wagering market, is that any such entity must now hold licensure consistent with the modernized statute rather than relying on any status obtained under the repealed Sale of Checks Law. This is a structural tightening of the state licensing layer beneath federal AML obligations, not an enforcement action; no Missouri-specific enforcement event against a money-transmission licensee was identified this cycle. #### Outlook The item to watch within this domain is whether Missouri's Division of Finance issues implementing rules or guidance clarifying transition requirements for money-transmitters previously licensed under the repealed Sale of Checks Law, and whether any enforcement action tests the new licensing perimeter's application to payment processors serving the state's sports-wagering market. Judgment: Federal Title 31 casino AML regime applies to Missouri casinos unchanged. Probable Judgment: No financial-integrity-sector commercial event identified for US-MO this cycle. Uncertain Regulatory horizon No dated horizon items this cycle. 3 items tracked without a confirmed date. 3 pending date · baseline financial-integrity-2026-07-06 Role action cards MLRO ### A Missouri crypto-kiosk operator is testing whether a kiosk-specific AML statute forecloses general consumer-protection enforcement against it. If the preemption-style argument succeeds, the practical AML/consumer-protection exposure for kiosk operators in jurisdictions with similar sector-specific statutes could narrow, changing the risk calculus for monitoring and reporting obligations tied to kiosk channels. 1 evidence refs Compliance ### Pending Missouri SB 1510 would concentrate kiosk-statute civil-enforcement authority solely in the Attorney General. A compliance function monitoring state-level crypto-kiosk obligations should track whether SB 1510 is enacted, since it would clarify (without yet changing) who holds civil-enforcement authority under RSMo 361.1100. 1 evidence refs Legal ### CoinFlip's motion to dismiss tests whether Missouri's kiosk statute displaces the AG's general fraud theory. Legal counsel advising crypto-kiosk operators should track the court's ruling on the preemption-style defence, since it will bear on whether a sector-specific AML statute can be read as an exclusive remedy against general consumer-protection claims. 1 evidence refs Board ### No material change for this persona this cycle. No material change for this persona this cycle CTO ### No material change for this persona this cycle. No material change for this persona this cycle Risk ### Missouri's crypto-kiosk enforcement architecture is in active dispute between statutory regimes. Risk functions tracking exposure concentration in crypto-kiosk channels should note that the scope of applicable enforcement authority in Missouri is currently unsettled pending the CoinFlip ruling and SB 1510's progress. 2 evidence refs Operations ### No material change for this persona this cycle. No material change for this persona this cycle Audit ### No material change for this persona this cycle. No material change for this persona this cycle Scenario sketches ### Kiosk statute as exclusive-remedy shield Illustrative scenario for analytical orientation only: if a court were to accept the argument that a sector-specific AML/consumer-protection statute displaces a state attorney general's general fraud authority, other crypto-kiosk operators facing consumer-protection suits in jurisdictions with similar industry-specific statutes could cite the Missouri ruling as persuasive authority, potentially narrowing the enforcement toolkit available against the sector even where a general-purpose law would otherwise reach the conduct. This is an illustration of a possible structural mechanism, not an observed or predicted outcome. Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact. ### AMLA direct/indirect supervision transition Illustrative scenario for analytical orientation only: as the AML Regulation (Reg (EU) 2024/1624) becomes directly applicable and Member States transpose the sixth AML Directive, the Anti-Money Laundering Authority established under Reg (EU) 2024/1620 could begin assuming direct supervision of select cross-border obliged entities, shifting the balance away from purely national supervisors. Such a shift could, illustratively, alter where evasion typologies migrate within the EU as entities adjust their footprint relative to the direct-versus-indirect supervision perimeter. This is illustration only, not an observed development or a prediction. 