--- title: "United States — New Hampshire (US-NH) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/united-states-new-hampshire/ source_html: /jurisdictions/united-states-new-hampshire/index.html description: "Financial integrity intelligence for United States – New Hampshire (US-NH): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: 2dab093b0df6d9dc88e5b2cc41989ef32327035f4d58ff199bc520a0e80e4b30 generator: "fe-fleet/md-twin@1.0" --- # United States — New Hampshire (US-NH) — 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 — New Hampshire US-NH Domains covered 8 of 8 Sources 121 Role actions 8 Horizon <90d 0 Jurisdiction profile FATF status: Largely Compliant Tier: B Risk direction: Increasing Enablement vs enforcement: Mixed NH regulates money transmission under RSA 399-G, supervised by the NH Banking Department, which operates an OFAC information-sharing MOU covering state-chartered banking organizations. More Federal BSA/AML enforcement (FinCEN, USAO-NH) has been aggressive historically (Ian Freeman case) but NH's legislature has simultaneously embraced crypto via the first-in-nation Strategic Bitcoin Reserve (HB 302, 2025), creating tension between permissive digital-asset policy and AML supervisory capacity. Key deficiencies - No NH-specific crypto-ATM consumer-protection/fraud-prevention statute, unlike Massachusetts, Iowa and 16+ other states that acted by late 2025 - State's high-profile unlicensed-MSB precedent (Ian Freeman/Church of the Invisible Hand) illustrates continuing vulnerability of disguised religious/nonprofit fronts for bitcoin kiosk laundering - Reliance on federal AML examination capacity (IRS, FinCEN) that has been reduced nationally, thinning oversight of NH-domiciled MSBs and crypto kiosk operators Recent developments (18m) - Governor Kelly Ayotte signed HB 302 in May 2025, making New Hampshire the first U.S. state to establish a Strategic Bitcoin Reserve authorizing the treasurer to invest up to 5% of state funds in bitcoin - FinCEN issued Notice FIN-2025-NTC1 (Aug 4, 2025) on CVC kiosk illicit-finance risk, explicitly citing prior USAO-District of New Hampshire prosecutions as typology evidence - New Hampshire Business Finance Authority's bitcoin-backed municipal bond plan received a Ba2 rating from Moody's in March 2026, an unprecedented sub-national bitcoin-linked debt instrument - National rollback of crypto AML oversight (IRS AML examiner headcount down 33% in FY2025; OCC-chartered crypto firms gaining exemption from state regulators) directly affects NH-domiciled money-transmission and crypto-kiosk populations United States federal law that applies in United States – New Hampshire is covered once, on the [United States](/jurisdictions/us/) page. This page covers United States – New Hampshire’s own layer: its own law, regulators and enforcement. Brief ## Lead signal #### Lead Signal New Hampshire enacted two statutes this cycle that, read together, describe a jurisdiction sharpening its posture at the retail edge of digital-asset activity while deliberately widening an exemption at the infrastructure-operation layer. Chapter 187 (SB 482), signed by the Governor on 19 June 2026 and taking effect 16 December 2026, imposes a $2,000-per-day per-customer transaction cap on digital asset transaction kiosks, a 48-hour hold with a refund right on a customer's first transaction, mandatory identity verification, fraud-risk warnings, and wallet screening against flagged addresses via blockchain analytics. The measure followed testimony from the Attorney General's office estimating roughly 250 such kiosks operating statewide and losses exceeding $2.6 million in a single municipality, Hampton, attributed to elder-fraud laundering through these machines. At the same time, HB 639 (the Blockchain Basic Laws), current law as of 18 August 2026, created a new statutory chapter exempting node operators, home and business digital-asset miners, and stakers from money-transmitter licensing under RSA 399-G, alongside a parallel exemption from securities treatment under RSA 421-B for mining and staking conducted with personal funds. Read full brief #### Lead Signal New Hampshire enacted two statutes this cycle that, read together, describe a jurisdiction sharpening its posture at the retail edge of digital-asset activity while deliberately widening an exemption at the infrastructure-operation layer. Chapter 187 (SB 482), signed by the Governor on 19 June 2026 and taking effect 16 December 2026, imposes a $2,000-per-day per-customer transaction cap on digital asset transaction kiosks, a 48-hour hold with a refund right on a customer's first transaction, mandatory identity verification, fraud-risk warnings, and wallet screening against flagged addresses via blockchain analytics. The measure followed testimony from the Attorney General's office estimating roughly 250 such kiosks operating statewide and losses exceeding $2.6 million in a single municipality, Hampton, attributed to elder-fraud laundering through these machines. At the same time, HB 639 (the Blockchain Basic Laws), current law as of 18 August 2026, created a new statutory chapter exempting node operators, home and business digital-asset miners, and stakers from money-transmitter licensing under RSA 399-G, alongside a parallel exemption from securities treatment under RSA 421-B for mining and staking conducted with personal funds. The pairing is the significant architecture here: New Hampshire is narrowing its anti-money-laundering perimeter precisely at the point where cash converts to and from digital assets through unattended kiosks, while simultaneously widening the exemption boundary for the upstream infrastructure that makes those assets exist and move. That is not a uniform liberalisation or a uniform tightening; it is a bifurcated enabler profile, and it is the kind of structural signal that a single enforcement action would not capture. #### Other Developments Examination powers strengthened. HB 1207, signed 10 July 2026, amended RSA 399-G to grant the New Hampshire Banking Department commissioner new powers effective 1 October 2026: the authority to require a licensee's books and records to be translated into English (at the licensee's expense, with an interpreter also chargeable to the licensee), and a new duty requiring delegate locations to post a certificate of authority. The Department's standing supervisory population, per its FY2026 annual report, comprised 202 active money-transmitter licensees and 1,638 authorised delegates — the base against which these expanded examination powers now apply. A routine bank acquisition. Hometown Financial Group, a Massachusetts-based lender, agreed to acquire Primary Bank of Bedford, New Hampshire, for $160 million, adding roughly $743 million in assets and four New Hampshire branches. Nothing in the reporting identifies an anti-money-laundering or sanctions dimension to the transaction; it reads as ordinary community-bank consolidation rather than a supervisory or integrity event, though it is noted here as the only commercial-activity development material to New Hampshire this cycle. #### Cross-Monitor Connections The kiosk-specific transaction limits and hold periods in SB 482 sit squarely at the boundary between financial-integrity architecture and payments-consumer-protection framing: the same statute that this brief reads as an anti-money-laundering control at the cash-conversion point is, from a payments-conduct perspective, a fraud-prevention and consumer-safeguard measure for an identical population of kiosk users. Similarly, HB 639's exemption of node operators, miners and stakers from money-transmitter licensing is a financial-integrity perimeter question here, but the same statutory language also defines the boundary of crypto-specific licensing obligations tracked elsewhere. Readers following either the payments or the crypto-regulatory treatment of New Hampshire this cycle will recognise the same two instruments described from a different vantage point. #### Outlook The kiosk regime under SB 482 takes effect on 16 December 2026, and the practical test of its anti-money-laundering value will be whether the $2,000 daily cap, the 48-hour hold on first transactions, and the blockchain-analytics wallet screening actually reduce the elder-fraud laundering volume that motivated the bill, or whether operators and bad actors adapt around a per-kiosk, per-customer limit. The Banking Department's new translated-records and interpreter authority under HB 1207, effective 1 October 2026, will be worth watching for how actively it is used in examinations of the state's money-transmitter population, particularly where firms operate with multilingual customer bases or offshore documentation. New Hampshire's infrastructure-layer exemption under HB 639 remains current law with no indication of near-term revisitation, so the bifurcated posture described above should be read as a durable structural feature of the state's regime rather than a transitional arrangement awaiting correction. Earlier periodic briefs (3) 25 Oct 2026 · fim-2026-10-25 #### Lead Signal New Hampshire enacted two statutes that, read together, describe a jurisdiction sharpening its posture at the retail edge of digital-asset activity while deliberately widening an exemption at the infrastructure-operation layer. Chapter 187 (SB 482), signed by the Governor on 19 June 2026 and taking effect 16 December 2026, imposes a $2,000-per-day per-customer transaction cap on digital asset transaction kiosks, a 48-hour hold with a refund right on a customer's first transaction, mandatory identity verification, fraud-risk warnings, and wallet screening against flagged addresses via blockchain analytics. The measure followed testimony from the Attorney General's office estimating roughly 250 such kiosks operating statewide and losses exceeding $2.6 million in a single municipality, Hampton, attributed to elder-fraud laundering through these machines. At the same time, HB 639 (the Blockchain Basic Laws), current law as of 18 August 2026, created a new statutory chapter exempting node operators, home and business digital-asset miners, and stakers from money-transmitter licensing under RSA 399-G, alongside a parallel exemption from securities treatment under RSA 421-B for mining and staking conducted with personal funds. The pairing is the significant architecture