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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 — North Dakota US-ND

Domains covered
8 of 8
Sources
148
Role actions
8
Horizon <90d
0
Jurisdiction profile
FATF status: Largely Compliant Tier: C Risk direction: Increasing Enablement vs enforcement: Mixed

North Dakota has no standalone state AML statute; entities and MSBs operating in-state are governed by the federal Bank Secrecy Act/AML Act framework (FinCEN, OFAC) with state money-transmitter licensing and examination performed by the North Dakota Department of Financial Institutions (DFI).

MoreNo ND-specific AML/CFT statutory deficiency has been separately assessed by FATF, which evaluates the US as a single jurisdiction.

Key deficiencies
  • No independent state-level beneficial ownership registry; ND-formed entities now fall under the federal CTA rollback exempting domestic reporting companies from BOI filing
  • No dedicated AML/CFT licensing or supervisory category for standalone cryptocurrency-mining operations monetizing the state's stranded/flared natural gas, despite the sector's structural resemblance to internationally-documented energy-to-crypto sanctions-evasion typologies
  • Minimal public-record density of ND-specific BSA/AML enforcement actions, limiting independent verification of state MSB supervisory effectiveness
Recent developments (18m)
  • FinCEN's March 2025 interim final rule exempted all US-formed 'domestic reporting companies' (including ND-chartered LLCs/corporations) from Corporate Transparency Act beneficial-ownership reporting
  • FATF's March 2024 enhanced follow-up report upgraded the US on Recommendation 24 (beneficial ownership transparency) from Non-Compliant to Largely Compliant, a rating that applies uniformly to ND-registered legal persons
  • Continued expansion of natural-gas-fired Bitcoin mining operations in the Bakken shale region operating outside dedicated AML/CFT supervisory categories

United States federal law that applies in United States – North Dakota is covered once, on the United States page. This page covers United States – North Dakota’s own layer: its own law, regulators and enforcement.

Brief

Lead signal

Lead Signal

The Financial Action Task Force reduced its grey list from 22 to 18 jurisdictions at its 30 October 2026 Plenary, removing Bulgaria, Cote d Ivoire, the Democratic Republic of Congo and Monaco, while adding no new entrants. The black list of Iran, Myanmar and North Korea was left unchanged. This is a global architecture movement rather than an action specific to North Dakota, and it is the only confirmed development this cycle. Independent reporting corroborates the four removals and the nil-addition outcome without disagreement, giving the finding a confirmed standing at the global level even though it does not, on its own, change anything in North Dakota's own regulatory posture.

Read full brief

Lead Signal

The Financial Action Task Force reduced its grey list from 22 to 18 jurisdictions at its 30 October 2026 Plenary, removing Bulgaria, Cote d Ivoire, the Democratic Republic of Congo and Monaco, while adding no new entrants. The black list of Iran, Myanmar and North Korea was left unchanged. This is a global architecture movement rather than an action specific to North Dakota, and it is the only confirmed development this cycle. Independent reporting corroborates the four removals and the nil-addition outcome without disagreement, giving the finding a confirmed standing at the global level even though it does not, on its own, change anything in North Dakota's own regulatory posture.

For a subnational jurisdiction such as North Dakota, a FATF grey-list movement is relevant mainly as an input into how banks and money-transmitters calibrate enhanced due diligence toward counterparties linked to the jurisdictions concerned, rather than as a direct change in North Dakota law or supervisory practice. Nothing in the material available this cycle indicates that the Department of Financial Institutions or any other North Dakota authority has issued guidance responding to the list change, and no such claim is made here.

Other Developments

No further sanctions-architecture developments meeting the bar were identified for North Dakota this cycle. Coverage of this jurisdiction's other financial-integrity domains was thin in the window, and the gate withheld those domains rather than publish thin or unverified material. Readers should treat the grey-list movement above as the complete sanctions-relevant picture for this cycle; nothing else is asserted.

Cross-Monitor Connections

A shift in the FATF grey list has routing significance beyond financial integrity narrowly defined. Jurisdictions moving off increased monitoring typically see a corresponding easing in correspondent-banking friction and in the intensity of enhanced due diligence applied by regulated institutions worldwide, which can in turn affect flows that other monitors track under conflict-finance and state-capture lenses. No North Dakota-specific cross-monitor linkage is asserted this cycle; the connection recorded here is the general architectural one between FATF status and global enhanced-due-diligence practice, not a finding about this jurisdiction's institutions.

Outlook

The FATF grey list is scheduled for its next substantive review at a future Plenary, and further movement on and off increased monitoring should be expected as a matter of ordinary cadence rather than as a surprise. Whether North Dakota-specific sanctions-architecture findings emerge will depend on research coverage reaching the subnational level in a future cycle; as at this writing, no such finding exists and none is projected.

Earlier periodic briefs (6)
4 Nov 2026 · fim-2026-11-01

Lead Signal

The Financial Action Task Force reduced its grey list from 22 to 18 jurisdictions at its 30 October 2026 Plenary, removing Bulgaria, Cote d Ivoire, the Democratic Republic of Congo and Monaco, while adding no new entrants. The black list of Iran, Myanmar and North Korea was left unchanged. This is a global architecture movement rather than an action specific to North Dakota, and it is the only confirmed development. Independent reporting corroborates the four removals and the nil-addition outcome without disagreement, giving the finding a confirmed standing at the global level even though it does not, on its own, change anything in North Dakota's own regulatory posture.

For a subnational jurisdiction such as North Dakota, a FATF grey-list movement is relevant mainly as an input into how banks and money-transmitters calibrate enhanced due diligence toward counterparties linked to the jurisdictions concerned, rather than as a direct change in North Dakota law or supervisory practice. Nothing in the material available indicates that the Department of Financial Institutions or any other North Dakota authority has issued guidance responding to the list change, and no such claim is made here.

Other Developments

No further sanctions-architecture developments meeting the bar were identified for North Dakota. Coverage of this jurisdiction's other financial-integrity domains was thin in the window, and the gate withheld those domains rather than publish thin or unverified material. Readers should treat the grey-list movement above as the complete sanctions-relevant picture; nothing else is asserted.

Cross-Monitor Connections

A shift in the FATF grey list has routing significance beyond financial integrity narrowly defined. Jurisdictions moving off increased monitoring typically see a corresponding easing in correspondent-banking friction and in the intensity of enhanced due diligence applied by regulated institutions worldwide, which can in turn affect flows that other monitors track under conflict-finance and state-capture lenses. No North Dakota-specific cross-monitor linkage is asserted; the connection recorded here is the general architectural one between FATF status and global enhanced-due-diligence practice, not a finding about this jurisdiction's institutions.

Outlook

The FATF grey list is scheduled for its next substantive review at a future Plenary, and further movement on and off increased monitoring should be expected as a matter of ordinary cadence rather than as a surprise. Whether North Dakota-specific sanctions-architecture findings emerge will depend on research coverage reaching the subnational level in a future cycle; as at this writing, no such finding exists and none is projected.

3 Nov 2026 · fim-2026-11-03

Lead Signal

The only development of structural weight reaching North Dakota originates well outside the state. At its Plenary on 30 October 2026, 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, taking the list from twenty-two to eighteen with no new additions. For a landlocked agricultural and energy-producing state with no direct correspondent exposure to any of the four exiting jurisdictions, the significance is architectural rather than transactional: the move narrows, at the margin, the population of jurisdictions for which United States financial institutions are expected to apply heightened scrutiny as a matter of global standard-setting, a standard North Dakota-chartered and state-licensed institutions ultimately absorb through their correspondent banking relationships and federal examination posture rather than through any state-specific rule change.

No North Dakota-specific sanctions action, designation, or enforcement development tied to this signal was identified in the window. The Department of the Treasury Office of Foreign Assets Control continued routine maintenance of its sanctions list, including North Korea-related and Democratic Republic of Congo-related designations, in late October, but nothing in that maintenance activity carries a North Dakota nexus beyond the baseline fact that all state-chartered and state-licensed financial entities operate subject to the federal sanctions architecture as a floor.

Other Developments

No state-specific sanctions-architecture movement was identified. North Dakotas own financial-institution enforcement record, including the states finalized agreement with Sigue Corp, continues to sit on the public record maintained by the Department of Financial Institutions, but nothing in that record was dated or re-activated within the current window, and no new designation, delisting petition, or sanctions-adjacent licensing action touching a North Dakota-regulated entity surfaced in the material available.

Global list contraction leaves North Dakota's own exposure profile unchanged. The FATF move is the kind of event that reshapes the population of counterparties a bank's correspondent-risk team must flag, but it does so uniformly across every United States institution; it does not alter anything specific to North Dakota's chartering or licensing regime, and no local regulator statement responding to the Plenary outcome was identified.

Cross-Monitor Connections

A contraction in the FATF grey list is, by its nature, a signal that travels across every monitor tracking jurisdictional risk rather than one confined to sanctions architecture alone. Where a jurisdiction exits increased monitoring, the practical effect on enablement questions tracked elsewhere in the fleet, who facilitates flows through or around a formerly grey-listed jurisdiction, and on state-capture or conflict-finance questions tied to the Democratic Republic of Congo specifically, is better read in those monitors' own cycles. Nothing in the North Dakota material establishes a state-level link to either strand, so no further routing is asserted here.

Outlook

The FATF list is scheduled to be revisited at the Task Force's next Plenary, and the direction of travel communicated, contraction with no additions, is consistent with continued incremental de-listing activity rather than a reversal. Whether that continues as scheduled is itself uncertain; no commitment beyond the next Plenary cycle was stated in the material reviewed. For North Dakota specifically, the absence of any state-level sanctions-architecture movement is consistent with a stable baseline: the state's exposure to sanctions-related financial integrity risk continues to run through the federal programme and through the correspondent relationships of its state-chartered institutions, rather than through any distinct state instrument, and nothing in the window reviewed suggests that is changing.

25 Oct 2026 · fim-2026-10-25

Lead Signal

North Dakota surfaced two linked developments that together sketch how a small state regulator manages a crypto footprint it did not design from scratch. A thirty-four-state settlement resolved Bank Secrecy Act and anti-money-laundering violations tied to Coinme Inc.'s virtual-currency kiosk operations, with North Dakota receiving a ten-thousand-dollar share of a two-and-a-half-million-dollar total recovery. In parallel, the Bank of North Dakota confirmed that Roughrider Coin, a dollar-backed tokenized interbank-settlement asset built with VersaBank, Fiserv and Fireblocks, has been live since October 2026 and available to roughly ninety state banks and credit unions.

Taken together, these two items describe opposite ends of the same regulatory perimeter: enforcement against a kiosk operator under the state's existing money-transmitter statute, and a new piece of state-adjacent financial infrastructure appearing in the market without any visible bespoke anti-money-laundering guidance attached to it yet. Neither item required North Dakota to write new law; both ran through or around the architecture the state already has.

