--- title: "United States — Montana (US-MT) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/united-states-montana/ source_html: /jurisdictions/united-states-montana/index.html description: "Financial integrity intelligence for United States – Montana (US-MT): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: 38c0aee1b5920fe89475a1c9c15df8fbb1a169425a4eecb3cb3bbd264686540d generator: "fe-fleet/md-twin@1.0" --- # United States — Montana (US-MT) — 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 — Montana US-MT Domains covered 8 of 8 Sources 175 Role actions 8 Horizon <90d 0 Jurisdiction profile FATF status: Not Member Tier: C Risk direction: Increasing Enablement vs enforcement: Mixed Montana's AML/CTF framework is almost entirely federally-mediated via the Bank Secrecy Act, FinCEN registration, and OFAC sanctions screening. More State-level oversight runs through the Montana Division of Banking & Financial Institutions (MSB/bank licensing) and the Commissioner of Securities and Insurance (securities/crypto-fraud enforcement). Montana has no state beneficial-ownership registry, and the March 2025 federal CTA rollback removed the sole remaining BOI backstop for domestically-formed LLCs. Key deficiencies - No state-level beneficial ownership registry; reliance on now-curtailed federal CTA/BOI reporting regime - Minimal-disclosure LLC formation regime consistent with the broader US pattern of anonymous shell-company formation - State securities/crypto enforcement capacity increasingly exposed to federal preemption (OCC national trust charters, potential CLARITY Act market-structure preemption) - Sparse independently-documented state-level BSA/AML enforcement record distinct from federal FinCEN/OFAC action Recent developments (18m) - FinCEN's March 2025 interim final rule exempted all domestic reporting companies (including Montana-formed LLCs) from Corporate Transparency Act beneficial ownership reporting - Montana lawmakers voted against establishing a state-level strategic Bitcoin reserve (February 2025) - Montana state securities regulators joined a multi-state warning to Congress that pending crypto market-structure legislation (CLARITY Act) could diminish state capacity to prosecute crypto fraud (October 2025) - OCC granted conditional national trust bank charters to five digital-asset firms (December 2025), enabling nationwide operation that bypasses state-by-state licensing including Montana's regime United States federal law that applies in United States – Montana is covered once, on the [United States](/jurisdictions/us/) page. This page covers United States – Montana’s own layer: its own law, regulators and enforcement. Brief ## Lead signal #### Lead Signal Montana surfaces this cycle through two findings that share a single structural thread: the absence of a state money-transmitter licensing regime is reshaping how federal and state actors treat crypto activity physically present in the state. On 8 October 2026, thirty-four state financial regulatory agencies reached a 2.5 million dollar settlement with crypto-kiosk operator Coinme Inc. over Bank Secrecy Act and anti-money-laundering program deficiencies. Montana was not among the thirty-four settling states, a fact consistent with Montana Division of Banking and Financial Institutions own published position that it does not regulate money transmitters. The absence is not an oversight; it is a standing structural feature of Montana law that places the state outside a national supervisory lever other states used to compel remediation from a national kiosk operator. Read full brief #### Lead Signal Montana surfaces this cycle through two findings that share a single structural thread: the absence of a state money-transmitter licensing regime is reshaping how federal and state actors treat crypto activity physically present in the state. On 8 October 2026, thirty-four state financial regulatory agencies reached a 2.5 million dollar settlement with crypto-kiosk operator Coinme Inc. over Bank Secrecy Act and anti-money-laundering program deficiencies. Montana was not among the thirty-four settling states, a fact consistent with Montana Division of Banking and Financial Institutions own published position that it does not regulate money transmitters. The absence is not an oversight; it is a standing structural feature of Montana law that places the state outside a national supervisory lever other states used to compel remediation from a national kiosk operator. The second development runs in a related register. At its 1 June 2026 meeting, Montana's Blockchain and Digital Innovation Task Force recommended taking no action on a Montana state-qualified stablecoin issuer bill, choosing instead to rely on the federal OCC pathway established under the GENIUS Act. Read together, the two findings describe a jurisdiction that is not building its own supervisory capacity over digital-asset intermediaries, but is instead deferring upward to federal gateways, whether FinCEN MSB registration for money-services activity or OCC certification for stablecoin issuance. #### Other Developments Federal MSB registration remains the sole AML gateway. Montana's Division of Banking and Financial Institutions states on its own site that it does not regulate money transmitters. For crypto-kiosk or money-transmission activity based in or serving Montana, the only applicable anti-money-laundering gateway is federal FinCEN registration as a money services business under 31 U.S.C. Chapter 53. No state-level licensing, examination, or enforcement layer sits above that federal baseline. Task Force reporting duty continues under SB 330. The Blockchain and Digital Innovation Task Force's deferral on a state stablecoin-issuer bill was recorded in primary meeting minutes and folds into its statutory reporting duty to the Economic Affairs Interim Committee. The choice not to build a state-qualified Permitted Payment Stablecoin Issuer regime is a deliberate narrowing of the state's own supervisory footprint over private stablecoin issuance, in favor of the federal OCC certification track. #### Cross-Monitor Connections The Coinme settlement and Montana's non-participation in it sit at the intersection of financial-integrity supervision and the digital-asset regulatory architecture that the crypto monitor tracks independently: the same underlying fact, that Montana lacks a money-transmitter licensing statute, explains both why thirty-four states could compel a national kiosk operator into remediation and why Montana itself could not. The Task Force's stablecoin deferral likewise connects directly to the federal GENIUS Act implementation track, where OCC certification is emerging as the default pathway for state-level actors unwilling or unable to stand up their own issuer regimes. Neither finding this cycle touches conflict finance, sanctions architecture, or beneficial-ownership registries at the Montana level. #### Outlook Montana's structural posture, no money-transmitter licensing statute, no state-qualified stablecoin issuer regime, reliance on federal gateways throughout, is unlikely to change on its own initiative in the near term absent a serious enforcement gap becoming publicly visible. The Coinme settlement's exclusion of Montana is the kind of enablement signal that this register treats as analytically significant in its own right: the absence of enforcement in a permissive jurisdiction is not evidence of absence of risk. Readers should watch whether the Task Force's continuing reports to the Economic Affairs Interim Committee produce any future move toward state-level licensing capacity, particularly if federal MSB registration proves insufficient to address kiosk-specific fraud typologies. Earlier periodic briefs (3) 25 Oct 2026 · fim-2026-10-25 #### Lead Signal Montana surfaces through two findings that share a single structural thread: the absence of a state money-transmitter licensing regime is reshaping how federal and state actors treat crypto activity physically present in the state. On 8 October 2026, thirty-four state financial regulatory agencies reached a 2.5 million dollar settlement with crypto-kiosk operator Coinme Inc. over Bank Secrecy Act and anti-money-laundering program deficiencies. Montana was not among the thirty-four settling states, a fact consistent with Montana Division of Banking and Financial Institutions own published position that it does not regulate money transmitters. The absence is not an oversight; it is a standing structural feature of Montana law that places the state outside a national supervisory lever other states used to compel remediation from a national kiosk operator. The second development runs in a related register. At its 1 June 2026 meeting, Montana's Blockchain and Digital Innovation Task Force recommended taking no action on a Montana state-qualified stablecoin issuer bill, choosing instead to rely on the federal OCC pathway established under the GENIUS Act. Read together, the two findings describe a jurisdiction that is not building its own supervisory capacity over digital-asset intermediaries, but is instead deferring upward to federal gateways, whether FinCEN MSB registration for money-services activity or OCC certification for stablecoin issuance. #### Other Developments Federal MSB registration remains the sole AML gateway. Montana's Division of Banking and Financial Institutions states on its own site that it does not regulate money transmitters. For crypto-kiosk or money-transmission activity based in or serving Montana, the only applicable anti-money-laundering gateway is federal FinCEN registration as a money services business under 31 U.S.C. Chapter 53. No state-level licensing, examination, or enforcement layer sits above that federal baseline. Task Force reporting duty continues under SB 330. The Blockchain and Digital Innovation Task Force's deferral on a state stablecoin-issuer bill was recorded in primary meeting minutes and folds into its statutory reporting duty to the Economic Affairs Interim Committee. The choice not to build a state-qualified Permitted Payment Stablecoin Issuer regime is a deliberate narrowing of the state's own supervisory footprint over private stablecoin issuance, in favor of the federal OCC certification track. #### Cross-Monitor Connections The Coinme settlement and Montana's non-participation in it sit at the intersection of financial-integrity supervision and the digital-asset regulatory architecture that the crypto monitor tracks independently: the same underlying fact, that Montana lacks a money-transmitter licensing statute, explains both why thirty-four states could compel a national kiosk operator into remediation and why Montana itself could not. The Task Force's stablecoin deferral likewise connects directly to the federal GENIUS Act implementation track, where OCC certification is emerging as the default pathway for state-level actors unwilling or unable to stand up their own issuer regimes. Neither finding touches conflict finance, sanctions architecture, or beneficial-ownership registries at the Montana level. #### Outlook Montana's structural posture, no money-transmitter licensing statute, no state-qualified stablecoin issuer regime, reliance on federal gateways throughout, is unlikely to change on its own initiative in the near term absent a serious enforcement gap becoming publicly visible. The Coinme settlement's exclusion of Montana is the kind of enablement signal that this register treats as analytically significant in its own right: the absence of enforcement in a permissive jurisdiction is not evidence of absence of risk. Readers should watch whether the Task Force's continuing reports to the Economic Affairs Interim Committee produce any future move toward state-level licensing capacity, particularly if federal MSB registration proves insufficient to address kiosk-specific fraud typologies. 