here: New Hampshire is narrowing its anti-money-laundering perimeter precisely at the point where cash converts to and from digital assets through unattended kiosks, while simultaneously widening the exemption boundary for the upstream infrastructure that makes those assets exist and move. That is not a uniform liberalisation or a uniform tightening; it is a bifurcated enabler profile, and it is the kind of structural signal that a single enforcement action would not capture. #### Other Developments Examination powers strengthened. HB 1207, signed 10 July 2026, amended RSA 399-G to grant the New Hampshire Banking Department commissioner new powers effective 1 October 2026: the authority to require a licensee's books and records to be translated into English (at the licensee's expense, with an interpreter also chargeable to the licensee), and a new duty requiring delegate locations to post a certificate of authority. The Department's standing supervisory population, per its FY2026 annual report, comprised 202 active money-transmitter licensees and 1,638 authorised delegates — the base against which these expanded examination powers now apply. A routine bank acquisition. Hometown Financial Group, a Massachusetts-based lender, agreed to acquire Primary Bank of Bedford, New Hampshire, for $160 million, adding roughly $743 million in assets and four New Hampshire branches. Nothing in the reporting identifies an anti-money-laundering or sanctions dimension to the transaction; it reads as ordinary community-bank consolidation rather than a supervisory or integrity event, though it is noted here as the only commercial-activity development material to New Hampshire. #### Cross-Monitor Connections The kiosk-specific transaction limits and hold periods in SB 482 sit squarely at the boundary between financial-integrity architecture and payments-consumer-protection framing: the same statute that this brief reads as an anti-money-laundering control at the cash-conversion point is, from a payments-conduct perspective, a fraud-prevention and consumer-safeguard measure for an identical population of kiosk users. Similarly, HB 639's exemption of node operators, miners and stakers from money-transmitter licensing is a financial-integrity perimeter question here, but the same statutory language also defines the boundary of crypto-specific licensing obligations tracked elsewhere. Readers following either the payments or the crypto-regulatory treatment of New Hampshire will recognise the same two instruments described from a different vantage point. #### Outlook The kiosk regime under SB 482 takes effect on 16 December 2026, and the practical test of its anti-money-laundering value will be whether the $2,000 daily cap, the 48-hour hold on first transactions, and the blockchain-analytics wallet screening actually reduce the elder-fraud laundering volume that motivated the bill, or whether operators and bad actors adapt around a per-kiosk, per-customer limit. The Banking Department's new translated-records and interpreter authority under HB 1207, effective 1 October 2026, will be worth watching for how actively it is used in examinations of the state's money-transmitter population, particularly where firms operate with multilingual customer bases or offshore documentation. New Hampshire's infrastructure-layer exemption under HB 639 remains current law with no indication of near-term revisitation, so the bifurcated posture described above should be read as a durable structural feature of the state's regime rather than a transitional arrangement awaiting correction. 4 Oct 2026 · fim-2026-10-04 #### Lead Signal The principal development bearing on New Hampshire-licensed money transmitters this period is federal rather than state-originated: FinCEN, jointly with federal banking agencies, proposed on 10 April 2026 a fundamental reform of Bank Secrecy Act AML/CFT program-rule requirements, covering banks, casinos and card clubs, and money services businesses. The proposal would reset minimum standards for AML programs and would require every AML program to explicitly incorporate countering the financing of terrorism, a structural integration of the AML and CFT pillars rather than treating CFT as a secondary add-on. The proposal has not been finalised, and no primary Federal Register text was retrieved this period, so this development is recorded at Probable confidence on the strength of two independent trade-press sources. #### Other Developments New Hampshire's own AML/CFT architecture is unchanged. The state's standing regime rests on RSA 399-G, the money-transmitter licensing statute, with RSA 399-G:17 requiring licensees to create and implement plans to comply with the Bank Secrecy Act. This governance obligation was illustrated in practice by the New Hampshire Banking Department's 2025 order to show cause against BAM Trading Services Inc., a controlling-person BSA/AML compliance matter that demonstrates the Department's willingness to exercise its enforcement leverage under the existing statute. #### Cross-Monitor Connections The FinCEN NPRM, once finalised, would have direct bearing on how New Hampshire's money-transmitter licensees — including crypto-asset operators licensed under the state's RSA 399-G regime — structure their AML programs going forward, connecting this federal-level development to the state's digital-asset licensing perimeter tracked separately. #### Outlook The FinCEN NPRM is not yet in force; its expected impact date carries a year-level uncertainty band centred on early 2027. Primary-source retrieval of the Federal Register text, once available, would allow this development's confidence to move beyond Probable. New Hampshire's own RSA 399-G baseline, including the BSA-compliance-plan obligation at RSA 399-G:17, remains the governing framework for the state's money transmitters in the interim. 14 Jul 2026 · fim-2026-07-14 #### Lead Signal New Hampshire enters this reporting cycle exhibiting a structural tension between two simultaneous trajectories: an accelerating embrace of bitcoin as a sovereign treasury instrument, and a contracting federal supervisory apparatus that the state depends on almost entirely for crypto-asset AML oversight. In May 2025 New Hampshire became the first US state to enact a legislated Strategic Bitcoin Reserve, with House Bill 302 authorizing the state treasury to hold up to five percent of state funds in bitcoin or digital assets exceeding a five-hundred-billion-dollar market capitalization threshold, of which bitcoin is currently the only qualifying instrument (fim-2026-W28-001). That legislative posture was reinforced in March 2026 when the New Hampshire Business Finance Authority received a provisional Ba2 rating from Moodys Ratings for a limited-recourse, pass-through bitcoin-backed conduit bond structure that places no state credit or public funds at risk (fim-2026-W28-002). Assessed against this same window, the federal examination capacity New Hampshire relies on, in the absence of any dedicated state-level crypto-AML examination unit, contracted sharply: Internal Revenue Service Bank Secrecy Act and AML examiner headcount assigned to money-services-business and crypto-firm oversight fell thirty-three percent in fiscal year 2025, from two hundred eight agents to one hundred thirty nine (fim-2026-W28-004). Read together, these developments support an assessed key judgment that New Hampshire simultaneous embrace of bitcoin as a sovereign treasury asset alongside its absence of state-level crypto-AML provenance controls constitutes a structural, not episodic, enabler gap, compounded by a two-sided supervisory deficit in which federal examination capacity and independent state-level examination capability are both thinning at once. #### Other Developments The Ian Freeman precedent continues to anchor New Hampshire enabler-jurisdiction posture. The Ian Freeman and Church of the Invisible Hand scheme disabled know-your-customer features on bitcoin kiosks, laundered scam proceeds through bank accounts opened under ostensible religious-nonprofit fronts, and never registered as a money services business with FinCEN, and it remains the primary evidentiary basis for national FinCEN convertible-virtual-currency kiosk typology guidance (fim-2026-W28-006). An appellate court affirmed the underlying federal conviction and sentence in July 2025, representing continued enforcement follow-through within the current reporting window (fim-2026-W28-007). FinCEN nationwide kiosk advisory formalized red-flag indicators for convertible virtual currency kiosk suspicious-activity-report filing in its August 2025 notice, citing prior prosecutions from the District of New Hampshire directly, and recording that the FBI Internet Crime Complaint Center logged more than ten thousand nine hundred fifty-six kiosk-related complaints in 2024, a ninety-nine percent year-on-year increase, with reported losses of approximately two hundred forty-six point seven million dollars (fim-2026-W28-003). The elder-fraud cash-to-bitcoin conversion pipeline that the advisory targets remains active nationally, including within outlets present in New Hampshire retail footprint, converting scam-victim cash instantly into bitcoin routed through cross-border laundering networks connected to Southeast Asian scam-compound operations (fim-2026-W28-012). Bitcoin Depot exit from the crypto-ATM market removes one node from that same conversion architecture. The operator filed for Chapter 11 bankruptcy in May 2026, having operated more than nine thousand kiosk locations globally as of August 2025, and cited stringent state and municipal compliance obligations, transaction limits, and litigation including Massachusetts and Iowa attorney-general lawsuits as drivers of its exit (fim-2026-W28-005). Beneficial-ownership visibility narrows at the federal level. A FinCEN interim final rule from March 2025 exempts all domestic reporting companies, including New Hampshire-formed limited liability companies and corporations, from Corporate Transparency Act beneficial-ownership reporting, leaving only foreign entities registered to do business in the state subject to filing obligations (fim-2026-W28-008). OFAC sanctions cadence continued at the national level with direct application to New Hampshire regulated firms through standard US-person jurisdiction and the standing New