Other Developments

Personnel-bar orders at the Department of Financial Institutions. The Department issued orders perpetually prohibiting Monica Trevino Trousdale and Brianna Ricks from employment or participation in any entity it licenses. The underlying conduct was not disclosed in the public notices, which limits how far the development can be read, but the action itself confirms the Department continues to exercise its personnel-exclusion power under the existing licensing regime.

Consumer warning on kiosk fraud. The Department separately published a Crypto ATM FAQ resource flagging that scammers are increasingly using virtual-currency kiosks as part of fraud schemes. This is not a new rule; it is a standing consumer-education posture that sits alongside the kiosk licensing requirements already in force under North Dakota Century Code chapter 13-09.1, which requires kiosk operators to hold a money-transmitter licence and comply with Bank Secrecy Act and anti-money-laundering obligations.

The standing data-security and kiosk-licensing framework. Two statutory overlays continue unchanged: a GLBA-Safeguards-styled law requiring regulated financial corporations to notify the Commissioner within forty-five days of a notification event affecting five hundred or more consumers, and the kiosk-specific enhanced-due-diligence and transaction-analytics regime, including a daily transaction cap, added to the money-transmission chapter. Neither moved; both remain the backdrop against which the Coinme settlement and the Roughrider Coin launch are read.

Cross-Monitor Connections

The Roughrider Coin launch is a commercial product event with a cross-monitor dimension: the vendor, issuer, platform and infrastructure relationships among the Bank of North Dakota, VersaBank, Fiserv and Fireblocks are a payments-infrastructure and commercial-activity story carried in full detail elsewhere, and this brief treats it only for what it signals about compliance architecture rather than market structure. The Coinme settlement, conversely, sits squarely in anti-money-laundering territory and is the substantive analytical anchor here, even though its commercial and payments dimensions are tracked separately.

Outlook

The open question going is whether the Department of Financial Institutions will issue any guidance addressing where Roughrider Coin sits relative to the kiosk-focused virtual-currency provisions in chapter 13-09.1, given that the product is bank-issued rather than kiosk-distributed and currently operates without visible bespoke anti-money-laundering treatment. Absence of such guidance is not itself a violation, but it is a gap worth tracking as adoption among the roughly ninety participating institutions continues. On enforcement, the multistate settlement structure behind the Coinme resolution illustrates a pattern likely to recur: a state with a general money-transmitter statute but limited independent examination capacity for crypto-specific risk leans on coordinated multistate action rather than standalone supervisory findings.

18 Oct 2026 · fim-2026-10-18

Lead Signal

North Dakota's Department of Financial Institutions (NDDFI) joined a 34-state multistate consent settlement with Coinme Inc., a Seattle-based money transmitter and virtual-currency kiosk operator, resolving findings that Coinme's Bank Secrecy Act and anti-money-laundering program fell short of requirements. Under the settlement, dated 2026-10-08, Coinme will pay $2.5M across the coalition, with North Dakota's allocated share set at $10,000, and must terminate its approximately 66 North Dakota kiosk locations by 2027-01-01 or face a further $4M penalty, alongside an independent BSA/AML compliance review. The episode is read architecturally rather than as an isolated incident: North Dakota licenses virtual-currency kiosk operators under N.D.C.C. ch. 13-09.1, with kiosk-specific obligations including mandatory blockchain analytics and designated compliance and customer-protection officers, yet those state-level licensing conditions coexisted with the AML program deficiencies that triggered the multistate action. The finding illustrates that state licensing authority and the adequacy of an operator's BSA/AML controls are tracked and enforced through separate channels: licensing does not itself certify compliance-program sufficiency, and the gap was closed here through coordinated multistate examination rather than through North Dakota's own kiosk statute.

Other Developments

Individual participation-prohibition orders. NDDFI Commissioner Lise Kruse issued orders around 2026-10-16 perpetually prohibiting Monica Trevino Trousdale and Brianna Ricks from employment or participation in the affairs of any NDDFI-licensed bank, credit union, or financial institution. The public notice did not publish the underlying predicate conduct, and no statutory citation for the conduct itself could be identified from the available record; the orders are cross-pillar in character, falling outside a single AML or sanctions lens, and stand as market-access enforcement against named individuals rather than against an institution.

Coinme market exit. The settlement functions simultaneously as a commercial event: Coinme's wind-down of its North Dakota kiosk network by the start of 2027 removes a licensed participant from the state's virtual-currency kiosk market, with the exit itself a direct and disclosed consequence of the BSA/AML findings rather than an independent business decision.

Cross-Monitor Connections

The Coinme settlement sits squarely at the intersection of financial-integrity and payments-market signal: the same enforcement action that evidences a BSA/AML compliance failure is also a market-structure event removing a kiosk operator from a state market, relevant to monitors tracking payment-corridor and non-bank payment-institution dynamics. The participation-prohibition orders against two named individuals similarly carry a market-access dimension beyond the AML/CTF frame, bearing on any monitor tracking licensing and conduct standing for financial-institution personnel in enabler and non-enabler jurisdictions alike.

Outlook

The 2027-01-01 wind-down deadline for Coinme's North Dakota kiosk operations is the operative date to watch: failure to complete the exit by that date exposes Coinme to a further $4M penalty under the settlement terms, as scheduled. Whether North Dakota pursues any state-specific consent action beyond its participation in the multistate settlement remains an open question not resolved by the current record. North Dakota's underlying AML/CTF architecture, resting on the federal Bank Secrecy Act as enforced by FinCEN and administered at the state level through NDDFI's licensing authority under N.D.C.C. ch. 13-09.1, is unchanged by this cycle's enforcement activity.

12 Oct 2026 · fim-2026-10-11

Lead Signal

The most consequential development touching North Dakota this cycle is not an enforcement action but a product launch with structural implications for the integrity perimeter around state-chartered banking. On October 1, 2026, the Bank of North Dakota went live with Roughrider Coin, a wholesale, institution-only, dollar-backed stablecoin issued on Fiserv's digital asset platform. VersaBank USA, N.A., an OCC-chartered bank, serves as issuer; Fireblocks provides tokenization; settlement runs on Solana. This is the first instance of a US state-owned bank bringing a stablecoin to live production, and it does so inside the window created by the GENIUS Act's state-issuer carve-out, before federal 'substantial similarity' implementing rules have been finalized. The architecture matters more than the headline: a correspondent-style wholesale instrument, confined to interbank and institutional counterparties, is being operated by a state entity under a federal exemption whose final contours are not yet settled, meaning the compliance perimeter Roughrider Coin currently sits inside is provisional rather than durable.

Around this lead signal, the sanctions architecture moved on multiple fronts this cycle, though none with a direct North Dakota nexus. OFAC designated the A7 Network as a Transnational Criminal Organization spanning Russia, Kyrgyzstan, Nigeria, and Zimbabwe, and advanced cartel-leadership and official-corruption designations tied to Mexico's Mexicali trafficking corridor. Separately, the Cuban Assets Control Regulations were tightened effective September 29, 2026, narrowing general licenses and eliminating the U-turn transaction authorization.

Other Developments

Mexico cartel-leadership and corruption designations. OFAC designated Ismael Zambada Sicairos, an alleged leader of the 'Los Mayos' faction, along with associated laundering-facilitator businesses and Mexican officials accused of corruption connected to the Mexicali trafficking corridor. This designation is sourced to a single specialist sanctions-tracking blog rather than an independently re-verified OFAC primary notice, which caps the confidence assigned to this specific finding at the probable tier pending direct corroboration.

Cuba sanctions tightened. OFAC amended the Cuban Assets Control Regulations to expand the Cuba Restricted List, eliminate the U-turn general license, remove the independent-entrepreneur account-maintenance authorization, and narrow educational and professional travel general licenses, effective September 29, 2026. This is a confirmed regulatory tightening rather than an isolated enforcement action, and it widens the operative distance between US and EU or UK sanctions practice on Cuba.

North Dakota individual enforcement action. The North Dakota Department of Financial Institutions issued an order suspending a former bank employee from employment or participation in the affairs of any North Dakota-licensed financial corporation, financial institution, or credit union. This is a routine individual-conduct matter and carries no connection to the Roughrider Coin launch or to any broader state-level AML variance; it is the only North Dakota-specific regulatory action identified this cycle.

Statutory delegation deadline approaching. The Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 requires OFAC to begin delegating SDN designation authority by October 18, 2026, with review every 180 days thereafter. This forward-looking statutory milestone was reported by a specialist sanctions brief and represents a near-term compliance date for institutions tracking the evolving architecture of US sanctions administration.

Cross-Monitor Connections

The Roughrider Coin launch sits precisely at the intersection this monitor shares with payments and digital-asset trackers elsewhere in the fleet: a wholesale stablecoin issued by a state-owned bank, tokenized by a third-party infrastructure provider, and settled on a public blockchain, is simultaneously a financial-integrity question (what AML/CTF and sanctions-screening obligations attach to a correspondent-style token moving between institutional counterparties) and a payments-architecture question (how such an instrument interoperates with existing settlement rails once federal implementing rules finalize). The Mexico designations, meanwhv ever, connect directly to the conflict-finance and enabler-jurisdiction reading of the same underlying facts: cartel leadership, laundering-facilitator businesses, and officials accused of corruption were named together, which is the pattern this monitor treats as a state-capture signal rather than a routine narcotics-sanctions action in isolation.

Outlook

The GENIUS Act's 'substantial similarity' implementing rules are expected to finalize in Q4 2026, as scheduled; that determination will decide whether North Dakota's reliance on the state-issuer carve-out for Roughrider Coin remains viable without further state legislative action. Until that rule finalizes, the compliance architecture underneath the first live state-bank stablecoin in the United States remains provisional. On sanctions, the October 18, 2026 statutory deadline for OFAC's first SDN-delegation tranche under the Graham Act is a near-term date to track, and the October 2026 FATF Plenary outcomes, not yet published as of this dispatch, may bear on the grey list and on pending mutual-evaluation publications for Canada and Turkiye.

28 Sep 2026 · fim-2026-09-28

Lead Signal

North Dakota's 2025 legislative session produced a structural, if narrow, tightening of the states anti-money-laundering architecture, and the mechanism is worth foregrounding because it is not a standalone AML statute but a re-anchoring of AML/CTF duty inside the states money-transmitter licensing chapter. Chapter 13-09 of the North Dakota Century Code, the original money-transmitter law, was repealed and replaced by chapter 13-09.1, the Money Transmission Modernization Act, which now carries its own dedicated section, 13-09.1-22, headed Anti-money laundering - Countering the financing of terrorism reports. The section heading and the chapter renumbering are confirmed against the official Century Code table of contents, though the full substantive text describing reporting thresholds and process was not independently retrieved this cycle. The same chapter was then used, in the same legislative session, as the vehicle to bring a previously ungoverned activity into licensed scope: HB 1447 requires North Dakota-licensed virtual-currency kiosk operators to use blockchain analytics software, appoint a named compliance officer, and cap transactions at 2,000 dollars a day, in force since August 1, 2025. The specific detail of the blockchain-analytics and named-officer requirement rests on a lower-tier secondary characterisation not yet cross-checked against enrolled bill text, though the in-force status and codification at NDCC sections 13-09.1-50 through -54 are independently confirmed.