28 Sep 2026 · fim-2026-09-28 #### Lead Signal Montana's crypto exposure has escalated this cycle against a backdrop of structural regulatory absence that has not itself changed. The state's own Commissioner of Securities and Insurance briefed a legislative Blockchain and Digital Innovation Task Force on rising crypto-ATM-facilitated fraud, reporting approximately $3.4 million in reported crypto-scam losses in 2025, driven substantially by cash-out schemes of the pig-butchering typology, against roughly 400 crypto ATMs operating statewide. Separately, the Montana State Auditor's Office recorded 25 fraud complaints in the first quarter of 2026, up from 11 in the same quarter of 2025, totalling approximately $3.3 million in reported losses. Neither figure is corroborated by a primary regulatory publication this cycle; both trace to a single aggregator report of an official briefing and to state press reporting respectively, and the Commissioner's own dataset was not independently opened. #### Other Developments Structural enabler condition confirmed at source. Montana's Division of Banking and Financial Institutions states directly on its own site that it does not regulate money transmitters, and this is confirmed as the sole applicable AML compliance gate: federal FinCEN BSA/MSB registration under 31 U.S.C. 5318(h), with no state-level licensing, reporting-threshold, or obliged-entity designation regime of any kind. This structural condition is stable and long-standing; it is not new this cycle, but it is the backdrop against which the crypto-ATM fraud escalation must be read, since it means no state licensing authority stands between an unlicensed money-services actor and Montana consumers. Policy response under discussion, not yet enacted. The task force briefing that surfaced the fraud figures also outlined possible countermeasures under consideration, including transaction limits, consumer warnings, and a possible money-transmitter-licensing regime for crypto ATMs specifically. None of these has been enacted as of this cycle; the record reflects discussion at the task-force stage only. #### Cross-Monitor Connections The crypto-ATM fraud escalation documented here is the same underlying fact set that the crypto monitor's consumer_protection module and the world-payments monitor's W10 (Consumer Protection & APP Fraud) module address from their respective lenses: crypto foregrounds the token/product-classification angle and the absence of an enacted crypto-ATM statute, while world-payments foregrounds the payment-corridor and money-transmission-licensing angle. All three readings trace to the same Commissioner of Securities and Insurance briefing and the same Daily Montanan complaint-volume reporting; none introduces a fact the others do not share. #### Outlook The question worth tracking is whether Montana's Blockchain and Digital Innovation Task Force converts its discussion of transaction limits, consumer warnings, or crypto-ATM-specific licensing into enacted policy. Until that happens, the structural enabler condition (no state money-transmitter statute) and the escalating fraud-loss trend continue to run in parallel rather than intersect through any new compliance obligation. 28 Aug 2026 · fim-2026-08-21 #### Lead Signal Montana remains the only U.S. state without a state-level money-transmitter licensing requirement, a structural fact confirmed directly by the state's own Division of Banking and Financial Institutions. Businesses operating as money transmitters, payment processors, or crypto exchanges in Montana rely solely on federal FinCEN Form 107 money-services-business registration and Bank Secrecy Act compliance; no state licence, bonding requirement, or state fee applies to money transmission specifically. This is not evidence of deliberate permissiveness on Montana's part in the way an enabler-jurisdiction finding often connotes — Montana continues to license consumer finance companies, escrow companies, banks, credit unions, and mortgage entities, and the absence is better characterised as a capacity gap than a policy choice. Even so, architecture matters more than intent for financial-integrity purposes: whatever the origin, the absence functions in practical effect as a light-touch enabler profile for payment and money-services-business structuring, and it is the kind of finding that generates no enforcement volume precisely because there is no state-level supervisory perimeter to enforce against. That absence of enforcement action is itself analytically significant under the enablement-as-signal principle: a jurisdiction cannot generate a money-transmitter enforcement record it has no statute to support. Every other U.S. state regulates money transmission under a state-specific licensing regime, a comparative point corroborated in secondary legal commentary, which sharpens Montana's position as the singular outlier in the state money-transmission-licensing landscape and the primary reason this jurisdiction now sits on a watch trajectory rather than a stable one. The jurisdiction risk tracker for Montana characterises this cycle's posture as a capacity deficit rather than deliberate enablement, with a stable overall trajectory and Assessed confidence, and flags both the money-transmitter gap and the digital-asset registration framework below as the two primary domains warranting continued attention. #### Other Developments Montana's Financial Freedom and Innovation Act creates a state registration pathway for digital-asset issuers. Senate Bill 265, effective October 2025, gives the Montana State Auditor's office authority to register issuers of "network tokens" under a non-securities pathway, and to prosecute fraudulent actors within that framework. The statute defines "network token," "blockchain," and "decentralized network," establishing Montana as an early mover among U.S. states in carving out a bespoke registration lane for token issuers distinct from securities regulation. Read alongside the money-transmitter licensing gap above, Senate Bill 265 is architecturally significant rather than merely incidental: it is a second instance this cycle of Montana choosing a permissive, registration-based posture toward a financial-innovation activity rather than a fuller licensing-and-supervision regime. This finding rests on a single secondary legal-commentary source; no primary publication from the State Auditor's office was reached this cycle, and implementing rules or a registration form have not yet been located, capping confidence at Assessed rather than a higher tier. Implementing rules for Senate Bill 265 are expected around the fourth quarter of 2026, though general industry practice for token issuers has not yet incorporated Montana's registration pathway. The three-pillar balance principle is worth noting explicitly here: this cycle's Montana findings sit entirely within the AML and cross-pillar structural space, with no CTF- or CPF-specific material identified, which is consistent with the jurisdiction's small financial-services footprint rather than indicative of an under-weighted counter-terrorist-financing gap. #### Cross-Monitor Connections No material cross-monitor signal was identified for Montana this cycle. Montana's money-transmitter licensing gap and its new digital-asset registration pathway are both domestic U.S. structural developments with no evidenced nexus to conflict-finance, commodity-flow, or information-operations typologies this cycle. Analysts should note the enabler-jurisdiction reading of the licensing gap as the connective thread most likely to surface cross-monitor relevance in a future cycle, particularly if a payment company or crypto-asset operator exploiting the absence of state-level money-transmitter supervision surfaces in a conflict-finance or sanctions-evasion context tracked elsewhere in the fleet. The Senate Bill 265 network-token registration pathway similarly bears watching for any future nexus to fraud typologies; no such nexus is evidenced at this time. #### Outlook Montana's structural profile is best read as two adjacent but distinct developments: a long-standing capacity deficit in money-transmitter supervision that is unlikely to close absent a legislative initiative not currently evidenced, and a newly bedding-in digital-asset registration framework under Senate Bill 265 whose implementing rules are expected around the fourth quarter of 2026. The State Auditor's registration form and rulemaking, once published, will be the key primary-source gap to close in a future cycle, and should materially firm up confidence on the Senate Bill 265 finding beyond its current Assessed tier. Absent either a state legislative move toward money-transmitter licensing or enforcement activity testing the Senate Bill 265 framework, Montana's systemic significance for financial-integrity purposes remains low, though the enabler-jurisdiction and digital-asset-innovation signals both warrant continued monitoring on a watch trajectory rather than being closed out as stable. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion Three sanctions and enforcement actions logged this cycle update the standing D1 picture on scam-compound financial infrastructure and North Korean revenue generation, and each illustrates a different facet of sanctions-regime architecture rather than a single incident to be assessed in isolation. On 30 October 2025, OFAC and the UK Office of Financial Sanctions Implementation jointly designated Chen Zhi, Prince Group, and Jin Bei Group Co. Ltd, the Cambodia-based conglomerate identified as operating forced-labor scam compounds and cryptocurrency fraud operations, alongside a Department of Justice indictment and a fifteen billion dollar Bitcoin seizure. No simultaneous European Union Council designation of the same network has been identified in the current research window. This timing and scope divergence, joint US-UK action without parallel EU listing, is itself the analytically significant data point under the three-level F2 sanctions-architecture analysis this domain applies: at the scheme level, the underlying forced-labor and fraud economy continues to generate proceeds; at the architecture level, multilateral sanctions coordination on transnational scam-compound networks remains uneven across the US, UK and EU; and at the strategic-consequence level, that unevenness creates a compliance-friction surface that financial institutions navigating multiple sanctions regimes must independently reconcile. Continue reading A second designation, issued by OFAC on 12 March 2026, targeted six individuals and two entities facilitating a North Korean remote-IT-worker revenue-generation scheme assessed at nearly eight hundred million dollars in 2024 proceeds directed toward weapons-of-mass-destruction and ballistic-missile programs. This is standing D1 coverage of DPRK revenue-generation architecture, and it is a CPF-pillar finding specifically, a designation that requires screening diligence from any US financial institution, including Montana-chartered or Montana-domiciled firms, against the risk of unwittingly engaging DPRK-linked remote contractors through indirect employment or subcontracting chains. A third action, the FinCEN Section 311 designation of Huione Group as a foreign financial institution of primary money-laundering concern effective 1 October 