--- title: "United States — New Jersey (US-NJ) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/united-states-new-jersey/ source_html: /jurisdictions/united-states-new-jersey/index.html description: "Financial integrity intelligence for United States – New Jersey (US-NJ): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: c41608e65e01b4cb1157020f32ed0ae20aa8802678358284048b010c36972b58 generator: "fe-fleet/md-twin@1.0" --- # United States — New Jersey (US-NJ) — 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 Jersey US-NJ Domains covered 8 of 8 Sources 168 Role actions 8 Horizon <90d 0 Jurisdiction profile FATF status: Compliant Tier: B Risk direction: Increasing Enablement vs enforcement: Mixed NJ-chartered and federally chartered banks, money transmitters, and casinos operate under the federal Bank Secrecy Act/FinCEN framework, layered with the NJ Department of Banking and Insurance (bank/MSB licensing), NJ Division of Gaming Enforcement (Atlantic City casino AML), and NJ Bureau of Securities (crypto/securities fraud). More NJ hosts TD Bank's principal US retail operation, Port Newark-Elizabeth (East Coast's largest container port), and sits inside the NYC financial corridor. Key deficiencies - Multi-year, multi-trillion-dollar transaction-monitoring coverage gaps at TD Bank's NJ-anchored US retail operation went undetected for years - NJ counties historically excluded from FinCEN's Residential Real Estate GTOs despite direct proximity to the NYC luxury real estate corridor - Proliferation of loosely-supervised crypto ATM kiosks implicated in elder-fraud and pig-butchering schemes, per NJ's own 2021 Commission of Investigation findings - Federal CTA domestic-entity exemption (March 2025) sharply reduces beneficial-ownership visibility into NJ-registered shell companies Recent developments (18m) - TD Bank, N.A. and TD Bank USA, N.A. entered guilty pleas before a federal judge in Newark, NJ (Oct. 2024) as part of a $3.1B coordinated federal resolution; monitorship and remediation continued through 2025-2026 and the USAO-NJ investigation was recognized in FinCEN's June 2026 Law Enforcement Awards - FinCEN's March 2025 interim final rule exempted nearly all US-formed 'domestic reporting companies' from CTA beneficial ownership reporting - FinCEN issued an April 2026 NPRM proposing to fundamentally reform BSA AML/CFT program requirements - FinCEN's nationwide Residential Real Estate AML rule took effect March 1, 2026, extending shell-company reporting to jurisdictions (including NJ) never covered by the prior GTOs - OFAC/FinCEN maintained a maximum-pressure Iran sanctions posture (NSPM-2, Feb. 2025) elevating correspondent-banking due-diligence burdens on NJ-based financial institutions United States federal law that applies in United States – New Jersey is covered once, on the [United States](/jurisdictions/us/) page. This page covers United States – New Jersey’s own layer: its own law, regulators and enforcement. Brief ## Lead signal #### Lead Signal The architecture of global sanctions enforcement moved on two fronts this cycle, while the bound jurisdiction of New Jersey registered only an episodic, enforcement-side footnote with no anti-money-laundering nexus of its own. At its first Plenary under the UK Presidency, the Financial Action Task Force removed Bulgaria, Cote d'Ivoire, the Democratic Republic of Congo and Monaco from its list of jurisdictions under increased monitoring, shrinking that list from twenty-two to eighteen while leaving the smaller list reserved for a call for action unchanged. Separately, the United States Treasury's Office of Foreign Assets Control pressed Operation Economic Outcast further into Iran's economy, reaching the automotive and rail sectors under Executive Order 13902 with a presumption-of-denial licensing posture, then reinforcing that move on 21 October with designations against legal, maritime and shipping facilitators alleged to be enabling Iranian sanctions evasion. Read full brief #### Lead Signal The architecture of global sanctions enforcement moved on two fronts this cycle, while the bound jurisdiction of New Jersey registered only an episodic, enforcement-side footnote with no anti-money-laundering nexus of its own. At its first Plenary under the UK Presidency, the Financial Action Task Force removed Bulgaria, Cote d'Ivoire, the Democratic Republic of Congo and Monaco from its list of jurisdictions under increased monitoring, shrinking that list from twenty-two to eighteen while leaving the smaller list reserved for a call for action unchanged. Separately, the United States Treasury's Office of Foreign Assets Control pressed Operation Economic Outcast further into Iran's economy, reaching the automotive and rail sectors under Executive Order 13902 with a presumption-of-denial licensing posture, then reinforcing that move on 21 October with designations against legal, maritime and shipping facilitators alleged to be enabling Iranian sanctions evasion. Neither movement originates in or is driven by New Jersey. The state's only jurisdiction-specific development this cycle was a civil-enforcement action in its regulated gaming sector, filed here for its relevance to enforcement architecture rather than for any demonstrated anti-money-laundering dimension. #### Other Developments A gaming-sector penalty with no laundering nexus established. New Jersey's Division of Gaming Enforcement ordered a civil penalty of $78,000 plus disgorgement of $306.48 against Penn Sports Interactive (operating as theScore Bet) for accepting unauthorized wagers under the state's sports-wagering regulations. The action sits within the state's existing casino and sports-wagering compliance architecture, which separately carries currency-transaction-reporting obligations for transactions aggregating $200,000 or more; the Division's rules require filing a copy of any currency transaction report with the Director. Nothing in the sourcing for this cycle connects the wagering penalty to those reporting obligations, and the claim is recorded as probable rather than confirmed. OFAC closed a sanctions-and-reporting matter with a logistics firm. Pegasus Worldwide Logistics reached a $175,015 settlement with the Office of Foreign Assets Control over potential violations involving blocked property and the firm's response to an OFAC subpoena. This is a federal action with no stated New Jersey nexus, but it is recorded here as part of the same enforcement architecture against which the state's own obliged entities operate. Two delistings trimmed the Specially Designated Nationals list. On 21 October, OFAC removed two individuals and two entities, together with associated naming variations, from the list under the Belarus and North Korea sanctions programs. The removals are a routine maintenance action within the broader designation architecture rather than a policy reversal. #### Cross-Monitor Connections The Iran-sector escalation under Operation Economic Outcast, and the associated disruption of an Iran-linked digital-asset exchange reported elsewhere this cycle, both sit at the intersection of sanctions enforcement and conflict-finance tracking: petroleum-payment flows routed through digital rails are the kind of channel that connects a sanctions monitor's designation activity to a conflict-finance monitor's interest in revenue capture by a sanctioned state. For New Jersey specifically, the absence of any state adoption of the multistate money-transmission modernization framework, combined with its continued regulation of virtual-currency businesses under the pre-existing Money Transmitters Act, means that any future digital-asset enforcement nexus in the state would likely run through money-transmission licensing and reporting channels rather than through a bespoke virtual-currency regime. That structural posture is worth flagging for monitors tracking compliance-technology adoption and digital-asset regulatory divergence across states, even though no New Jersey-specific digital-asset development occurred this cycle. #### Outlook The FATF grey-list contraction is a durable structural signal: a list that moved from twenty-two to eighteen jurisdictions under a new presidency sets an early marker for how the current leadership intends to manage the monitoring process, and the four removed jurisdictions (Bulgaria, Cote d'Ivoire, the DRC and Monaco) will likely see reduced enhanced-due-diligence friction from obliged entities globally once the removal is reflected in institutional risk ratings. The Iran-sector escalation under Operation Economic Outcast appears likely to continue; the sequencing from sector determinations to designations against facilitators is consistent with an architecture built for sustained pressure rather than a single action. For New Jersey, no state-specific AML or sanctions-regime development is in view at this time; the gaming-sector penalty and its surrounding currency-transaction-reporting architecture remain the only local thread, and whether it develops a laundering dimension will depend on sourcing not yet available. Earlier periodic briefs (3) 28 Sep 2026 · fim-2026-09-28 #### Lead Signal New Jersey's financial-crime-adjacent regulatory picture this cycle centres on a pending state-level licensing instrument for digital-asset businesses, the Digital Asset and Blockchain Technology Act (A3454/S1304). The bill would create a dedicated licensing and registration perimeter for digital-asset businesses operating in or directed at New Jersey, but the administering authority is disputed: the bill's own text names the Bureau of Securities in the Division of Consumer Affairs, while a secondary source (Bates Group) instead attributes administration to the Department of Banking and Insurance. This is not yet resolved, and the Act is not yet in force. #### Other Developments Existing obliged-entity layer confirmed stable. New Jersey's current AML/CFT-adjacent obliged-entity framework runs through the Money Transmitters Act, N.J.S.A. 17:15C-1 et seq., implemented via N.J.A.C. 3:27 and administered by the Department of Banking and Insurance. This layer was readopted with only technical changes this cycle, with an expiration date of 2030, and remains the sole state-level licensing structure for money transmitters absent a bespoke New Jersey AML statute. Money transmitters operating in the state are separately expected to register with FinCEN as Money Services Businesses in parallel with state licensure, under the federal Bank Secrecy Act framework. Effective-date structure of the pending Act. The pending Digital Asset and Blockchain Technology Act sets an effective date of the 25th month following enactment for its core licensing section, meaning that even if the bill were enacted promptly, the operative licensing requirement would not bind digital-asset businesses for more than two years afterward. #### Cross-Monitor Connections The administering-authority dispute in the pending Digital Asset and Blockchain Technology Act is a live overlap point with both the world-payments monitor, which tracks the same instrument under its W1a licensing spine, and the crypto monitor, which tracks the same pending licensing perimeter under its crypto_licensing module. All three monitors are observing the identical unresolved administrative question from their respective institutional lenses, and resolution of the dispute -- whether toward the Bureau of Securities or the Department of Banking and Insurance -- will shape how digital-asset businesses in New Jersey are supervised across the payments, crypto, and financial-integrity domains alike. #### Outlook The central open question for New Jersey's financial-integrity exposure in the digital-asset space is which authority will administer the pending Act if and when it is enacted, and what that resolution implies for the alignment (or divergence) between digital-asset licensing and the existing money-transmitter AML/CFT framework. Given the bill's own effective-date structure -- 25 months after enactment for the core licensing section -- this is a multi-year horizon item rather than an immediate compliance deadline. In the interim, the Money Transmitters Act and its N.J.A.C. 3:27 implementing rules remain the sole binding obliged-entity layer applicable to money-services and digital-asset activity in the state. 