Other Developments

A rejected carve-out leaves mining and node-operation scope unresolved. HB 1239, a bill that would have exempted digital-asset miners and blockchain node operators from North Dakota's money-transmitter license, failed on House second reading by a wide margin, 14 yeas to 75 nays, on February 17, 2025. The decisiveness of the vote is itself the signal: this was not a near-miss procedural failure but a clear legislative rejection of a mining/node exemption model that a number of other states have adopted. The result is that North Dakota's licensing perimeter for on-chain infrastructure activity remains governed by the general money-transmitter standard rather than any bespoke exemption, an outcome that sits alongside, rather than in tension with, the kiosk-licensing extension enacted the same session.

The AML section's operative mechanics remain a research gap. Because only the section heading of 13-09.1-22 was confirmed this cycle, downstream readers should treat the actual reporting thresholds, timing, and SAR-equivalent process as unverified pending fuller retrieval of the statutory text.

Cross-Monitor Connections

The kiosk-licensing and compliance-control findings in this cycle sit squarely at the intersection of financial-integrity and payments-regulation analysis: the same HB 1447 provisions that create an AML-adjacent compliance-technology obligation for kiosk operators also define a licensing and consumer-facing transaction-cap regime that a payments-focused reading would foreground differently. Readers tracking the crypto-specific angle of the same underlying facts, including the licensing mechanics and the failed mining exemption, will find a parallel treatment developed independently for the digital-asset monitor's own audience.

Outlook

With the 2025 session closed and HB 1447 in force since August 2025, the near-term outlook for North Dakota centres on implementation and verification rather than further legislative change: confirming the substantive reporting mechanics of section 13-09.1-22, and cross-checking the kiosk operator control requirements against enrolled bill text now that only a secondary characterisation supports the specific compliance-officer and analytics-software detail. The rejected HB 1239 exemption model may resurface in a future session as a renewed legislative vehicle, though as of this cycle no such reintroduction has been identified, and any resolution of the miner/node-operator licensing question will most likely depend on either a new bill or supervisory guidance from the Department of Financial Institutions rather than judicial or enforcement action.

Domain intelligence (D1–D8)

D1 Sanctions

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Sanctions

The sanctions-architecture picture relevant to North Dakota this cycle is defined by a single global movement: the Financial Action Task Force reduced its list of jurisdictions under increased monitoring from 22 to 18 at its 30 October 2026 Plenary. Bulgaria, Cote d Ivoire, the Democratic Republic of Congo and Monaco were removed, and no jurisdiction was added. The black list naming Iran, Myanmar and North Korea for coordinated countermeasures was left unchanged. This is a confirmed finding, corroborated across FATF's own list page and independent wire-service reproductions of the Plenary outcome, with no disagreement among them on either the identity of the four removals or the nil-addition result.

Continue reading

The designation framework distinguishes carefully between tiers of concern. A jurisdiction named on the FATF call-for-action list sits in the category that attracts comprehensive countermeasures; a jurisdiction on increased monitoring, as the four removed jurisdictions were until 30 October 2026, sits in a materially lighter category calling for heightened scrutiny rather than coordinated countermeasures. Movement from the monitoring list to no list at all removes even that lighter designation. None of this changes the separate and more serious designations that remain in force against Iran, Myanmar and North Korea, which continue under the comprehensive-countermeasures category and were not before the Plenary this cycle.

For North Dakota specifically, this is architecture, not incident: nothing in the record indicates any North Dakota institution, transaction, or supervisory action connected to any of the four jurisdictions removed, or to the three jurisdictions whose status was unchanged. The relevance to this jurisdiction is indirect and institutional rather than direct and local. Banks, money-transmitters and other regulated entities operating in North Dakota apply risk-based due diligence calibrated in part by reference to the FATF list, and a reduction in the list's size is capable of marginally easing the enhanced-due-diligence burden attached to counterparties previously linked to Bulgaria, Cote d Ivoire, the Democratic Republic of Congo or Monaco. No claim is made here that any North Dakota institution has in fact adjusted its practice in response; the record available this cycle does not extend that far, and the honest position is to note the global movement and stop there rather than infer a local consequence that has not been evidenced.

It is also worth stating plainly what this cycle's record does not contain. No North Dakota-specific sanctions enforcement action, licensing condition, or Treasury Department of Financial Institutions guidance document responding to the FATF Plenary outcome was identified. The absence of such material is not itself evidence that nothing is happening locally; it reflects the limits of what this cycle's research reached, and it is recorded here as an absence rather than papered over with inference.

Outlook

The FATF calendar runs on a fixed Plenary cadence, and the next substantive review of both the increased-monitoring list and the call-for-action list should be expected in the ordinary course rather than as a surprising event. Whether any of the jurisdictions newly off the list are added back, and whether any new jurisdiction is added for the first time, remains to be seen at the next Plenary; no prediction is offered here beyond noting that such movement is a structural feature of the process rather than an unusual occurrence. For North Dakota, the practical question going forward is whether future cycles surface any jurisdiction-specific application of this global architecture to local institutions; as things stand, none has been identified, and the position should be read as a structural backdrop rather than as a local development in its own right.

Judgment: FATF grey list shrank from 22 to 18 jurisdictions, a confirmed global movement not specific to US-ND. Probable
Cumulative analysis

Sanctions Architecture and Evasion

Two sanctions-architecture developments surfaced this cycle. On August 7, 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control designated a network of cryptocurrency exchanges for facilitating financing to Iran's Islamic Revolutionary Guard Corps-Qods Force, an action Treasury linked to Iranian attacks on commercial vessels transiting the Strait of Hormuz. The designation is Tier-1 sourced directly from Treasury's press release and carries High confidence; it is architecturally significant because it targets crypto-exchange infrastructure as a sanctions-evasion conduit rather than a single named individual or entity, extending OFAC's designation practice onto the exchange layer that intermediates IRGC-linked financial flows. For obliged entities with VASP counterparty exposure, this is the kind of designation that a properly configured sanctions-screening program, including blockchain-analytics tooling, should be expected to catch at the counterparty level.

Separately, the FATF grey list continued to churn. Cambodia was removed at the February 2026 plenary, a decision secondary reporting attributes to significant demonstrated progress against its AML/CFT action plan since its original 2019 listing; this removal carries Assessed confidence, resting on a single Tier-3 corroborating source rather than a directly retrieved FATF statement for this specific removal. Laos, by contrast, remained on the grey list through the June 2026 plenary, with the Tier-3 aggregator tracker cross-checked against the FATF's own Tier-1 February 2026 listing, which also shows Lao PDR still listed. The broader tracker record shows the February and June 2026 plenaries adding Kuwait and Papua New Guinea, and Bosnia and Herzegovina and Iraq respectively — an active plenary cycle by listing volume, even though North Dakota itself has no direct exposure to either the Cambodia removal or the Laos continuation.

Applying the three-pillar lens, this cycle's sanctions signal sits squarely in the CTF pillar rather than the AML pillar: the OFAC designation responds to a terrorism-financing nexus channelled through crypto-exchange infrastructure, a pattern this monitor treats as structurally distinct from the money-laundering-driven AML enforcement volume that typically dominates sanctions reporting. CTF and CPF findings are often under-represented relative to AML enforcement simply because AML actions generate more volume; this cycle's designation is a useful corrective data point precisely because it is CTF-pillar and Tier-1 sourced. It is also worth noting what did not happen this cycle: no North Dakota enforcement action tied to sanctions-screening failures was identified, and the state's incorporation-by-reference approach to federal BSA/OFAC obligations means the absence of independent state sanctions-enforcement activity is itself consistent with the state's designed architecture rather than a gap — North Dakota does not maintain a sanctions-enforcement function distinct from the federal layer, so silence here is structural, not evidentiary of enablement.

Outlook

Watch for a possible pattern of further Treasury action against crypto-exchange infrastructure linked to Iranian financing, given the August 7 designation's focus on exchanges rather than end users. On the FATF side, the pace of listing additions across the February and June 2026 plenaries suggests an active monitoring cycle; whether any additional jurisdictions move on or off the list at the next plenary will matter more for global-architecture tracking than for North Dakota specifically, absent a confirmed state-level sanctions nexus.

domain_sub_briefs · D1 · Cumulative analysis
Periodic updates (3)
4 Nov 2026 · fim-2026-11-01

Sanctions

The sanctions-architecture picture relevant to North Dakota is defined by a single global movement: the Financial Action Task Force reduced its list of jurisdictions under increased monitoring from 22 to 18 at its 30 October 2026 Plenary. Bulgaria, Cote d Ivoire, the Democratic Republic of Congo and Monaco were removed, and no jurisdiction was added. The black list naming Iran, Myanmar and North Korea for coordinated countermeasures was left unchanged. This is a confirmed finding, corroborated across FATF's own list page and independent wire-service reproductions of the Plenary outcome, with no disagreement among them on either the identity of the four removals or the nil-addition result.

The designation framework distinguishes carefully between tiers of concern. A jurisdiction named on the FATF call-for-action list sits in the category that attracts comprehensive countermeasures; a jurisdiction on increased monitoring, as the four removed jurisdictions were until 30 October 2026, sits in a materially lighter category calling for heightened scrutiny rather than coordinated countermeasures. Movement from the monitoring list to no list at all removes even that lighter designation. None of this changes the separate and more serious designations that remain in force against Iran, Myanmar and North Korea, which continue under the comprehensive-countermeasures category and were not before the Plenary.

For North Dakota specifically, this is architecture, not incident: nothing in the record indicates any North Dakota institution, transaction, or supervisory action connected to any of the four jurisdictions removed, or to the three jurisdictions whose status was unchanged. The relevance to this jurisdiction is indirect and institutional rather than direct and local. Banks, money-transmitters and other regulated entities operating in North Dakota apply risk-based due diligence calibrated in part by reference to the FATF list, and a reduction in the list's size is capable of marginally easing the enhanced-due-diligence burden attached to counterparties previously linked to Bulgaria, Cote d Ivoire, the Democratic Republic of Congo or Monaco. No claim is made here that any North Dakota institution has in fact adjusted its practice in response; the record available does not extend that far, and the honest position is to note the global movement and stop there rather than infer a local consequence that has not been evidenced.

It is also worth stating plainly what the record does not contain. No North Dakota-specific sanctions enforcement action, licensing condition, or Treasury Department of Financial Institutions guidance document responding to the FATF Plenary outcome was identified. The absence of such material is not itself evidence that nothing is happening locally; it reflects the limits of what the research reached, and it is recorded here as an absence rather than papered over with inference.