2025, identified over four billion dollars in illicit proceeds and imposes enhanced-due-diligence and correspondent-account restriction obligations nationwide. Montana-chartered banks and money-services businesses inherit this obligation through the national Bank Secrecy Act framework rather than through any Montana-specific rulemaking, illustrating how a sub-national jurisdiction with no independent sanctions authority is bound entirely by federally-mandated sanctions and AML programs; Montana exposure to this designation, and to the Prince Group and DPRK designations alike, runs exclusively through that federal channel. The obligation architecture activated by these three actions is uneven across firm types even within a single national framework: the Huione Section 311 designation directly triggers correspondent-banking and payment-company enhanced-due-diligence obligations under Section 311 of the USA PATRIOT Act, a covered-and-enforced control; the DPRK IT-worker designation activates screening obligations across banks, payment companies and cross-sector customer relationships generally, also assessed as covered; but no comparable formal obligation reference is recorded this cycle for the Prince Group and Chen Zhi designation beyond the general sanctions-screening baseline, a control-coverage asymmetry that is itself worth tracking as this scam-compound architecture evolves. Read together, these three actions describe a sanctions-evasion architecture built around Southeast Asian scam-compound economies and DPRK state-directed revenue generation, both of which rely on correspondent-banking access and crypto-asset conversion points that nationally-supervised institutions are now required to screen against. The absence of an EU designation running parallel to the US-UK Prince Group action is not, on its own, evidence of non-enforcement by the EU; but under the enablement-as-signal principle this domain applies, the divergence in timing and scope across allied sanctions regimes is a structural finding in its own right, independent of whatever EU action may eventually follow. #### Outlook The most consequential open question for this domain is whether EU Council action against the Prince Group and Chen Zhi network materializes, which would close the regime-divergence gap identified this cycle; its absence to date is logged as a standing watch item rather than a settled non-action. Further OFAC, OFSI or EU designations of ruble-stablecoin facilitators or additional Southeast Asian scam-compound nodes are plausible next-cycle developments given the pace of designations logged this cycle, though any such development would need independent confirmation before being treated as more than a scenario. For Montana specifically, the forward risk of this domain runs entirely through the national sanctions-screening obligations imposed on federally-supervised and BSA-covered institutions; no Montana-specific sanctions authority or independent enforcement action is anticipated, consistent with the structural reliance of the jurisdiction on federal sanctions administration. Institutions with correspondent-banking relationships touching Cambodia-domiciled payment or virtual-asset intermediaries carry the most direct near-term exposure from the Huione Section 311 designation; the enhanced-due-diligence requirement it imposes is a nationwide baseline, not a Montana-specific one, and is already in force rather than pending. Judgment: No Montana-specific or dedicated federal sanctions search was run this MT-scoped dispatch this cycle. Uncertain #### Beneficial Ownership and Corporate Transparency The single most consequential structural development in this domain, and arguably in the entire jurisdiction profile this cycle, is the FinCEN interim final rule issued in March 2025 exempting all US-formed reporting companies from Corporate Transparency Act beneficial-ownership-information reporting, effective 26 March 2025. Under the corrected characterization applied by challenge review, this action is properly described as an elimination of domestic reporting rather than a curtailment: only foreign entities registering to do business in a US state remain subject to CTA reporting obligations. For Montana specifically, this removes the sole federal beneficial-ownership disclosure backstop that ever applied to Montana-formed LLCs and corporations, because Montana itself collects no beneficial-ownership information at formation and has no state-level registry to fall back on. The result, read architecturally rather than as an isolated rulemaking event, is that Montana-formed entities, and by extension the registered-agent and nominee-incorporation services that layer ownership through corporate managers, now face no functioning beneficial-ownership disclosure requirement at either the state or federal level absent a foreign-registration trigger. Continue reading This dynamic is catalogued in the active scheme inventory of the interpreter as Anonymous LLC formation post-CTA rollback: Montana, like most US states, permits LLC formation without collecting beneficial-ownership information at inception or thereafter, and registered-agent and nominee-incorporation services can layer ownership through corporate managers, obscuring true control. The severity assigned to this scheme architecture is preliminary and rated HIGH, reflecting the combination of an enabler-role jurisdiction, an active status, and the recent removal of the one federal control that previously existed. This US-specific rollback sits against a durable, structurally distinct backdrop on the other side of the Atlantic that this domain tracks as standing context regardless of any single cycle: the European Union AML Package is not one instrument but three. The AML Regulation, Regulation (EU) 2024/1624, known as the AMLR, is directly applicable across Member States without national transposition; the sixth Anti-Money Laundering Directive, known as 6AMLD, requires transposition into each Member State domestic law on its own timetable; and the AMLA Regulation, Regulation (EU) 2024/1620, establishes the Anti-Money Laundering Authority, which is progressively assuming direct supervision of a defined set of high-risk cross-border obliged entities while indirect supervision of the remainder continues to run through national authorities. That three-instrument architecture is shifting the beneficial-ownership and broader AML supervisory perimeter of the EU from a purely national model toward a hybrid EU-level regime, a structural fact independent of this cycle US-MT findings, and the frame against which any future EU beneficial-ownership scrutiny of US corporate-secrecy practices, including practices in Montana, should be read. No AMLA-specific regulatory-horizon item was carried in this cycle research window for the US-MT jurisdiction profile, so this paragraph is offered as standing architectural context rather than a this-cycle development. The reasoning layer of this domain additionally assessed, at Assessed rather than High confidence since it is an analytical inference rather than a FATF plenary finding, that the post-rollback US beneficial-ownership disclosure regime now diverges from FATF Recommendation 24 and 25 risk-based transparency guidance. This divergence assessment is distinct from, but reinforces, the plain structural fact that Montana-formed entities lack any disclosure mechanism: the FATF-alignment question asks whether the current US posture meets an external standard, while the Montana-specific finding establishes what the domestic mechanism actually requires, currently nothing, absent foreign registration. #### Outlook Two watch items follow directly from this cycle material change. First, any legal challenge or legislative reversal of the CTA domestic-entity exemption would be a first-order development for this domain and should be tracked closely given the structural centrality of the exemption to Montana, and the broader US, beneficial-ownership posture. Second, any Montana-specific state-level beneficial-ownership disclosure proposal in a future legislative session would partially offset the federal rollback for Montana-formed entities specifically, though no such proposal has been identified in the current research window. On the EU side of the standing architecture, the direct-supervision selection methodology of AMLA and the 2027 application date of the AMLR remain the relevant forward markers, though neither surfaced as a this-cycle US-MT-relevant development and both are noted here only as durable background against which future EU scrutiny of US corporate-transparency practices should be assessed. It is worth stating plainly what this cycle does and does not establish: it does not establish that Montana is uniquely permissive relative to other US states, since the CTA rollback and the absence of a state registry are both features of the broader US corporate-formation landscape, not Montana-specific policy choices; what it does establish is that Montana, as a representative US sub-national jurisdiction with no state registry, now illustrates in concentrated form what the federal rollback means in practice for any US state lacking an independent beneficial-ownership disclosure mechanism. Judgment: No new Montana-specific beneficial-ownership development this cycle; federal CTA/BOI regime continues to apply. Probable #### Enabler Jurisdictions and Professional Facilitators The F3 enabler-jurisdiction filter of this domain applies a deliberate capacity-deficit-versus-political-choice distinction, and this cycle material change sits squarely on the political-choice side of that line for Montana. The Office of the Comptroller of the Currency granted conditional national trust bank charters to five digital-asset firms, BitGO, Fidelity Digital Assets, Paxos, the First National Digital Currency Bank of Circle, and Ripple National Trust Bank, on 12 December 2025, enabling each to operate nationwide custody and settlement activity without seeking state-by-state money-transmitter or trust licensure. This is a structural preemption of the direct supervisory visibility of state regulators over consumer-facing crypto custody and settlement activity, including the Montana Division of Banking and Financial Institutions, and it is assessed rather than confirmed at High confidence pending a primary-source OCC release, since the current evidence base relies on secondary reporting for the charter approvals themselves. Continue reading This is not a capacity failure on the part of Montana. The Montana Commissioner of Securities and Insurance issued a cease-and-desist against the Forsage smart-contract pyramid scheme in 2021, demonstrating that enforcement capacity existed and was exercised against a genuinely cross-border crypto-fraud typology. The federal preemption dynamic operating this cycle is better read as a political choice imposed on an actively-enforcing state regulator than as a response to any documented Montana enforcement-capacity deficit, a distinction this domain F3 filter treats as analytically load-bearing, since conflating the two would misattribute a federal-level structural decision to a state-level shortcoming. A second, still-unresolved preemption risk runs through the pending CLARITY Act. The bill passed the House in July 2025, cleared the Senate Banking Committee by a vote of fifteen to nine in May 2026, and was placed on the Senate Legislative Calendar on 1 June 2026, with the Senate now in recess until 13 July 2026 and unresolved ethics, preemption-scope, and Banking and Agriculture Committee reconciliation issues outstanding. Montana