3 Sep 2026 · fim-2026-08-05 #### Lead Signal FinCEN's April 2026 Notice of Proposed Rulemaking proposing to reform Bank Secrecy Act AML/CFT program requirements on an effectiveness basis marks the most significant compliance-architecture development this cycle. Issued jointly with prudential regulators and superseding a July 2024 proposed rule, the NPRM would require financial institutions — including casinos and card clubs regulated under 31 CFR Part 1021 — to demonstrate documented, board-approved, effectiveness-based governance rather than the presence of checklist program components. The shift is architectural rather than incident-driven: it changes what a compliant program must prove, not merely what a single institution failed to do, and its reach extends across banks, money-services businesses, and gambling-sector licensees alike. This cycle's most significant US AML compliance-architecture shift is assessed as running directly into gambling-sector obligations, given the NPRM's explicit coverage of casinos and card clubs alongside banks and money-services businesses. The NPRM's gambling-sector reach is notable given a parallel and more narrowly incident-driven finding this cycle: FinCEN determined ten Mexico-based gambling establishments to be of primary money-laundering concern for facilitating payments benefiting senior Sinaloa Cartel members. Read together, the two developments illustrate the three-pillar balance this analysis aims to preserve — a structural governance reform running alongside a discrete enforcement determination in the same sector, each reinforcing the case that gambling-adjacent financial infrastructure remains an active laundering interface warranting the heavier compliance standard the NPRM proposes. #### Other Developments Beneficial-ownership scope narrows domestically. The Corporate Transparency Act's beneficial-ownership-information reporting regime now exempts all US-created entities, leaving only foreign reporting companies in scope; a Government Accountability Office assessment found this change eliminates more than ninety-nine percent of previously-covered entities from the reporting requirement, even as the Eleventh Circuit separately affirmed the CTA's underlying constitutionality. Cambodia enforcement outpaces delivered outcomes. The Office of Foreign Assets Control designated twenty-nine Cambodia-linked targets, including a sitting senator whose casino empire hosted scam compounds, but independent monitoring found more than seventy percent of identified scam compounds still bypassed by the domestic crackdown. Mexico's cartel-finance corridor draws dual designations. A CJNG fuel-smuggling and tax-evasion scheme generating hundreds of millions of dollars annually drew a supplemental FinCEN alert and OFAC designations against two nationals and nine entities, layered atop the separate ten-establishment gambling determination above. Conflict-gold enforcement targets the refining interface. The Office of Foreign Assets Control designated Gasabo Gold Refinery and affiliated Rwandan mining companies for laundering M23/RDF conflict gold from eastern Democratic Republic of Congo, while the European Council imposed a sectoral ban on Sudanese gold purchase, import and transfer alongside an export ban on mercury and cyanide used in gold mining. Both actions target the trading and refining interface itself rather than only armed groups, a maturing enforcement philosophy assessed with high confidence, though smuggling-route resilience will likely blunt near-term impact. Iran-Hizballah shipping network sanctioned. The Economic Fury campaign designated more than two dozen individuals, entities and vessels connected to Iranian oil-smuggling and Hizballah-linked gold financing, using a complex web of owners, operators, managers and ship-management companies to obscure beneficial ownership across flag-of-convenience jurisdictions; this finding rests on secondary reporting only this cycle, with the primary Treasury release not directly fetched. FATF grey list shifts. The June 2026 plenary added Iraq and Bosnia and Herzegovina to the grey list and removed Namibia and Algeria, while Russia's FATF suspension continues to stand. UAE issues trade-based-laundering guidance. The UAE Central Bank issued dedicated supervisory guidance on trade-based money laundering and transshipment risk for banks, exchange houses and hawala providers, effective April 2026, though no direct primary-source URL was retrieved for this development this cycle. #### Cross-Monitor Connections The Cambodia and Mexico findings both connect directly to gambling-sector infrastructure functioning as a laundering interface, a theme with direct relevance to any gambling-regulatory monitoring of casino and card-club licensees under the same 31 CFR Part 1021 perimeter that FinCEN's NPRM would tighten. The Rwanda and Sudan conflict-gold actions connect to commodity-flow and extractive-industry monitoring, where the targeting of refining and trading interfaces rather than only armed groups mirrors a pattern worth tracking against other conflict-commodity corridors. The Economic Fury campaign's layered flag-of-convenience shipping structures connect to broader sanctions-evasion-architecture monitoring of vessel ownership obfuscation, a persistent vector across Iranian oil-smuggling and other sanctioned-trade routes. #### Outlook FinCEN's NPRM comment period closed June 9, 2026, and the rule is not expected to take effect before 2027 at the earliest; the practical compliance-lift for casino and card-club licensees will depend on the final rule's governance-documentation specifics. Cambodia's enforcement-delivery gap and Mexico's dual gambling/cartel-finance designations both warrant continued monitoring for whether announced sanctions translate into operational disruption or remain largely declaratory. The FATF grey-list additions of Iraq and Bosnia and Herzegovina will shape correspondent-banking risk-appetite decisions for institutions with exposure to those corridors in the coming cycle. 14 Jul 2026 · fim-2026-07-14 #### Lead Signal The defining architecture-level finding this cycle emerges from New Jersey but resonates across the US federal AML system: a systemically significant regional bank, TD Bank, N.A. and TD Bank USA, N.A., entered guilty pleas as part of a coordinated federal resolution assessed at 1.3 billion dollars in FinCEN civil money penalties within a 3.1 billion dollar multi-agency total, corrected in this cycle to its accurate 2024-10-10 dating rather than a previously conflated 2026-06-19 reference point. The corrected record shows that approximately 18.3 trillion dollars in transaction activity, some 92 percent of total volume, went unmonitored between January 2018 and April 2024 because vendor transaction-monitoring scenarios were left unmodified. This is not an isolated processing failure; it is a structural control gap that functioned, for four years, as laundering infrastructure at national scale, complete with complicit insiders opening accounts for shell companies and money mules. The OCC and Federal Reserve responded with asset-growth restrictions and a mandated overhaul of AML transaction-monitoring technology, placing the bank under continuing independent monitorship. The TD Bank correction sits alongside a second architecture-level story: US beneficial-ownership visibility contracted sharply this period. FinCEN's interim final rule exempting domestic reporting companies from Corporate Transparency Act reporting remains in force, and the nationwide Residential Real Estate Rule intended to close a parallel real-estate blind spot was vacated by a federal district court just eighteen days after taking effect. Read together, the enforcement action and the transparency rollback describe a financial system where detection capacity at the transaction-monitoring layer and visibility capacity at the ownership layer are both under structural strain simultaneously. #### Other Developments Sanctions-regime divergence widens. OFAC's designation of Lukoil on 2025-10-22, paired with a General License 131 wind-down series for Lukoil International GmbH's non-Russian assets, was not mirrored by the EU or UK on equivalent terms at the same date. The same divergence pattern appears in the comprehensive termination of US Syria sanctions effective 2025-07-01, where FinCEN issued exceptive relief permitting correspondent accounts for the Commercial Bank of Syria while EU and UK relaxation proceeded on differing timelines and scope. A third data point, National Security Presidential Memorandum-2, sustains a US Iran maximum-pressure posture beyond parallel EU and UK measures, elevating correspondent-banking due-diligence burdens specifically for US institutions. Crypto oversight backstops contract while kiosk infrastructure persists. Unlicensed convertible virtual currency kiosks continue to convert victim cash into bitcoin and USDT within minutes, routing funds to overseas scam-compound wallets while bypassing bank-grade KYC, a pattern FinCEN's August 2025 advisory nationally cited against a state commission-of-investigation report from 2021. Concurrently, the Department of Justice's April 2025 policy memorandum disbanded the National Cryptocurrency Enforcement