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 · Sanctions Architecture no_change T2 · EU AML Package / AMLA no_change T3 · FATF Grey List no_change T4 · Beneficial-Ownership Register Status no_change T5 · Crypto & Digital-Asset Integrity watch T6 · Sanctions Regime Divergence no_change Registers ### Enforcement actions - 12 Dec 2025 - 17 Dec 2025 - 26 Mar 2025 - 18 May 2026 - 14 Oct 2025 - 14 Oct 2025 - 20 May 2026 - 25 Jun 2025 - 30 Jun 2025 - 1 May 2026 - 1 Feb 2026 - A Missouri man was sentenced to 10 years in prison for his role in a $147 million health care fraud conspiracy, part of a broader national health-care-fraud enforcement wave referenced in FinCEN's 2026 Health Care Fraud Advisory. 12 Dec 2025 - Missouri Attorney General Catherine Hanaway sent demand letters to Bitcoin Depot and four competitor crypto ATM companies seeking evidence of suspected violations of state consumer-protection law tied to hidden fees and scam-facilitation allegations. 1 Dec 2025 - FinCEN issued an interim final rule formally exempting all US-formed 'domestic reporting companies' and their beneficial owners from Corporate Transparency Act BOI reporting, restricting the federal BOI regime to foreign entities registering to do business in a US state or tribal jurisdiction. 26 Mar 2025 - Sustained multi-state regulatory pressure — including Missouri's AG investigation, Connecticut's banking-license suspension, and Massachusetts/Iowa litigation — drove the largest US crypto ATM operator, with machines in Missouri among its ~9,700 US kiosks, into bankruptcy and cessation of operations. 17 May 2026 ### Sanctions changes - 14 Oct 2025 - 14 Oct 2025 - 16 Jan 2026 - 14 Apr 2026 - 14 Apr 2026 - 23 Jan 2026 - 16 Jan 2026 - 24 Aug 2026 - 20 Aug 2026 - OFAC designated the Prince Group Transnational Criminal Organization and 146 associated targets, including chairman Chen Zhi, for operating massive pig-butchering scam networks and laundering billions via crypto; DOJ concurrently seized ~127,271 bitcoin ($15B). Relevant to Missouri given crypto-ATM/exchange exposure to pig-butchering proceeds flows. 14 Oct 2025 - FinCEN finalized a Section 311 special measure designating Huione Group a foreign financial institution of primary money laundering concern, severing it from the US financial system after it was linked to over $4 billion in laundered proceeds (2021-2025), including North Korean cyber-heist and crypto-investment-scam funds. 14 Oct 2025 ### Regulatory horizon (register) - GENIUS Act implementing regulations (AML/sanctions + prudential NPRMs) - GENIUS Act implementing regulations (AML/sanctions + prudential NPRMs) - SB 1510 — AG enforcement authority for Virtual Currency Kiosk Consumer Protection Act - SB 1510 - AG civil-enforcement authority for Virtual Currency Kiosk Act - FinCEN AML/CFT Program Reform Rule Finalization - GENIUS Act State Money-Transmitter/Stablecoin Equivalency Determination - US FATF 5th Round Mutual Evaluation Progress Reporting ### Active schemes - Crypto ATM Kiosk Cash-to-Crypto Scam Conversion Pipeline - Anonymous LLC Formation Compounded by Federal CTA Domestic Exemption - Health Care Fraud Proceeds Layering via Missouri Conspiracy Network Sources - [As crypto industry expands, US slashes office examining dirty money safeguards of cryptocurrency exchanges - ICIJ](https://www.icij.org/investigations/coin-laundry/as-crypto-industry-expands-u-s-slashes-office-examining-dirty-money-safeguards-of-cryptocurrency-exchanges/) - [https://senate.mo.gov/24info/pdf-bill/House/HCS-SB/SB1359.pdf](https://senate.mo.gov/24info/pdf-bill/House/HCS-SB/SB1359.pdf) - [https://revisor.mo.gov/main/OneSection.aspx?section=361.900](https://revisor.mo.gov/main/OneSection.aspx?section=361.900) - [https://www.gamblinginsider.com/news/153263/missouri-forces-torch-electronics-to-suspend-slot-machine-operations](https://www.gamblinginsider.com/news/153263/missouri-forces-torch-electronics-to-suspend-slot-machine-operations) - [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://www.federalregister.gov/documents/2026/08/31/2026-17724/notice-of-ofac-sanctions-action](https://www.federalregister.gov/documents/2026/08/31/2026-17724/notice-of-ofac