joined a multi-state NASAA coalition warning that the bill, if passed in something close to its current form, could narrow state crypto-fraud enforcement authority nationally. This risk is assessed as uncertain rather than settled-worsening, correcting an earlier baseline characterization that treated the trajectory of the bill as confidently deteriorating; the accurate posture this cycle is that the outcome remains genuinely open pending Senate floor action and committee reconciliation. Underneath both preemption dynamics sits a longer-standing structural tension: state money-transmitter regulators nationally, including regulators in Montana, operate with examiner resources long assessed by the Money Transmitter Regulators Association as structurally constrained relative to the scale of the money-services and digital-asset industry supervised. This capacity constraint compounds, rather than substitutes for, the political-choice preemption described above; both dynamics operate on Montana simultaneously, and the risk assessment of the interpreter for this jurisdiction accordingly characterizes the enforcement-versus-enablement balance as mixed rather than uniformly one or the other. The near-term risk this domain flags is a supervisory vacuum: state oversight is being structurally narrowed before any equivalent federal enforcement capacity has been demonstrated at scale. The standing global coverage of this domain, the UK enabler ecosystem, Dubai and the UAE, Singapore, and the Swiss reform trajectory, is carried forward unchanged this cycle; no jurisdiction-specific development in those markets surfaced in the current US-MT-focused research window. The domestic US federal-preemption dynamic described above is analytically distinct from, but structurally comparable to, the professional-facilitator and permissive-jurisdiction patterns tracked in those standing markets: in both cases, the enabler role of a jurisdiction is defined less by the presence of illicit intent and more by the structural gap between formal supervisory authority and demonstrated enforcement reach. Read alongside the D2 beneficial-ownership finding, the D3 preemption dynamic compounds a single underlying enabler condition for Montana: an entity or asset-custody structure that faces no independent beneficial-ownership disclosure requirement is, under the OCC charter regime, now also less likely to face independent state-level custody or transmitter oversight, two supervisory layers narrowing in the same cycle, on different legal bases, for the same underlying digital-asset and corporate-structure activity. #### Outlook The Senate floor-vote scheduling and Banking and Agriculture Committee reconciliation outcome of the CLARITY Act, expected to clarify after the Senate returns from recess on 13 July 2026, is the single most consequential near-term marker for this domain; its resolution, in either direction, would materially update the enabler-jurisdiction picture for Montana and other states relying on independent crypto-fraud enforcement authority. A confirmed primary-source citation for the national trust charter approvals of the OCC remains an identified evidence gap and should be sourced directly from the OCC own release in the next research cycle. Absent either development, the structural narrowing of the independent supervisory reach of Montana over digital-asset firms should be read as an active and ongoing condition rather than a settled endpoint, with the overall risk direction of the jurisdiction recorded as deteriorating on a structural rather than episodic basis. Judgment: No new enabler-jurisdiction development specific to Montana this cycle. Uncertain #### Conflict Finance and Extractive-Industry Integrity No conflict-finance or extractive-industry-integrity development specific to this jurisdiction was identified in the current research window. The standing global coverage of this domain, Russian war-economy financing, Sahel minerals, and DRC governance, is carried forward unchanged rather than restated as new material, consistent with the no-change assessment of the interpreter for this domain this cycle. Montana, as a US sub-national jurisdiction, has no independent nexus to conflict-finance or extractive-industry-integrity typologies in the current evidence base; any exposure would run, as in the sanctions-architecture domain, through national-level US financial-system obligations rather than through a Montana-specific channel. This entry is flagged for limited signal honestly rather than padded with content not supported by this cycle research: the absence of a Montana-specific conflict-finance development is itself recorded as the material finding for this domain this cycle, not omitted from the standing six-domain structure. This is consistent with the three-pillar balance principle applied across this domain: the absence of enforcement action is not treated as an absence of risk, but this cycle research bundle did not surface evidence sufficient to update the standing global picture for a US sub-national jurisdiction with no documented extractive-industry or conflict-adjacent financial nexus. Continue reading Two structural conditions are worth naming for completeness. First, no primary or secondary source in this cycle research bundle documented a Montana-domiciled institution correspondent or custodial exposure to conflict-affected extractive supply chains. Second, no evidence emerged of Montana-based capital participating in, or facilitating, financing streams connected to the Russian war economy, Sahel mineral extraction, or DRC governance failures tracked at the global level. Both absences are recorded as the honest state of this cycle evidence rather than treated as a confirmed clean bill for the jurisdiction going forward. #### Outlook No jurisdiction-specific watch items are identified for this domain this cycle. The standing global trackers of this domain, Russian war-economy financing, Sahel minerals, and DRC governance, remain the relevant forward markers, and any future Montana-specific nexus, for example through a state-chartered institution correspondent exposure to conflict-affected extractive supply chains, would represent a first-order development for this jurisdiction profile were it to emerge in a subsequent cycle. Where the standing trackers of this domain are concerned, this baseline treats the current no-change status as the honest and complete record rather than as license to speculate about latent risk. Any subsequent-cycle development, for example a Montana-chartered institution correspondent relationship surfacing exposure to conflict-adjacent extractive financing, or a documented link between Montana-domiciled capital and Sahel or DRC extractive operations, would represent a first-order, not incremental, change to this domain baseline and should be assessed independently rather than folded into the existing no-change trajectory. Judgment: No conflict-finance signal specific to Montana this cycle. Uncertain #### Crypto / Digital Assets / Financial Innovation Montana's digital-asset posture this cycle is defined by what its own Blockchain and Digital Innovation Task Force chose not to build. At its 1 June 2026 meeting, the Task Force recommended taking no action on a Montana state-qualified stablecoin issuer bill, a Permitted Payment Stablecoin Issuer-style regime, and instead agreed to rely on the federal OCC certification pathway created under the GENIUS Act. This is a Confirmed finding drawn directly from primary task-force minutes, which record the consensus and motion. The practical effect is that private stablecoin issuance touching Montana will be supervised, if at all, at the federal level rather than through any state-specific prudential or disclosure regime tailored to Montana's own market. Continue reading The same underlying structural feature, Montana's absence of a money-transmitter licensing statute, also explains the state's position relative to the 8 October 2026 multistate settlement between thirty-four state regulators and crypto-kiosk operator Coinme Inc. Montana was not a party to that 2.5 million dollar Bank Secrecy Act and anti-money-laundering settlement. Montana's own Division of Banking and Financial Institutions confirms on its website that it does not regulate money transmitters, which removes the supervisory basis that the other thirty-four states used to bring Coinme to remediation. For a digital-innovation monitor, this is best read as an architecture finding rather than an incident: it is not that Montana failed to enforce against a bad actor, but that Montana's regulatory architecture does not contain the lever the other states used. Taken together, these two Confirmed findings describe a state that is, by design, narrowing its own supervisory footprint over digital-asset innovation in favor of federal frameworks, whether FinCEN's money-services-business gateway or the OCC's stablecoin certification track. This is consistent with Montana's broader legislative posture of favoring permissive, federally-deferential treatment of on-chain and token activity, though those broader statutory protections sit outside this cycle's evidence base and are not restated here. #### Outlook The Task Force's recommendation is not legislatively final; it is a recommendation folded into a report to the Economic Affairs Interim Committee, and the question of whether Montana ultimately introduces its own stablecoin-issuer framework or continues to defer to the OCC pathway remains open pending further legislative session activity. Separately, Montana's continued absence from any state-level money-transmitter framework means that future multistate enforcement actions of the Coinme type are likely to produce the same pattern: participation by licensing states, non-participation by Montana, with federal FinCEN registration as the only backstop. Readers tracking digital-asset financial innovation in Montana should watch both the Economic Affairs Interim Committee's handling of the Task Force report and any federal GENIUS Act implementation guidance that might alter the calculus for state-level deferral. Judgment: Montana remains confirmed as the sole US state with no money-transmitter licensing statute; a 2026 informal DBFI data-request letter to MSBs/crypto firms was issued and withdrawn, predating this window. Probable #### Compliance Technology and Active Defence This domain records the sole improving-trajectory finding of this cycle, a notable departure from the deteriorating or worsening trajectories recorded across the beneficial-ownership, enabler-jurisdiction, and crypto-integrity domains this cycle. FinCEN has proposed a rule to fundamentally reform financial-institution AML and CFT program requirements under the AML Act of 2020. The proposal would standardize risk-based program expectations across financial institutions and introduce a notice-and-consultation framework between FinCEN and federal banking supervisors ahead of significant AML and CFT supervisory actions, a governance-level reform to the examination process itself rather than a technology deployment or tooling mandate. This is a High-confidence, Tier-1-sourced finding, reflecting the proposed-rule publication and fact sheet issued by FinCEN itself. Continue reading For Montana specifically, this proposal directly affects examination posture at Montana-chartered and other federally-supervised banks. The notice-and-consultation framework, if finalized as proposed, would introduce a structured step between FinCEN and banking supervisors before significant supervisory actions are taken, a procedural