Hampshire Banking Department information-sharing memorandum of understanding with OFAC. Exodus Movement, a self-custody wallet software provider, settled with OFAC in February 2026 over apparent sanctions violations (fim-2026-W28-009), and Gracetown, Inc. was assessed a civil monetary penalty in December 2025 (fim-2026-W28-010); New Hampshire, as a US state, retains no independent sanctions-designation authority of its own (fim-2026-W28-015). Legislative horizon items bear directly on the state crypto-forward posture. Federal regulators must finalize GENIUS Act stablecoin implementing regulations ahead of a January 2027 deadline (fim-2026-W28-013), while law-enforcement and banking groups have warned that the pending Clarity Act market-structure bill could create AML oversight gaps through exemptions for decentralized and automated crypto services (fim-2026-W28-014). #### Cross-Monitor Connections The crypto-ATM elder-fraud conversion pipeline and the market exit of Bitcoin Depot carry consumer-fraud monitoring relevance beyond this monitor own AML, CTF and CPF scope, and have accordingly been flagged to FCW for its information-operations and financial-fraud coverage (fim-2026-W28-005, fim-2026-W28-012). The underlying architecture, in which cash deposited into nationally distributed kiosks converts instantly into bitcoin before moving through cross-border laundering networks linked to Southeast Asian scam-compound operations, sits at the intersection of consumer-protection failure and cross-border illicit finance that FCW is positioned to track from the demand side, even where this assessment is anchored to the New Hampshire-specific enabler and supervisory-capacity dimensions. #### Outlook Three regulatory horizon items will determine whether New Hampshire structural tension resolves toward tighter provenance control or further divergence. Finalization of GENIUS Act implementing regulations ahead of the January 2027 deadline is assessed as improving for custody and AML-provenance expectations applicable to state-level digital-asset programmes such as the Strategic Bitcoin Reserve and bitcoin-bond conduit (fim-reg-2026-101). Continued build-out of the Strategic Bitcoin Reserve allocation toward its statutory five percent cap during 2026 leaves custody, audit and AML-provenance controls for treasury-held bitcoin as an open supervisory question with an uncertain trajectory (fim-reg-2026-102). Passage or failure of the Clarity Act ahead of the 2026 midterm cycle is assessed as carrying a worsening risk direction for the federal crypto-AML perimeter within which New Hampshire crypto-forward money-services and kiosk population operates (fim-reg-2026-103). None of these developments has yet resolved the compounding two-sided supervisory gap identified this cycle. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion New Hampshire has no independent sanctions-designation authority of its own. As a US state, all sanctions designations and delistings applicable to New Hampshire-regulated financial and virtual-asset firms flow uniformly from the Office of Foreign Assets Control, transmitted through the standing New Hampshire Banking Department information-sharing memorandum of understanding with OFAC (fim-2026-W28-015). This is a structural provenance point rather than an enforcement gap: the absence of a distinct state sanctions regime reflects the constitutional allocation of foreign-affairs power to the federal government, and it applies identically to every US state, not to New Hampshire specifically. Continue reading Within that uniform architecture, the national OFAC enforcement cadence continued this cycle in ways directly applicable to New Hampshire crypto-forward regulated environment. Exodus Movement, a self-custody crypto wallet software provider, reached a settlement with OFAC in February 2026 for apparent sanctions violations, establishing standard US-person jurisdiction over virtual-asset software firms operating within New Hampshire regulatory environment even where the firm itself has no state-specific nexus (fim-2026-W28-009). Separately, OFAC assessed a civil monetary penalty against Gracetown, Inc. in December 2025, part of the continuing national enforcement cadence that New Hampshire-chartered banking organizations monitor under the standing information-sharing arrangement with the state banking department (fim-2026-W28-010). Applying an architecture-over-incident lens, neither the Exodus Movement settlement nor the Gracetown penalty constitutes a New Hampshire-specific sanctions-evasion architecture; both are data points generated by the uniform federal enforcement structure that New Hampshire, like every other US state, sits beneath. What is analytically significant is the absence of any documented New Hampshire-specific divergence from that national regime this cycle. New Hampshire-chartered banking organizations continue to apply the identical federal OFAC list that governs the rest of the US financial system, and no jurisdiction-level sanctions-evasion transit corridor, procurement route, or divergence point specific to New Hampshire has been identified. Given the state constitutional inability to operate an autonomous sanctions authority, this uniformity is the expected structural condition rather than a finding of enforcement adequacy or inadequacy in its own right. The Exodus Movement settlement carries a secondary significance for New Hampshire given the state crypto-forward posture more broadly. New Hampshire hosts a Moodys-rated bitcoin-backed conduit bond and a legislated Strategic Bitcoin Reserve, and the extension of standard OFAC self-custody-software jurisdiction to a wallet-software provider signals that the same federal sanctions architecture applicable to any US virtual-asset firm will apply equally to whatever custody, wallet, or software infrastructure New Hampshire state-level crypto programmes come to rely upon, without any distinct state-level sanctions carve-out or additional protection. #### Outlook No New Hampshire-specific sanctions-architecture development is currently on the near-term regulatory horizon beyond the continuing national OFAC cadence. The next material watch point is any OFAC Russia-programme or other designation action touching a New Hampshire-chartered or New Hampshire-domiciled financial institution directly, which would test for the first time whether the state uniform-application posture holds under a jurisdiction-specific designation rather than a generalized national action. Given New Hampshire complete dependence on the federal sanctions-designation apparatus, and the absence of any state-level mechanism to accelerate, delay, or diverge from federal listings, the sanctions-architecture posture for this jurisdiction is best read as a passthrough of the broader national trajectory rather than an independent variable, and its trajectory this cycle is assessed as stable. Judgment: No NH-specific sanctions-evasion signal identified this cycle. Uncertain #### Beneficial Ownership and Corporate Transparency New Hampshire sits outside the European Union Anti-Money Laundering Package direct perimeter entirely; as a US state, its corporate-transparency exposure runs through the federal Corporate Transparency Act framework administered by FinCEN, not through any EU-level instrument. The directly relevant development for New Hampshire this cycle is a March 2025 interim final rule in which FinCEN exempted all domestic reporting companies, including New Hampshire-formed limited liability companies and corporations, from Corporate Transparency Act beneficial-ownership-information reporting; only foreign entities registered to do business in New Hampshire remain subject to the filing obligation (fim-2026-W28-008). Applying an architecture-over-incident lens, this is a durable structural narrowing of federal beneficial-ownership visibility into New Hampshire-domiciled corporate structures, not a single-instance regulatory event, and the standing beneficial-ownership tracker for this jurisdiction has moved to a deteriorating trajectory as a direct consequence. Continue reading Globally, the European Union Anti-Money Laundering Package sets the structural direction toward which beneficial-ownership and corporate-transparency regulation elsewhere is converging, even though it does not apply to New Hampshire directly. That package now comprises three distinct instruments: the directly applicable Anti-Money Laundering Regulation, known as the AMLR (Regulation (EU) 2024/1624); the sixth Anti-Money Laundering Directive, or 6AMLD, which each EU member state transposes into national law individually; and the Anti-Money Laundering Authority Regulation (Regulation (EU) 2024/1620), which establishes the Anti-Money Laundering Authority itself and defines a supervisory perimeter under which the Authority will directly or indirectly supervise a defined population of cross-border obliged entities, shifting supervision away from a purely national-authority model toward a hybrid European Union-level regime. This architecture is durable structural backdrop against which any jurisdiction beneficial-ownership posture, including New Hampshire, can be read comparatively; it does not itself apply to New Hampshire-formed entities, and per-member-state transposition tracking of the sixth Anti-Money Laundering Directive is correspondingly not applicable to this jurisdiction, which sits outside the European Economic Area entirely. Read against that backdrop, the New Hampshire domestic exemption moves in the opposite direction from the European Union trajectory: where the European Union architecture is consolidating beneficial-ownership visibility upward toward a hybrid supervisory authority, the federal exemption of domestic reporting companies narrows visibility into New Hampshire-formed entities specifically, leaving only foreign entities registered to do business in the state subject to beneficial-ownership filing. The practical effect is that beneficial-ownership information for the substantial majority of New Hampshire corporate structures, including any entities interposed within the state Strategic Bitcoin Reserve custody or bond-conduit arrangements, is no longer collected at the federal beneficial-ownership registry level, absent some other applicable disclosure requirement. The federal exemption also interacts