-sanctions-action) - [https://home.treasury.gov/news/press-releases/sb0611](https://home.treasury.gov/news/press-releases/sb0611) - [https://www.fincen.gov/news/news-releases/fincen-issues-supplemental-alert-fuel-smuggling-and-tax-evasion-schemes-southern](https://www.fincen.gov/news/news-releases/fincen-issues-supplemental-alert-fuel-smuggling-and-tax-evasion-schemes-southern) - [https://agbrief.com/news/cambodia/26/01/2026/cambodia-battles-to-avoid-third-fatf-grey-list-placement-amid-scam-crackdown/](https://agbrief.com/news/cambodia/26/01/2026/cambodia-battles-to-avoid-third-fatf-grey-list-placement-amid-scam-crackdown/) - [https://www.chainalysis.com/blog/ofac-iran-oil-payments-august-2026/](https://www.chainalysis.com/blog/ofac-iran-oil-payments-august-2026/) - [Missouri Revisor of Statutes](https://revisor.mo.gov/main/OneSection.aspx?section=361.700&bid=19608) - [Missouri Senate](https://www.senate.mo.gov/24info/pdf-bill/tat/SB1359.pdf) - [Missouri Division of Finance](http://finance.mo.gov/virtual-currency-kiosk-operators) - [Topograph](https://www.topograph.co/guides/business-registers-in-missouri-united-states) - [Missouri Independent](https://missouriindependent.com/2022/03/03/mosers-board-votes-to-divest-pension-fund-of-russia-linked-investments/) - [CSBS](https://www.csbs.org/sites/default/files/external-link-files/MTMA%20Legislative%20Update%20-%20June%202026.pdf) - [https://www.stlmag.com/news/bitcoin-atms-missouri-ag-hanaway/](https://www.stlmag.com/news/bitcoin-atms-missouri-ag-hanaway/) - [https://www.senate.mo.gov/BillTracking/Bills/BillInformation?year=2026&billid=74595](https://www.senate.mo.gov/BillTracking/Bills/BillInformation?year=2026&billid=74595) - [https://www.acams.org/en/news/breaking-news-fincen-permanently-eliminates-beneficial-ownership-reporting-us-entities](https://www.acams.org/en/news/breaking-news-fincen-permanently-eliminates-beneficial-ownership-reporting-us-entities) - [U.S. Government (eCFR / FinCEN)](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1021) - [Internal Revenue Service](https://www.irs.gov/government-entities/indian-tribal-governments/itg-faq-8-answer-what-are-the-reporting-requirements-for-casinos) - [Fact Sheet on MSB Registration Rule | FinCEN.gov](https://www.fincen.gov/fact-sheet-msb-registration-rule) - [FinCEN Notice, FIN-2025-NTC1, August 4, 2025](https://www.fincen.gov/system/files/2025-08/FinCEN-Notice-CVCKIOSK.pdf) - [Enforcement Actions for Failure to Register as a Money Services Business | FinCEN.gov](https://www.fincen.gov/enforcement-actions-failure-register-money-services-business) - [Application of the Definition of Money Transmitter to Brokers and Dealers in Currency and Other Commodities | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/application-definition-money-transmitter-brokers-and) - [Enforcement Actions | FinCEN.gov](https://www.fincen.gov/news/enforcement-actions) - [Fincen](https://www.fincen.gov/sites/default/files/shared/msbstatecontactsfinal.pdf) - [Important Information for MSBs | FinCEN.gov](https://www.fincen.gov/resources/financial-institutions/money-services-businesses) - [GUIDANCE TO MONEY SERVICES BUSINESSES ON OBTAINING AND MAINTAINING BANKING SERVICES | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/guidance-money-services-businesses-obtaining-and) - [News Releases on Unregistered Money Transmitter Enforcement Actions | FinCEN.gov](https://www.fincen.gov/news-releases-unregistered-money-transmitter-enforcement-actions-0) - [Treasury Convenes Financial Institutions and Law Enforcement to Identify and Dismantle Money Laundering Networks | FinCEN.gov](https://www.fincen.gov/news/news-releases/treasury-convenes-financial-institutions-and-law-enforcement-identify-and) - [Frequently Asked Questions | FinCEN.gov](https://www.fincen.gov/boi-faqs) - [Beneficial Ownership Information Reporting Rule Fact Sheet | FinCEN.gov](https://www.fincen.gov/beneficial-ownership-information-reporting-rule-fact-sheet) - [Beneficial Ownership Information Reporting | FinCEN.gov](https://www.fincen.gov/boi) - [Small Entity Compliance Guide | FinCEN.gov](https://www.fincen.gov/boi/small-entity-compliance-guide) - [Fact Sheet: Beneficial Ownership Information Reporting Notice of Proposed Rulemaking (NPRM) | FinCEN.gov](https://www.fincen.gov/news/news-releases/fact-sheet-beneficial-ownership-information-reporting-notice-proposed-rulemaking) - [Beneficial