change with proactive-compliance implications for how AML and CFT examination findings translate into supervisory consequences, rather than a change to the underlying program obligations banks must meet. The remit of this domain distinguishes proactive-compliance-oriented regulatory guidance from purely tick-box program requirements, and this proposal sits on the proactive-compliance side of that distinction: it is aimed at how supervisory judgment is exercised and communicated, not merely at what a program must document. It is worth noting explicitly that this is the only domain this cycle recording an improving trajectory for the US-MT jurisdiction profile, against a backdrop in which the beneficial-ownership, enabler-jurisdiction, and crypto-integrity domains are all recorded as worsening or deteriorating. This asymmetry is itself analytically significant under the remit of this domain: a supervisory-process reform proposal does not offset the substantive rollback of beneficial-ownership disclosure or the federal preemption of state digital-asset oversight recorded elsewhere this cycle, and should not be read as a general improvement in the overall risk posture of the jurisdiction. It is, more narrowly, a procedural-governance improvement specific to how AML and CFT supervision is conducted, which is a materially different question from what substantive disclosure or licensure obligations exist in the first place. The broader remit of this domain spans compliance technology and active defence more generally, deployment of transaction-monitoring systems, screening-technology upgrades, and analogous tooling investments, but this cycle only material US-MT-relevant development is the supervisory-process reform described above rather than a technology-deployment or tooling-specific finding. That absence of a technology-deployment development this cycle should be read honestly: it reflects the scope of what the current research window identified for this jurisdiction, not an assessment that no such developments exist industry-wide. The notice-and-consultation framework of the proposed rule is also relevant to how the sanctions and beneficial-ownership findings recorded elsewhere in this cycle brief would be examined going forward: if finalized, significant AML and CFT supervisory actions arising from, for example, a Montana-chartered bank correspondent exposure to the Huione Group Section 311 designation or its screening posture against the DPRK IT-worker network would first pass through the proposed consultation step, changing the sequencing of federal supervisory action without changing the underlying substantive obligation to screen and report. The distinction between program-requirement standardization and notice-and-consultation procedure matters for how the proactive-compliance framing of this domain should be applied: standardization of risk-based program expectations could, depending on final scope, either raise or lower the substantive compliance bar facing federally-supervised banks, while the consultation framework changes only the sequencing and communication of supervisory findings. Both elements remain proposed rather than final, and confidence in the eventual substantive effect on Montana-chartered banks is accordingly held at the proposal stage rather than at the level of a confirmed operative rule. #### Outlook The finalization timing and ultimate scope of the proposed rule remain unconfirmed this cycle, with a general industry expectation centered on a 2026 Q3 window, though the interpreter own gap assessment records final-rule timing and scope as not yet established. Any finalized version that meaningfully alters the scope of the notice-and-consultation framework, or that narrows or expands the standardized risk-based program expectations from what was proposed, would represent a first-order development for this domain in a subsequent cycle. Absent finalization, Montana-chartered and other federally-supervised banks should expect the current examination posture to continue under existing AML Act of 2020 program requirements, with the proposed notice-and-consultation framework representing a prospective rather than a currently operative procedural change. Judgment: No RegTech/compliance-technology development specific to Montana this cycle. Uncertain #### AML/CTF Regime Montana's standing anti-money-laundering and counter-terrorist-financing architecture for money-transmission and crypto-kiosk activity remains, on current evidence, entirely federal. The state's own Division of Banking and Financial Institutions states on its website that it does not regulate money transmitters, meaning there is no state-level licensing, examination, or supervisory gateway through which AML/CTF program adequacy for crypto-adjacent money-services activity is assessed. The only applicable gateway is federal FinCEN registration as a money services business under 31 U.S.C. Chapter 53. This is a Confirmed, architecture-level finding, not an incident: it describes a durable structural feature of Montana's regulatory landscape rather than a single enforcement event. Continue reading This structural absence became visible in practice through the 8 October 2026 multistate settlement in which thirty-four state financial regulatory agencies reached a 2.5 million dollar settlement with crypto-kiosk operator Coinme Inc. over Bank Secrecy Act and AML program deficiencies. Montana was not among the thirty-four settling states. Because Montana does not license money transmitters, it did not have the supervisory standing that the other states used to bring Coinme into a remediation settlement. For AML/CTF purposes, this is best read as a capacity deficit: Montana is not positioned to independently compel BSA/AML remediation from a crypto-kiosk operator the way licensing states are, and depends on whichever other states' licensing frameworks reach the operator in question, plus the federal FinCEN layer, to do that work on its behalf. The AML/CTF significance of the Task Force's parallel deferral on a state stablecoin-issuer bill follows the same logic. By relying on the federal OCC certification pathway under the GENIUS Act rather than building a Montana-specific issuer regime, the state is also declining to build whatever AML/CTF program requirements a state-level stablecoin issuer regime might have carried, leaving that supervisory function to federal process as well. #### Outlook Absent a change to Montana's money-transmitter statute, the state's AML/CTF exposure for crypto-kiosk and money-services activity will continue to run exclusively through the federal FinCEN MSB gateway, with no state-level backstop. This leaves Montana structurally reliant on other states' multistate enforcement coalitions, of the kind that produced the Coinme settlement, to address AML/CTF deficiencies at operators with a Montana presence or customer base. Readers should watch whether any future multistate AML/CTF settlement explicitly names a Montana-based or Montana-serving operator, which would test whether the federal-only gateway is adequate in practice, as distinct from this cycle's finding that Montana is simply outside the thirty-four-state Coinme settlement's party list. Judgment: US-MT has no state-level AML supervisory regime distinct from the federal layer; federal BSA/FinCEN governs, and federal CTA beneficial-ownership obligations apply to Montana-formed entities. Probable Judgment: No disclosed financial-integrity-sector commercial transaction with a Montana nexus was identified this cycle. Uncertain Regulatory horizon Proposed 2027-Q1 · ±half_year ### Montana Consumer Loan Act crypto-collateral amendment preview Montana's Division of Banking previewed a bill for the 2027 legislative session that would let consumer lenders accept cryptocurrency as loan collateral. [Source](https://citizenportal.ai/articles/8030758/Montana/2026-Legislature-MT/Division-of-Banking-previews-three-bills-to-modernize-Bank-Act-consumer-loan-rules-and-mortgage-enforcement) 1 dated · 1 pending date · baseline fim-2026-07-05 Role action cards MLRO ### Montana's non-participation in the 34-state Coinme BSA/AML settlement confirms the state has no money-transmitter AML licensing gateway. Montana-based or Montana-serving crypto-kiosk and money-services activity is supervised for AML/CTF purposes only through federal FinCEN MSB registration, with no state-level examination layer. SAR and BSA program obligations for such entities should be assessed against the federal baseline alone, since no Montana state AML licensing regime exists to supplement it. 1 evidence refs Compliance ### Montana's Blockchain Task Force deferred a state-qualified stablecoin issuer regime to the federal OCC GENIUS Act pathway. Entities contemplating stablecoin issuance with Montana nexus should expect the applicable certification and compliance pathway to run through the OCC federally rather than through any forthcoming Montana-specific issuer framework, at least for the near term. 1 evidence refs Board ### Montana's structural absence of money-transmitter licensing left it outside a 34-state BSA/AML enforcement settlement against a national crypto-kiosk operator. This is a capacity deficit, not a one-off enforcement gap: the same absence of state licensing infrastructure will recur in future multistate actions touching Montana-based or Montana-serving operators, with federal registration as the only backstop. 1 evidence refs CTO ### Montana's deferral to the federal OCC pathway for stablecoin issuance narrows state-level technical and compliance requirements for issuers operating from or into the state. Technical architecture for any Montana-nexus stablecoin issuance should be built to federal OCC GENIUS Act certification requirements, since no competing state-qualified issuer framework is being developed in parallel. 1 evidence refs Risk ### Montana's capacity deficit in money-transmitter licensing is a structural, not episodic, enabler-jurisdiction signal worth continued monitoring. The Coinme settlement exclusion demonstrates how a permissive licensing gap can leave exposure concentrated in federal-only AML gateways; this pattern should be factored into exposure assessments for any counterparties with Montana-based or Montana-routed crypto-kiosk activity. 1 evidence refs Audit ### Montana's AML/CTF control environment for money-services and crypto-kiosk activity rests solely on the federal FinCEN MSB registration gateway, with no state-level audit trail requirement. Internal audit scope for Montana-nexus crypto money-services activity should not assume any state-level examination record exists; documented evidence of control adequacy will only be found at the federal registration layer. 1 evidence refs Scenario sketches ### AMLA direct-supervision transition and cross-border evasion routing 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 AML Regulation and per-state sixth AML Directive transposition, illicit actors could probe for jurisdictions and entity types that fall into supervisory seams during the transition period, where national authorities assume AMLA has assumed a role it has not yet operationally taken up, or vice versa. This is an architecture-level illustration of a possible transitional seam, not an observed fact about any specific entity or jurisdiction, including Montana, which sits outside the EU AML Package's direct perimeter entirely. 