Outlook

The FATF calendar runs on a fixed Plenary cadence, and the next substantive review of both the increased-monitoring list and the call-for-action list should be expected in the ordinary course rather than as a surprising event. Whether any of the jurisdictions newly off the list are added back, and whether any new jurisdiction is added for the first time, remains to be seen at the next Plenary; no prediction is offered here beyond noting that such movement is a structural feature of the process rather than an unusual occurrence. For North Dakota, the practical question going forward is whether future cycles surface any jurisdiction-specific application of this global architecture to local institutions; as things stand, none has been identified, and the position should be read as a structural backdrop rather than as a local development in its own right.

3 Nov 2026 · fim-2026-11-03

Sanctions

The sanctions-architecture picture relevant to North Dakota is dominated entirely by a global event rather than any local one. At its 30 October 2026 Plenary, 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. The list now stands at eighteen jurisdictions, down from twenty-two, with no new jurisdictions added at this Plenary. Secondary wire reporting describes the four exiting jurisdictions as having completed the action plans the Task Force had required of them, which is the formal basis on which a jurisdiction exits increased monitoring rather than remaining subject to it indefinitely.

For North Dakota, a state whose financial sector consists principally of state-chartered banks, credit unions and money-transmitter licensees supervised by the Department of Financial Institutions, this kind of global list movement does not translate into any direct state-level action. North Dakota does not maintain its own sanctions list or its own grey-list-equivalent instrument; its institutions inherit sanctions-architecture obligations through the federal Bank Secrecy Act and anti-money-laundering framework, and through the Office of Foreign Assets Control's designation and delisting activity, which continued on its ordinary maintenance cadence in late October with North Korea-related and Democratic Republic of Congo-related designations. No designation, delisting, or licensing action specific to a North Dakota-chartered or -licensed entity was identified as connected to either the FATF Plenary outcome or the OFAC maintenance activity in the window examined.

The states own enforcement record remains visible on the public docket maintained by the Department of Financial Institutions, which continues to show the states finalized agreement with Sigue Corp. That record is a standing feature of the state's regulatory posture rather than a development dated to this cycle, and nothing in the material reviewed indicates it was reopened, amended, or extended in the window.

What the FATF contraction does change, at the margin, is the population of jurisdictions against which United States financial institutions, including those chartered or licensed in North Dakota, are expected to calibrate enhanced due diligence as a matter of the FATF call-for-action and increased-monitoring framework. A jurisdiction's removal from increased monitoring is a reduction in the global backdrop of heightened scrutiny, not an elimination of risk; the four jurisdictions exiting do so because they completed specific, previously identified action plans, and their prior listing history remains part of the record any institution doing business connected to them would reasonably consider. North Dakota institutions with correspondent relationships or customer relationships touching any of the four jurisdictions absorb this change through their own risk-based compliance programmes rather than through any instruction issued at the state level, since North Dakota has no independent high-risk-jurisdiction list of its own and defers to the federal and FATF frameworks on this question.

No divergence between the FATF list and any other list relevant to North Dakota institutions, such as the lists maintained by the European Union or by the United Kingdom under its post-2026 regime, was identified as materially affecting North Dakota, and no claim is made here about any list other than the FATF increased-monitoring list, which is the only list movement evidenced in the material reviewed.

Outlook

The Task Force is expected to revisit its list again at a future Plenary, and the direction evidenced, contraction with no additions, is consistent with continued incremental de-listing rather than reversal, though whether that pattern holds at the next sitting is not established by anything reviewed here and should be treated as unresolved rather than assumed. For North Dakota specifically, the absence of any state-level sanctions development in this window is consistent with a stable baseline: the states sanctions-architecture exposure continues to run through the federal programme and through the risk-based compliance programmes of its state-chartered and state-licensed institutions, and nothing in the material reviewed indicates that channel is under near-term pressure to change.

12 Oct 2026 · fim-2026-10-11

Sanctions

This cycle's sanctions-architecture signal centers on three distinct actions, none with a North Dakota nexus but each material to the broader sanctions landscape institutions must screen against. OFAC blocked all property and interests in property of the A7 Network, a Transnational Criminal Organization operating across Russia, Kyrgyzstan, Nigeria, and Zimbabwe, under Executive Order 13581 as amended. This is a confirmed designation drawn from the Federal Register notice itself, and it falls into the architecture-over-incident category this monitor foregrounds: a cross-jurisdictional network designation signals an evolving map of TCO-linked financial flows rather than a single discrete enforcement episode.

Separately, OFAC designated Ismael Zambada Sicairos, an alleged leader of the 'Los Mayos' faction of Sinaloa Cartel leadership, together with associated laundering-facilitator businesses and Mexican officials accused of corruption tied to the Mexicali trafficking corridor. This designation was reported by a single specialist sanctions-tracking blog rather than independently re-verified against a direct OFAC primary notice, and confidence is accordingly held at the probable tier pending corroboration. The pairing of cartel leadership with named corrupt officials in the same action is itself a structural signal, read elsewhere in this cycle under conflict finance, because it names both the illicit-proceeds generator and the facilitating state apparatus in a single sweep rather than treating them as separate enforcement tracks.

Third, OFAC amended the Cuban Assets Control Regulations effective September 29, 2026, expanding the Cuba Restricted List, eliminating the U-turn general license, removing the independent-entrepreneur account-maintenance authorization, and narrowing educational and professional travel general licenses. This is a confirmed regulatory tightening, not an isolated case, and it widens the divergence between US sanctions practice on Cuba and that of the EU or UK, a divergence institutions with cross-border Cuba-adjacent exposure must now navigate under two materially different regimes.

A forward-looking statutory development also bears watching: the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 requires OFAC to begin delegating SDN designation authority by October 18, 2026, with a review cycle every 180 days thereafter. This deadline, reported by a specialist sanctions brief, had not yet passed as of this cycle and represents a near-term structural change to how SDN designations are administered going forward, independent of any single enforcement action.

No North Dakota-specific sanctions nexus was identified this cycle. The state's only enforcement-adjacent action, a routine individual-employment suspension by the state's financial-institutions regulator, is unconnected to any of the sanctions developments above and is addressed separately from the sanctions architecture.

Outlook

The October 18, 2026 statutory deadline for OFAC's first SDN-delegation tranche under the Graham Act is the most concrete near-term date to track; its review-every-180-days structure signals a durable change to designation administration rather than a one-off event. The widening gap between US and EU/UK sanctions treatment of Cuba, evident in the September 29, 2026 CACR amendments, is likely to remain a live compliance friction point for institutions operating across those regimes. The Mexico cartel-leadership and corruption designations warrant continued monitoring for direct OFAC primary-source corroboration, which would allow the current probable-confidence finding to be upgraded.

D2 Beneficial Ownership

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Judgment: No US-ND-specific beneficial-ownership development identified this cycle; coverage thin. Uncertain

D3 Enabler Jurisdictions

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Enabler Jurisdictions and Professional Facilitators

North Dakota's Money Brokers Act was amended by HB 1127, effective August 1, 2025, to define "loan" to include any "alternative financing product" that the Department of Financial Institutions later designates. This is a contingent enabler-perimeter development rather than a realized one: the amendment gives DFI discretionary authority to bring currently unlicensed alternative-financing arrangements within the Money Brokers Act's licensing scope, but DFI has not yet exercised that discretion. Whether this closes a genuine enabler gap or simply preserves DFI's existing latitude therefore depends on an administrative designation that has not occurred as of this cycle. Sourcing for this development is a single Tier-3 law-firm secondary source; no Tier-1 confirmation of DFI's designation activity was reached this cycle.

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Separately, a coordinated multistate enforcement action against Bayview Asset Management LLC and affiliates, taken through the North Dakota Department of Financial Institutions in conjunction with CSBS, addressed deficient cybersecurity practices connected to a data breach affecting 5.8 million customers. This is Tier-1 sourced from the ND DFI enforcement-actions page and reflects state-level enforcement capacity being exercised against a facilitator-adjacent control failure rather than an enabler-jurisdiction licensing gap per se; the penalty amount was not confirmed from accessible source text this cycle.

Outlook

The determinative question for this domain is whether DFI exercises its HB 1127 designation authority. Until it does, North Dakota's enabler-jurisdiction posture on alternative financing products remains unresolved rather than closed or open, and this monitor will treat it as a watch item pending confirmation.

Judgment: No US-ND-specific enabler-jurisdiction development identified this cycle. Uncertain

D4 Conflict Finance

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Conflict Finance

The most significant conflict-finance signal this cycle is the October 5, 2026 OFAC action against Sinaloa Cartel leadership, specifically Ismael Zambada Sicairos, an alleged leader of the 'Los Mayos' faction, together with associated laundering-facilitator businesses spanning currency exchange, real estate, security, and entertainment sectors, and Mexican officials accused of corruption tied to the Mexicali trafficking corridor. Read through the conflict-finance lens rather than the sanctions-architecture lens alone, this action is notable for what it names together in a single sweep: the illicit-proceeds generator, the laundering infrastructure that moves those proceeds into the licit economy, and the state officials alleged to have facilitated or tolerated the arrangement. That combination is the pattern this monitor treats as a direct state-capture and conflict-finance signal, distinct from a narcotics-sanctions action that targets only the trafficking organization itself.

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This designation was reported by a single specialist sanctions-tracking blog rather than independently re-verified against a direct OFAC primary notice, which caps confidence at the probable tier for the specific details of which businesses and officials were named. The structural reading, however, that this action sits in a continuum with earlier 2025 FinCEN Section 2313a special measures against named Mexican financial institutions and the June 2026 FinCEN alert on fiscal-fuel-theft and tax-evasion schemes along the southern border, is a pattern worth tracking even while individual designation details await corroboration.

No North Dakota nexus exists in this development; it is a Mexico-domiciled conflict-finance signal with no connection identified to the Roughrider Coin launch or to any North Dakota-chartered or North Dakota-domiciled entity.

Outlook

The Mexicali corridor designations should be read as part of a continuing pattern of US financial-crime enforcement attention to Mexican trafficking-adjacent laundering networks and official corruption, following the 2025 special measures and the June 2026 fuel-smuggling alert. Direct OFAC primary-source corroboration of the specific October 5, 2026 designations would allow this finding to move from probable to confirmed confidence, and continued monitoring of the Mexicali corridor pattern is warranted given the structural combination of trafficking, laundering infrastructure, and alleged official corruption named together in this action.