Ownership Reporting Outreach and Education Toolkit | FinCEN.gov](https://www.fincen.gov/boi/toolkit) - [Treasury Department won’t enforce beneficial ownership rule under the Corporate Transparency Act - ICIJ](https://www.icij.org/inside-icij/2025/03/treasury-department-wont-enforce-beneficial-ownership-rule-under-the-corporate-transparency-act/) - [Updated: March 2025 1 Financial Crimes Enforcement Network](https://www.fincen.gov/system/files/shared/BOI-FAQs-QA-508C.pdf) - [Quick Reference | FinCEN.gov](https://www.fincen.gov/boi/quick-reference) - [1 Notice to Customers: Beneficial Ownership Information Reference Guide](https://www.fincen.gov/system/files/shared/BOI-Notice-to-Customers-508FINAL.pdf) - [Potential Money Laundering Risks Related to Shell Companies | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/potential-money-laundering-risks-related-shell-companies) - [Financial Crimes Enforcement Network The Role of Domestic Shell Companies in](https://www.fincen.gov/system/files/shared/LLCAssessment_FINAL.pdf) - [Financial Crimes Enforcement Network Registration of Money Services Business](https://www.fincen.gov/system/files/shared/FinCENRMSB_ElectronicFilingInstructions.pdf) - [Money Services Business (MSB) Agent List | FinCEN.gov](https://www.fincen.gov/money-services-business-msb-agent-list) - [How Anonymous Companies Are Used to Launder Money in US Real Estate | Global Witness](https://www.globalwitness.org/en/campaigns/corruption-and-money-laundering/anonymous-companies-used-to-launder-money-in-us-real-estate/) - [Anonymous companies - Frequently Asked Questions | Global Witness](https://www.globalwitness.org/en/archive/anonymous-companies-frequently-asked-questions/) - [FinCEN Advisory - FIN-2017-A003 | FinCEN.gov](https://www.fincen.gov/resources/advisories/fincen-advisory-fin-2017-a003) - [fincen logo MONEY SERVICES BUSINESS REGISTRATION FACT SHEET](https://www.fincen.gov/system/files/shared/FinCENfactsheet.pdf) - [Money Services Business (MSB) Registration | FinCEN.gov](https://www.fincen.gov/resources/money-services-business-msb-registration) - [Annual FinCEN Program Recognizes Law Enforcement Cases Supported by BSA Data | FinCEN.gov](https://www.fincen.gov/news/news-releases/annual-fincen-program-recognizes-law-enforcement-cases-supported-bsa-data) - [E Richard Webber, United States District Court for the Eastern District of Missouri: Profile and Biography - Bloomberg Markets](https://www.bloomberg.com/profile/person/3047056) - [Jill A Morris, United States District Court for the Western District of Missouri: Profile and Biography - Bloomberg Markets](https://www.bloomberg.com/profile/person/20294439) - [DOJ Seizes $15 Billion in Bitcoin](https://www.chainalysis.com/blog/southeast-asia-crypto-scam-network-mining-pig-butchering-october-2025/) - [US DOJ Announces Largest Ever Seizure of Funds Related to Crypto Scams | TRM Labs](https://www.trmlabs.com/resources/blog/us-doj-announces-largest-ever-seizure-of-funds-related-to-crypto-scams) - [Prince Group targeted with $15B crypto seizure and sanctions for pig butchering operations](https://www.elliptic.co/blog/prince-group-targeted-with-crypto-sanctions-for-global-pig-butchering-operations) - [Pig butchering scam](https://www.trmlabs.com/glossary/pig-butchering-scam) - [OFAC Sanctions Tracker: How Sanctions Impact Crypto Crime - Chainalysis](https://www.chainalysis.com/blog/ofac-sanctions/) - [Crypto National Security & Pig Butchering Scams – Ep. 174](https://www.chainalysis.com/blog/crypto-national-security-pig-butchering-ep-174/) - [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) - [U.S. Crackdown on Southeast Asian Crypto Scam Centers](https://www.chainalysis.com/blog/asian-scam-centers-crypto-fraud-april-2026/) - [Money laundering](https://www.trmlabs.com/glossary/money-laundering) - [MSB Registrant Search | FinCEN.gov](https://www.fincen.gov/resources/msb-state-selector) - [Money Services Businesses | FinCEN.gov](https://www.fincen.gov/money-services-businesses) - [Fincen](https://www.fincen.gov/system/files/schema/code/FinCENReferenceCodes.xsd) - [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/) - [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/) - [Three Sentenced in Nationwide Card Fraud, Money Laundering Conspiracy](https://www.occrp.org/en/daily/16244-three-sentenced-in-nationwide-card-fraud-money-laundering-conspiracy) - [1 