Team and deprioritised BSA-only violations, and separate reporting describes federal preemption reducing state regulators' oversight authority over crypto firms. A joint FinCEN/OFAC rulemaking proposing AML and sanctions obligations for permitted payment stablecoin issuers under the GENIUS Act remains pending, with finalisation expected in the fourth quarter of 2026. A network-finance and clemency countervailing signal. Chinese money laundering networks operate a cash-pickup-to-bank-check pipeline that collects bulk cash from cartel-linked proceeds across multiple states, converts it to official bank checks to sever the audit trail, and transfers value to China via informal systems, with 7.1 billion dollars in suspected related suspicious activity documented nationally. Separately, a defendant prosecuted for a 200 million dollar-plus Ponzi scheme received presidential clemency in 2025 and was subsequently reported to have resumed fraudulent solicitation, illustrating how executive clemency power can neutralise the deterrent value of a successful prosecution independent of prosecutorial rigour. Compliance-technology reform proposed. FinCEN issued an NPRM in April 2026 proposing a fundamental reform of BSA AML/CFT program requirements, covering risk-assessment methodology, board approval, and location requirements for compliance officers; the comment period closed in June 2026 with the final rule outcome still pending. #### Cross-Monitor Connections The clemency dynamic affecting the Ponzi-fraud prosecution is assessed as state-capture-adjacent and warrants WDM cross-reference: executive power exercised to neutralise a completed financial-crime prosecution operates independently of, and potentially counter to, institutional enforcement rigour. Separately, the Lukoil designation and the Syria sanctions termination, each diverging from EU and UK timing, function as sanctions-as-macro-variable inputs relevant to GMM's cross-jurisdictional regime-divergence tracking. Both flags describe architecture rather than incident: one concerns the durability of prosecutorial deterrence under executive discretion, the other concerns the compliance-timing costs imposed on multinational institutions operating across divergent sanctions regimes. #### Outlook Three pending items will determine whether this cycle's deterioration deepens or partially corrects. The FinCEN BSA AML/CFT program rule, if finalised, would reset baseline compliance expectations industry-wide but its outcome remains genuinely uncertain. The GENIUS Act stablecoin AML/sanctions rule is expected to finalise in the fourth quarter of 2026 and would newly bind stablecoin issuers and correspondent banks. The Residential Real Estate Rule's vacatur is under appeal, and its outcome will determine whether the intended remedy for New Jersey's historic real-estate beneficial-ownership blind spot is restored or remains suspended. The next FATF plenary in October 2026 is a watch event for possible commentary on the broader US AML deregulatory trajectory evident in the CTA exemption and the proposed BSA program reform. Domain intelligence (D1–D8) #### Sanctions Two distinct movements define the sanctions architecture this cycle: a contraction of the Financial Action Task Force's list of jurisdictions under increased monitoring, and a deepening of United States sectoral pressure on Iran. At its inaugural Plenary under the UK Presidency, the FATF removed Bulgaria, Cote d'Ivoire, the Democratic Republic of Congo and Monaco from the increased-monitoring list, taking it from twenty-two to eighteen jurisdictions while leaving the smaller call-for-action list unchanged. This is properly read as increased monitoring falling away for those four jurisdictions, not as a sanctions action in itself, and it should not be conflated with the separate, harder designations discussed below. Obliged entities applying enhanced due diligence keyed to that list will need to update their screening posture to reflect the narrower set of eighteen. Continue reading Separately, the Office of Foreign Assets Control pressed Operation Economic Outcast further into the Iranian economy. On 1 October, OFAC announced sector determinations reaching Iran's automotive and rail sectors under Executive Order 13902, carrying a presumption-of-denial licensing posture for transactions touching those sectors. On 21 October, OFAC reinforced that action with designations targeting legal, maritime and shipping facilitators alleged to be assisting Iran's sanctions evasion, a sequencing that moves from sector-level determination to facilitator-level designation and is properly read as a comprehensive-sanctions-style architecture continuing to deepen rather than a single incident. Separately, OFAC closed a $175,015 settlement with Pegasus Worldwide Logistics over potential violations involving blocked property and the firm's response to an OFAC subpoena, and removed two individuals and two entities, with associated naming variations, from the Specially Designated Nationals list under the Belarus and North Korea programs on the same day as the facilitator designations. The delistings are routine list maintenance rather than a change in policy direction. For New Jersey, no state-specific sanctions development surfaced this cycle. The one state-level finding identified in the state's financial-integrity perimeter this cycle was a civil penalty against a licensed sports-wagering operator for accepting unauthorized wagers, filed for its relevance to the state's enforcement architecture rather than for any demonstrated sanctions or anti-money-laundering dimension; it is noted here only because the gaming sector's parallel currency-transaction-reporting obligations (filing with the Division of Gaming Enforcement for transactions aggregating $200,000 or more) sit within the same regulatory perimeter the sanctions-screening function would eventually touch, should a nexus emerge. #### Outlook The near-term question for the FATF list is whether the new UK Presidency continues a pattern of net removals at subsequent plenaries or whether additions offset this cycle's contraction; obliged entities should expect periodic recalibration of enhanced-due-diligence scope rather than a one-off event. For Iran, the sequencing observed this cycle, sector determination followed by facilitator designation, suggests the architecture is built for sustained pressure, and further designations reaching adjacent sectors or additional facilitator categories would be consistent with that trajectory, though this is not a prediction of specific future action. New Jersey's own exposure remains indirect: absent a demonstrated nexus between its gaming-sector enforcement activity and sanctions or laundering typologies, the state's sanctions-relevant posture continues to run through the federal Treasury and FinCEN framework rather than through any distinct state instrument. #### Beneficial Ownership and Corporate Transparency As a non-EEA jurisdiction, New Jersey and the wider United States sit outside the EU AML Package's direct regulatory perimeter; the AML Regulation, the sixth Anti-Money Laundering Directive, and the AMLA Regulation bind EU Member States and their obliged entities, not US federal or state registries. The directly relevant developments for US-NJ this cycle concern the domestic federal beneficial-ownership architecture, which contracted sharply. FinCEN's interim final rule, effective 2025-03-26, exempted nearly all US-formed domestic reporting companies from Corporate Transparency Act beneficial-ownership reporting, removing federal visibility into the numerically largest category of state-registered entities; only foreign-formed entities retain reporting obligations. This reverses a core plank of the 2021 AML Act's shell-company transparency reform for the largest category of entities registered in states including New Jersey. Continue reading A parallel contraction occurred in real estate. FinCEN's nationwide Residential Real Estate Rule took effect 2026-03-01, extending shell-company beneficial-ownership reporting to jurisdictions never previously covered by Geographic Targeting Orders, including New Jersey, which had never had a single county covered by the pre-2026 GTOs despite direct proximity to the New York City luxury real-estate corridor that New York GTOs did cover. This created a longstanding structural arbitrage incentive for illicit buyers to prefer New Jersey closings. The new rule's intended remedy, however, was vacated by the US District Court for the Eastern District of Texas on 2026-03-19, just eighteen days after taking effect; FinCEN and DOJ have appealed, but the vacatur remains in force, meaning reporting persons are not currently required to file Real Estate Reports. Globally, the EU AML Package sets the structural direction for beneficial-ownership transparency: it establishes the AML Regulation, Regulation (EU) 2024/1624, as a directly applicable instrument, the sixth AML Directive for per-Member-State transposition, and the AMLA Regulation, Regulation (EU) 2024/1620, establishing the Anti-Money Laundering Authority with a direct and indirect-supervision perimeter that shifts obliged-entity supervision from purely national authorities toward a hybrid EU-level regime. This durable architecture is the backdrop against which global beneficial-ownership reform trends are read, even though it does not itself bind US-NJ entities; its relevance to US-NJ is contextual, illustrating an alternative trajectory (centralising, expanding transparency) running counter to the domestic US trajectory (exempting, contracting) documented in this cycle. #### Outlook The Residential Real Estate Rule's appeal outcome is the single most consequential pending item for US-NJ beneficial-ownership visibility; until resolved, the rule's intended remedy for the New Jersey real-estate blind spot remains suspended. The CTA domestic-entity exemption shows no indication of reversal this cycle and should be treated as the durable baseline for the numerically largest category of NJ-registered entities. #### Enabler Jurisdictions and Professional Facilitators The defining D3 finding this cycle is a systemically significant bank's transaction-monitoring control failure functioning as national-scale laundering infrastructure. TD Bank's US retail operation ran transaction-monitoring systems with unmodified vendor scenarios that excluded approximately 18.3 trillion dollars, roughly 92 percent of total transaction volume, from screening between 2018 and 2024. Complicit insiders opened accounts for shell companies and money mules, and a single narcotics-linked customer laundered more than 400 million dollars via bulk cash deposits without adequate SAR or CTR filing. The corporate resolution, comprising