with the enabler-jurisdiction dimension addressed elsewhere in this cycle: the Ian Freeman scheme relied in part on ostensible religious and nonprofit fronts to obscure beneficial control of accounts receiving money-transmission proceeds, a technique that beneficial-ownership disclosure exists specifically to counter (fim-2026-W28-006). A narrower federal domestic reporting-company disclosure regime does not resolve that class of front-entity risk, and its removal for domestic filers arguably widens the pool of undisclosed New Hampshire-formed vehicles that could in principle be used for equivalent front-entity structuring going forward. Separately, no New Hampshire Treasurer disclosure documentation describing beneficial-ownership or provenance-screening procedures for state-acquired bitcoin holdings has been located, leaving the beneficial-ownership dimension of the Strategic Bitcoin Reserve itself an open question this cycle. #### Outlook The near-term watch point for New Hampshire beneficial-ownership posture is any further FinCEN final-rule action either restoring or additionally narrowing the domestic beneficial-ownership-information reporting scope established by the March 2025 interim final rule. No New Hampshire state-level legislative response addressing the resulting visibility gap has been identified this cycle. Given the deteriorating trajectory already recorded on the standing beneficial-ownership tracker, and the structural nature of the federal exemption, the analytically significant question going forward is whether any other disclosure mechanism, state-level or federal, will substitute for the visibility lost at the Corporate Transparency Act registry level, particularly with respect to entities associated with the state crypto-forward treasury and bond-conduit programmes. Judgment: No NH-specific beneficial-ownership development found this cycle. Uncertain #### Enabler Jurisdictions and Professional Facilitators New Hampshire's status as an enabler jurisdiction this cycle is defined by simultaneity rather than direction. HB 639, current law as of 18 August 2026, created a new statutory chapter exempting node operators, home and business digital-asset miners, and stakers from money-transmitter licensing under RSA 399-G, and extended a parallel exemption from securities treatment under RSA 421-B where mining or staking is conducted with personal funds. This deepens a posture the state had already established: New Hampshire is one of a small number of jurisdictions that does not require a licence for standalone virtual-currency transmission, and HB 639 extends that permissiveness explicitly to the infrastructure-operation layer of the crypto ecosystem — the entities that run the nodes, mine the assets, and validate the chains, rather than the entities that convert those assets to and from dollars for customers. Continue reading Against that widening at the infrastructure layer, the same legislative session narrowed the state's posture at the retail cash-conversion point. SB 482 (Chapter 187), signed 19 June 2026 and effective 16 December 2026, imposes a $2,000-per-day per-customer transaction cap, a 48-hour hold with refund right on first transactions, mandatory identity verification, fraud-risk warnings, and blockchain-analytics wallet screening specifically on digital asset transaction kiosks. The bill followed Attorney General testimony estimating roughly 250 such kiosks statewide and losses exceeding $2.6 million in Hampton alone, attributed to a documented elder-fraud laundering channel. The analytical significance of reading these two instruments together is that New Hampshire cannot be filed as simply "permissive" or simply "tightening" this cycle. It is doing both, at two different points in the same value chain, and the exemption from licensing for infrastructure operators remains current law with no indication the kiosk tightening will be extended upstream to reach it. A jurisdiction that exempts the production and validation layer from licensing while regulating the retail conversion layer is making a considered choice about where its enforcement resources and consumer-protection concerns are best deployed — and the absence of any move to licence miners, stakers, or node operators is itself a signal about where New Hampshire does not intend to extend its perimeter, at least for now. #### Outlook The durability of this bifurcated posture will be tested by whether other states follow New Hampshire's lead on either half of the pairing. If the kiosk-specific consumer protections under SB 482 prove effective at reducing elder-fraud losses once they take effect on 16 December 2026, other enabler jurisdictions with similarly permissive infrastructure-exemption regimes may adopt comparable retail-layer controls without disturbing their underlying licensing exemptions for miners and node operators. Conversely, if losses persist after the kiosk rules take effect, pressure may build to extend scrutiny upstream, though nothing in the current legislative record suggests that is imminent. For now, New Hampshire's structural choice — exempt the infrastructure, regulate the retail conversion point — stands as enacted and should be read as a considered design rather than an unresolved gap. Judgment: HB 639's statutory exemption of node operators/miners/stakers from MTL licensing deepens NH's documented posture as a deliberately permissive jurisdiction for crypto infrastructure, while SB 482 simultaneously tightens the retail cash-conversion point -- a bifurcated enabler profile. Probable Judgment: No NH-specific conflict-finance signal identified this cycle. Uncertain #### Crypto, Digital Assets, and Financial Innovation New Hampshire enacted two materially significant digital-asset instruments within the same legislative window. SB 482 (Chapter 187), signed by the Governor on 19 June 2026 and effective 16 December 2026, establishes the state's first statutory response to a documented elder-fraud laundering channel operating through digital asset transaction kiosks. The Attorney General's office had testified that roughly 250 such kiosks operate statewide, with losses exceeding $2.6 million in the single municipality of Hampton. The statute responds with a $2,000-per-day per-customer transaction cap, a mandatory 48-hour hold with a refund right on a customer's first transaction, mandatory identity verification before funds are accepted, conspicuous fraud-risk warnings, and screening of transactions against flagged wallet addresses using blockchain analytics. Continue reading Separately, HB 639 — the state's Blockchain Basic Laws, current law as of 18 August 2026 — created new RSA chapter 359-V, exempting node operators, home and business digital-asset miners, and stakers from money-transmitter licensing under RSA 399-G. A parallel provision exempts mining and staking conducted with personal funds from securities treatment under RSA 421-B. Notably, the exemption applies regardless of whether a federal FinCEN money-services-business obligation also attaches to the same activity — New Hampshire's exemption operates at the state licensing layer only and does not purport to override federal requirements. Taken together, these two statutes describe a crypto-integrity posture that is escalating rather than static, in both directions. The kiosk measure is the more AML-adjacent of the two: it targets a specific, quantified fraud-laundering vector at the point where value crosses from cash into digital assets and back, using tools — transaction caps, holds, and wallet screening — that are recognisably anti-money-laundering controls even though the statute is framed in consumer-protection terms. The infrastructure exemption, by contrast, removes a licensing requirement rather than adding one, and does so for the layer of activity — running nodes, mining, staking — that has historically drawn far less AML scrutiny than exchange or custody activity, precisely because it does not typically involve direct customer-facing fiat conversion. #### Outlook The kiosk rules take effect 16 December 2026, and the first indicator of their real-world effect will be whether reported elder-fraud losses attributable to kiosk conversion decline in the following reporting cycles, or whether the fraud simply migrates to channels the statute does not reach — person-to-person transfers, kiosks operated outside the regulated footprint, or out-of-state machines accessible to New Hampshire residents. On the infrastructure side, HB 639 is now settled law with no signal of imminent revisitation; the state's choice to exempt miners, stakers, and node operators from licensing should be read as a durable structural feature of its digital-asset regime, not a temporary gap awaiting closure. Readers should watch for whether federal action — a FinCEN guidance update or a federal AML rule specific to node operators or miners — eventually supersedes the practical significance of the state-level exemption. Judgment: NH enacted two material crypto-integrity instruments this cycle window: SB 482 (kiosk consumer/AML-adjacent protections) and HB 639 (MTL exemption for node operators/miners/stakers). Probable #### Compliance Technology and Active Defence The single most consequential development for New Hampshire compliance-technology and active-defence posture this cycle is a national one with direct jurisdictional bite: Internal Revenue Service Bank Secrecy Act and anti-money-laundering examiner headcount assigned to money-services-business and crypto-asset-firm oversight fell thirty-three percent in fiscal year 2025, from two hundred eight agents to one hundred thirty nine (fim-2026-W28-004). Applying an architecture-over-incident lens, this is a structural capacity shift in the federal supervisory architecture rather than an isolated staffing adjustment, and it carries disproportionate significance for New Hampshire specifically because the state has no dedicated state-level crypto-AML examination unit of its own and therefore depends on federal examination capacity more heavily than states that maintain independent supervisory infrastructure for this sector. Continue reading That dependency is compounded rather than offset by New Hampshire own regulatory trajectory this cycle. The state has simultaneously become the most crypto-forward jurisdiction in the country, hosting a