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 MT-specific or dedicated federal sanctions search run this cycle; coverage gap at federal level. T2 · EU AML Package / AMLA no_change Not applicable to US-MT; no EEA membership. T3 · FATF Grey List no_change No MT-specific angle; no dedicated FATF plenary search run this cycle. T4 · Beneficial-Ownership Register Status no_change Federal CTA/BOI regime continues to apply to Montana-formed entities; no new MT-specific development this cycle. T5 · Crypto & Digital-Asset Integrity no_change Montana's absence of a money-transmitter statute continues to make it an outlier for crypto MSB establishment; no new development within the window. T6 · Sanctions Regime Divergence no_change Not applicable at state level; US-MT bound by the single federal OFAC regime. Registers ### Enforcement actions - 2 Oct 2025 - 12 Dec 2025 - 26 Mar 2025 - 1 Oct 2025 - 1 Mar 2026 - 8 Oct 2026 - State securities regulators, including Montana's, formally warned Congress that the CLARITY Act's market-structure provisions could strip states of authority to pursue crypto fraud, at a moment when crypto criminal activity is rising alongside record investor demand. 2 Oct 2025 - OCC granted conditional national trust bank charters to five digital-asset firms, permitting nationwide custody, settlement and fiduciary crypto services without state-by-state chartering, superseding state licensing regimes including Montana's. 12 Dec 2025 - FinCEN issued an interim final rule removing the requirement for all US-formed companies and their beneficial owners to report beneficial ownership information under the Corporate Transparency Act, retaining reporting only for foreign entities registered to do business in a US state. 26 Mar 2025 - FinCEN designated Huione Group as a foreign financial institution of primary money laundering concern under Section 311 special measures, following identification of over $4 billion in illicit proceeds laundered through the group, applicable nationwide including to Montana-domiciled financial institutions' sanctions/AML screening obligations. 1 Oct 2025 ### Sanctions changes - 30 Oct 2025 - 12 Mar 2026 - 1 Jul 2026 - 13 Jul 2026 - 1 Jul 2026 - 28 May 2026 - 30 Jun 2026 - OFAC and UK's OFSI dually sanctioned Chen Zhi, Prince Group, and Jin Bei Group Co. Ltd for operating Cambodia-based scam compounds tied to forced labor and cryptocurrency fraud, alongside a DOJ indictment and a $15 billion Bitcoin seizure. 30 Oct 2025 - OFAC designated six individuals and two entities for facilitating North Korean IT-worker schemes that generated nearly $800 million in 2024 to fund DPRK weapons of mass destruction and ballistic missile programs, applicable to all US financial institutions' sanctions screening, including any Montana-based firms unwittingly engaging DPRK-linked remote IT contractors. 12 Mar 2026 - President Trump's March 2025 executive order established a US Strategic Bitcoin Reserve and a separate digital-asset stockpile, centralizing forfeited/seized crypto assets rather than auctioning them, changing the national posture on asset disposition that Montana law-enforcement forfeiture referrals now feed into. 6 Mar 2025 ### Regulatory horizon (register) - Montana SB 265 implementing rules - Montana Consumer Loan Act crypto-collateral amendment preview - GENIUS Act stablecoin AML/sanctions implementing rules - FinCEN AML/CFT Program reform final rule - CLARITY Act crypto market-structure bill Senate action ### Active schemes - [HIGH] Anonymous LLC formation post-CTA rollback - Crypto MLM/pyramid fraud targeting Montana residents - Federal preemption erodes state crypto oversight Sources - [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) - [OFAC / U.S. Treasury](https://ofac.treasury.gov/recent-actions) - [U.S. Department of the Treasury](https://home.treasury.gov/news/press-releases/sb0545) - [Chainalysis](https://www.chainalysis.com/blog/isis-designation-crypto-addresses-july-2026/) - [AML UAE (compliance blog)](https://amluae.com/fatf-grey-list-countries-update-19th-june-2026/) - [CNBC](https://www.cnbc.com/2026/06/14/uk-forces-board-sanctioned-russian-shadow-fleet-oil-tanker.html) - [Geopolitics and Security Studies Center (GSSC)](https://www.gssc.lt/en/publication/what-is-next-for-russias-shadow-fleet-closing-the-gaps-in-maritime-sanctions-enforcement/) - [FinCEN](https://www.fincen.gov/news/news-releases/fincen-issues-expanded-southwest-border-geographic-targeting-order) - [VOA News (citing UNODC)](https://www.voanews.com/a/un-warns-of-growing-criminal-threat-from-mekong-region-casinos-sezs/6762228.html) - [Not For Sale (NGO)](https://wearenotforsale.org/blog/golden-triangle-special-economic-zone-case-study/) - [Asia Gaming Brief (IAG)](https://asgam.com/2026/04/27/cambodia-shuts-down-91-casinos-said-to-be-scam-fronts/) - [EUR-Lex / EU Official Journal](https://eur-lex.europa.eu/eli/reg/2024/1624/oj/eng) - [Moody's](https://www.moodys.com/web/en/us/kyc/resources/insights/a-review-of-amla-and-amlr-2026.html) - [financialregulations.eu](https://financialregulations.eu/blog/eu-aml-package-amla-amlr-guide) - [Guidehouse](https://guidehouse.com/insights/financial-services/2026/ai-based-transaction-monitoring) - [Stout](https://www.stout.com/en/insights/article/modernizing-aml-transaction-monitoring-model-risk-management) - [Montana Dept. of Administration (Blockchain & Digital Innovation Task Force)](https://doa.mt.gov/_docs/bfid/Blockchain_Task_Force/Meetings/2026-02-11-Minutes.pdf) - [https://banking.mt.gov/News/The-Challenge-of-Being-the-Only-State-Not-Regulating-Money-Transmitters](https://banking.mt.gov/News/The-Challenge-of-Being-the-Only-State-Not-Regulating-Money-Transmitters) - [https://www.cooley.com/news/insight/2024/2024-08-20-us-states-adopt-model-money-transmission-act-but-harmonization-remains-elusive](https://www.cooley.com/news/insight/2024/2024-08-20-us-states-adopt-model-money-transmission-act-but-harmonization-remains-elusive) - [https://www.thebulldog.law/montana-s-financial-freedom-and-innovation-act-legal-guide-for-digital-asset-companies](https://www.thebulldog.law/montana-s-financial-freedom-and-innovation-act-legal-guide-for-digital-asset-companies) - [https://doa.mt.gov/BFID/mortgage-consumer-finance/](https://doa.mt.gov/BFID/mortgage-consumer-finance/) - [https://citizenportal.ai/articles/7417911/montana/2026-legislature-mt/montana-securities-and-consumer-officials-warn-of-rising-crypto-fraud-outline-state-policy-options](https://citizenportal.ai/articles/7417911/montana/2026-legislature-mt/montana-securities-and-consumer-officials-warn-of-rising-crypto-fraud-outline-state-policy-options) - [https://dailymontanan.com/2026/04/15/state-auditor-says-nearly-1-million-in-fraud-loss-prevented-fraud-reports-on-record-pace/](https://dailymontanan.com/2026/04/15/state-auditor-says-nearly-1-million-in-fraud-loss-prevented-fraud-reports-on-record-pace/) - [https://banking.mt.gov/](https://banking.mt.gov/) - [https://www.csbs.org/newsroom/state-financial-regulators-reach-25-million-settlement-crypto-kiosk-operator](https://www.csbs.org/newsroom/state-financial-regulators-reach-25-million-settlement-crypto-kiosk-operator) - [https://doa.mt.gov/_docs/bfid/Blockchain_Task_Force/Minutes-06-01-26.pdf](https://doa.mt.gov/_docs/bfid/Blockchain_Task_Force/Minutes-06-01-26.pdf) - [https://www.mcdermottlaw.com/insights/montana-pump-fakes-a-requirement-for-money-transmitters/](https://www.mcdermottlaw.com/insights/montana-pump-fakes-a-requirement-for-money-transmitters/) - [https://www.ridgewayfs.com/money-transmitter-license-requirements-by-state/](https://www.ridgewayfs.com/money-transmitter-license-requirements-by-state/) - [https://mtbeef.org/ranchers-required-to-file-beneficial-ownership-information-reports-under-new-law/](https://mtbeef.org/ranchers-required-to-file-beneficial-ownership-information-reports-under-new-law/) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [MSB Registrant Search | FinCEN.gov](https://www.fincen.gov/resources/msb-state-selector) - [Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2025-26) - [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) - [How crypto regulation changed in 2025: a global review](https://www.elliptic.co/blog/how-crypto-regulation-changed-in-2025) - [Elliptic's 2026 regulatory and policy outlook: 5 crypto trends to expect in 2026](https://www.elliptic.co/blog/regulatory-and-policy-crypto-trends-to-except-in-2026) - [Crypto regulatory affairs: CLARITY Act Senate delay creates uncertainty](https://www.elliptic.co/blog/crypto-regulatory-affairs-clarity-act-senate-delay-creates-uncertainty) - [Elliptic's 2026 regulatory and policy outlook: US sets the pace](https://www.elliptic.co/blog/elliptics-2026-regulatory-and-policy-outlook-us-sets-the-pace) - [Fact Sheet on MSB Registration Rule | FinCEN.gov](https://www.fincen.gov/fact-sheet-msb-registration-rule) - [Elliptic's 2026 regulatory and policy outlook: the next generation of blockchain analytics](https://www.elliptic.co/blog/elliptics-2026-regulatory-and-policy-outlook-next-gen-blockchain-analytics) - [Montana](https://www.fincen.gov/sites/default/files/SARStats_files/SAR03/BSAR_O_States/Montana.xls) - [Enforcement Actions | FinCEN.gov](https://www.fincen.gov/news/enforcement-actions) - [News | FinCEN.gov](https://www.fincen.gov/news) - [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) - [Beneficial Ownership Information Reporting | FinCEN.gov](https://www.fincen.gov/boi) - [Financial Crimes Enforcement Network; Inflation Adjustment of Civil Monetary Penalties | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/federal-register-notices/financial-crimes-enforcement-network-8) - [UNITED STATES OF AMERICA FINANCIAL CRIMES ENFORCEMENT NETWORK](https://www.fincen.gov/system/files/enforcement_action/2025-02-06/FinCEN-Brinks-FINALv508.pdf) - [Fincen](https://www.fincen.gov/sites/default/files/enforcement_action/2025-02-06/FinCEN-Brinks-FINALv508.pdf) - [United States Department of the Treasury Financial Crimes Enforcement Network - Home | FinCEN.gov](https://www.fincen.gov/) - [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) - [The Role of Domestic Shell Companies in Financial Crime ...](https://www.fincen.gov/sites/default/files/shared/LLCAssessment_FINAL.pdf) - [How America’s biggest law firm drives global wealth into tax havens - ICIJ](https://www.icij.org/investigations/pandora-papers/baker-mckenzie-global-law-firm-offshore-tax-dodging/) - [Potential Money Laundering Risks Related to Shell ...](https://www.fincen.gov/system/files/shared/AdvisoryOnShells_FINAL.pdf) - [FinCEN Advisory - FIN-2017-A003 | FinCEN.gov](https://www.fincen.gov/resources/advisories/fincen-advisory-fin-2017-a003) - [US poised to crack down on anonymous shell companies - ICIJ](https://www.icij.org/investigations/paradise-papers/us-poised-to-crack-down-on-anonymous-shell-companies/) - [Report reveals threat to U.S. interests from anonymous shell company owners | Global Witness](https://www.globalwitness.org/en/archive/report-reveals-threat-us-interests-anonymous-shell-company-owners/) - [REPUBLIC REGISTERED AGENT SERVICES INC.](https://aleph.occrp.org/entities/61edeeca1b28e9975c168ebff8ad18c408853bc9.b6789ffd95a2146747fe263b573db65de597cbf4) - [US lawmakers move to end anonymous shell companies in national defense spending bill - ICIJ](https://www.icij.org/inside-icij/2020/11/us-lawmakers-move-to-end-anonymous-shell-companies-in-national-defense-spending-bill/) - [Fact Sheet: Proposed Rule to Fundamentally Reform Financial](https://www.fincen.gov/system/files/2026-04/Program-NPRM-FactSheet.pdf) - [State Contact Information For MSBs](https://www.fincen.gov/sites/default/files/shared/msbstatecontactsfinal.pdf) - [The Anti-Money Laundering Act of 2020 | FinCEN.gov](https://www.fincen.gov/anti-money-laundering-act-2020) - [The Bank Secrecy Act | FinCEN.gov](https://www.fincen.gov/resources/statutes-and-regulations/bank-secrecy-act) - [FinCEN Proposes Rule to Fundamentally Reform Financial Institution Programs Designed to Fight Illicit Finance | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-proposes-rule-fundamentally-reform-financial-institution-programs) - [FinCEN’s Legal Authorities | FinCEN.gov](https://www.fincen.gov/resources/fincens-legal-authorities) - [United States Department of the Treasury Financial Crimes Enforcement Network - Home | FinCEN.gov](https://fincen.gov/news_room/aml_history.html) - [FinCEN Exchange | FinCEN.gov](https://fincen.gov/resources/financial-crime-enforcement-network-exchange) - [Agencies Release Revised Bank Secrecy Act/Anti-Money Laundering Examination Manual | FinCEN.gov](https://www.fincen.gov/news/news-releases/agencies-release-revised-bank-secrecy-actanti-money-laundering-examination) - [From trading bans to total embrace, a global guide to crypto regulation](https://www.icij.org/investigations/coin-laundry/cryptocurrency-regulations-global-explainer/) - [Proposed GOP Bill Targets Foreign Crypto Mining Hardware - Bloomberg](https://www.bloomberg.com/news/articles/2026-03-30/proposed-gop-bill-targets-foreign-crypto-mining-hardware) - [Sweeping US Crypto Legislation Targets Stablecoins, Mining - Bloomberg](https://www.bloomberg.com/news/articles/2022-06-07/sweeping-us-crypto-legislation-targets-stablecoins-mining) - [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) - [British Columbia Moves to Limit AI Power Use, Ban Crypto Mining - Bloomberg](https://www.bloomberg.com/news/articles/2025-10-20/british-columbia-moves-to-limit-ai-power-use-ban-crypto-mining) - [The Opportunity Before Congress on Crypto Legislation - Chainalysis](https://blog.chainalysis.com/reports/opportunity-congress-crypto-legislation) - [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) - [Crypto (BTC) Mining Industry Groups Knock US EIA's Bid to Collect Energy Data - Bloomberg](https://www.bloomberg.com/news/articles/2024-02-07/-abuse-of-authority-crytpo-backers-say-bid-to-collect-energy-data-is-political) - [Bitcoin Miners in US Consume Up to 2.3% of Nation’s Electricity, EIA Report Says - Bloomberg](https://www.bloomberg.com/news/articles/2024-02-01/bitcoin-miners-in-us-consume-up-to-2-3-of-nation-s-electricity) - [Spacey’s Holiguards film backed by alleged crypto scammer](https://www.icij.org/investigations/coin-laundry/holiverse-lado-forsage-cryptocurrency-scam/) - [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) - [Money Services Business Definition | FinCEN.gov](https://www.fincen.gov/money-services-business-definition) - [Money Services Business (MSB) Registration | FinCEN.gov](https://www.fincen.gov/resources/money-services-business-msb-registration) - [Application of FinCEN’s Regulations to Virtual Currency Software Development and Certain Investment Activity | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/application-fincens-regulations-virtual) - [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) - [Financial Fraud Enforcement Task Force (FFETF) | FinCEN.gov](https://www.fincen.gov/financial-fraud-enforcement-task-force-ffetf) - [Advisories | FinCEN.gov](https://www.fincen.gov/resources/advisoriesbulletinsfact-sheets/advisories) - [Recent Actions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/enforcement-actions) - [United States Department of the Treasury Financial Crimes Enforcement Network - Home | FinCEN.gov](https://www.fincen.gov/?var=v100002) - [1 Financial Crimes Enforcement Network U.S. Department of the Treasury](https://www.fincen.gov/system/files/shared/FinCEN%20Enforcement%20Statement_FINAL%20508.pdf) - [1 Financial Crimes Enforcement Network (FinCEN)](https://www.fincen.gov/system/files/2026-05/FinCEN-Year-in-Review-2025.pdf) - [Fact Sheet: Proposed Rule to Implement the GENIUS Act’s Anti-](https://www.fincen.gov/system/files/2026-04/FactSheet-PPSI-program-NPRM.pdf) - [Alerts/Advisories/Notices/Bulletins/Fact Sheets | FinCEN.gov](https://www.fincen.gov/resources/advisoriesbulletinsfact-sheets) - [www.fincen.gov Guidance FIN-2013-G001 Issued: March 18, 2013 Subject:](https://www.fincen.gov/system/files/guidance/FIN-2013-G001.pdf) - [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) - [F I N C E N G U I D A N C E 1](https://www.fincen.gov/system/files/2019-05/FinCEN%20CVC%20Guidance%20FINAL.pdf) - [Whether a Company that Provides an Armored Car Coin and Currency Exchange Service is a Money Transmitter and Whether the Armored Car Service Exemption Would Apply to the Service | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/whether-company-provides-armored-car-coin-and) - [South Dakota Dynasty Trusts: Tax Haven for Rich Families - Bloomberg](https://www.bloomberg.com/news/articles/2014-01-09/south-dakota-dynasty-trusts-tax-haven-for-rich-families) - [Guidance on Obtaining and Retaining Beneficial Ownership Information | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/guidance-obtaining-and-retaining-beneficial-ownership) - [consultation](https://www.fatf-gafi.org/content/dam/fatf-gafi/public-consultation/Consultation-RBA-BO-Transparency-Legal%20Arrangements%20(R.25)-Oct23.docx.coredownload.inline.docx) - [1 Fact Sheet: FinCEN Issues Final Rule to](https://www.fincen.gov/system/files/shared/RREFactSheet.pdf) - [Requests by Law Enforcement for Financial Institutions to Maintain Accounts | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/requests-law-enforcement-financial-institutions-maintain) - [GUIDANCE FOR A RISK-BASED APPROACH BENEFICIAL OWNERSHIP AND](https://www.fatf-gafi.org/content/dam/fatf-gafi/recommendations/Guidance-Beneficial-Ownership-Transparency-Legal-Arrangements.pdf.coredownload.inline.pdf) - [FATF guidance TRANSPARENCY AND BENEFICIAL OWNERSHIP October 2014](https://www.fatf-gafi.org/content/dam/fatf-gafi/guidance/Guidance-transparency-beneficial-ownership.pdf) - [Don’t take it on trust | Global Witness](https://www.globalwitness.org/en/campaigns/corruption-and-money-laundering/anonymous-company-owners/dont-take-it-trust/) - [Information Sharing Under Section 314(b) | FinCEN.gov](https://www.fincen.gov/resources/section-314b) - [RESPONDING TO ILLEGAL MINING AND TRAFFICKING IN METALS AND MINERALS](https://www.unodc.org/cld/uploads/pdf/Illegal_Mining_and_Trafficking_in_Metals_and_Minerals_E.pdf) - [Sanctions Compliance Guidance for the Virtual Currency](https://ofac.treasury.gov/media/913571/download) - [Mining Industry Act 1926](https://www.legislation.gov.uk/ukpga/Geo5/16-17/28/enacted) - [Mines Regulations 2014 and other legislation - HSE](https://www.hse.gov.uk/mining/legislatlist.htm) - [MINING A.1. POLICY AND REGULATIONS](https://www.un.org/esa/dsd/dsd_aofw_ni/ni_pdfs/NationalReports/germany/mining.pdf) - [Special Measures | FinCEN.gov](https://www.fincen.gov/resources/statutes-and-regulations/special-measures) - [Anti-Money Laundering Programs for Dealers in Precious ...](https://www.fincen.gov/system/files/guidance/faq060305.pdf) - [TSEM6240 - Legal background to trusts & estates: rules of perpetuity - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/trusts-settlements-and-estates-manual/tsem6240) - [Perpetuities and Accumulations Act 2009 - Explanatory Notes](https://www.legislation.gov.uk/ukpga/2009/18/notes) - [ON AMENDING THE RULE AGAINST PERPETUITIES AND FURTHER REDUCING](https://assets.publishing.service.gov.uk/media/5a7ebdd4e5274a2e8ab47e7e/bis_14_963_bis_response_to_call_on_amending_the_rule_against_perpetuities_2.pdf) - [TSEM6540 - Legal background to trusts and estates: Scottish law: rules against perpetuities - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/trusts-settlements-and-estates-manual/tsem6540) - [Perpetuities and Accumulations Act 2009](https://www.legislation.gov.uk/ukpga/2009/18/crossheading/application-of-rule-against-perpetuities) - [TSEM11000 - Glossary - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/trusts-settlements-and-estates-manual/tsem11000) - [1925. Trustee Act, 1925. Cm 19‘, 20. 563 Session and Chapter. Short Title.](https://www.legislation.gov.uk/ukpga/Geo5/15-16/20/pdfs/ukpga_19250020_en.pdf) - [1 Residential Real Estate Reporting Frequently Asked Questions](https://www.fincen.gov/system/files/shared/RREFAQs.pdf) - [1 Legal estates and equitable interests.E+W](https://www.legislation.gov.uk/ukpga/Geo5/15-16/20/body/data.xht) - [Crypto Bill Seen Hindering Fraud Prosecutions, States Warn - Bloomberg](https://www.bloomberg.com/news/articles/2025-10-02/crypto-bill-seen-hindering-fraud-prosecutions-states-warn) - [Lummis Says Bitcoin Reserve Is Likely to Come First From States - Bloomberg](https://www.bloomberg.com/news/articles/2025-02-28/lummis-says-bitcoin-reserve-is-likely-to-come-first-from-states) - [Bitcoin Strategic Reserves - Chainalysis](https://www.chainalysis.com/blog/bitcoin-strategic-reserves/) - [Bitcoin Reserve Bills Are Failing in Quick Succession in States - Bloomberg](https://www.bloomberg.com/news/articles/2025-02-27/bitcoin-reserve-bills-are-failing-in-quick-succession-in-states) - [Watch How Will the US Bitcoin Reserve Work, Exactly? - Bloomberg](https://www.bloomberg.com/news/videos/2025-03-14/how-will-the-us-bitcoin-reserve-work-exactly-video) - [Bitcoin Reserve Clamor Among US States Risks Being No More Than Just Noise](https://www.bloomberg.com/news/articles/2025-01-20/bitcoin-reserve-efforts-by-states-are-little-more-than-noise) - [GENIUS Act Passes Senate, Paving the Way for Landmark US Crypto Legislation | TRM Labs](https://www.trmlabs.com/resources/blog/genius-act-passes-senate-paving-the-way-for-landmark-us-crypto-legislation) - [Landmark cryptocurrency legislation passes US House, to be signed into law by President Trump - ICIJ](https://www.icij.org/news/2025/07/landmark-cryptocurrency-legislation-passes-u-s-house-to-be-signed-into-law-by-president-trump/) - [Trump Signs Executive Order Creating Strategic Bitcoin Reserve, Crypto Stockpile - Bloomberg](https://www.bloomberg.com/news/articles/2025-03-07/trump-signs-order-creating-bitcoin-reserve-and-crypto-stockpile) - [How Will Trump’s US Strategic Bitcoin Reserve Work? - Bloomberg](https://www.bloomberg.com/news/articles/2025-03-11/how-will-trump-s-us-strategic-bitcoin-reserve-work) - [Watch Trump Establishes First US Bitcoin Reserve - Bloomberg](https://www.bloomberg.com/news/videos/2025-03-10/trump-establishes-first-us-bitcoin-reserve) - [2026 Crypto Crime Report: Scams](https://www.chainalysis.com/blog/crypto-scams-2026/) - [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) - [1st Review of the Suspicious Activity Reporting System (SARS) | FinCEN.gov](https://www.fincen.gov/1st-review-suspicious-activity-reporting-system-sars) - [The State of Crypto Scams 2025: Keeping our industry safe with blockchain analytics](https://www.elliptic.co/blog/the-state-of-crypto-scams-2025-keeping-our-industry-safe-with-blockchain-analytics) - [U.S. Crackdown on Southeast Asian Crypto Scam Centers](https://www.chainalysis.com/blog/asian-scam-centers-crypto-fraud-april-2026/) - [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) - [Trump administration curbs state oversight of crypto industry - ICIJ](https://www.icij.org/investigations/coin-laundry/trump-administration-curbs-state-oversight-of-crypto-industry/) - [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 TD Bank Consent Order, Number 2024-02](https://www.fincen.gov/sites/default/files/enforcement_action/2024-10-10/FinCEN-TD-Bank-Consent-Order-508FINAL.pdf) - [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) - [1 ORDER](https://www.fincen.gov/system/files/2025-06/CIP-TIN-Exemption-Order-final508.pdf) - [Guidance | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance) - [Cross River Bank Gets FDIC Enforcement Order Over Lending - Bloomberg](https://www.bloomberg.com/news/articles/2023-04-28/cross-river-bank-receives-fdic-enforcement-order-over-lending) - [PPSI-AMLCFT-NPRM.pdf](https://www.fincen.gov/system/files/2026-04/PPSI-AMLCFT-NPRM.pdf) - [FinCEN Consent Order Number 2023-04](https://www.fincen.gov/sites/default/files/enforcement_action/2023-11-21/FinCEN_Consent_Order_2023-04_FINAL508.pdf) - [2026 Crypto Crime Report – Illicit Crypto Trends & Typologies | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/2026-crypto-crime-report) - [OFAC Sanctions Tracker: How Sanctions Impact Crypto Crime - Chainalysis](https://www.chainalysis.com/blog/ofac-sanctions/) - [1 The U.S. Department of the Treasury’s (Treasury)](https://www.fincen.gov/system/files/2025-08/FinCEN-Advisory-CMLN-508.pdf) - [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) - [Maduro Accused of 25 Years of Narco-Terrorism Crimes by DOJ - Bloomberg](https://www.bloomberg.com/news/articles/2026-01-03/doj-releases-maduro-indictment-alleges-narco-terrorism-scheme) - [Bank Secrecy Act Records Track Money Laundering Methods of Drug Gang | FinCEN.gov](https://www.fincen.gov/resources/law-enforcement/case-examples/bank-secrecy-act-records-track-money-laundering-methods) - [Blockchain Legal Library](https://www.trmlabs.com/blockchain-legal-library) - [Montana Association of Counties - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/0747485D:US) - [Chainalysis Links 2026 • March 31-April 1 • New York, NY](https://www.chainalysis.com/links-nyc/) - [Mountain States Indemnity Co - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/14954Z:US) - [Nicola Rundle Your Reference: Our Reference: Date: 12 Jan 23](https://www.contractsfinder.service.gov.uk/Notice/Attachment/40bfc613-abbf-4d24-8850-eff71f1de3a2) - [CIS SECURITY LTD overview - Find and update company information - GOV.UK](https://find-and-update.company-information.service.gov.uk/company/01555444) - [Insurance Industry Home | FinCEN.gov](https://www.fincen.gov/insurance-industry-home) - [Catalogue of Research Databases | OCCRP ID](https://id.occrp.org/databases/) - [Montana Health Network Health Insurance Plan & Trust - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/0347322D:US) - [Definition of Money Transmitter (Merchant Payment Processor) | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/definition-money-transmitter-merchant-payment) - [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) - [MONEY TRANSMITTER REGULATORS ASSOCIATION](https://www.fincen.gov/system/files/shared/money_transmitters_regulators.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) - [Administrative Ruling on the Application of FinCEN Regulations to Currency Transporters, Including Armored Car Services, and Exceptive Relief | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/administrative-ruling-application-fincen) - [Special Notice RMSB Posting](https://www.fincen.gov/system/files/shared/msbregformDRAFT.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 / US Department of the Treasury](https://www.fincen.gov/boi) - [FinCEN / US Department of the Treasury](https://www.fincen.gov/1st-review-suspicious-activity-reporting-system-sars) - [ICIJ](https://www.icij.org/investigations/coin-laundry/holiverse-lado-forsage-cryptocurrency-scam/) - [Bloomberg](https://www.bloomberg.com/news/articles/2025-10-02/crypto-bill-seen-hindering-fraud-prosecutions-states-warn) - [Bloomberg](https://www.bloomberg.com/news/articles/2025-02-28/lummis-says-bitcoin-reserve-is-likely-to-come-first-from-states) - [ICIJ](https://www.icij.org/investigations/coin-laundry/trump-administration-curbs-state-oversight-of-crypto-industry/) - [Chainalysis](https://www.chainalysis.com/blog/ofac-sanctions/) - [FinCEN / US Department of the Treasury](https://www.fincen.gov/system/files/2026-04/FactSheet-PPSI-program-NPRM.pdf) Coverage gaps fim-int-2026-07-07-G001: A Montana-specific legislative reco… fim-int-2026-07-07-G001: A Montana-specific legislative record (bill number, roll-call vote) verifying the February 2025 state Bitcoin reserve rejection is absent from the current evidence base. [resolved] fim-int-2026-07-07-G002: A confirmed primary-source citation… fim-int-2026-07-07-G002: A confirmed primary-source citation (OCC official news release) for the 12 December 2025 national trust charter approvals was not present in the research bundle; only secondary reporting is currently held. [resolved] fim-int-2026-07-07-G003: Whether federal agencies met the 18… fim-int-2026-07-07-G003: Whether federal agencies met the 18 July 2026 GENIUS Act statutory deadline for final implementing rules is not yet confirmed and requires a subsequent-cycle check. [resolved] fim-int-2026-07-07-G004: Montana-specific direct BSA/AML enf… fim-int-2026-07-07-G004: Montana-specific direct BSA/AML enforcement-docket documentation, distinct from national FinCEN/OFAC/OCC actions, remains sparse and should be sourced directly from Montana Division of Banking & Financial Institutions and CSI enforcement dockets. [resolved] fim-int-2026-07-07-G005: The CLARITY Act's Senate floor-vote… fim-int-2026-07-07-G005: The CLARITY Act's Senate floor-vote scheduling and Banking/Agriculture Committee reconciliation outcome remained unresolved at the time of research and requires follow-up after the Senate returns from recess on 13 July 2026. [resolved] fim-int-2026-07-14-G001: No T1 primary source (UN Panel of E… fim-int-2026-07-14-G001: No T1 primary source (UN Panel of Experts, OFAC, or OFSI) was located this cycle covering a Houthi/Yemen sanctions channel check. [resolved] fim-int-2026-07-14-G002: Cambodia and Laos national risk ass… fim-int-2026-07-14-G002: Cambodia and Laos national risk assessment (NRA) references were not located this cycle to corroborate enforcement-gap characterisations. [resolved] fim-int-2026-07-14-G003: Central Asia/Pacific beneficial-own… fim-int-2026-07-14-G003: Central Asia/Pacific beneficial-ownership registry developments were not sourced this cycle. [resolved] fim-int-2026-07-14-G004: No T1-T2 primary source for SR 26-2… fim-int-2026-07-14-G004: No T1-T2 primary source for SR 26-2 or the FinCEN NPRM text was retrieved; all findings rest on tier-4 vendor/advisory characterisation, capping confidence at Assessed. [resolved] fim-int-2026-08-20-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-08-20-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): No direct fetch of the Montana Secretary of State bill-text repository or State Auditor's SB 265 rulemaking/registration-form page was made this cycle; SB 265 evidence rests on T3 legal-commentary only. [resolved] fim-int-2026-08-20-G002: D1, D2, D4, and D6 had thin or no c… fim-int-2026-08-20-G002: D1, D2, D4, and D6 had thin or no coverage this cycle for US-MT; per the DELTA-ONLY research posture, absence does not imply the federal parent layer is inactive. [resolved] fim-int-2026-08-20-G003: Tier D jurisdiction checks (KH, LA,… fim-int-2026-08-20-G003: Tier D jurisdiction checks (KH, LA, MX, CO) were not independently re-derived for this bound-JID pass; should not be read as cleared. [resolved] fim-int-2026-09-28-G001: D1, D2, D4, D6 domains were not act… fim-int-2026-09-28-G001: D1, D2, D4, D6 domains were not actively re-researched for US-MT this cycle; pooled web-search budget was allocated solely to this bound jurisdiction. [resolved] fim-int-2026-09-28-G002: Tier-D watch jurisdictions (KH, LA,… fim-int-2026-09-28-G002: Tier-D watch jurisdictions (KH, LA, MX, CO) were not searched this cycle due to single-jurisdiction dispatch budget; absence should be read as awaiting_primary_source, not no_source. [resolved] fim-int-2026-09-28-G003: Gaming Advisory Council MAR Notice … fim-int-2026-09-28-G003: Gaming Advisory Council MAR Notice No. 2026-258.1 referenced on dojmt.gov/gaming was not independently opened this cycle; rulemaking content unverified. [resolved] fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): Montana DOJ Gambling Control Division administrative-rule/notice page was not directly checked for new rulemaking filings in this window, which could bear on crypto-adjacent gambling AML questions. [open] fim-int-2026-10-11-G002: Tier D jurisdictions (KH, LA, MX, C… fim-int-2026-10-11-G002: Tier D jurisdictions (KH, LA, MX, CO) were not actively re-swept this cycle; the shared union search budget was concentrated on US-MT. [open] fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): No T1 federal CTA/BOI primary source independently re-fetched this cycle; relying on secondary Montana-focused commentary. [open] fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', 'value': 'D1'}): No dedicated search of OFAC, OFSI, UN Panel of Experts, or FATF plenary outputs was run for this MT-scoped dispatch; T1/T3 standing-tracker coverage gap at the federal level, not an earned null. [open] FIM-GAP-001 (D2): The March 2025 federal CTA/BOI rollback re… FIM-GAP-001 (D2): The March 2025 federal CTA/BOI rollback removed the last transparency backstop for beneficial ownership of Montana-formed domestic entities; Montana itself collects no beneficial-ownership information at LLC/corporate formation, leaving no public or law-enforcement-accessible register of true owners for the large majority of Montana legal entities. FIM-GAP-002 (D3): Federal actions in 2025-2026 (OCC national… FIM-GAP-002 (D3): Federal actions in 2025-2026 (OCC national trust charters bypassing state licensure; pending CLARITY Act preemption of state crypto enforcement scope) are structurally reducing Montana's independent supervisory reach over digital-asset firms operating in or serving the state. FIM-GAP-003 (D6): Publicly available, Montana-specific BSA/A… FIM-GAP-003 (D6): Publicly available, Montana-specific BSA/AML enforcement action documentation within the 18-month baseline window is sparse; most identifiable AML/CTF/CPF-relevant events touching Montana are national-level FinCEN/OFAC/OCC actions with indirect state nexus rather than actions taken directly by or against Montana-domiciled entities. FIM-GAP-004 (D5): State money-transmitter regulators nationa… FIM-GAP-004 (D5): State money-transmitter regulators nationally, including in smaller states like Montana, have historically operated with constrained examiner resources relative to the scale of the money-services and digital-asset industry they are tasked with supervising, a structural tension long noted by the Money Transmitter Regulators Association. ## Evidence #### Confidence-tiered claims Montana was not among the 34 states party to the 2026-10-08 Coinme BSA/AML settlement, consistent with its no-money-transmitter-licensing posture. [[Source 1]](#sec-sources) Probable · 1 source The Task Force recommended taking no action on a Montana state-qualified stablecoin issuer bill, deferring to the OCC federal GENIUS Act pathway. [[Source 1]](#sec-sources) Probable · 1 source Montana has no money-transmitter licensing statute of any kind; federal FinCEN MSB registration under 31 U.S.C. § 5330 still applies. [[Source 1]](#sec-sources) Probable · 1 source Federal Corporate Transparency Act beneficial-ownership reporting to FinCEN continues to apply to Montana-formed/registered entities as it does nationally. [[Source 1]](#sec-sources) Probable · 1 source Montana does not regulate money transmitters; no state-level money-transmitter licensing statute exists. [[Source 1]](#sec-sources) Probable · 1 source The Task Force delivered its statutory Final Report to the Economic Affairs Interim Committee on 2026-07-01. [[Source 1]](#sec-sources) Probable · 1 source