FIN-2022-A002 June 15, 2022 Advisory on Elder Financial Exploitation](https://www.fincen.gov/system/files/advisory/2022-06-15/FinCEN%20Advisory%20Elder%20Financial%20Exploitation%20FINAL%20508.pdf) - [FinCEN Issues Analysis on Elder Financial Exploitation | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-analysis-elder-financial-exploitation) - [Elder Financial Exploitation: Threat Pattern & Trend ...](https://www.fincen.gov/system/files/shared/FTA_Elder_Financial_Exploitation_508Final.pdf) - [Advisory on Elder Financial Exploitation](https://www.fincen.gov/sites/default/files/advisory/2022-06-15/FinCEN%20Advisory%20Elder%20Financial%20Exploitation%20FINAL%20508.pdf) - [FinCEN Reminds Financial Institutions to Remain Vigilant to Elder Financial Exploitation | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-reminds-financial-institutions-remain-vigilant-elder-financial) - [FinCEN Joins Agencies in Issuing A Statement on Elder Financial Exploitation | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-joins-agencies-issuing-statement-elder-financial-exploitation) - [1 The U.S. Department of the Treasury’s (Treasury) Financial](https://www.fincen.gov/system/files/2026-03/FinCEN-Advisory-Health-Care-Fraud.pdf) - [Advisories | FinCEN.gov](https://www.fincen.gov/resources/advisoriesbulletinsfact-sheets/advisories) - [Press Releases | FinCEN.gov](https://www.fincen.gov/news/press-releases) - [2026 Crypto Crime Report: Scams](https://www.chainalysis.com/blog/crypto-scams-2026/) - [Consolidated assessment ratings](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Assessment-ratings.html) - [Mutual Evaluations](https://www.fatf-gafi.org/en/topics/mutual-evaluations.html) - [Mutual Evaluation of the United States](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationoftheunitedstates.html) - [United States](https://www.fatf-gafi.org/en/countries/detail/United-States.html) - [Assessments](https://www.fatf-gafi.org/en/calendars/assessments.html) - [The FATF Recommendations](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html) - [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) - [REPORT ON THE STATE OF EFFECTIVENESS AND COMPLIANCE WITH THE FATF STANDARDS](https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/Report-on-the-State-of-Effectiveness-Compliance-with-FATF-Standards.pdf.coredownload.pdf) - [Consolidated assessment ratings (2014 - 2026 assessments)](https://www.fatf-gafi.org/en/publications/mutualevaluations/documents/assessment-ratings.html) - [Documents - Financial Action Task Force (FATF)](https://www.fatf-gafi.org/publications/mutualevaluations/documents/mutualevaluationoftheunitedstates.html) - [1 1. See 31 U.S.C. § 5312(a)(2); 31 C.F.R. § 1010.100(t). 2.](https://www.fincen.gov/system/files/2026-06/FinCEN-Alert-Fiscal-Fuel-Theft.pdf) - [PPSI-AMLCFT-NPRM.pdf](https://www.fincen.gov/system/files/2026-04/PPSI-AMLCFT-NPRM.pdf) - [2026 Crypto Crime Report – Illicit Crypto Trends & Typologies | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/2026-crypto-crime-report) - [FinCEN Advisory FIN-2026-A002, 6/5/2026](https://www.fincen.gov/system/files/2026-06/FinCEN-Advisory-Non-Work-Authorized-Populations.pdf) - [The Maduro indictment: a blockchain intelligence perspective](https://www.elliptic.co/blog/the-maduro-indictment-a-blockchain-intelligence-perspective) - [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) - [Blockchain Legal Library](https://www.trmlabs.com/blockchain-legal-library) - [1 The U.S. Department of the Treasury’s (Treasury)](https://www.fincen.gov/system/files/2025-08/FinCEN-Advisory-CMLN-508.pdf) - [Special Notice RMSB Posting](https://www.fincen.gov/system/files/shared/msbregformDRAFT.pdf) - [IMPORTANT NOTICE FOR MSBs | FinCEN.gov](https://www.fincen.gov/important-notice-msbs) - [MSB Registration List](https://www.fincen.gov/system/files/shared/msb_registration_list.pdf) - [Specific Information about each Agent | FinCEN.gov](https://www.fincen.gov/specific-information-about-each-agent) - [Canaccord-Consent-Order-No-2026-01. ...](https://www.fincen.gov/system/files/2026-03/Canaccord-Consent-Order-No-2026-01.pdf) - [Key Changes in FinCEN’s Proposed Rule to Refocus AML/CFT Programs on](https://www.fincen.gov/system/files/2026-04/Key-Changes-Program-NPRM.pdf) - [FinCEN Consent Order Imposing Civil Money