legislated Strategic Bitcoin Reserve and a Moodys-rated bitcoin-backed conduit bond, expanding precisely the category of activity, money-services-business and crypto-asset-firm activity, whose federal examination capacity is contracting. The result is a compounding, two-sided supervisory gap: examination demand generated by New Hampshire own crypto-forward policy choices is rising at the same time that the federal supply of examination capacity available to meet that demand is falling, with no New Hampshire-specific mitigating measure, such as a new state examination unit or an equivalent third-party assurance mechanism, identified this cycle to offset the reduction. This compliance-technology and active-defence assessment also connects directly to the enabler-jurisdiction and beneficial-ownership dimensions addressed elsewhere this cycle. The Ian Freeman unlicensed-money-services-business scheme, which relied on disabled know-your-customer controls and undisclosed nonprofit-front bank accounts, was itself detected and prosecuted through federal law-enforcement and examination channels of the kind now operating at reduced capacity nationally; and the federal beneficial-ownership visibility narrowing produced by the March 2025 Corporate Transparency Act domestic-reporting-company exemption removes a second, independent source of information that active-defence and compliance-technology functions might otherwise have relied upon to identify comparable front-entity structures going forward. Neither the examiner-capacity contraction nor the beneficial-ownership exemption is, individually, a New Hampshire-specific policy decision; both are federal-level structural developments that happen to bear with particular force on a state that has chosen an unusually crypto-forward regulatory posture without building equivalent independent state-level examination or transparency infrastructure to match it. #### Outlook Fiscal year 2026 Internal Revenue Service examiner headcount data is not yet available, and obtaining it is the principal near-term item that would clarify whether the fiscal year 2025 capacity reduction represents a one-off adjustment or a continuing trend with compounding significance for New Hampshire-dependent federal oversight. Absent any New Hampshire-specific state-level examination capacity build-out, and absent clarity on whether the federal contraction continues into fiscal year 2026, the compliance-technology and active-defence trajectory for this jurisdiction is assessed as deteriorating, reflecting a widening gap between the volume and complexity of crypto-asset activity New Hampshire own policy choices are generating and the federal examination capacity available to supervise it. Judgment: No RegTech or active-defence development identified for NH this cycle; D6 is exempt from the substantive-finding floor. Uncertain #### AML/CTF Regime New Hampshire's standing money-transmitter supervisory architecture under RSA 399-G was strengthened this cycle by HB 1207, signed 10 July 2026, which amends the Banking Department commissioner's examination powers effective 1 October 2026. Two specific new provisions take effect on that date: the commissioner may require a licensee's books and records to be translated into English, with both the translation and an interpreter chargeable to the licensee's own expense, and delegate locations operating under a money-transmitter's authority must post a certificate of authority on-site. The New Hampshire Banking Department remains the designated supervisor of money transmitters under RSA 399-G, overseeing a population that its FY2026 annual report placed at 202 active licensees operating through 1,638 authorised delegates. Continue reading These amendments sit alongside, rather than replace, the broader body of money-transmitter law the Department administers, and they matter because they expand the Department's practical examination toolkit rather than its formal licensing scope. A commissioner empowered to demand translated records and to compel an interpreter's presence during an examination — at the licensee's cost — gains meaningfully greater visibility into the operations of money transmitters whose documentation, correspondence, or customer records are not maintained in English, a capability gap that supervisory bodies in jurisdictions with growing immigrant or cross-border customer populations have often identified as a practical constraint on effective examination. Similarly, the delegate certificate-of-authority posting duty is a modest but concrete transparency measure, making it easier for a customer, investigator, or examiner to confirm on the spot that a given location is in fact operating under a valid delegated authority rather than holding itself out as such without one. This cycle's development should be read as incremental strengthening of an already-established regime rather than a new regulatory architecture. New Hampshire has long required money-transmitter licensing under RSA 399-G, subject to the standing exemption for standalone virtual-currency transmission; HB 1207 does not touch that exemption boundary. It instead reinforces the Department's capacity to supervise the population that does require licensing, including any fiat-touching crypto exchange or custody business operating in the state. #### Outlook The practical significance of HB 1207's amendments will depend on how actively the Banking Department deploys its new translated-records and interpreter authority once it takes effect on 1 October 2026. If used selectively in examinations of money transmitters whose customer base or corporate structure crosses linguistic or jurisdictional lines, the provision could meaningfully improve the Department's ability to detect compliance gaps that English-only examination previously missed. The delegate certificate-of-authority requirement is more straightforward to assess: compliance should be visible and verifiable at the point of inspection, and any gap between the number of certificates issued and the number of delegate locations the Department has on file would itself be a notable supervisory finding in a future cycle. Judgment: NH Banking Department remains the designated money-transmitter supervisor under RSA 399-G; HB 1207 strengthened examination powers effective 1 October 2026. Probable #### Commercial Activity The single commercial-activity development identified for New Hampshire this cycle is Hometown Financial Group's agreement to acquire Primary Bank, based in Bedford, New Hampshire, for $160 million. The transaction adds approximately $743 million in assets and four New Hampshire branches to the Massachusetts-based acquirer, which intends to operate the combined franchise under the TruNorth Bank brand. Nothing in the available reporting identifies an anti-money-laundering, sanctions, or beneficial-ownership dimension to the deal; it presents as a routine community-bank consolidation of the kind that occurs regularly across New England's smaller-bank sector. Continue reading The analytical interest of this transaction for a financial-integrity reading is limited precisely because it is unremarkable. A cross-border or cross-state acquisition of a regulated depository institution ordinarily triggers a standard set of prudential and change-of-control reviews by state and federal banking regulators, and the absence of any disclosed integrity concern in this instance is consistent with those reviews proceeding as expected rather than surfacing anything requiring escalation. This is worth stating explicitly rather than leaving silent: a transaction of this kind, involving a depository institution rather than a money-services business or digital-asset firm, carries a materially different risk profile from the kiosk-related and crypto-infrastructure developments addressed elsewhere this cycle, and readers should not infer any connection between the two threads of New Hampshire activity. #### Outlook Absent any disclosed integrity concern, the Hometown Financial Group acquisition of Primary Bank is not expected to generate further financial-integrity findings in subsequent cycles unless regulatory review surfaces an issue not yet reported. The transaction is noted here chiefly for completeness and to distinguish it clearly from New Hampshire's more structurally significant digital-asset and money-transmitter developments addressed elsewhere in this brief. Judgment: Hometown Financial Group's $160M acquisition of Primary Bank (Bedford, NH) is a routine community-bank consolidation with no disclosed AML or sanctions dimension. Probable Regulatory horizon No dated horizon items this cycle. 3 items tracked without a confirmed date. 3 pending date · baseline financial-integrity-2026-07-05 Role action cards MLRO ### New Hampshire enacted kiosk-specific transaction controls and strengthened money-transmitter examination powers this cycle, while separately exempting crypto infrastructure operators from licensing. A new $2,000 daily cap, 48-hour first-transaction hold, and wallet screening apply to digital asset kiosks from 16 December 2026, giving MLROs operating or supervising kiosk-adjacent business a concrete new control set to implement. Separately, the Banking Department gained translated-records and interpreter authority in examinations from 1 October 2026, which may surface in future money-transmitter exams. 2 evidence refs Compliance ### Two enacted statutes materially change the compliance landscape for digital-asset kiosk operators and money transmitters in New Hampshire. Kiosk operators must build toward the SB 482 requirements ahead of the 16 December 2026 effective date, while any NH-licensed money transmitter should anticipate the Banking Department's expanded examination toolkit from 1 October 2026. Node operators, miners, and stakers remain outside money-transmitter licensing under HB 639. 3 evidence refs Legal ### New Hampshire's crypto-infrastructure licensing exemption under HB 639 is now current law, confirmed in parallel with a new kiosk consumer-protection statute. Counsel advising digital-asset infrastructure clients in New Hampshire can rely on the HB 639 exemption from money-transmitter licensing and from RSA 421-B securities treatment for personal-fund mining and staking as settled current law, while noting that fiat-touching exchange or custody activity remains within the licensing perimeter. 