guilty pleas and a coordinated 3.1 billion dollar multi-agency penalty including a 1.3 billion dollar FinCEN civil money penalty, was confirmed on 2024-10-10, a date this cycle corrects from an erroneous 2026-06-19 baseline reference that had conflated the enforcement resolution with a separate June 2026 FinCEN Law Enforcement Awards recognition of the underlying USAO-NJ investigation. Fifteen individual co-conspirators secured guilty pleas for money laundering and unlicensed money transmitting, with more than 7.5 million dollars in associated criminal penalties, though the exact individual plea dates remain unverified this cycle. Continue reading Applying the enabler-jurisdiction framework's four-dimension test, capacity versus choice is the central question: TD Bank possessed the resources to build adequate monitoring coverage and chose not to modify vendor scenarios for years, a choice-driven rather than capacity-constrained failure. The systemic significance dimension is high given the bank's scale and the multi-year duration of the coverage gap. A separate and countervailing D3 signal concerns executive clemency. A defendant prosecuted by USAO-NJ for a 200-million-dollar-plus Ponzi and investment fraud scheme received presidential clemency in 2025 and was subsequently reported to have resumed fraudulent solicitation activity. This illustrates a state-capture-adjacent dynamic distinct from the TD Bank finding: here the enforcement architecture functioned correctly through successful prosecution, but executive clemency power neutralised its deterrent value independent of prosecutorial rigour. This is a secondary-tier-sourced finding held at Assessed confidence. #### Outlook TD Bank's remediation programme under independent monitor oversight continues through 2026 and is the key indicator to track for whether the control-failure architecture is genuinely being rebuilt rather than only remediated on paper. The clemency-driven countervailing dynamic has no clear resolution path and is likely to remain a standing analytical caveat on the deterrent value of even successful district-level prosecutions. #### Conflict Finance and Extractive-Industry Integrity This cycle conflict-finance findings mark a shift toward targeting the refining and trading interface itself, rather than only the armed groups that generate conflict resources. OFAC designated the Gasabo Gold Refinery and affiliated Rwandan mining companies, Bugambira Mines, Wolfram Mining, and Rwinkwavu Mining, for laundering conflict gold smuggled from eastern Democratic Republic of Congo through Rwanda ahead of transport to major refining and processing countries. This is a High-confidence finding, resting on a direct Treasury/OFAC press release, and it follows the designation of the Rwanda Defence Force itself in March 2026 for supporting the M23 armed group, indicating that this action extends the sanctions architecture from the armed actor itself to the commercial refining infrastructure that monetises the resource it controls. The designation of specific named mining companies alongside the refinery indicates that this action also reaches into the upstream mining layer within Rwanda territory, suggesting the sanctioned architecture spans from extraction through refining within a single jurisdiction, which is analytically distinct from cases where extraction and refining occur in different jurisdictions and only one leg is reachable by a single sanctions authority. Continue reading In a parallel but independently sourced instrument, the EU Council imposed a ban on the purchase, import or transfer of gold originating in Sudan, alongside an export ban on mercury and cyanide used in gold mining. This is also a High-confidence finding, resting on a direct Council of the EU primary source, and it targets the financial architecture of the Sudan war economy at the sectoral rather than entity-specific level, a broader instrument than a designation against any single trader or refiner. The jurisdiction-risk tracker characterises the condition of Sudan as episodic rather than structural in enforcement terms, noting that impact is likely to be limited by smuggling-route resilience, while the condition of Rwanda is characterised as structural, reflecting the state-linked and mining-sector-embedded nature of the underlying laundering scheme. The analytical significance of these two instruments, taken together, is that they represent a maturing conflict-finance enforcement philosophy: rather than sanctioning only the armed group or its direct financiers, enforcement is now reaching backward into the refining and trading layer that provides access to formal or quasi-formal markets for resource extraction by armed groups. This is precisely the layer where conflict-derived commodities are laundered into ordinary commercial gold-trade flows and lose their traceable origin. Targeting this interface is a structurally more consequential intervention than targeting extraction alone, because it addresses the point at which illicit-origin material re-enters licit trade, though its practical effect depends heavily on whether alternative refining and trading routes are available to absorb the same material, the smuggling-route-resilience concern the jurisdiction-risk tracker flags for Sudan applies with comparable force to the Rwanda-transiting DRC gold trade. Both instruments are tagged to the CPF pillar within the three-pillar framework of this monitor, a useful corrective against the structural tendency for AML findings to dominate enforcement-volume-driven reporting; conflict-gold laundering through refining infrastructure is a proliferation-adjacent and conflict-finance risk that generates comparatively little routine enforcement volume relative to conventional AML casework, and the two High-confidence designations of this cycle are accordingly weighted appropriately rather than treated as secondary to the AML-labelled findings of this cycle. These findings are directly relevant to WDM state-capture tracking, given the Rwandan state-military complicity implicit in the joint Rwanda Defence Force and Gasabo Gold Refinery designations, and to SCEM conflict-finance tracking more broadly; both cross-references are carried in the cross-monitor flags of this cycle at Assessed and High confidence respectively. #### Outlook The key judgment for this domain, held at High confidence, is that conflict-finance enforcement is maturing toward targeting the refining and trading interface rather than only armed groups, though smuggling-route resilience will likely blunt near-term impact. Watch for whether additional refining or trading entities, in Rwanda or in other transit jurisdictions, are designated in coming cycles, which would indicate the architecture-level shift identified this cycle is being sustained rather than remaining a single instance; and whether the sectoral ban of the EU on Sudan generates measurable disruption to gold-trade flows or is substantially circumvented via the same smuggling-route resilience that has historically blunted commodity-specific sanctions in conflict-affected extractive sectors. A further variable is whether the twentieth Russia sanctions package of the EU, addressed separately in the sanctions-architecture domain of this monitor, establishes any precedent for sectoral commodity-trade restrictions that could inform future extractive-sector instruments beyond Sudan. #### Crypto / Digital Assets / Financial Innovation The one digital-asset development with a sanctions nexus this cycle occurred outside New Jersey: an Iran-linked digital-asset exchange was disrupted under Operation Economic Outcast for processing petroleum payments connected to the Strait of Hormuz, a development assessed at probable confidence given its sourcing. No New Jersey-specific crypto or digital-asset development was identified this cycle, and the state is therefore read here through its existing regulatory posture rather than through any new event. Continue reading New Jersey continues to regulate virtual-currency businesses under its pre-existing Money Transmitters Act rather than through a bespoke digital-asset licensing regime, and the state has not adopted the Conference of State Bank Supervisors' Money Transmission Modernization Act, whose adoption count rose to thirty-five states this cycle without New Jersey among them. That combination, continued reliance on the general money-transmission statute, no adoption of the multistate modernization framework, and legislative activity in the state Assembly and Senate directed at a standalone virtual-currency regulatory framework, means New Jersey's digital-asset perimeter remains narrower and less harmonized with other states than the multistate trend line, even as thirty-five other states converge on a common framework. Any enforcement nexus touching digital assets in New Jersey at this time would run through money-transmitter licensing, registration and reporting obligations rather than through a dedicated virtual-currency compliance regime. This is a structural observation about regulatory architecture, not a finding that New Jersey harbors elevated digital-asset risk relative to other states; the record for this cycle shows no enforcement action, no new rule, and no licensing development specific to the state's digital-asset sector. The federal settlement actions and sanctions delistings tracked elsewhere this cycle carry no New Jersey nexus either, and nothing in the sourcing available this cycle connects the Hormuz-related exchange disruption to any New Jersey-licensed or New Jersey-domiciled entity. #### Outlook The pending New Jersey legislation establishing a dedicated regulatory framework for virtual-currency businesses, if and when it advances, would close the gap between the state's current reliance on the general money-transmission statute and the more specific frameworks now adopted by a majority of states. Until that legislation moves, or until New Jersey elects to adopt the multistate modernization framework, the state's digital-asset businesses remain governed by the same licensing and anti-money-laundering program requirements, including a written program with know-your-customer procedures, that apply to money transmitters generally. Whether the Hormuz-related exchange disruption or the broader Iran-sector sanctions escalation produces any downstream effect on New Jersey-licensed money transmitters or virtual-currency businesses is not yet established in the available record and should be read as an open question rather than an expected development. #### Compliance Technology and Active Defence This cycle's D6 signal pairs a concrete, mandated remediation programme with a pending fundamental reform proposal. As part of the coordinated federal resolution against