Penalty, ...](https://www.fincen.gov/system/files/enforcement_action/2023-04-05/USAA_Consent_Order_Final_508_2.pdf) - [SAR-FAQs-October-2025.pdf](https://www.fincen.gov/system/files/2025-10/SAR-FAQs-October-2025.pdf) - [Interagency Statement on Sharing Bank Secrecy Act Resources | FinCEN.gov](https://www.fincen.gov/news/news-releases/interagency-statement-sharing-bank-secrecy-act-resources) - [The Bank Secrecy Act | FinCEN.gov](https://www.fincen.gov/resources/statutes-and-regulations/bank-secrecy-act) - [Fact Sheet: Proposed Rule to Fundamentally Reform Financial](https://www.fincen.gov/system/files/2026-04/Program-NPRM-FactSheet.pdf) - [CONSENT ORDER IMPOSING CIVIL MONEY PENALTY](https://www.fincen.gov/sites/default/files/enforcement_action/2023-04-05/CBOT_Enf_Action_121621_508_FINAL.pdf) - [FinCEN Announces Recipients of Its 11th Law Enforcement Awards Program | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-announces-recipients-its-11th-law-enforcement-awards-program) - [Every Crime Is a Financial Crime: Inside IRS-CI’s Fight Against Illicit Finance with Chief Guy Ficco](https://www.trmlabs.com/resources/trm-talks/every-crime-is-a-financial-crime-inside-irs-cis-fight-against-illicit-finance-with-chief-guy-ficco) - [International Narcotics Control Strategy Report Volume II Money Laundering](https://syntheticdrugs.unodc.org/uploads/syntheticdrugs/res/library/cybercrime_html/US_International_Narcotics_Control_Strategy_Report_Money_Laundering.pdf) - [FinCEN Awards Recognize Partnership Between Law Enforcement and Financial Institutions to Fight Financial Crime | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-awards-recognize-partnership-between-law-enforcement-and-financial) - [FinCEN Director’s Law Enforcement Awards Program Recognizes](https://www.fincen.gov/system/files/shared/Significant%20Fraud%20PDF.pdf) - [FinCEN Director’s Law Enforcement Awards Program Recognizes Significance of BSA Reporting by Financial Institutions | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-directors-law-enforcement-awards-program-recognizes-significance-bsa) - [Financial Trend Analysis Fentanyl-Related Illicit Finance](https://www.fincen.gov/system/files/shared/FinCEN-FTA-Fentanyl.pdf) - [Chainalysis Links 2026 • March 31-April 1 • New York, NY](https://www.chainalysis.com/links-nyc/) - [FinCEN Awards Recognize Law Enforcement Success Stories Supported by Bank Secrecy Act Reporting | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-awards-recognize-law-enforcement-success-stories-supported-bank-secrecy) - [2025 TRM Wrapped: Celebrating a Year of Private-Public Disruption | TRM Blog](https://www.trmlabs.com/resources/blog/2025-trm-wrapped) - [Retailers keep cashing in on crypto ATMs as scams surge - ICIJ](https://www.icij.org/investigations/coin-laundry/retailers-keep-cashing-in-on-crypto-atms-as-scams-surge/) - [US Faces Court Scrutiny Over $15 Billion Bitcoin Seizure Linked to Crypto Hack - Bloomberg](https://www.bloomberg.com/news/articles/2026-03-24/us-s-mysterious-15-billion-crypto-haul-faces-questions-in-court) - [$15 billion seized by US originates from Iran/China bitcoin miner "theft"](https://www.elliptic.co/blog/15-billion-us-seizure-reveals-prince-groups-connection-to-iran-china-bitcoin-mining-theft) - [Law enforcement, banks warn of money laundering gaps in major US crypto bill - ICIJ](https://www.icij.org/investigations/coin-laundry/law-enforcement-banks-warn-of-money-laundering-gaps-in-major-us-crypto-bill/) - [Cryptocurrency Field Guide for Law Enforcement](https://www.chainalysis.com/blog/law-enforcement-crypto-field-guide/) - [The DOJ's NCET Disbanded: What This Means for Digital Assets - Chainalysis](https://www.chainalysis.com/blog/ncet-blanche-memo/) - [Consumer Protection the Main Focus for Crypto Regulators in 2022](https://www.elliptic.co/blog/consumer-protection-the-main-focus-for-crypto-regulators-in-2022) - [Bitcoin Exchange Sees Complaints Soar - Bloomberg](https://www.bloomberg.com/news/articles/2017-08-30/bitcoin-exchange-sees-complaints-soar-as-users-demand-money) - [From trading bans to total embrace, a global guide to crypto regulation](https://www.icij.org/investigations/coin-laundry/cryptocurrency-regulations-global-explainer/) - [As crypto industry expands, US slashes office examining dirty money safeguards of cryptocurrency exchanges - ICIJ](https://www.icij.org/investigations/coin-laundry/as-crypto-industry-expands-u-s-slashes-office-examining-dirty-money-safeguards-of-cryptocurrency-exchanges/) - [FinCEN (U.S. Treasury)](https://www.fincen.gov/boi) - [FinCEN (U.S. Treasury)](https://www.fincen.gov/system/files/2026-03/FinCEN-Advisory-Health-Care-Fraud.pdf) - [FinCEN (U.S. Treasury)](https://www.fincen.gov/system/files/2025-08/FinCEN-Notice-CVCKIOSK.pdf) - [FinCEN (U.S. Treasury)](https://www.fincen.gov/system/files/2026-04/PPSI-AMLCFT-NPRM.pdf) - [ICIJ](https://www.icij.org/investigations/coin-laundry/massachusetts-sues-bitcoin-depot-alleging-the-crypto-atm-operator-knowingly-facilitated-crypto-scams/) - [FATF](https://www.fatf-gafi.org/en/publications/Mutualevaluations/united-states-fur-2024.html) - [Elliptic](https://www.elliptic.co/blog/prince-group-targeted-with-crypto-sanctions-for-global-pig-butchering-operations) - [ICIJ](https://www.icij.org/investigations/coin-laundry/crypto-atm-operator-bitcoin-depot-files-for-bankruptcy/) Coverage gaps fim-int-2026-07-06-G001: Missouri Attorney General's own pre… fim-int-2026-07-06-G001: Missouri Attorney General's own press release (ago.mo.gov) for the Bitcoin Depot investigation was not directly cited in the initial baseline pass; direct citation would strengthen source-tier integrity beyond secondary ICIJ reporting. [resolved] fim-int-2026-07-06-G002: No Tier 1-2 sourced Missouri-specif… fim-int-2026-07-06-G002: No Tier 1-2 sourced Missouri-specific CTF/CPF or extractive-industry conflict-finance scheme was identified; targeted search of FinCEN/DOJ Missouri-district press releases would confirm whether this is a genuine null finding or a visibility gap. [resolved] fim-int-2026-07-06-G003: FinCEN's March 2025 interim final r… fim-int-2026-07-06-G003: FinCEN's March 2025 interim final rule exempting domestic reporting companies remains interim pending a final rule; confirmation of the final rule's publication and terms would resolve whether the domestic exemption is durable or reversible. [resolved] fim-int-2026-07-06-G004: No assessment was made of whether M… fim-int-2026-07-06-G004: No assessment was made of whether Missouri-incorporated entities with EU-facing financial activity face exposure under the EU AMLR/6AMLD/AMLA regime; cross-border nexus data would clarify this. [resolved] fim-int-2026-07-14-G001: No EU AML Package (AMLR/6AMLD/AMLA)… fim-int-2026-07-14-G001: No EU AML Package (AMLR/6AMLD/AMLA) transposition or supervisory build-out developments were surfaced this cycle; search effort concentrated on US-MO, Yemen, Mexico and UAE vectors. [resolved] fim-int-2026-07-14-G002: No primary Missouri court filing (a… fim-int-2026-07-14-G002: No primary Missouri court filing (as opposed to press coverage) was retrieved for the CoinFlip suit, capping confidence at Assessed. [resolved] fim-int-2026-08-05-G001: No Tier-1/2 FinCEN or FCA/JMLSG AI/… fim-int-2026-08-05-G001: No Tier-1/2 FinCEN or FCA/JMLSG AI/ML supervisory-expectation source was retrieved this cycle to populate a full D6 enforcement-gap-log entry. [resolved] fim-int-2026-08-05-G002: Colombia yielded no material findin… fim-int-2026-08-05-G002: Colombia yielded no material finding this cycle; coverage gap rather than a confirmed no-change result. [resolved] fim-int-2026-08-05-G003: No direct OFAC.gov or EU Council pr… fim-int-2026-08-05-G003: No direct OFAC.gov or EU Council primary source was retrieved this cycle for the specific shadow-fleet vessel-count figures. [resolved] fim-int-2026-09-05-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G001 ({'scheme': 'financial_integrity', 'value': 'D3'}): No prior baseline exists for US-MO enabler-jurisdiction-specific finding; D3 has not been independently re-derived against a prior state. [resolved] fim-int-2026-09-05-G002: Laos and Colombia Tier-D coverage r… fim-int-2026-09-05-G002: Laos and Colombia Tier-D coverage returned no qualifying material within this cycle's pooled search budget and require priority search next cycle. [resolved] fim-int-2026-09-05-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G003 ({'scheme': 'financial_integrity', 'value': 'D1'}): Torch Electronics enforcement finding remains Tier-3-only sourced this cycle pending T1/T2 corroboration. [resolved] fim-int-2026-09-28-G001: Tier-D watch jurisdictions (Cambodi… fim-int-2026-09-28-G001: Tier-D watch jurisdictions (Cambodia, Laos, Mexico, Colombia) were not reached this cycle; pooled research budget was concentrated on US-MO. [resolved] fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', 'value': 'D2'}): No Tier-1 Missouri source directly affirms the absence of a state beneficial-ownership register; the finding rests on a Tier-4 commercial KYB guide. [resolved] fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', 'value': 'D1'}): MOSERS' 2022 divestment decision was not independently re-verified against a Tier-1 MOSERS filing this cycle; only a T3 investigative-press account was retrieved. [resolved] fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): Tier D jurisdictions (Cambodia, Laos, Mexico, Colombia) and standing Russia/Houthi-Yemen sanctions channels were not independently re-checked this cycle; search budget was concentrated on the bound jurisdiction. [open] fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): The underlying CoinFlip motion-to-dismiss document was not independently retrieved this cycle; the claim rests on a single T3 press report. [open] fim-int-2026-10-25-G001: Global Tier-D sweep (Cambodia, Laos… fim-int-2026-10-25-G001: Global Tier-D sweep (Cambodia, Laos, Mexico, Colombia) and the FATF/OFAC/OFSI global feeds were not independently re-swept this cycle given the search budget was concentrated on US-MO-specific material. [open] fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): Missouri's Virtual Currency Kiosk Consumer Protection Act (RSMo 361.1100) and pending SB 1510 AG-enforcement bill were identified but reported in depth under the crypto consumer rather than independently re-verified here as an AML-adjacent development. [open] FIM-GAP-001 (D2): Missouri's Secretary of State does not col… FIM-GAP-001 (D2): Missouri's Secretary of State does not collect beneficial ownership information at entity formation, and the March 2025 federal CTA rollback removed the FinCEN BOI backstop for domestically formed entities, leaving no reliable mechanism to identify the true owners of Missouri-registered LLCs and corporations. FIM-GAP-002 (D5): Crypto ATM kiosks proliferated nationally … FIM-GAP-002 (D5): Crypto ATM kiosks proliferated nationally (4,128 in 2019 to 37,342 in January 2025) including in Missouri gas stations and convenience stores, with FinCEN noting some kiosk operators failed to register as MSBs; state-specific tailored AML/consumer-protection rules for kiosks in Missouri only began with the AG's December 2025 investigation, well after the sector's fraud exposure was well documented nationally. FIM-GAP-003 (D3): This baseline could not directly retrieve … FIM-GAP-003 (D3): This baseline could not directly retrieve a Missouri state-government primary source (e.g., a Missouri Attorney General or Missouri Division of Finance press release/official page) for the Bitcoin Depot investigation; the finding is sourced via ICIJ's secondary reporting, which quotes the AG's press release but is not the AG's own publication. FIM-GAP-004 (D4): No Missouri-specific conflict-finance, ext… FIM-GAP-004 (D4): No Missouri-specific conflict-finance, extractive-industry, or CTF/CPF-financing-mechanism scheme (e.g., hawala-based terrorist financing, NGO misuse, DPRK/Iran proliferation corridor) was identified in open-source Tier 1-2 reporting within the 18-month window. ## Evidence #### Confidence-tiered claims Argues Missouri's Virtual Currency Kiosk Consumer Protection Act (RSMo 361.1100) is the industry-specific regime that displaces the AG's general Merchandising Practices Act fraud theory [[Source 1]](#sec-sources) Probable · 1 source Would amend RSMo 361.1100 to grant the Missouri Attorney General sole authority to bring civil actions for kiosk-statute violations, with civil penalties up to $10,000 per violation and $1,000 per injunction breach [[Source 1]](#sec-sources) Probable · 1 source FinCEN's 11 August 2026 final rule permanently exempts US-formed entities from CTA beneficial-ownership reporting; Missouri has no state-level BO registry so no state-specific variance exists [[Source 1]](#sec-sources) Probable · 1 source Missouri commercial casinos remain subject to the uniform federal Bank Secrecy Act / Title 31 casino AML regime (31 CFR Part 1021), administered through FinCEN, with no US-MO-specific AML instrument change identified this cycle. [[Source 1]](#sec-sources) Probable · 1 source