1 evidence refs Board ### New Hampshire is pursuing a bifurcated regulatory strategy toward digital assets, tightening at retail conversion points while exempting infrastructure operators. Institutions with exposure to New Hampshire-licensed money transmitters or kiosk operators should expect increased examination scrutiny and new consumer-facing controls, while any strategic interest in crypto-infrastructure operations (mining, staking, node operation) in the state benefits from a confirmed, settled licensing exemption. 2 evidence refs CTO ### New Hampshire requires blockchain-analytics wallet screening at digital asset kiosks and confirms a licensing exemption for node operators, miners, and stakers. Technical teams supporting kiosk operators need wallet-screening integration against flagged-address lists in place by 16 December 2026. Teams running node infrastructure, mining, or staking operations in New Hampshire operate under a confirmed state-law exemption from money-transmitter licensing, though federal FinCEN obligations are unaffected by the state exemption. 2 evidence refs Risk ### A documented elder-fraud laundering channel through digital-asset kiosks prompted New Hampshire's new statutory controls this cycle. The scale cited by the Attorney General's office — roughly 250 kiosks statewide and over $2.6 million in losses in one municipality alone — indicates the typology was material before the new controls existed; risk functions should treat the new caps and holds as a mitigant to monitor for effectiveness, not an eliminated exposure. 1 evidence refs Operations ### No material change for this persona this cycle. No material change for this persona this cycle Audit ### The New Hampshire Banking Department gained new examination evidence-gathering powers effective 1 October 2026. The translated-records and interpreter authority, and the delegate certificate-of-authority posting duty, give auditors a new basis to test whether money-transmitter licensees and their delegates can demonstrate compliance with documentation and on-site posting requirements going forward. 1 evidence refs Scenario sketches ### AMLA direct-supervision transition and cross-border obliged-entity evasion routing Illustrative scenario for analytical orientation only. As the EU moves from purely national AML supervision toward a hybrid regime under the AMLA Regulation (Reg (EU) 2024/1620), with the directly-applicable AML Regulation (Reg 2024/1624) and per-state Sixth AML Directive transposition operating alongside it, a cross-border obliged entity newly within AMLA's direct-supervision perimeter could, in principle, respond by shifting marginal volume toward affiliated entities or counterparties in jurisdictions outside that perimeter, including permissive non-EEA venues. This is an illustrative structural mechanism only, not an observed development in any jurisdiction named in this brief, and does not describe New Hampshire specifically. Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact. Standing trackers (T1–T6) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture no_change T2 · EU AML Package / AMLA no_change T3 · FATF Grey List no_change T4 · Beneficial-Ownership Register Status no_change T5 · Crypto & Digital-Asset Integrity escalating NH enacted SB 482 (kiosk protections, eff. 16 Dec 2026) and HB 639 (MTL exemption, eff. 18 Aug 2026, current law). T6 · Sanctions Regime Divergence no_change Registers ### Enforcement actions - 4 Aug 2025 - 17 Feb 2026 - 18 May 2026 - 12 Feb 2026 - 9 Dec 2025 - 6 Mar 2026 - 30 Jun 2026 - FinCEN issued Notice FIN-2025-NTC1 urging financial institutions to increase vigilance around CVC kiosk illicit-finance risk, citing prior USAO-District of New Hampshire prosecutions (unlicensed virtual-currency exchange businesses) among its evidentiary typology basis for red-flag indicators. 4 Aug 2025 - IRS AML examiner headcount assigned to oversee BSA/AML compliance at crypto firms and other money transmitters fell 33 percent in FY2025 (to 139 agents from 208 in FY2024), reducing federal supervisory bandwidth precisely in the sector (unlicensed/underlicensed MSBs, crypto kiosks) that produced New Hampshire's landmark Freeman prosecution. 17 Feb 2026 - Bitcoin Depot, formerly the world's largest crypto-ATM operator (~9,700 kiosks), filed for bankruptcy and ceased operations, citing increasingly stringent state and municipal compliance obligations, transaction limits and outright restrictions as the direct cause of business infeasibility. 17 May 2026 ### Sanctions changes - 23 Apr 2026 - 30 Jun 2026 - 30 Jun 2026 - 1 Jul 2026 - 1 Jul 2026 - 13 Jul 2026 - 28 May 2026 - OFAC reached a settlement agreement with Exodus Movement, Inc. (a self-custody crypto wallet software provider) resolving apparent sanctions violations, a national enforcement/licence action directly applicable to virtual-asset software firms in NH's crypto-forward regulatory environment via standard OFAC jurisdiction over all US persons/entities. 12 Feb 2026 - OFAC assessed a civil monetary penalty against Gracetown, Inc. for apparent sanctions violations, part of the continuing national OFAC enforcement cadence that NH-chartered banking organizations must monitor under the standing NH Banking Department/OFAC information-sharing Memorandum of Understanding covering sanctions-compliance supervision of state-licensed entities. 9 Dec 2025 ### Regulatory horizon (register) - US Treasury National Risk Assessment refresh (NMLRA/NTFRA/NPFRA) - FinCEN / federal banking agencies NPRM: fundamental reform of BSA AML/CFT program rules - NH SB 482 digital asset transaction kiosk consumer protections - GENIUS Act stablecoin implementing regulations finalization - NH Strategic Bitcoin Reserve treasury allocation build-out - Congressional Clarity Act crypto market-structure legislation outcome ### Active schemes - [HIGH] Unlicensed bitcoin-kiosk laundering via church-front entities - [HIGH] Crypto-ATM cash-to-crypto elder-fraud conversion pipeline Sources - [New Hampshire Banking Department](https://www.banking.nh.gov/consumer-credit-licensees-registrants/money-transmitters) - [New Hampshire Banking Department](https://mm.nh.gov/files/uploads/banking/enforcement-orders/20250527-order-to-show-cause-bam-trading-services-inc.pdf) - [Norton Rose Fulbright](https://www.nortonrosefulbright.com/en-us/knowledge/publications/fa891ed4/proposed-fincen-amlcft-rule-key-changes-for-financial-institutions) - [American Bankers Association](https://bankingjournal.aba.com/2026/04/fincen-banking-agencies-propose-to-overhaul-bank-secrecy-act-compliance/) - [https://legiscan.com/NH/bill/SB482/2026?guid=59Wh0SvggocImLuteAfjZH](https://legiscan.com/NH/bill/SB482/2026?guid=59Wh0SvggocImLuteAfjZH) - [https://legiscan.com/NH/text/HB639/id/3063137](https://legiscan.com/NH/text/HB639/id/3063137) - [https://gc.nh.gov/rsa/html/xxxvi/399-g/399-g-mrg.htm](https://gc.nh.gov/rsa/html/xxxvi/399-g/399-g-mrg.htm) - [https://www.bankingdive.com/news/massachusetts-lender-acquires-nh-bank-160m/824608/](https://www.bankingdive.com/news/massachusetts-lender-acquires-nh-bank-160m/824608/) - [FinCEN Notice, FIN-2025-NTC1, August 4, 2025](https://www.fincen.gov/system/files/2025-08/FinCEN-Notice-CVCKIOSK.pdf) - [MSB Registrant Search | FinCEN.gov](https://www.fincen.gov/resources/msb-state-selector) - [Enforcement Actions for Failure to Register as a Money Services Business | FinCEN.gov](https://www.fincen.gov/enforcement-actions-failure-register-money-services-business) - [Fact Sheet on MSB Registration Rule | FinCEN.gov](https://www.fincen.gov/fact-sheet-msb-registration-rule) - [Enforcement Actions | FinCEN.gov](https://www.fincen.gov/news/enforcement-actions) - [FinCEN Consent Order Imposing Civil Money Penalty](https://www.fincen.gov/system/files/enforcement_action/2025-02-06/FinCEN-Brinks-FINALv508.pdf) - [News Releases on Unregistered Money Transmitter Enforcement Actions | FinCEN.gov](https://www.fincen.gov/news-releases-unregistered-money-transmitter-enforcement-actions-0) - [GUIDANCE TO MONEY SERVICES BUSINESSES ON OBTAINING AND MAINTAINING BANKING SERVICES | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/guidance-money-services-businesses-obtaining-and) - [Application of the Definition of Money Transmitter to Brokers and Dealers in Currency and Other Commodities | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/application-definition-money-transmitter-brokers-and) - [Definition of Money Transmitter (Merchant Payment Processor) | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/definition-money-transmitter-merchant-payment) - [MEMORANDUM OF UNDERSTANDING U.S. Department of ...](https://ofac.treasury.gov/media/31316/download?inline=) - [Answers to Frequently Asked Bank Secrecy Act (BSA) Questions | FinCEN.gov](https://www.fincen.gov/resources/answers-frequently-asked-bank-secrecy-act-bsa-questions) - [The Bank Secrecy Act | FinCEN.gov](https://www.fincen.gov/resources/statutes-and-regulations/bank-secrecy-act) - [FinCEN’s Legal Authorities | FinCEN.gov](https://www.fincen.gov/resources/fincens-legal-authorities) - [1st Review of the Suspicious Activity Reporting System (SARS) | FinCEN.gov](https://www.fincen.gov/1st-review-suspicious-activity-reporting-system-sars) - [Case Examples | FinCEN.gov](https://www.fincen.gov/resources/law-enforcement/case-examples?field_tags_investigation_target_id=675) - [Fact Sheet for Bank Secrecy Act Effectiveness and Efficiency | FinCEN.gov](https://www.fincen.gov/fact-sheet-bank-secrecy-act-effectiveness-and-efficiency) - [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) - [1 Financial Crimes Enforcement Network (FinCEN)](https://www.fincen.gov/system/files/2026-05/FinCEN-Year-in-Review-2025.pdf) - [Civil Penalties and Enforcement Information | Office of Foreign Assets Control](https://ofac.treasury.gov/civil-penalties-and-enforcement-information) - [Recent Actions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/enforcement-actions) - [Frequently Asked Questions | FinCEN.gov](https://www.fincen.gov/boi-faqs) - [Alerts/Advisories/Notices/Bulletins/Fact Sheets | FinCEN.gov](https://www.fincen.gov/resources/advisoriesbulletinsfact-sheets) - [Press Releases | FinCEN.gov](https://www.fincen.gov/news/press-releases) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [Guidance | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance) - [2026 