Judgment: No conflict-finance development identified for US-ND this cycle. Uncertain

D5 Crypto / Digital Assets / Financial Innovation

no_changewatchstanding position

Crypto, Digital Assets, and Financial Innovation

Two developments define this cycle's digital-asset picture for North Dakota, and they pull in different directions. The first is enforcement: Coinme Inc. reached a thirty-four-state settlement of two-and-a-half-million dollars resolving Bank Secrecy Act and anti-money-laundering violations connected to its virtual-currency kiosk business, with North Dakota's share set at ten thousand dollars. The underlying statute is the state's money-transmitter licensing chapter, which requires kiosk operators to hold a licence and comply with federal Bank Secrecy Act and anti-money-laundering requirements. The settlement confirms the framework can be enforced, but it was enforced through a coordinated multistate action rather than a standalone North Dakota examination finding, which says something about where the state's independent crypto-specific supervisory capacity currently sits.

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The second is a new piece of infrastructure appearing largely outside that enforcement lens. The Bank of North Dakota confirmed the live operation of Roughrider Coin, a dollar-backed tokenized asset used for interbank settlement, built in partnership with VersaBank as issuer, Fiserv for platform integration, and Fireblocks for tokenisation and custody infrastructure. Adoption is voluntary and reported at roughly ninety participating banks and credit unions as of early October 2026. No North Dakota Department of Financial Institutions guidance addressing the product's anti-money-laundering or Bank Secrecy Act treatment has been located. That silence is itself notable: a live, materially adopted tokenized settlement instrument is operating in the state's banking sector without a visible bespoke supervisory statement placing it inside or outside existing money-transmission or kiosk-specific rules.

A consumer-facing warning rounds out the picture. The Department published a Crypto ATM FAQ resource noting that scammers increasingly use virtual-currency kiosks as part of fraud schemes, and cautioning that no legitimate business or government agency demands cryptocurrency payment to resolve a problem. This sits alongside, rather than inside, the kiosk-specific enhanced-due-diligence and transaction-analytics requirements, including a daily transaction cap, that were added to the money-transmission statute and remain unchanged this cycle.

Read together, the architecture here is a general-purpose money-transmitter and kiosk-licensing regime doing double duty: it is actively enforced against kiosk operators, as the Coinme settlement shows, but it has not yet visibly extended its reach, or been confirmed not to extend its reach, to a bank-issued tokenized settlement asset operating at meaningful scale within the state's own banking infrastructure.

Outlook

The principal open question is regulatory classification: whether the Department of Financial Institutions will state, one way or another, whether Roughrider Coin falls within the virtual-currency provisions of the kiosk-licensing chapter or sits entirely outside them as a bank-issued instrument. Given the product's scale among community banks and credit unions, continued silence on that point is itself a condition worth monitoring rather than a neutral fact. On enforcement, the multistate settlement structure behind the Coinme resolution is likely to recur as the default mechanism for a state with general money-transmitter authority but limited independent crypto-specific examination capacity; a future standalone North Dakota enforcement action, were one to occur, would mark a different and more assertive posture than what this cycle shows.

Judgment: No US-ND-specific crypto/digital-asset AML development identified this cycle; secondary reporting suggests FATF flagged virtual-asset misuse as a priority but this was not independently verified. Uncertain
Cumulative analysis

Crypto, Digital Assets, and Financial Innovation

North Dakota's HB 1447 brings cryptocurrency-kiosk operators within the state's money-transmitter licensing regime under NDCC ch. 13-09.1, extending an existing licensing chapter rather than creating a new one. The statute requires crypto-kiosk operators to hold a North Dakota money transmitter license, deploy blockchain-analytics software for suspicious-activity detection, appoint a compliance officer, file quarterly reports, and cap a new user's transactions at two thousand dollars during their early transactions. This finding is corroborated across two independent Tier-3 press sources but has not yet been confirmed against a Tier-1 ND.gov or ndlegis.gov bill-status record, so confidence is Assessed rather than High pending that primary-source check.

Structurally, this is a jurisdiction responding to a fraud typology — crypto-kiosk-facilitated fraud — by extending an existing money-transmission licensing chapter rather than building bespoke crypto legislation from scratch. North Dakota did not create a new stand-alone virtual-currency-business licence category; it treated crypto kiosks as a subset of money transmission already regulated under 13-09.1, meaning the AML/CFT reporting duties, bonding, and examination powers that attach to money-transmitter licensees under existing law now attach to crypto-kiosk operators as well.

The blockchain-analytics mandate deserves particular attention from a financial-innovation perspective: North Dakota has, by statute, required a specific class of crypto-adjacent obliged entity to deploy on-chain analytics tooling as a licensing condition, a legislature directly mandating a compliance-technology capability rather than leaving analytics adoption to institutional risk appetite. No state-specific token-classification framework, tax-treatment statute, or cross-border-transfer restriction beyond the federal BSA/OFAC baseline was identified for North Dakota this cycle; the HB 1447 licensing extension is the sole confirmed crypto-specific development.

Outlook

The principal open question is whether HB 1447 has in fact been signed into law and what its confirmed effective date is; no Tier-1 ND.gov or ndlegis.gov source was reached this cycle to close that gap, and the finding should be treated as Assessed rather than confirmed until a primary source is located. If confirmed, the compliance-officer and quarterly-reporting requirements will be the first concrete test of how North Dakota's DFI supervises the newly-licensed kiosk sub-sector.

domain_sub_briefs · D5 · Cumulative analysis
Standing baseline position

ND DFI joined a 34-state $2.5M BSA/AML settlement with crypto-kiosk operator Coinme (announced 2026-10-08), requiring Coinme to exit the virtual-currency-kiosk business (66 ND locations) by 2027-01-01.

Periodic updates (4)
25 Oct 2026 · fim-2026-10-25

Crypto, Digital Assets, and Financial Innovation

Two developments define the digital-asset picture for North Dakota, and they pull in different directions. The first is enforcement: Coinme Inc. reached a thirty-four-state settlement of two-and-a-half-million dollars resolving Bank Secrecy Act and anti-money-laundering violations connected to its virtual-currency kiosk business, with North Dakota's share set at ten thousand dollars. The underlying statute is the state's money-transmitter licensing chapter, which requires kiosk operators to hold a licence and comply with federal Bank Secrecy Act and anti-money-laundering requirements. The settlement confirms the framework can be enforced, but it was enforced through a coordinated multistate action rather than a standalone North Dakota examination finding, which says something about where the state's independent crypto-specific supervisory capacity currently sits.

The second is a new piece of infrastructure appearing largely outside that enforcement lens. The Bank of North Dakota confirmed the live operation of Roughrider Coin, a dollar-backed tokenized asset used for interbank settlement, built in partnership with VersaBank as issuer, Fiserv for platform integration, and Fireblocks for tokenisation and custody infrastructure. Adoption is voluntary and reported at roughly ninety participating banks and credit unions as of early October 2026. No North Dakota Department of Financial Institutions guidance addressing the product's anti-money-laundering or Bank Secrecy Act treatment has been located. That silence is itself notable: a live, materially adopted tokenized settlement instrument is operating in the state's banking sector without a visible bespoke supervisory statement placing it inside or outside existing money-transmission or kiosk-specific rules.

A consumer-facing warning rounds out the picture. The Department published a Crypto ATM FAQ resource noting that scammers increasingly use virtual-currency kiosks as part of fraud schemes, and cautioning that no legitimate business or government agency demands cryptocurrency payment to resolve a problem. This sits alongside, rather than inside, the kiosk-specific enhanced-due-diligence and transaction-analytics requirements, including a daily transaction cap, that were added to the money-transmission statute and remain unchanged.

Read together, the architecture here is a general-purpose money-transmitter and kiosk-licensing regime doing double duty: it is actively enforced against kiosk operators, as the Coinme settlement shows, but it has not yet visibly extended its reach, or been confirmed not to extend its reach, to a bank-issued tokenized settlement asset operating at meaningful scale within the state's own banking infrastructure.

Outlook

The principal open question is regulatory classification: whether the Department of Financial Institutions will state, one way or another, whether Roughrider Coin falls within the virtual-currency provisions of the kiosk-licensing chapter or sits entirely outside them as a bank-issued instrument. Given the product's scale among community banks and credit unions, continued silence on that point is itself a condition worth monitoring rather than a neutral fact. On enforcement, the multistate settlement structure behind the Coinme resolution is likely to recur as the default mechanism for a state with general money-transmitter authority but limited independent crypto-specific examination capacity; a future standalone North Dakota enforcement action, were one to occur, would mark a different and more assertive posture than what shows.

18 Oct 2026 · fim-2026-10-18

Crypto, Digital Assets, and Financial Innovation

North Dakota's crypto-kiosk regime centres on N.D.C.C. ch. 13-09.1, which requires a virtual-currency kiosk operator to hold a North Dakota money transmitter licence, deploy blockchain analytics to detect and prevent suspicious activity, and designate both a full-time compliance officer and a full-time customer-protection officer. This cycle's material development is North Dakota's participation in a 34-state, $2.5M multistate consent settlement with Coinme Inc., a Seattle-based money transmitter and kiosk operator, following findings that Coinme's Bank Secrecy Act and anti-money-laundering program did not meet requirements. North Dakota's allocated share of the settlement is $10,000. Under the settlement terms, Coinme must terminate its approximately 66 North Dakota kiosk locations by 2027-01-01 or face a further $4M penalty, and must undergo an independent BSA/AML compliance review.

The analytically significant point is architectural rather than incidental: North Dakota's kiosk-specific licensing statute, in force since 2025-08-01, already imposed blockchain-analytics and compliance-officer obligations on virtual-currency kiosk operators, yet those requirements did not by themselves prevent the AML program deficiencies that produced this settlement. The deficiency was surfaced and resolved through a coordinated 34-state examination process rather than through North Dakota's own supervisory mechanism acting alone, indicating that state kiosk licensing conditions and the adequacy of an operator's federal BSA/AML compliance program are distinct and separately monitored dimensions of the same regulated activity. A licensed kiosk operator under this framework is not thereby certified as BSA/AML-compliant; licensure and compliance-program adequacy are assessed through different channels, with the multistate examination apparatus serving as the mechanism that catches gaps a single state's kiosk statute does not independently test for.

This cycle's signal also illustrates a three-pillar point: the finding is squarely AML/CTF in character, with no counterpart proliferation-finance or broader financial-innovation signal surfaced this cycle for North Dakota specifically. The absence of any parallel state-specific consent order beyond North Dakota's participation in the multistate settlement remains an open question, not a confirmed non-event.

Outlook

The operative date is 2027-01-01, the deadline by which Coinme must have exited the North Dakota kiosk market under the settlement terms, as scheduled; non-compliance exposes Coinme to a further $4M penalty under the agreement. Whether North Dakota's DFI will pursue any state-specific consent order against Coinme beyond its role in the multistate settlement is not resolved by the current record. North Dakota's underlying kiosk statute, N.D.C.C. ch. 13-09.1, remains unchanged in text this cycle notwithstanding the enforcement action taken under the broader BSA/AML framework it sits alongside.