TD Bank confirmed on 2024-10-10, the OCC and Federal Reserve Board of Governors imposed asset-growth restrictions and mandated an overhaul of the bank's AML transaction-monitoring technology, with remediation proceeding under independent monitor oversight. This mandate is a direct response to the discovery that unmodified vendor monitoring scenarios had excluded approximately 18.3 trillion dollars, some 92 percent of transaction volume, from screening over a four-year period, and it represents the clearest instance this cycle of compliance-technology failure translating into a binding, multi-year remediation obligation. Continue reading Separately, and forward-looking rather than remedial, FinCEN issued an NPRM on 2026-04-07 proposing a fundamental reform of BSA AML/CFT program requirements, covering risk-assessment methodology, board-approval processes, and the location requirements for compliance officers. The comment period closed 2026-06-09 and the final-rule outcome remains pending, with impact expected around 2027. This proposal is directly relevant to the proactive-compliance thesis underlying D6: it would reset the baseline expectations for what an effective, rather than merely compliant, BSA AML programme looks like across the regulated population, independent of any single enforcement episode. The FinCEN awards-recognition event on 2026-06-19, in which the USAO-NJ investigation into TD Bank received recognition through FinCEN's 11th Law Enforcement Awards Program, is itself a genuine and separately dated event; it should not be read as a second enforcement action but as institutional recognition of the underlying investigative work, distinct from the 2024-10-10 corporate resolution. #### Outlook The TD Bank remediation programme is the concrete, near-term indicator of whether compliance-technology overhaul following a record enforcement action produces genuine detection-capacity improvement. The BSA AML/CFT Program Rule, by contrast, is the structural, sector-wide indicator to track; its currently pending and uncertain outcome will determine whether the effectiveness-oriented reset extends across the regulated population or remains confined to institutions under direct remediation mandates. NJ's AML/CFT obliged-entity layer is the Money Transmitters Act (N.J.S.A. 17:15C-1 et seq.), implemented via N.J.A.C. 3:27, administered by DOBI; no NJ-specific AML statute exists distinct from the federal BSA. No crypto/fintech/integrity-infrastructure commercial event identified for US-NJ this cycle. Regulatory horizon Proposed 2027-Q1 · ±multi_year ### NJ Digital Asset and Blockchain Technology Act (pending) Digital-asset businesses operating in or directed at New Jersey would need a new state licence distinct from money-transmitter licensure, once effective. [New Jersey Legislature / Bureau of Securities (disputed administering body) Source](https://pub.njleg.gov/Bills/2026/A3500/3454_I1.HTM) 1 dated · 2 pending date · baseline financial-integrity-2026-07-05 Role action cards Compliance ### FATF narrowed its increased-monitoring list and OFAC deepened Iran-sector sanctions, with no New Jersey-specific regime change. Enhanced-due-diligence screening lists should be updated to reflect the FATF list moving from twenty-two to eighteen jurisdictions, and sanctions screening for Iran-sector exposure should account for the automotive, rail and facilitator designations under Operation Economic Outcast. Neither development changes New Jersey's own regulatory perimeter. 2 evidence refs Legal ### OFAC closed a sanctions-and-reporting settlement and trimmed two sanctions-list entries, while a New Jersey gaming-sector penalty carries no established laundering nexus. The Pegasus Worldwide Logistics settlement and the Belarus and North Korea delistings illustrate continuing federal enforcement and list-maintenance activity. The New Jersey sports-wagering civil penalty is recorded as a regulatory enforcement matter only; no sanctions or money-laundering liability has been established in connection with it. 3 evidence refs Board ### Global sanctions architecture moved materially this cycle; New Jersey's own exposure remained limited to a gaming-sector enforcement matter. The FATF grey-list contraction and the Iran-sector sanctions escalation are structurally significant at a global level. For the state, the only identified development was a civil penalty in the regulated gaming sector, which does not by itself indicate elevated institutional risk. 3 evidence refs CTO ### An Iran-linked digital-asset exchange was disrupted for processing petroleum payments, while New Jersey continues to regulate virtual-currency businesses under its general money-transmission statute. No New Jersey-specific digital-asset architecture development occurred this cycle. The state has not adopted the multistate money-transmission modernization framework now adopted by thirty-five states, meaning any digital-asset compliance-technology implication in the state continues to run through money-transmitter licensing systems rather than a dedicated virtual-currency regime. Risk ### Sanctions-architecture movement at the global level outpaced any New Jersey-specific risk signal this cycle. The FATF list contraction and Iran-sector escalation are the dominant risk-typology signals this cycle. The New Jersey gaming-sector penalty is an episodic, enforcement-side data point with no cross-typology escalation established. 3 evidence refs Operations ### Sanctions screening lists require updating to reflect the narrower FATF list and continued Iran-sector designations. Screening workflows keyed to the FATF increased-monitoring list should reflect the removal of four jurisdictions, and transaction-monitoring rules touching Iran-sector counterparties should account for the automotive, rail and facilitator designations. No New Jersey-specific operational change is indicated. 2 evidence refs Audit ### No material change for this persona this cycle No material change for this persona this cycle Standing trackers (T1–T6) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture stable OFAC issued Russia-related GL 131K replacing GL 131J; no material UN/OFAC/OFSI Yemen-Houthi movement found. T2 · EU AML Package / AMLA no_change No AMLR/6AMLD/AMLA application-date or supervisory-perimeter movement surfaced this cycle. T3 · FATF Grey List improving October plenary removed Bulgaria, Côte d'Ivoire, DRC and Monaco; grey list now 18 jurisdictions. T4 · Beneficial-Ownership Register Status no_change No material BO-registry development surfaced this cycle. T5 · Crypto & Digital-Asset Integrity watch Iran-linked exchange disrupted; CSBS MTMA adoption at 35 states as of Oct 8, 2026 (NJ not adopting). T6 · Sanctions Regime Divergence no_change No new EU/US/UK autonomous-listing divergence beyond already-documented UK reg 33(1)(b) EDD trigger. Registers ### Enforcement actions - 10 Oct 2024 - 10 Oct 2024 - 10 Oct 2024 - 2025-08 - 3 Aug 2026 - 3 Aug 2026 - 13 Oct 2026 - TD Bank entered guilty pleas before a federal judge in Newark, NJ to BSA program failures and conspiracy to commit money laundering. FinCEN assessed a record $1.3B civil money penalty as part of a coordinated $3.1B multi-agency resolution (DOJ, Federal Reserve, OCC) with a four-year independent monitorship; the USAO-NJ investigative role was recognized in FinCEN's June 2026 Law Enforcement Awards. 19 Jun 2026 - As part of the coordinated federal resolution alongside FinCEN's CMP, OCC and the Federal Reserve imposed formal enforcement actions on TD Bank's US operations, including asset-growth restrictions and mandated overhaul of AML transaction-monitoring technology after multi-trillion-dollar screening coverage gaps were identified in the bank's NJ-anchored retail operation. 19 Jun 2026 - Alongside the TD Bank corporate resolution, USAO-NJ and DOJ's Money Laundering, Narcotics and Forfeiture Section secured guilty pleas from 15 additional defendants for money laundering, unlicensed money transmitting, and related crimes tied to the drug-proceeds laundering network that exploited TD Bank's NJ-anchored retail branches; the case was recognized in FinCEN's June 2026 Law Enforcement Awards. 19 Jun 2026 ### Sanctions changes - 22 Oct 2025 - 22 Oct 2025 - 1 Jul 2025 - 25 Jun 2026 - 2 Mar 2026 - 13 Jul 2026 - 30 Jun 2026 - 23 Apr 2026 - 15 Apr 2026 - 21 Oct 2026 - 21 Oct 2026 - OFAC designated Public Joint-Stock Company Oil Company Lukoil on Oct. 22, 2025 to increase pressure on Russia's energy sector, and issued a series of general licenses (GL 131) authorizing wind-down negotiations for Lukoil International GmbH's non-Russian assets, affecting compliance screening for NJ-based energy/trading firms in the global crude supply chain. 22 Oct 2025 - Effective July 1, 2025, the US ended comprehensive Syria sanctions; FinCEN issued exceptive relief in May 2025 permitting US financial institutions to open and maintain correspondent accounts for the Commercial Bank of Syria, easing compliance burden for NJ-based banks with Syria-linked correspondent exposure. 1 Jul 2025 ### Regulatory horizon (register) - UK Economic Crime and Corporate Transparency Act 2023 failure-to-prevent-fraud offence - NJ Digital Asset and Blockchain Technology Act (pending) - FATF mutual evaluation reports of Mexico and US - FinCEN AML/CFT Program Rule final rule finalization - GENIUS Act payment stablecoin issuer AML/sanctions rule finalization - Next FATF Plenary jurisdictional list review ### Active schemes - [CRITICAL] Large regional bank AML control failure enabling narcotics-proceeds laundering - Crypto ATM kiosk pipeline for pig-butchering and elder-fraud proceeds - [HIGH] Chinese money laundering network cash pickups through tri-state bank branches Sources - [FinCEN Director’s Law Enforcement Awards Program Recognizes](https://www.fincen.gov/system/files/shared/LEAP2020_State-Local%20LE%20508.pdf) - [FATF](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-june-2026.html) - [U.S. Department of the Treasury](https://home.treasury.gov/news/press-releases/sb0547) - [Kle Legal](https://klealegal.com/newsroom/amld6-eu-aml-package-entity-management) - [Amnesty International](https://www.amnesty.org/en/latest/news/2026/04/cambodia-casinos-get-state-approval-despite-links-to-human-rights-abuse-at-scamming-compounds/) - [Wikipedia (citing FinCEN, UNODC, Reuters)](https://en.wikipedia.org/wiki/Scam_centers_in_Cambodia) - [Brownstein Hyatt Farber Schreck](https://www.bhfs.com/insight/fincen-proposes-sweeping-aml-cft-reforms-what-casinos-need-to-know/) - [Gibson Dunn](https://www.gibsondunn.com/the-genius-act-a-new-era-of-stablecoin-regulation/) - [Federal Register / FinCEN](https://www.federalregister.gov/documents/2026/04/10/2026-07033/anti-money-laundering-and-countering-the-financing-of-terrorism-programs) - [FinCEN.gov](https://www.fincen.gov/system/files/2026-04/Program-NPRM-FactSheet.pdf) - [FinCEN.gov](https://www.fincen.gov/boi) - [US Treasury/OFAC](https://home.treasury.gov/news/press-releases/sb0543) - [Council of the EU](https://www.consilium.europa.eu/en/press/press-releases/2026/07/13/sudan-council-strengthens-eu-sanctions-regime-by-targeting-gold-trade/) - [US Treasury/OFAC](https://home.treasury.gov/news/press-releases/sb0545) - [FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-combats-financial-support-sinaloa-cartel-finding-transactions-involving) - [Chainalysis](https://www.chainalysis.com/blog/asian-scam-centers-crypto-fraud-april-2026/) - [Khaleej Times](https://www.khaleejtimes.com/business/uae-central-bank-tightens-anti-money-laundering-rules) - [NJ Department of Banking and Insurance](https://nj.gov/dobi/proposed/re230501njac3_32.pdf) - [New Jersey Legislature](https://pub.njleg.gov/Bills/2026/A3500/3454_I1.HTM) - [Lowenstein Sandler LLP](https://www.lowenstein.com/news-insights/publications/client-alerts/new-jersey-wants-its-own-bitlicense-regulation-crypto) - [FATF](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-october-2026.html) - [Morgan Lewis](https://www.morganlewis.com/pubs/2026/10/ofac-further-intensifies-iran-sanctions-under-operation-economic-outcast) - [Steptoe LLP](https://www.steptoe.com/en/news-publications/international-compliance-blog/weekly-sanctions-update-october-26-2026.html) - [American Bankers Association](https://bankingjournal.aba.com/2026/10/recent-news-from-treasurys-office-of-foreign-assets-control-oct-19/) - [Sports Betting Dime](https://www.sportsbettingdime.com/news/industry/new-jersey-doles-out-nearly-100k-in-civil-penalties-to-three-sportsbooks/) - [https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-october-2026.html](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-october-2026.html) - [https://www.morganlewis.com/pubs/2026/10/ofac-further-intensifies-iran-sanctions-under-operation-economic-outcast](https://www.morganlewis.com/pubs/2026/10/ofac-further-intensifies-iran-sanctions-under-operation-economic-outcast) - [https://www.steptoe.com/en/news-publications/international-compliance-blog/weekly-sanctions-update-october-26-2026.html](https://www.steptoe.com/en/news-publications/international-compliance-blog/weekly-sanctions-update-october-26-2026.html) - [https://bankingjournal.aba.com/2026/10/recent-news-from-treasurys-office-of-foreign-assets-control-oct-19/](https://bankingjournal.aba.com/2026/10/recent-news-from-treasurys-office-of-foreign-assets-control-oct-19/) - [https://www.sportsbettingdime.com/news/industry/new-jersey-doles-out-nearly-100k-in-civil-penalties-to-three-sportsbooks/](https://www.sportsbettingdime.com/news/industry/new-jersey-doles-out-nearly-100k-in-civil-penalties-to-three-sportsbooks/) - [United States Department of the Treasury Financial Crimes Enforcement Network - Home | FinCEN.gov](https://www.fincen.gov/) - [1 Financial Crimes Enforcement Network (FinCEN)](https://www.fincen.gov/system/files/2026-05/FinCEN-Year-in-Review-2025.pdf) - [Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov](https://www.fincen.gov/news/news-releases/financial-action-task-force-identifies-jurisdictions-anti-money-laundering-5) - [News | FinCEN.gov](https://www.fincen.gov/news) - [Press Releases | FinCEN.gov](https://www.fincen.gov/news/press-releases) - [FinCEN Alert on the Use of Front Companies...](https://www.fincen.gov/system/files/2026-05/FinCEN-Alert-IRGC.pdf) - [Alerts/Advisories/Notices/Bulletins/Fact Sheets | FinCEN.gov](https://www.fincen.gov/resources/advisoriesbulletinsfact-sheets) - [Treasury Convenes Financial Institutions and Law Enforcement to Identify and Dismantle Money Laundering Networks | FinCEN.gov](https://www.fincen.gov/news/news-releases/treasury-convenes-financial-institutions-and-law-enforcement-identify-and) - [1 Fact Sheet: FinCEN Issues Final Rule to](https://www.fincen.gov/system/files/shared/RREFactSheet.pdf) - [FinCEN Year In Review | FinCEN.gov](https://www.fincen.gov/about-fincen/fincen-year-review) - [PPSI-AMLCFT-NPRM.pdf](https://www.fincen.gov/system/files/2026-04/PPSI-AMLCFT-NPRM.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/2026-05/FinCEN-WCHT-Notice.pdf) - [Federal Register/Vol. 91, No. 69/Friday, April 10, 2026/ ...](https://ofac.treasury.gov/media/935481/download?inline=) - [FinCEN Proposes New Regulation to Enhance Transparency in Convertible Virtual Currency Mixing and Combat Terrorist Financing | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-proposes-new-regulation-enhance-transparency-convertible-virtual-currency) - [1 The U.S. Department of the Treasury’s (Treasury)](https://www.fincen.gov/system/files/2025-08/FinCEN-Advisory-CMLN-508.pdf) - [Fact Sheet: Proposed Rule to Fundamentally Reform Financial](https://www.fincen.gov/system/files/2026-04/Program-NPRM-FactSheet.pdf) - [Answering the Questions in Treasury's DeFi Risk Assessment](https://www.trmlabs.com/resources/trm-talks/answering-the-questions-in-treasurys-defi-risk-assessment) - [Treasury Department Publishes National Money Laundering Risk Assessment and National Terrorist Financing Risk Assessment | FinCEN.gov](https://www.fincen.gov/news/news-releases/treasury-department-publishes-national-money-laundering-risk-assessment-and) - [Fact Sheet: Proposed Rule to Strengthen and Modernize ...](https://www.fincen.gov/system/files/shared/Program-NPRM-FactSheet-508.pdf) - [FinCEN Assesses Civil Money Penalty Against New Jersey ...](https://www.fincen.gov/system/files/shared/20101216.pdf) - [UNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY](https://www.fincen.gov/system/files/shared/PamrapoAssessment.pdf) - [FinCEN Assesses Civil Money Penalty Against New Jersey | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-assesses-civil-money-penalty-against-new-jersey) - [Interagency Interpretive Guidance on Providing Banking Services to Money Services Businesses Operating in the United States | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/interagency-interpretive-guidance-providing-banking) - [News Releases on Unregistered Money Transmitter Enforcement Actions | FinCEN.gov](https://www.fincen.gov/news-releases-unregistered-money-transmitter-enforcement-actions) - [Enforcement Actions for Failure to Register as a Money Services Business | FinCEN.gov](https://www.fincen.gov/enforcement-actions-failure-register-money-services-business) - [UNITED STATES OF AMERICA DEPARTIVffiNT OF THE TREASURY](https://www.fincen.gov/system/files?file=enforcement_action/2020-05-21/BalticAssessment.pdf) - [FinCEN Penalizes New Jersey Money Services Business for Repeated Violations of the Bank Secrecy Act | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-penalizes-new-jersey-money-services-business-repeated-violations-bank) - [MSB Registrant Search | FinCEN.gov](https://www.fincen.gov/resources/msb-state-selector) - [Definition of Money Transmitter (Merchant Payment Processor) | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/definition-money-transmitter-merchant-payment) - [FinCEN Director’s Law Enforcement Awards Program Recognizes](https://www.fincen.gov/system/files/shared/LEAP2020_State-Local%20LE%20508.pdf) - [Questions swirl around US plans for record $15B Prince Group crypto seizure - ICIJ](https://www.icij.org/investigations/coin-laundry/questions-swirl-around-us-plans-for-record-15b-prince-group-crypto-seizure/) - [1 The U.S. Department of the Treasury’s (Treasury) Financial](https://www.fincen.gov/system/files/2026-03/FinCEN-Advisory-Health-Care-Fraud.pdf) - [1 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) - [Jersey Probes Roman Abramovich Over Suspected Money Laundering | OCCRP](https://www.occrp.org/en/news/jersey-probes-roman-abramovich-over-suspected-money-laundering) - [Bob Menendez Case Sparks New Jersey Review of SEC, DOJ Officials - Bloomberg](https://www.bloomberg.com/news/articles/2023-12-01/bob-menendez-case-sparks-new-jersey-review-of-sec-doj-officials) - [The DOJ's NCET Disbanded: What This Means for Digital Assets - Chainalysis](https://www.chainalysis.com/blog/ncet-blanche-memo/) - [U.S. Adds Narcoterror Charge Against Uruguayan Trafficking Suspect | OCCRP](https://www.occrp.org/en/news/us-adds-narcoterror-charge-against-uruguayan-trafficking-suspect) - [The Rise of Wrench Attacks and Crypto-related Violent Crime | TRM Labs](https://www.trmlabs.com/resources/blog/the-rise-of-wrench-attacks-and-crypto-related-violent-crime) - [Anti-Money Laundering Proposal for Casinos to be discussed at Regional Meetings | FinCEN.gov](https://www.fincen.gov/news/news-releases/anti-money-laundering-proposal-casinos-be-discussed-regional-meetings) - [Important Information for Casinos | FinCEN.gov](https://www.fincen.gov/resources/financial-institutions/casinos) - [Guidance | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance?field_tags_financial_institution_target_id=659&page=0) - [Recognizing Suspicious Activity - Red Flags for Casinos and Card Clubs | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/recognizing-suspicious-activity-red-flags-casinos-and-card) - [FinCEN Fines Cantor Gaming $12 Million for Egregious and Systemic Violations of Anti-Money Laundering Rules | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-fines-cantor-gaming-12-million-egregious-and-systemic-violations-anti) - [Casino or Card Club Compliance Program Assessment | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/casino-or-card-club-compliance-program-assessment) - [Suspicious Activity Reporting in the Gaming Industry](https://www.fincen.gov/system/files/shared/GamingIndustry508March2012.pdf) - [Suspicious Activity Reporting](https://www.fincen.gov/sites/default/files/shared/neilanderaml.pdf) - [Frequently Asked Questions Casino Record keeping, Reporting, and Compliance Program Requirements | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/frequently-asked-questions-casino-record-keeping-reporting) - [Frequently Asked Questions Casino Recordkeeping, Reporting, and Compliance Program Requirements | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/frequently-asked-questions-casino-recordkeeping-reporting-0) - [Trade-Based Money Laundering (TBML) handbook - Customs data to identify trade-based money laundering - Guidance - GOV.UK](https://www.gov.uk/guidance/trade-based-money-laundering-tbml-handbook/customs-data-to-identify-trade-based-money-laundering) - [Trade-Based Money Laundering (TBML) handbook - Evidence - Guidance - GOV.UK](https://www.gov.uk/guidance/trade-based-money-laundering-tbml-handbook/evidence) - [Money Laundering vulnerabilities of Free Trade Zones](https://www.fatf-gafi.org/content/dam/fatf/documents/reports/ML%20vulnerabilities%20of%20Free%20Trade%20Zones.pdf) - [Trade-Based Money Laundering (TBML) handbook - Common