Crypto Crime Report: Scams](https://www.chainalysis.com/blog/crypto-scams-2026/) - [Retailers keep cashing in on crypto ATMs as scams surge - ICIJ](https://www.icij.org/investigations/coin-laundry/retailers-keep-cashing-in-on-crypto-atms-as-scams-surge/) - [Amid a scam crackdown, crypto giants keep fueling bitcoin ATMs - ICIJ](https://www.icij.org/investigations/coin-laundry/amid-a-scam-crackdown-crypto-giants-keep-fueling-bitcoin-atms/) - [How Crypto ATMs in the U.S. Became A Favorite Tool for Scammers | OCCRP](https://www.occrp.org/en/blog/18883-how-crypto-atms-in-the-u-s-became-a-favorite-tool-for-scammers) - [Massachusetts sues Bitcoin Depot, alleging the crypto ATM operator knowingly facilitated crypto scams - ICIJ](https://www.icij.org/investigations/coin-laundry/massachusetts-sues-bitcoin-depot-alleging-the-crypto-atm-operator-knowingly-facilitated-crypto-scams/) - [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) - [Crypto scams and elder financial exploitation: cracking down on fraud targeting the vulnerable](https://www.elliptic.co/blog/analysis/crypto-scams-and-elder-financial-exploitation-cracking-down-on-fraud-targeting-the-vulnerable) - [Crypto ATM operator Bitcoin Depot files for bankruptcy - ICIJ](https://www.icij.org/investigations/coin-laundry/crypto-atm-operator-bitcoin-depot-files-for-bankruptcy/) - [2026 Crypto Crime Report – Illicit Crypto Trends & Typologies | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/2026-crypto-crime-report) - [Rate of Illicit Activity at Crypto ATMs is Double That of Overall Crypto Industry | TRM Labs](https://www.trmlabs.com/resources/blog/illicit-activity-involving-crypto-atms-is-double-that-of-overall-crypto-industry) - [Cryptocurrency Regulation: How Governments Around the World Regulate Crypto](https://www.chainalysis.com/blog/cryptocurrency-regulation-explained/) - [2025 Regulatory outlook: It’s crunch time for the US Congress on crypto legislation](https://www.elliptic.co/blog/2025-regulatory-outlook-its-crunch-time-for-the-us-congress-on-crypto-legislation) - [How crypto regulation changed in 2025: a global review](https://www.elliptic.co/blog/how-crypto-regulation-changed-in-2025) - [Bitcoin ATMs: amid recent UK enforcement action, what are the risks of crypto kiosks?](https://www.elliptic.co/blog/analysis/bitcoin-atms-amid-recent-uk-enforcement-action-what-are-the-risks-of-crypto-kiosks) - [Blockchain Legal Library](https://www.trmlabs.com/blockchain-legal-library) - [How the USAO New Hampshire Returned $3.5 Million to Scam Victims | TRM Labs](https://www.trmlabs.com/resources/blog/how-the-usao-new-hampshire-returned-3-5-million-to-scam-victims?hss_channel=lcp-18742807) - [Financial Fraud Enforcement Task Force (FFETF) | FinCEN.gov](https://www.fincen.gov/financial-fraud-enforcement-task-force-ffetf) - [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) - [Attorney Sentenced in Fraud Case | FinCEN.gov](https://www.fincen.gov/resources/law-enforcement/case-examples/attorney-sentenced-fraud-case) - [State & Federal Agencies Seize $8.9 Million—Brought Together by Gateway Alert Match Program | FinCEN.gov](https://www.fincen.gov/resources/law-enforcement/case-examples/state-federal-agencies-seize-89-million-brought-together) - [New failure to prevent fraud guidance published - GOV.UK](https://www.gov.uk/government/news/new-failure-to-prevent-fraud-guidance-published) - [Membership of the Parole Board between 1 April 2024 and ...](https://assets.publishing.service.gov.uk/media/6878dfcc2bad77c3dae4dd77/2024-2025-Membership_of_the_Parole_Board.pdf) - [DEPARTMENT OF THE TREASURY BANK SECRECY ACT ADVISORY GROUP](https://www.fincen.gov/system/files/shared/bsaag_members.pdf) - [Published on 29 February 2024 Effective from 29 May 2024 Attorney General’s](https://assets.publishing.service.gov.uk/media/65e1ab9d2f2b3b00117cd803/Attorney_General_s_Guidelines_on_Disclosure_-_2024.pdf) - [Ian Freeman Sentenced to Eight Years In Bitcoin Money Laundering Scheme In “Church of the Invisible Hand” Case | TRM Labs](https://www.trmlabs.com/resources/blog/ian-freeman-sentenced-to-eight-years-in-prison-for-running-bitcoin-money-laundering-scheme-in-church-of-the-invisible-hand-case) - [SBF Faces Skeptical Judges at Appeal of FTX Fraud Verdict - Bloomberg](https://www.bloomberg.com/news/articles/2025-11-04/sbf-to-argue-he-was-presumed-guilty-after-ftx-in-trial-appeal) - [Asset Seizure and Cryptocurrency - Chainalysis](https://www.chainalysis.com/blog/cryptocurrency-asset-seizure/) - [How Cryptocurrencies Are Frozen, Seized, and Forfeited](https://www.chainalysis.com/blog/cryptoasset-realization-explained/) - [DIGEST OF CYBER ORGANIZED CRIME SECOND EDITION](https://www.unodc.org/documents/Cybercrime/publications/digest_cyber_organized_crime_2nd_ed.pdf?v=3.6) - [Bankman-Fried to Appeal 25-Year Sentence, Conviction for Fraud - Bloomberg](https://www.bloomberg.com/news/articles/2024-04-11/bankman-fried-to-appeal-25-year-sentence-conviction-for-fraud) - [SBF Sentencing: 8 Other Crypto Executives Accused Facing Fraud Cases - Bloomberg](https://www.bloomberg.com/news/articles/2024-03-28/sbf-sentencing-8-other-crypto-executives-accused-facing-fraud-cases) - [Sam Bankman-Fried Asks for New Trial on FTX Fraud Charges - Bloomberg](https://www.bloomberg.com/news/articles/2026-02-10/sam-bankman-fried-asks-for-new-trial-over-ftx-fraud-charges) - [Sam Bankman-Fried Sentencing: SBF Gets 25 Years in Prison Over FTX Collapse - Bloomberg](https://www.bloomberg.com/news/articles/2024-03-28/bankman-fried-is-sentenced-to-25-years-in-prison) - [US: Two Charged In $1.89 Billion Crypto Fraud Scheme, Third Member Pleads Guilty | OCCRP](https://www.occrp.org/en/news/us-two-charged-in-189-billion-crypto-fraud-scheme-third-member-pleads-guilty) - [Trump Tells New Hampshire Voters He’d Prevent a Federal Reserve Digital Dollar - Bloomberg](https://www.bloomberg.com/news/articles/2024-01-18/trump-tells-new-hampshire-voters-he-d-prevent-a-federal-reserve-digital-dollar) - [Bitcoin Strategic Reserves - Chainalysis](https://www.chainalysis.com/blog/bitcoin-strategic-reserves/) - [Enhancing Law Enforcement’s Role in Expanding the US Strategic Bitcoin Reserve | TRM Labs](https://www.trmlabs.com/resources/blog/enhancing-law-enforcements-role-in-expanding-the-us-strategic-bitcoin-reserve) - [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) - [Strategy CEO Says Reserve Reduces Pressure to Sell Bitcoin - Bloomberg](https://www.bloomberg.com/news/articles/2025-12-02/strategy-ceo-sees-reserve-used-to-make-payments-in-perpetuity) - [Crypto Execs Head to White House Amid US Bitcoin Reserve Questions - Bloomberg](https://www.bloomberg.com/news/articles/2025-03-06/crypto-execs-head-to-white-house-amid-questions-around-us-bitcoin-reserve) - [What the GENIUS and Market Structure Bills Mean for Crypto Compliance](https://www.chainalysis.com/blog/genius-act-market-structure-bills-crypto-compliance-july-2025/) - [Trump Team’s Bitcoin Reserve Strategy Takes a Market Beating - Bloomberg](https://www.bloomberg.com/news/articles/2026-02-06/trump-team-s-bitcoin-reserve-strategy-takes-a-market-beating) - [CCRC refers convictions of Clive Freeman to the Court of Appeal - Criminal Cases Review Commission](https://ccrc.gov.uk/news/ccrc-refers-convictions-of-clive-freeman-to-the-court-of-appeal/) - [Tribunal decisions](https://tribunalsdecisions.service.gov.uk/utiac/39047) - [Arianna J Freeman, United States Court of Appeals for the Third Circuit: Profile and Biography - Bloomberg Markets](https://www.bloomberg.com/profile/person/23065064) - [Court of Appeal cases fixed for hearing (Criminal Division) - GOV.UK](https://www.gov.uk/government/publications/court-of-appeal-cases-fixed-for-hearing-criminal-division) - [Decision (Permission to Appeal) [AP]](https://www.scotcourts.gov.uk/media/mvrbjkiw/upper-tribunal-decision-bell-v-slc-2026ut38.pdf) - [The Criminal Procedure Rules 2025](https://www.legislation.gov.uk/uksi/2025/909) - [https://www.gov.uk/planning-inspectorate Appeal Decision](https://acp.planninginspectorate.gov.uk/ViewDocument.aspx?fileid=65099248) - [Consultation Paper 268 Criminal Appeals A consultation paper](https://cdn.websitebuilder.service.justice.gov.uk/uploads/sites/54/2025/02/Criminal-Appeals-Consultation-Paper-1.pdf) - [DB v 1) Lancashire & South Cumbria NHS Foundation Trust 2) Secretary of State for Justice: [2026] UKUT 28 (AAC) - GOV.UK](https://www.gov.uk/administrative-appeals-tribunal-decisions/db-v-1-lancashire-and-south-cumbria-nhs-foundation-trust-2-secretary-of-state-for-justice-2026-ukut-28-aac) - [Bitcoin-Backed Municipal Bond Earns Ba2 Rating From Moody’s - Bloomberg](https://www.bloomberg.com/news/articles/2026-03-31/bitcoin-backed-municipal-bond-clears-hurdle-with-moody-s-rating) - [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 Trump Establishes First US Bitcoin Reserve - Bloomberg](https://www.bloomberg.com/news/videos/2025-03-10/trump-establishes-first-us-bitcoin-reserve) - [Crypto Regulatory Affairs: New York state passes Bitcoin mining moratorium](https://www.elliptic.co/blog/crypto-regulatory-affairs-new-york-state-passes-bitcoin-mining-moratorium) - [New Jersey Governor Race: NJ Democratic Hopefuls Warm Up to Crypto - Bloomberg](https://www.bloomberg.com/news/articles/2025-05-07/new-jersey-democrats-warm-up-to-crypto-in-crowded-governor-s-race) - [Trump administration curbs state oversight of crypto industry - ICIJ](https://www.icij.org/investigations/coin-laundry/trump-administration-curbs-state-oversight-of-crypto-industry/) - [Whether a Company that Provides Online Real-Time Deposit, Settlement, and Payment Services for Banks, Businesses and Consumers is a Money Transmitter rather | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/whether-company-provides-online-real-time) - [Money Services Business (MSB) Registration | FinCEN.gov](https://www.fincen.gov/money-services-business-msb-registration) - [Virtual Asset Service Provider (VASP): Definition, Compliance & Examples](https://www.trmlabs.com/glossary/virtual-asset-service-provider-vasp) - [MONEY TRANSMITTER REGULATORS ASSOCIATION](https://www.fincen.gov/sites/default/files/shared/money_transmitters_regulators.pdf) - [Am I an MSB? | FinCEN.gov](https://www.fincen.gov/am-i-msb) - [MONEY TRANSMITTER REGULATORS ASSOCIATION](https://www.fincen.gov/system/files/shared/money_transmitters_regulators.pdf) - [Money Services