12 Oct 2026 · fim-2026-10-11

Crypto / Digital Assets / Financial Innovation

The Bank of North Dakota's launch of Roughrider Coin on October 1, 2026 is the defining digital-asset development of this cycle and the first instance of a US state-owned bank issuing a live stablecoin. Roughrider Coin is a wholesale, institution-only, dollar-backed interbank stablecoin; VersaBank USA, N.A., an OCC-chartered bank, is the issuer; Fireblocks provides tokenization; and settlement runs on Solana's public blockchain. The program went live on Fiserv's digital asset platform, and a four-institution pilot cohort was announced on October 5, 2026, confirming movement from announcement to operational production within days.

Viewed through the financial-integrity lens, the structurally significant fact is the legal basis under which this instrument currently operates: the GENIUS Act's state-issuer carve-out permits a state-chartered or state-owned issuer to issue a payment stablecoin pending finalization of the federal and state 'substantial similarity' implementing rules. Those implementing rules have not yet been finalized, meaning Roughrider Coin currently operates inside a provisional compliance perimeter rather than a settled one. Three-pillar balance requires noting explicitly that AML/CTF obligations attaching to this instrument, general customer due diligence expectations consistent with FATF Recommendations applicable to banks and crypto-asset operators, are the applicable baseline today, pending any stablecoin-specific federal rule that finalizes later.

The wholesale, institution-only design limits the counterparty universe to correspondent-bank-type relationships rather than retail customers, which narrows but does not eliminate the AML exposure surface: screening and due diligence obligations attach to the institutional counterparties onboarded to the pilot and to any future expansion of the program. No enforcement action, supervisory guidance, or AML-specific finding from the North Dakota Department of Financial Institutions addressing Roughrider Coin specifically was identified this cycle; the only North Dakota enforcement action this cycle, an individual-employment suspension, is unconnected to the stablecoin launch.

Outlook

The GENIUS Act's 'substantial similarity' implementing rules are expected to finalize in Q4 2026, as scheduled, and that determination will decide whether North Dakota's continued reliance on the state-issuer carve-out for Roughrider Coin remains viable without further state legislative or regulatory action. Until that rule finalizes, the AML/CTF compliance architecture underneath the first live US state-bank stablecoin remains provisional rather than settled, and institutions in the pilot cohort should expect that the applicable due-diligence baseline may change once federal rules are finalized.

28 Sep 2026 · fim-2026-09-28

Crypto, Digital Assets, and Financial Innovation

North Dakota's 2025 session delivered two settled, first-surfaced facts on the digital-asset front that together define the states current posture toward on-chain activity. The first is enactment: HB 1447 brings North Dakota-licensed virtual-currency kiosk operators fully within the states money-transmitter licensing regime, layering on blockchain-analytics software requirements, a named compliance officer, and a 2,000 dollar per-day transaction cap, effective since August 1, 2025. The in-force status and the statutory codification at NDCC sections 13-09.1-50 through -54 are confirmed at the highest sourcing tier, though the specific operational detail describing the analytics-software and named-officer requirements traces to a lower-tier secondary characterisation not yet checked against the enrolled bill text. The second is rejection: HB 1239, which would have carved digital-asset miners and blockchain node operators out of the same money-transmitter licensing requirement, failed decisively on House second reading, 14 yeas to 75 nays, on February 17, 2025. Read together, the two outcomes describe a legislature willing to extend licensing and consumer-facing controls onto new use cases (kiosks) while declining, by a wide margin, to narrow that same licensing perimeter for infrastructure-level activity (mining and node operation). That is a meaningfully different signal than either fact alone: it indicates that North Dakota's default posture is inclusion within the general money-transmitter framework rather than a pattern of case-by-case exemption-seeking succeeding.

The compliance-technology dimension of HB 1447 is also a financial-innovation signal in its own right: a state legislature mandating blockchain analytics software as a condition of licensure is treating that software as baseline regulatory infrastructure for a licensed activity, not an optional control. That mandate sits within the broader compliance-technology and active-defence conversation even though this cycle's substrate does not support a standalone assessment of North Dakota's broader RegTech posture beyond this single statutory requirement.

Outlook

The near-term trajectory for North Dakota's digital-asset regulatory perimeter depends on two open threads. First, verification: the compliance-officer and blockchain-analytics specifics attributed to HB 1447 rest on a secondary source and should be treated as provisional until the enrolled bill text is independently checked. Second, the unresolved status of mining and node-operation activity following HB 1239's decisive failure leaves a genuine ambiguity that a future legislative session or supervisory guidance from the Department of Financial Institutions could resolve in either direction; nothing in this cycle's substrate indicates which outcome is more likely, and no reintroduced bill has been identified as of this cycle.

D6 Compliance Technology & Active Defence

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Compliance Technology and Active Defence

HB 1447's requirement that North Dakota crypto-kiosk operators deploy blockchain-analytics software for suspicious-activity detection is this cycle's sole compliance-technology development, and it is a narrow but concrete instance of the active-defence thesis this monitor tracks: a state legislature mandating, by statute, that a specific class of obliged entity adopt on-chain analytics tooling as a condition of licensure. This is qualitatively different from analytics adoption driven by institutional risk management or supervisory expectation, because it converts a compliance-technology capability into a binding legal requirement enforceable through the licensing regime itself.

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The mandate is corroborated by the same two independent Tier-3 press sources supporting the broader HB 1447 finding, with confidence assessed rather than high pending a Tier-1 primary-source confirmation of the bill's enacted text. No further compliance-technology development — for banks, non-bank payment firms, or other obliged-entity categories in North Dakota — was identified this cycle. This is a jurisdiction-specific data point for a wider pattern this monitor watches: state-level statutory mandates for on-chain analytics deployment remain comparatively rare relative to federal supervisory guidance, making North Dakota's approach a useful case for comparison against other US state crypto-kiosk regimes as they emerge.

Outlook

Once a Tier-1 source confirms HB 1447's final text, the compliance-technology angle worth tracking is which specific blockchain-analytics vendors or standards North Dakota's Department of Financial Institutions accepts as satisfying the statutory mandate, since that operational detail will determine how meaningfully the requirement functions in practice.

Judgment: No RegTech/compliance-technology development identified this cycle. Uncertain

D7 AML/CTF Regime

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AML/CTF Regime

North Dakota's money-transmitter chapter, NDCC ch. 13-09.1-22, requires licensees to file all federally-required currency, recordkeeping, and Suspicious Activity Reports under the Anti-Money Laundering Act of 2020. This is a Tier-1-sourced, High-confidence structural finding, drawn directly from the North Dakota Legislative Council's codified statute text. It functions as an incorporation-by-reference provision: rather than establishing an independent state AML reporting regime, North Dakota's money-transmitter law binds its licensees to the federal BSA/AMLA 2020 reporting framework, meaning currency-transaction-report, recordkeeping, and SAR obligations that would otherwise apply only through federal registration also attach as a condition of state licensure.

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This cycle's development is the extension of that existing reporting duty to a newly-licensed population: HB 1447 brings crypto-kiosk operators within the money-transmitter licensing chapter, and because the AML/CFT reporting duty in 13-09.1-22 attaches to licensees generically rather than to a specific sub-category, crypto-kiosk operators become subject to the same federally-required reporting obligations as any other North Dakota money transmitter once licensed. This is best characterised as a record-baseline update rather than a new AML obligation category: the reporting duty itself is unchanged, but the population of entities bound by it has grown to include a sub-sector — crypto kiosks — that FBI-reported fraud-loss data suggests has been a meaningful fraud vector.

The renewal-fee structure under the same statutory chapter is tied to virtual-currency-transmission volume and capped at $2,500, a detail indicating the legislature anticipated virtual-currency money transmission as a distinct volume category within the existing licensing chapter even before HB 1447's kiosk-specific extension. Framed through the three-pillar lens, this domain's finding is squarely AML-pillar: the SAR/CTR/recordkeeping duty is a classic money-laundering-reporting mechanism, and no CTF- or CPF-specific state-level obligation was identified for North Dakota's money-transmitter chapter this cycle. That absence is itself unsurprising given the incorporation-by-reference structure — CTF program requirements largely live at the federal BSA/OFAC layer that 13-09.1-22 already binds licensees to, rather than being independently legislated at the state level.

Outlook

The federal AML/CFT program-effectiveness rulemaking FinCEN is understood to be developing, expected around 2027 Q1, would flow through to ND-licensed money transmitters — including now crypto-kiosk operators — via the same incorporation-by-reference mechanism in 13-09.1-22 that currently binds them to the 2020 AML Act framework; the rulemaking's scope and stringency relative to current MSB practice is not yet finalized, and this is a Tier-4-sourced, Low-confidence forward-looking item pending FinCEN's proposed rule.

Judgment: North Dakota's standing AML/CTF descriptive position (federal BSA baseline via DFI money-transmitter and financial-corporation data-security regimes) is unchanged; no amendment identified in the window. Probable
Standing baseline position

NDCC ch. 13-01.2 (HB1127, GLBA-Safeguards-styled data-security/breach-notification) and NDCC §§13-09.1-50 to -54 (HB1447, virtual-currency kiosk MTL/AML overlay) remain the standing state-level AML/data-security framework. A 34-state $2.5M BSA/AML settlement was reached with Coinme Inc. (ND share $10,000; Coinme must cease ND kiosk operations by year-end 2026 or pay an additional $4M), and NDDFI issued perpetual employment-prohibition orders against two individuals under NDCC §6-01-04.

Periodic updates (1)
28 Sep 2026 · fim-2026-09-28

AML/CTF Regime

North Dakota's anti-money-laundering and counter-terrorist-financing exposure is structurally embedded within its money-transmitter licensing chapter rather than expressed as a free-standing AML statute, and this cycle surfaced the clearest evidence yet of that architecture. Chapter 13-09, the states original money-transmitter law, was repealed in full and replaced by chapter 13-09.1, the Money Transmission Modernization Act. That replacement chapter carries its own dedicated section, 13-09.1-22, titled Anti-money laundering - Countering the financing of terrorism reports, which now sits inside the licensing statute itself rather than in a separate title. This is confirmed at the highest sourcing tier as to the section heading and the chapter renumbering; the substantive reporting mechanics, including any threshold amounts, timing requirements, or SAR-equivalent process, were not independently retrieved this cycle and remain an open verification item.

The same 2025 session extended the reach of this AML architecture to a category of activity not previously subject to it: HB 1447 brings virtual-currency kiosk operators within the states money-transmitter license, and with that licensing comes exposure to the chapter's AML/CTF reporting section by operation of the statutes structure. The bill separately requires those newly-licensed kiosk operators to use blockchain analytics software and appoint a named compliance officer, controls that function as AML-adjacent even though their stated purpose in the record is framed around fraud detection rather than money-laundering reporting specifically. The specific analytics-software and compliance-officer detail traces to a lower-tier secondary source not yet cross-checked against the enrolled bill text, while the in-force status since August 1, 2025 and the statutory codification are independently confirmed.