techniques of trade-based money laundering - Guidance - GOV.UK](https://www.gov.uk/guidance/trade-based-money-laundering-tbml-handbook/common-techniques-of-trade-based-money-laundering) - [Trade-Based Money Laundering](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Trade-basedmoneylaundering.html) - [Trade-Based Money Laundering (TBML) handbook - Guidance - GOV.UK](https://www.gov.uk/guidance/trade-based-money-laundering-tbml-handbook) - [FATF/Egmont Trade-based Money Laundering: Trends and Developments](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Trade-based-money-laundering-trends-and-developments.html) - [Counter fraud | Newark & Sherwood District Council](https://www.newark-sherwooddc.gov.uk/counterfraud/) - [Opening remarks at Trade-Based Money Laundering Press Conference](https://www.fatf-gafi.org/en/publications/Fatfgeneral/Remarks-presser-conf-tbml-report.html) - [FinCEN Renews Residential Real Estate Geographic Targeting Orders | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-renews-residential-real-estate-geographic-targeting-orders-0) - [FinCEN GEOGRAPHIC TARGETING ORDER, April 14, 2025](https://www.fincen.gov/system/files/shared/RRE-GTO-Order-April-14-2025-FINAL508.pdf) - [Geographic Targeting Order Covering TITLE INSURANCE COMPANY October 9, 2025](https://www.fincen.gov/system/files/2025-10/RRE-GTO-Order.pdf) - [FinCEN Renews Real Estate Geographic Targeting Orders | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-renews-real-estate-geographic-targeting-orders-0) - [FREQUENTLY ASKED QUESTIONS Issued: October 9, 2025](https://www.fincen.gov/system/files/2025-10/RRE-GTO-FAQs.pdf) - [FinCEN Renews Real Estate “Geographic Targeting Orders” to Identify High-End Cash Buyers in Six Major Metropolitan Areas | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-renews-real-estate-geographic-targeting-orders-identify-high-end-cash) - [Geographic Targeting Orders Involving Certain Real Estate ...](https://www.fincen.gov/system/files/shared/508_FAQ_April2023REGTO.pdf) - [FinCEN Renews and Expands Real Estate Geographic Targeting Orders | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-renews-and-expands-real-estate-geographic-targeting-orders-2) - [Residential Real Estate Rule | FinCEN.gov](https://www.fincen.gov/rre) - [Geographic Targeting Order Covering TITLE INSURANCE ...](https://www.fincen.gov/sites/default/files/shared/Real%20Estate%20GTO_Order_4.29.22_for%20Press%20Release.pdf) - [Treasury Anti-Money Laundering Regulations | FinCEN.gov](https://www.fincen.gov/treasury-anti-money-laundering-regulations) - [Jersey's measures to combat money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/MER-Jersey-2024.html) - [FinCEN Penalizes New Jersey Community Bank for Risky Dealings with Foreign Money Exchanges | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-penalizes-new-jersey-community-bank-risky-dealings-foreign-money) - [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/) - [TD to Pay $3.1 Billion in Money Laundering Case, Face Asset Cap - Bloomberg](https://www.bloomberg.com/news/articles/2024-10-10/td-will-plead-guilty-to-money-laundering-charges-in-nj-court) - [UNITED STATES OF AMERICA FINANCIAL CRIMES ENFORCEMENT NETWORK](https://www.fincen.gov/system/files/2026-03/Canaccord-Consent-Order-No-2026-01.pdf) - [Chelsea FC faces over six dozen charges for improper conduct under Abramovich’s ownership - ICIJ](https://www.icij.org/news/2025/09/chelsea-fc-faces-over-six-dozen-charges-for-improper-conduct-under-abramovichs-ownership/) - [Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Countering the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov](https://www.fincen.gov/news/news-releases/financial-action-task-force-identifies-jurisdictions-anti-money-laundering-3) - [FinCEN Assesses Record $1.3 Billion Penalty against TD Bank | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-assesses-record-13-billion-penalty-against-td-bank) - [TD Bank hit with $3B penalty in U.S. money laundering settlement - ICIJ](https://www.icij.org/investigations/fincen-files/td-bank-hit-with-3b-penalty-in-u-s-money-laundering-settlement/) - [The Criminal Money Laundering Scams That Cost TD Bank Billions - Bloomberg](https://www.bloomberg.com/news/features/2025-03-18/the-criminal-money-laundering-scams-that-cost-td-bank-billions) - [FinCEN TD Bank Consent Order, Number 2024-02](https://www.fincen.gov/system/files/enforcement_action/2024-10-10/FinCEN-TD-Bank-Consent-Order-508FINAL.pdf) - [Watch How TD Became a Convenient Bank for Money Launderers - Bloomberg](https://www.bloomberg.com/news/videos/2025-03-18/how-td-became-a-convenient-bank-for-money-launderers-video) - [TD’s Laundering Settlement ‘Darkest Day’ for Bank, Chair Says - Bloomberg](https://www.bloomberg.com/news/articles/2025-04-10/td-s-laundering-settlement-darkest-day-for-bank-chair-says) - [TD Bank Resolves Treasuries Spoofing Case Amid Wider US Probes - Bloomberg](https://www.bloomberg.com/news/articles/2024-09-30/td-bank-resolves-treasuries-spoofing-case-amid-wider-us-probes) - [Iran Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/iran-sanctions) - [comprehensive iran sanctions, accountability](https://ofac.treasury.gov/media/5691/download?inline=) - [An overview of O.F.A.C. Regulations involving Sanctions against Iran](https://ofac.treasury.gov/system/files/126/iran.pdf) - [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [Counter Terrorism and Counter Narcotics Designations; Sudan-related Designations and Designation Update; Russia-related Designation Update; Issuance of Counter Terrorism General License | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20260219) - [Russia-related Designation Update and Designation Removal | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20260108) - [Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 Reporting Requirements Under Section 104(e) | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/federal-register-notices/comprehensive-iran-sanctions-0) - ["CISADA: "The New U.S. Sanctions on Iran"](https://ofac.treasury.gov/media/7871/download) - [Iran-related Designations; International Criminal Court-related Designations; Russia-related Designations Removals; Foreign Sanctions Evaders Determination Removal; Issuance of Iran-related and International Criminal Court-related General Licenses | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20251218) - [Frequently Asked Questions - Newly Added | Office of Foreign Assets Control](https://ofac.treasury.gov/faqs/added) - [FinCEN Notice, FIN-2025-NTC1, August 4, 2025](https://www.fincen.gov/system/files/2025-08/FinCEN-Notice-CVCKIOSK.pdf) - [‍New Jersey Man Pleads Guilty To Defrauding First Responders in Crypto Scam | TRM Labs](https://www.trmlabs.com/resources/blog/new-jersey-man-pleads-guilty-to-defrauding-first-responders-in-crypto-scam) - [1 1. See 31 U.S.C. § 5312(a)(2); 31 CFR § 1010.100(t). 2.](https://www.fincen.gov/system/files/shared/FinCEN_Alert_Pig_Butchering_FINAL_508c.pdf) - [Bitcoin ATMs are a legal and fast-growing part of the crypto world, despite flying under the regulatory radar](https://www.bloomberg.com/features/2018-bitcoin-atm-money-laundering/) - [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) - [Must-Know Crypto Investigations of 2023: North America | TRM Labs](https://www.trmlabs.com/resources/blog/must-know-crypto-investigations-of-2023-north-america) - [Iran-related Designations; Russia-related Designation Removal | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20251009) - [Frequently Asked Questions - Recently Updated | Office of Foreign Assets Control](https://ofac.treasury.gov/faqs/updated) - [Iran-related Designations; Issuance of Russia-related General License and Amended Frequently Asked Questions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20260528_33) - [Russia-related Designations; Counter Terrorism Designations and Removal; Iran-related Designation Removal | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20241017) - [Non-Proliferation Designations; Iran-related Designations | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20250401) - [Iran-related Designations; Counter Terrorism Designations, Updates, and Removals; Balkans-related Designation Removal | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20251120) - [1118 | Office of Foreign Assets Control](https://ofac.treasury.gov/faqs/1118) - [August 16, 2023 OFAC Settles with Construction Specialties ...](https://ofac.treasury.gov/media/932086/download) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [SEC draws the line: Which cryptoassets are securities and which are not?](https://www.elliptic.co/blog/sec-explains-which-cryptoassets-are-securities-and-which-are-not) - [PWG Report on Digital Assets: Building Crypto’s Future Together](https://www.chainalysis.com/blog/pwg-report-digital-assets-building-the-future-of-crypto-july-2025/) - [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/) - [What is crypto AML compliance?](https://www.elliptic.co/blockchain-basics/what-is-crypto-aml-compliance) - [Crypto regulatory affairs: US regulators issue comprehensive guidance on tokenized securities](https://www.elliptic.co/blog/crypto-regulatory-affairs-us-regulators-issue-comprehensive-guidance-on-tokenized-securities) - [The Landscape of Seizable Crypto Assets in 2025 - Chainalysis](https://www.chainalysis.com/blog/landscape-of-seizable-crypto-assets-2025/) - [U.S. Crackdown on Southeast Asian Crypto Scam Centers](https://www.chainalysis.com/blog/asian-scam-centers-crypto-fraud-april-2026/) - [Trump administration curbs state oversight of crypto industry - ICIJ](https://www.icij.org/investigations/coin-laundry/trump-administration-curbs-state-oversight-of-crypto-industry/) - [SAR-FAQs-October-2025.pdf](https://www.fincen.gov/system/files/2025-10/SAR-FAQs-October-2025.pdf) - [Interagency Statement on Sharing Bank Secrecy Act Resources | FinCEN.gov](https://www.fincen.gov/news/news-releases/interagency-statement-sharing-bank-secrecy-act-resources) - [Enforcement Actions | FinCEN.gov](https://www.fincen.gov/news/enforcement-actions) - [FIN-2025-G001 Issued: September 5, 2025](https://www.fincen.gov/system/files/2025-09/Crossborderguidance-508C.pdf) - [The Bank Secrecy Act | FinCEN.gov](https://www.fincen.gov/resources/statutes-and-regulations/bank-secrecy-act) - [FinCEN Number 2023-03, CONSENT ORDER IMPOSING ...](https://www.fincen.gov/system/files?file=enforcement_action/2023-09-29/SHBA_9-28_FINAL_508.pdf) - [FinCEN Consent Order Imposing Civil Money Penalty](https://www.fincen.gov/sites/default/files/enforcement_action/2025-02-06/FinCEN-Brinks-FINALv508.pdf) - [FinCEN Announces Recipients of Its 11th Law Enforcement Awards Program | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-announces-recipients-its-11th-law-enforcement-awards-program) - [American