Business (MSB) Registration | FinCEN.gov](https://www.fincen.gov/resources/money-services-business-msb-registration) - [The National Money Transmitters Association, Inc.](https://www.fincen.gov/sites/default/files/shared/national_money_transmitters.pdf) - [As crypto industry expands, US slashes office examining dirty money safeguards of cryptocurrency exchanges - ICIJ](https://www.icij.org/investigations/coin-laundry/as-crypto-industry-expands-u-s-slashes-office-examining-dirty-money-safeguards-of-cryptocurrency-exchanges/) - [Law enforcement, banks warn of money laundering gaps in major US crypto bill - ICIJ](https://www.icij.org/investigations/coin-laundry/law-enforcement-banks-warn-of-money-laundering-gaps-in-major-us-crypto-bill/) - [From trading bans to total embrace, a global guide to crypto regulation](https://www.icij.org/investigations/coin-laundry/cryptocurrency-regulations-global-explainer/) - [cryptocurrency Archives - ICIJ](https://www.icij.org/tags/cryptocurrency/) - [Latest News from ICIJ | The Global Muckraker](https://www.icij.org/category/inside-icij/) - [Politics Archives - ICIJ](https://www.icij.org/tags/politics/) - [Crypto giants moved billions linked to money launderers, drug traffickers and North Korean hackers](https://www.icij.org/investigations/coin-laundry/cryptocurrency-exchanges-binance-okx-money-laundering-crime/) - [The Coin Laundry, a global cryptocurrency investigation](https://www.icij.org/investigations/coin-laundry/) - [The Coin Laundry Archives - ICIJ](https://www.icij.org/tags/coin-laundry/) - [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-Appointed Group Urges Regulators to Clarify Crypto Trading Rules - Bloomberg](https://www.bloomberg.com/news/articles/2025-07-30/trump-crypto-group-unveils-proposals-to-boost-digital-finance) - [Crypto regulatory affairs: US Congress starts work on stablecoin and digital asset legislation](https://www.elliptic.co/blog/crypto-regulatory-affairs-us-congress-starts-work-on-stablecoin-digital-asset-legislation) - [1 BILLING CODE: 4810-02 DEPARTMENT OF THE TREASURY](https://www.fincen.gov/system/files/shared/Order_Bitzlato_FINAL%20508.pdf) - [Ian Freeman Sentenced to Eight Years In Bitcoin Money Laundering Scheme In “Church of the Invisible Hand” Case | TRM Labs](https://www.trmlabs.com/resources/blog/ian-freeman-sentenced-to-eight-years-in-prison-for-running-bitcoin-money-laundering-scheme-in-church-of-the-invisible-hand-case?scLang=en) - [U.S. Department of the Treasury / Office of Foreign Assets Control](https://ofac.treasury.gov/media/31316/download?inline=) - [Financial Crimes Enforcement Network (FinCEN)](https://www.fincen.gov/system/files/2025-08/FinCEN-Notice-CVCKIOSK.pdf) - [U.S. Department of the Treasury / Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/enforcement-actions) - [TRM Labs](https://www.trmlabs.com/resources/blog/ian-freeman-sentenced-to-eight-years-in-prison-for-running-bitcoin-money-laundering-scheme-in-church-of-the-invisible-hand-case) - [International Consortium of Investigative Journalists (ICIJ)](https://www.icij.org/investigations/coin-laundry/as-crypto-industry-expands-u-s-slashes-office-examining-dirty-money-safeguards-of-cryptocurrency-exchanges/) - [Chainalysis](https://www.chainalysis.com/blog/bitcoin-strategic-reserves/) - [Bloomberg](https://www.bloomberg.com/news/articles/2026-03-31/bitcoin-backed-municipal-bond-clears-hurdle-with-moody-s-rating) Coverage gaps fim-int-2026-07-07-G001: No newly-initiated NH-specific stat… fim-int-2026-07-07-G001: No newly-initiated NH-specific state-level enforcement action independent of national advisories was identified within the 18-month window beyond the July 2025 appellate affirmation of the Freeman conviction; additional NH-specific docket monitoring would clarify whether this reflects genuinely reduced activity or thinner public reporting. [resolved] fim-int-2026-07-07-G002: No evidence of any 2026 New Hampshi… fim-int-2026-07-07-G002: No evidence of any 2026 New Hampshire legislative-session bill addressing crypto-ATM consumer protection was located; tracking NH General Court bill introductions would resolve whether the state intends to close this statutory gap. [resolved] fim-int-2026-07-07-G003: FY2026 IRS BSA/AML examiner headcou… fim-int-2026-07-07-G003: FY2026 IRS BSA/AML examiner headcount data is not yet available; obtaining it would clarify whether the FY2025 33% capacity reduction is a one-off adjustment or a continuing trend affecting NH-dependent federal oversight. [resolved] fim-int-2026-07-07-G004: No NH State Treasurer disclosure or… fim-int-2026-07-07-G004: No NH State Treasurer disclosure or procurement documentation describing AML-provenance or custody screening procedures for state-acquired bitcoin was located; Treasurer filings or audit reports would materially improve confidence on the Strategic Bitcoin Reserve provenance-control horizon item. [resolved] fim-int-2026-07-14-G001: No independently verified EU AMLR/6… fim-int-2026-07-14-G001: No independently verified EU AMLR/6AMLD transposition or AMLA supervisory-perimeter development this cycle; T1 primary EU sources not retrieved. [resolved] fim-int-2026-07-14-G002: No conflict-finance domain developm… fim-int-2026-07-14-G002: No conflict-finance domain development identified or sourced this cycle. [resolved] fim-int-2026-07-14-G003: Global beneficial-ownership registr… fim-int-2026-07-14-G003: Global beneficial-ownership registry effectiveness data not independently verified this cycle. [resolved] fim-int-2026-07-14-G004: UK ECCTA2023 'large organisation' t… fim-int-2026-07-14-G004: UK ECCTA2023 'large organisation' threshold scope and updated SFO/FCA guidance not reconfirmed this cycle. [resolved] fim-int-2026-10-04-G001: No T1 Federal Register NPRM text fo… fim-int-2026-10-04-G001: No T1 Federal Register NPRM text for the FinCEN AML/CFT program-rule reform was retrieved this cycle; confidence capped at Probable pending primary-source retrieval. [open] fim-int-2026-10-04-G002: NH-specific SAR/CTR volume and FIU-… fim-int-2026-10-04-G002: NH-specific SAR/CTR volume and FIU-coordination data were not located this cycle. [open] fim-int-2026-10-04-G003: Tier D watch jurisdictions (KH, LA,… fim-int-2026-10-04-G003: Tier D watch jurisdictions (KH, LA, MX, CO) were not independently searched this cycle given the US-NH union dispatch allocation. [open] fim-int-2026-10-25-G001: Tier D jurisdiction collection (Cam… fim-int-2026-10-25-G001: Tier D jurisdiction collection (Cambodia, Laos, Mexico, Colombia) was not performed this cycle because this research run was dispatched single-JID to US-NH only. [open] fim-int-2026-10-25-G002: D1 (Sanctions), D2 (Beneficial Owne… fim-int-2026-10-25-G002: D1 (Sanctions), D2 (Beneficial Ownership), D4 (Conflict Finance), and D6 (Compliance Technology) carry thin coverage for US-NH this cycle; no NH-specific signal was found or sought beyond a confirmation of no change. [open] FIM-GAP-001 (D3): Despite New Hampshire's landmark unlicense… FIM-GAP-001 (D3): Despite New Hampshire's landmark unlicensed-MSB prosecution (Ian Freeman), no newly-dated, NH-specific federal or state enforcement action was identified within the strict 18-month baseline window (Jan 2025–Jul 2026); available NH-nexus material consists predominantly of national-scope advisories/policy shifts with NH relevance rather than fresh state-specific actions. FIM-GAP-002 (D5): New Hampshire has not enacted a crypto-ATM… FIM-GAP-002 (D5): New Hampshire has not enacted a crypto-ATM-specific consumer-protection or fraud-prevention statute, unlike at least 18 U.S. states (including neighboring Massachusetts) that had done so by September 2025; this leaves the elder-fraud cash-to-crypto vector addressed only through general fraud/MSB law and federal advisories rather than kiosk-specific transaction limits or ID-verification mandates. FIM-GAP-003 (D6): National IRS AML examiner capacity assigne… FIM-GAP-003 (D6): National IRS AML examiner capacity assigned to MSB/crypto-firm oversight fell 33 percent in FY2025, thinning the federal supervisory layer that NH — lacking its own dedicated crypto-AML examination unit — relies upon most heavily given its history as the situs of a major unlicensed-MSB laundering scheme. FIM-GAP-004 (D1): New Hampshire, as a U.S. state, has no aut… FIM-GAP-004 (D1): New Hampshire, as a U.S. state, has no autonomous sanctions-designation authority; all sanctions listings/delistings applicable to NH-regulated entities flow uniformly from OFAC at the federal level. The sanctions_change_register above therefore reflects national OFAC actions applicable to NH via the state's standing OFAC/NH Banking Department information-sharing MOU rather than any NH-originated sanctions action. ## Evidence #### Confidence-tiered claims The main NH law applicable to money transmitters is RSA 399-G [[Source 1]](#sec-sources) Probable · 1 source Licensees must create and implement plans to comply with the Bank Secrecy Act [[Source 1]](#sec-sources) Probable · 1 source A 'fundamental' reform of AML/CFT program requirements under the Bank Secrecy Act, covering banks, casinos/card clubs and MSBs [[Source 1]](#sec-sources) Probable · 1 source All AML programs would be required to include countering the financing of terrorism (CFT) [[Source 1]](#sec-sources) Probable · 1 source 2025 order to show cause against BAM Trading Services Inc. tied to controlling-person BSA/AML compliance failures [[Source 1]](#sec-sources) Probable · 1 source $2,000/day per-customer cap, 48-hour hold with refund right on first transaction, mandatory ID verification, fraud-risk warnings, blockchain-analytics wallet screening on digital asset transaction kiosks [[Source 1]](#sec-sources) Probable · 1 source Node operators, miners (home and business digital-asset mining), and stakers are exempt from RSA 399-G money-transmitter licensing under new RSA chapter 359-V; a parallel exemption from RSA 421-B securities treatment also applies to mining/staking with personal funds [[Source 1]](#sec-sources) Probable · 1 source HB 1207 (signed 10 July 2026) grants the NH Banking Department new powers effective 1 October 2026: requiring translated books/records and an interpreter at licensee expense (RSA 399-G:6, para. V), and a new certificate-of-authority posting duty for delegate locations (RSA 399-G:10, para. VIII) [[Source 1]](#sec-sources) Probable · 1 source