The legislature also declined, by a wide margin, to narrow the population subject to this licensing-and-AML architecture: HB 1239, which would have exempted digital-asset miners and node operators from the money-transmitter license, failed 14 yeas to 75 nays on February 17, 2025. Because AML/CTF obligation under North Dakota's regime attaches through the licensing statute, the practical effect of that rejection is that miners and node operators remain, at minimum, within the scope of a licensing question that has not been resolved in the direction of exemption, leaving their AML-obligation status uncertain rather than settled.

Outlook

The most consequential open item for North Dakota's AML/CTF regime is verification rather than further legislative change: the actual reporting thresholds and process under section 13-09.1-22 have not been independently confirmed beyond the section heading, and resolving that gap would materially sharpen any assessment of how the states AML obligations actually operate in practice for licensed money transmitters, including the newly-licensed kiosk operators. Separately, the AML-obligation status of miners and node operators remains genuinely unresolved following HB 1239's decisive failure, and any future legislative attempt to revisit that exemption question, or supervisory guidance clarifying scope, would be the next material development to track.

D8 Commercial Activity

no_changeno_changestanding position

Commercial Activity

The commercial event of record this cycle is the launch of Roughrider Coin, a dollar-backed tokenized interbank-settlement asset developed by the Bank of North Dakota in partnership with VersaBank as issuer, Fiserv for platform integration, and Fireblocks for tokenisation and custody infrastructure. The product has been live since early October 2026 and is reported as adopted, on a voluntary basis, by approximately ninety North Dakota banks and credit unions, described as modernizing interbank payments for community banks and credit unions. The commercial value of the arrangement was not publicly disclosed.

Continue reading

From a financial-integrity vantage point, the significance of this event is less about the deal structure among the named commercial parties, which is tracked in full detail elsewhere, and more about what the product's appearance says about compliance architecture keeping pace with product innovation. A state-chartered bank deploying a tokenized settlement instrument across a large share of the state's community banking sector is a meaningful infrastructure event, and it occurred without any visible accompanying statement from the Department of Financial Institutions addressing how the product sits relative to existing anti-money-laundering or money-transmission obligations. That gap between commercial deployment and supervisory articulation is the item worth carrying forward, even though the commercial mechanics of the launch itself belong to a different analytical lens.

The other commercial-adjacent item this cycle is enforcement rather than product activity: the multistate settlement with Coinme Inc. resolved Bank Secrecy Act and anti-money-laundering violations tied to that company's virtual-currency kiosk business in North Dakota and thirty-three other states, with the state's recovery set at ten thousand dollars against a total settlement of two-and-a-half-million dollars. This is a commercial actor's compliance failure being resolved through coordinated regulatory action rather than a new commercial development, but it bears on the same broader theme: the state's financial-services commercial landscape now includes both traditional kiosk-based virtual-currency businesses operating under enforcement scrutiny and a new bank-led tokenized-asset product operating, for now, without comparable scrutiny.

Outlook

Going forward, the comparison between these two commercial threads is likely to sharpen. If the Department of Financial Institutions does eventually address Roughrider Coin's regulatory status, the contrast with the enforcement posture already shown toward kiosk operators like Coinme will become a useful marker of how the state calibrates oversight between bank-led and non-bank-led digital-asset products. Until such guidance appears, the commercial picture is one of parallel but differently supervised activity within the same broad digital-asset space.

Judgment: No financial-integrity-sector commercial event identified for US-ND this cycle. Uncertain
Regulatory horizon
Proposed2027-Q1 · ±multi_year

HB 1239 'Freedom Act' digital-asset mining protections and MTL exemption

No change this cycle — the bill did not pass; ND miners/node operators remain unclear as to MTL scope pending any future DFI guidance or renewed legislative vehicle.
North Dakota Legislative Assembly Source
1 dated · 3 pending date · baseline financial-integrity-2026-07-05
Role action cards
MLRO

The FATF reduced its increased-monitoring list from 22 to 18 jurisdictions on 30 October 2026, with no North Dakota-specific sanctions finding this cycle.

The global reduction may marginally ease enhanced-due-diligence calibration for counterparties linked to the four removed jurisdictions, but no local SAR-relevant or reportable-activity development was identified for North Dakota this cycle.

1 evidence refs
Compliance

The global FATF grey list shrank to 18 jurisdictions, with no North Dakota policy-gap development identified this cycle.

This is a structural global change relevant to due-diligence calibration frameworks generally; no North Dakota-specific control-framework or obliged-entity exposure finding exists this cycle.

1 evidence refs
Board

A global FATF Plenary outcome reduced the increased-monitoring list; no North Dakota-specific strategic exposure was identified this cycle.

The development is structural and global rather than institution-specific; it is noted at board level as context rather than as a material local risk event this cycle.

1 evidence refs
Risk

The FATF grey list contracted from 22 to 18 jurisdictions on 30 October 2026, a confirmed global architecture movement with no North Dakota-specific exposure concentration identified.

This is logged as a structural global typology shift relevant to cross-border due-diligence exposure generally; no local concentration or escalation signal was found this cycle.

1 evidence refs
Standing trackers (T1–T6)
TrackerStatusNote
T1 · Russian Sanctions-Evasion Architectureno_changeNo material change identified in the window.
T2 · EU AML Package / AMLAno_changeNo new application-date or transposition-deadline movement identified; not independently re-verified this cycle.
T3 · FATF Grey Listmaterial_changeGrey list fell from 22 to 18 jurisdictions on 30 October 2026 (Bulgaria, Cote d'Ivoire, DRC, Monaco removed; none added).
T4 · Beneficial-Ownership Register Statusno_changeNo material global BO-registry development identified in the window.
T5 · Crypto & Digital-Asset IntegritywatchSecondary reporting of the FATF Plenary communique flags virtual-asset misuse and fraud/scam compounds as a priority; not independently verified this cycle.
T6 · Sanctions Regime Divergenceno_changeNo new EU/US/UK autonomous-listing divergence event identified beyond routine OFAC SDN maintenance.
Registers

Enforcement actions

  • 21 Mar 2025
  • 14 Oct 2025
  • 23 Jun 2026
  • 1 Oct 2025
  • 1 Aug 2025
  • 8 Jan 2025
  • 8 Oct 2026
  • 16 Oct 2026
  • 8 Oct 2026
  • 16 Oct 2026
  • FinCEN issued an interim final rule revising the CTA's definition of 'reporting company' to cover only foreign entities registered to do business in the US, formally exempting all domestic entities — including those formed under North Dakota law — from beneficial ownership information reporting. 21 Mar 2025
  • OFAC designated the Prince Group TCO and its founder Chen Zhi for operating cryptocurrency-enabled 'pig butchering' scam networks and laundering proceeds through mining operations and shell companies; DOJ simultaneously unsealed an indictment. UK OFSI sanctioned an affiliated exchange. This nationally-binding designation obligates all US financial institutions and MSBs, including those licensed in North Dakota, to block related transactions. 14 Oct 2025
  • FinCEN proposed and subsequently moved to designate Huione Group as a financial institution of primary money laundering concern under Section 311 special measures, after identifying over $98 billion in cryptocurrency inflows including proceeds linked to North Korean cyber heists and global scam networks; a further NPRM in 2026 proposed severing successor entities (including H-Pay Service PLC) from the US financial system. 1 Oct 2025
  • OFAC and OFSI jointly designated entities tied to the A7A5 ruble-pegged stablecoin network, its affiliated exchange Grinex, and Kyrgyzstani issuer Old Vector, which processed over $72 billion in 2025 and has been linked to at least $39 billion in Russian sanctions-evasion-associated flows. 1 Aug 2025

Sanctions changes

  • 1 Aug 2025
  • 1 Oct 2025
  • 14 Oct 2025
  • 23 Jun 2026
  • 7 Aug 2026
  • 28 Oct 2026
  • 14 Oct 2026
  • 14 Oct 2026
  • OFAC designated entities tied to the Russian ruble-backed A7A5 token network, exchange Grinex, and Kyrgyzstani issuer Old Vector as part of coordinated action with UK OFSI, targeting a network that processed over $72 billion in 2025. 1 Aug 2025
  • The European Commission's 19th sanctions package enacted a transaction ban on the A7A5 token itself and related entities, following the earlier OFAC/OFSI designations of the network's exchange and issuer infrastructure. 1 Oct 2025
  • OFAC and UK OFSI jointly designated the Prince Group Transnational Criminal Organization, its founder Chen Zhi, and 146 associated targets for cryptocurrency-enabled scam operations; OFAC subsequently expanded the designation with 25 additional bitcoin addresses. 14 Oct 2025

Regulatory horizon (register)

  • UK failure-to-prevent-fraud offence implementation
  • HB 1239 'Freedom Act' digital-asset mining protections and MTL exemption
  • GENIUS Act stablecoin AML/CFT rule finalization (payment stablecoin issuers)
  • FinCEN AML/CFT Program Modernization rule (risk-based reform)
  • US 5th-round FATF mutual evaluation follow-up