Fugitive Used Big Banks To Shuffle More Than $1 Million Offshore, Records Show - ICIJ](https://www.icij.org/investigations/offshore/american-fugitive-used-big-banks-shuffle-more-1-million-offshore-records-show/) - [New Jersey ICE Facility Plan Halted as Federal Review Moves Forward - Bloomberg](https://www.bloomberg.com/news/articles/2026-05-12/new-jersey-ice-detention-project-paused-as-us-to-conduct-review) - [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) - [Freed by Trump, a $200 Million Fraudster Started a New Scam](https://www.bloomberg.com/features/2025-eli-weinstein-ponzi-fraud/) - [Summary of Nominated Cases State and Local – San Jose Police Department](https://www.fincen.gov/system/files/shared/Summary%20of%20LEAP%20Nominated%20Cases.pdf) - [FinCEN (U.S. Department of the Treasury)](https://www.fincen.gov/news/news-releases/fincen-assesses-record-13-billion-penalty-against-td-bank) - [FinCEN (U.S. Department of the Treasury)](https://www.fincen.gov/news/news-releases/fincen-announces-recipients-its-11th-law-enforcement-awards-program) - [FinCEN (U.S. Department of the Treasury)](https://www.fincen.gov/system/files/2025-08/FinCEN-Notice-CVCKIOSK.pdf) - [U.S. Department of the Treasury](https://home.treasury.gov/system/files/246/2026-NMLRA.pdf) - [Bloomberg Businessweek](https://www.bloomberg.com/news/features/2025-03-18/the-criminal-money-laundering-scams-that-cost-td-bank-billions) - [ICIJ](https://www.icij.org/investigations/fincen-files/td-bank-hit-with-3b-penalty-in-u-s-money-laundering-settlement/) - [OFAC (U.S. Department of the Treasury)](https://ofac.treasury.gov/faqs/added) - [New Jersey Department of Banking and Insurance](https://www.nj.gov/dobi/) - [Bloomberg](https://www.bloomberg.com/features/2025-eli-weinstein-ponzi-fraud/) - [FinCEN (U.S. Department of the Treasury)](https://www.fincen.gov/system/files/2026-04/Program-NPRM-FactSheet.pdf) Coverage gaps fim-int-2026-07-05-G001: The three TD Bank enforcement_actio… fim-int-2026-07-05-G001: The three TD Bank enforcement_action_register dates in the baseline (2026-06-19) were flagged by challenge review as materially incorrect against the actual 2024-10-10 DOJ/FinCEN resolution date; a definitive, independently re-pulled enforcement timeline should be confirmed against DOJ/FinCEN primary sources before publication. [resolved] fim-int-2026-07-05-G002: FinCEN's Residential Real Estate Ru… fim-int-2026-07-05-G002: FinCEN's Residential Real Estate Rule is in active litigation (vacated 2026-03-19, appeal pending); current in-force status should be reconfirmed at the next cycle against the FinCEN docket or appellate outcome. [resolved] fim-int-2026-07-05-G003: Direct primary-source NJ state-regu… fim-int-2026-07-05-G003: Direct primary-source NJ state-regulator enforcement data (NJ Department of Banking and Insurance orders; NJ Bureau of Securities cease-and-desist dockets) was not independently retrieved this cycle beyond federal secondary citation; recommend direct pull from njoag.gov and dobi.nj.gov. [resolved] fim-int-2026-07-05-G004: The July 2025 Syria comprehensive-s… fim-int-2026-07-05-G004: The July 2025 Syria comprehensive-sanctions termination has not been re-verified against a 2026-dated OFAC source to confirm no intervening reimposition or modification. [resolved] fim-int-2026-07-05-G005: The research payload's publication_… fim-int-2026-07-05-G005: The research payload's publication_gate metrics (jurisdiction_source_floor_met=false, tier_a_b_national_primary_pct=0.0, schema_valid=false) are inconsistent with the profile-level source_quality block (floor_met=true); this metric discrepancy requires operator reconciliation before publish-grade confidence can be assigned to this jurisdiction row. [resolved] fim-int-2026-07-05-G006: The exact dates of the 15 individua… fim-int-2026-07-05-G006: The exact dates of the 15 individual co-conspirator guilty pleas in the TD Bank-linked network are not independently established; only the coordinated October 2024 resolution window is confirmed. [resolved] fim-int-2026-07-14-G001: No Tier 1 EU Commission or AMLA pri… fim-int-2026-07-14-G001: No Tier 1 EU Commission or AMLA primary-source citation obtained this cycle for the AMLD6/AMLA 10 July 2026 deadline convergence; both corroborating sources are Tier 4 secondary commentary. [resolved] fim-int-2026-07-14-G002: No Tier 1 FinCEN NPRM primary-text … fim-int-2026-07-14-G002: No Tier 1 FinCEN NPRM primary-text citation obtained this cycle; casino AML/CFT Program NPRM analysis rests on two Tier 2 law-firm alerts. [resolved] fim-int-2026-07-14-G003: Mexico and Colombia (Tier D watch j… fim-int-2026-07-14-G003: Mexico and Colombia (Tier D watch jurisdictions) were not searched this cycle due to pooled search-budget constraints; no material-change assertion should be inferred from their absence. [resolved] fim-int-2026-07-14-G004: D4 (Conflict Finance and Extractive… fim-int-2026-07-14-G004: D4 (Conflict Finance and Extractive-Industry Integrity) yielded no sourced findings this cycle; coverage remains thin for Sahel/DRC/oil-revenue-corruption standing topics. [resolved] fim-int-2026-08-05-G001: No fresh AMLR application, 6AMLD tr… fim-int-2026-08-05-G001: No fresh AMLR application, 6AMLD transposition, or AMLA supervisory-perimeter development was retrieved this cycle for the EU AML Package. [resolved] fim-int-2026-08-05-G002: No fresh Houthi/Yemen-specific UN P… fim-int-2026-08-05-G002: No fresh Houthi/Yemen-specific UN Panel of Experts, OFAC, or OFSI material was located this cycle. [resolved] fim-int-2026-08-05-G003: No fresh material was identified fo… fim-int-2026-08-05-G003: No fresh material was identified for Laos or Colombia under the Tier D sweep this cycle. [resolved] fim-int-2026-08-05-G004: No direct OFAC/treasury.gov primary… fim-int-2026-08-05-G004: No direct OFAC/treasury.gov primary URL was retrieved for the Kok An/Cambodia designation; only Tier-2 secondary reporting available. [resolved] fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): Administering authority for the pending Digital Asset and Blockchain Technology Act is disputed between primary bill text (Bureau of Securities) and secondary commentary (Department of Banking and Insurance); resolution requires the enacted text or a regulator clarification. [resolved] fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', 'value': 'D1'}): D1, D3, D4 and D6 domains had no US-NJ-specific findings this cycle; a single-subnational-JID dispatch structurally limits coverage of global/cross-jurisdictional trackers. [resolved] fim-int-2026-11-01-G010: Tier D watch (KH, LA, MX, CO) not a… fim-int-2026-11-01-G010: Tier D watch (KH, LA, MX, CO) not actively re-queried this cycle given pooled union search budget; carried forward as a coverage gap. [open] fim-int-2026-11-01-G011 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G011 ({'scheme': 'financial_integrity', 'value': 'D2'}): EU AML Package/AMLA and beneficial-ownership register status returned no material movement within pooled research budget; recorded as standing no-change rather than confirmed absence. [open] fim-int-2026-11-01-G001: Tier D watch (Cambodia, Laos, Colom… fim-int-2026-11-01-G001: Tier D watch (Cambodia, Laos, Colombia) not actively re-queried this cycle given pooled union search budget. [open] fim-int-2026-11-01-G002: No US-NJ-specific state-level AML/C… fim-int-2026-11-01-G002: No US-NJ-specific state-level AML/CFT, BO or sanctions instrument distinct from the federal BSA/FinCEN framework was identified this cycle; carried as a structural note rather than a researched gap. [open] FIM-GAP-001 (D2): Until the nationwide Residential Real Esta… FIM-GAP-001 (D2): Until the nationwide Residential Real Estate Rule took effect March 1, 2026, FinCEN's Residential Real Estate GTOs — requiring title insurers to identify beneficial owners behind all-cash shell-company home purchases — never included any New Jersey county, despite NJ counties bordering the same NYC luxury real estate corridor covered by New York GTOs. FIM-GAP-002 (D2): FinCEN's March 2025 interim final rule exe… FIM-GAP-002 (D2): FinCEN's March 2025 interim final rule exempted nearly all US-formed domestic reporting companies from Corporate Transparency Act beneficial ownership reporting, removing federal visibility into the beneficial ownership of NJ-registered LLCs and corporations that would previously have been required to report. FIM-GAP-003 (D3): A defendant prosecuted by USAO-NJ (Newark)… FIM-GAP-003 (D3): A defendant prosecuted by USAO-NJ (Newark) for a $200M+ Ponzi/investment fraud scheme received presidential clemency in 2025 and was subsequently reported to have resumed fraudulent solicitation activity, illustrating how federal clemency policy can neutralize NJ-based prosecutorial outcomes. FIM-GAP-004 (D3): Direct primary-source citations from NJ's … FIM-GAP-004 (D3): Direct primary-source citations from NJ's own state regulators (adjudicated NJ Department of Banking and Insurance orders; NJ Bureau of Securities cease-and-desist dockets) were not independently retrievable in this research cycle beyond references embedded in federal FinCEN publications; NJ state-level enforcement data should be pulled directly from njoag.gov/dobi in the next cycle. ## Evidence #### Confidence-tiered claims Bulgaria, Cote d'Ivoire, DRC, Monaco removed; grey list now 18 [[Source 1]](#sec-sources) Probable · 1 source Automotive and rail sectors targeted Oct 1, 2026; presumption-of-denial posture [[Source 1]](#sec-sources) Probable · 1 source ~$100,000 combined; theScore $78,000 + $306.48 disgorgement [[Source 1]](#sec-sources) Probable · 1 source 175015 [[Source 1]](#sec-sources) Probable · 1 source Bulgaria, Côte d'Ivoire, DRC and Monaco removed from increased monitoring at October 2026 plenary; grey list now 18 jurisdictions; black list unchanged. [[Source 1]](#sec-sources) Probable · 1 source Operation Economic Outcast reached Iran's automotive and rail sectors (Oct 1, 2026) under EO 13902, with a presumption-of-denial licensing posture, reinforced Oct 21 by designations against legal, maritime and shipping facilitators of Iran's sanctions evasion. [[Source 1]](#sec-sources) Probable · 1 source DGE civil penalty of $78,000 plus $306.48 disgorgement for accepting unauthorized wagers under N.J.A.C. 13:69N-1.11(a). [[Source 1]](#sec-sources) Probable · 1 source Pegasus Worldwide Logistics reached a $175,015 settlement with OFAC over potential sanctions and reporting violations involving blocked property and response to an OFAC subpoena. [[Source 1]](#sec-sources) Probable · 1 source Two individuals and two entities (and naming variations) removed from the SDN List under the Belarus and North Korea sanctions programs on Oct 21, 2026. [[Source 1]](#sec-sources) Probable · 1 source