Active schemes

  • CTA rollback restores shell-entity opacity for ND-formed companies
  • Flared-gas Bitcoin mining as unsupervised energy-to-crypto vector
  • Tribal-land oil economy jurisdictional oversight complexity
Sources
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  44. Special Measures | FinCEN.gov
  45. Alerts/Advisories/Notices/Bulletins/Fact Sheets | FinCEN.gov
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  48. Enforcement Actions for Failure to Register as a Money Services Business | FinCEN.gov
  49. IRS investigating sanctioned Russian oligarchs' use of South Dakota trusts, agent says - ICIJ
  50. A Money Services Business Guide Financial Crimes Enforcement Network
  51. FinCEN Assesses $1.5 Million Civil Money Penalty against Kingdom Trust Company for Violations of the Bank Secrecy Act | FinCEN.gov
  52. Bakken Oil Express LLC - Company Profile and News - Bloomberg Markets
  53. Enforcement Actions | FinCEN.gov
  54. Financial Fraud Enforcement Task Force (FFETF) | FinCEN.gov
  55. A Quick Reference Guide for Money Services Businesses
  56. FinCEN Director’s Law Enforcement Awards Program Recognizes
  57. North Dakota Bakken Oil Rises Again in Shadow of Mighty Permian - Bloomberg
  58. MSB Registrant Search | FinCEN.gov
  59. Money Services Business (MSB) Registration | FinCEN.gov
  60. Fact Sheet on MSB Registration Rule | FinCEN.gov
  61. State Contact Information For MSBs
  62. Definition of Money Transmitter (Merchant Payment Processor) | FinCEN.gov
  63. GUIDANCE TO MONEY SERVICES BUSINESSES ON OBTAINING AND MAINTAINING BANKING SERVICES | FinCEN.gov
  64. Important Information for MSBs | FinCEN.gov
  65. Prepared Remarks of FinCEN Deputy Director Jamal El-Hindi, delivered at the CSBS State Federal Supervisory Forum | FinCEN.gov
  66. Application of the Definition of Money Transmitter to Brokers and Dealers in Currency and Other Commodities | FinCEN.gov
  67. UPDATED: Notice Regarding National Small Business United v. Yellen, No. 5:22-cv-01448 (N.D. Ala.) | FinCEN.gov
  68. Treasury Department won’t enforce beneficial ownership rule under the Corporate Transparency Act - ICIJ
  69. Beneficial Ownership Information Reporting | FinCEN.gov
  70. Frequently Asked Questions | FinCEN.gov
  71. FinCEN Not Issuing Fines or Penalties in Connection with Beneficial Ownership Information Reporting Deadlines | FinCEN.gov
  72. U.S. Beneficial Ownership Information Registry Now Accepting Reports | FinCEN.gov
  73. Corporate Transparency Act
  74. FinCEN Issues Notice to Financial Institution Customers on Beneficial Ownership Information Requirements | FinCEN.gov
  75. Updated: March 2025 1 Financial Crimes Enforcement Network
  76. Beneficial Ownership Information Reporting Rule Fact Sheet | FinCEN.gov
  77. ConocoPhillips (COP) Is Supplying a Bitcoin (BTC) Miner With Gas From Bakken - Bloomberg
  78. Crypto Sanctions: 2026 Crypto Crime Report
  79. Why Bitcoin Mining Is Being Touted as a Solution to Gas Flaring - Bloomberg
  80. 2026 Crypto Crime Report – Illicit Crypto Trends & Typologies | TRM Labs
  81. How Iran Uses Bitcoin Mining to Evade Sanctions
  82. US Sanctions North Korean Crypto-Laundromat, Indicts Bitcoin Mining CEO | OCCRP
  83. Iran Uses Crypto Mining to Lessen Impact of Sanctions
  84. Crypto Mining Can Be Used to Evade Russia Sanctions, IMF Warns - Bloomberg
  85. DOJ Seizes $15 Billion in Bitcoin
  86. Sanctions: Iranians Flock to Crypto; Int'l Actions Target Russia - Chainalysis
  87. The DOJ's NCET Disbanded: What This Means for Digital Assets - Chainalysis
  88. DOJ Uses Organized Crime Statute in $263 Million Cryptocurrency Theft, Money Laundering and Home Invasion Conspiracy | TRM Labs
  89. Blockchain Legal Library
  90. Suspect foreign money flows into booming American tax havens on promise of eternal secrecy - ICIJ
  91. International Co-operation on Money Laundering Detection, Investigation, and
  92. 1 1. See 31 U.S.C. § 5312(a)(2); 31 C.F.R. § 1010.100(t). 2.
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  94. United States' progress in strengthening measures to tackle money laundering and terrorist financing
  95. United States
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  97. Mutual Evaluation of the United States
  98. Mutual Evaluations
  99. Report on the State of Effectiveness and Compliance with the FATF Standards
  100. U.S. RECEIVES ‘OUTSTANDING’ EVALUATION FOR ANTI-MONEY LAUNDERING EFFORT | FinCEN.gov
  101. Madagascar's progress in strengthening measures to tackle money laundering and terrorist financing
  102. Assessments
  103. The FATF Recommendations
  104. Fincen
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  106. Financial Crimes Enforcement Network Registration of Money Services Business
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  108. PPSI-AMLCFT-NPRM.pdf
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  110. 1 Financial Crimes Enforcement Network U.S. Department of the Treasury
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  112. Key Changes in FinCEN’s Proposed Rule to Refocus AML/CFT Programs on
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  117. GUIDANCE FOR A RISK-BASED APPROACH EFFECTIVE SUPERVISION AND ENFORCEMENT BY
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  119. F I U 's in action
  120. Williston, North Dakota, Oil Fracking Boom Fueled a Housing Crisis - Bloomberg
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  124. Secretary Bessent Announces Initiatives to Combat Rampant Fraud in Minnesota | FinCEN.gov
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  126. Publication of Updates to OFAC's Specially Designated Nationals and Blocked Persons List and 13599 List Removals | Office of Foreign Assets Control
  127. North Dakota Oil Production Expected to Take a Month to Recover From Cold Snap - Bloomberg
  128. STATE CONTACT INFORMATION FOR MSBs
  129. To view or print PDF content, download the free Adobe Acrobat Reader.
  130. Special Notice RMSB Posting
  131. The National Money Transmitters Association, Inc. 12 Welwyn Road, Suite C
  132. North Dakota Grain Growers Association - Company Profile and News - Bloomberg Markets
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Coverage gaps
fim-int-2026-07-05-G001: Public-record enforcement actions s…
fim-int-2026-07-05-G001: Public-record enforcement actions specifically attributable to North Dakota (as opposed to nationally-applicable actions) are sparse, limiting independent verification of ND DFI's state MSB supervisory effectiveness. [resolved]
fim-int-2026-07-05-G002: No FinCEN guidance yet resolves the…
fim-int-2026-07-05-G002: No FinCEN guidance yet resolves the AML/BSA classification boundary for standalone flared-gas Bitcoin-mining operations at scale in North Dakota specifically, leaving the FIN-2014-R001 use-case boundary untested against the state's growing sector. [resolved]
fim-int-2026-07-05-G003: No ND-specific CTF/CPF typology rep…
fim-int-2026-07-05-G003: No ND-specific CTF/CPF typology reporting or state-level RegTech/SupTech supervisory initiative distinct from the federal FinCEN framework was identified this baseline; future cycles should verify whether such state-level activity exists. [resolved]
fim-int-2026-07-05-G004: The exact scheduling of the US 5th-…
fim-int-2026-07-05-G004: The exact scheduling of the US 5th-round FATF mutual evaluation has not been published on the FATF assessment calendar, leaving the timing of any reassessment of the CTA rollback's effect on US Recommendation 24 compliance uncertain. [resolved]
fim-int-2026-07-05-G005: No independent data was available o…
fim-int-2026-07-05-G005: No independent data was available on the practical application of the Customer Due Diligence Rule (31 CFR 1010.230) to ND-chartered legal-entity customers specifically, which would substantiate how much of the CTA rollback's beneficial-ownership screening loss the CDD Rule actually offsets in practice. [resolved]
fim-int-2026-08-20-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-08-20-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): No ND.gov or ndlegis.gov T1 confirmation of HB 1447's final signature/effective date was reached this cycle. [resolved]
fim-int-2026-08-20-G002 ({'scheme': 'financial_integrity', '…
fim-int-2026-08-20-G002 ({'scheme': 'financial_integrity', 'value': 'D1'}): Mexico and Colombia Tier-D FATF checks were not actively researched this cycle due to pooled search-budget constraints. [resolved]
fim-int-2026-08-20-G003 ({'scheme': 'financial_integrity', '…
fim-int-2026-08-20-G003 ({'scheme': 'financial_integrity', 'value': 'D3'}): Whether DFI has exercised its discretion under HB 1127 to designate any 'alternative financing product' remains unconfirmed this cycle. [resolved]
fim-int-2026-09-05-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-09-05-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): D1 (sanctions architecture) not actively researched this cycle for US-ND; pooled search budget directed to bound jurisdiction. [resolved]
fim-int-2026-09-05-G002 ({'scheme': 'financial_integrity', '…
fim-int-2026-09-05-G002 ({'scheme': 'financial_integrity', 'value': 'D2'}): D2 (beneficial ownership) not actively researched this cycle for US-ND. [resolved]
fim-int-2026-09-05-G003 ({'scheme': 'financial_integrity', '…
fim-int-2026-09-05-G003 ({'scheme': 'financial_integrity', 'value': 'D7'}): HB 1127's financial-data-security provisions rest on two T3 law-firm summaries; primary enrolled statutory text not directly retrieved this cycle. [resolved]
fim-int-2026-09-05-G004: Tier D jurisdiction watch (KH, LA, …
fim-int-2026-09-05-G004: Tier D jurisdiction watch (KH, LA, MX, CO) not actively searched this cycle. [resolved]
fim-int-2026-09-28-G001: Global T1 sanctions/BO/enabler-juri…
fim-int-2026-09-28-G001: Global T1 sanctions/BO/enabler-jurisdiction standing trackers (T1-T4, T6) were not actively re-run this cycle; pooled union budget was concentrated on US-ND research vectors. [resolved]
fim-int-2026-09-28-G002: Tier-D jurisdiction watch (KH, LA, …
fim-int-2026-09-28-G002: Tier-D jurisdiction watch (KH, LA, MX, CO) was not checked this cycle. [resolved]
fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', '…
fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', 'value': 'D7'}): Full substantive text of N.D.C.C. §13-09.1-22's AML/CTF reporting mechanics (thresholds, SAR-equivalent process) was not independently retrieved this cycle; only the section heading was confirmed at T1. [resolved]
fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): No direct OFAC/Treasury primary citation was independently re-verified for the Oct 5, 2026 Sinaloa Cartel leadership and official-corruption designation; reliance is on a single law-firm sanctions-tracking blog. [resolved]
fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', 'value': 'D2'}): No US-ND-specific beneficial-ownership variance exists to report; the federal FinCEN rule narrowing BOI reporting applies uniformly and is not state-specific. [resolved]
fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', 'value': 'D7'}): October 2026 FATF Plenary outcomes (first under UK Presidency) were not yet published as of this dispatch; grey-list changes and mutual-evaluation publications for Canada and Türkiye remain pending. [resolved]
fim-int-2026-10-18-G001: This dispatch is bound to the singl…
fim-int-2026-10-18-G001: This dispatch is bound to the single subnational jurisdiction US-ND; Tier D jurisdiction sweeps (KH/LA/MX/CO) and broader D1-D4/D6 global domains were not independently searched given the pooled union search budget and JID-bound scope. [resolved]
fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): The underlying predicate conduct for the Trevino Trousdale/Ricks participation-prohibition orders was not published in the public notice; no statutory provision for the predicate conduct could be cited. [resolved]
fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): No NDDFI AML/BSA guidance specific to Roughrider Coin's reserve, redemption or issuance treatment was located this cycle. [resolved]
fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): Underlying conduct behind the Trevino Trousdale and Ricks perpetual prohibition orders is not disclosed in the public NDDFI notices. [resolved]
fim-int-2026-10-25-G003: Tier D jurisdiction watch (Cambodia…
fim-int-2026-10-25-G003: Tier D jurisdiction watch (Cambodia, Laos, Mexico, Colombia) and EEA/UK-specific AML Package trackers are not applicable to this single-JID US-ND dispatch. [resolved]
fim-int-2026-11-01-G001: US-ND-specific D2-D8 domain finding…
fim-int-2026-11-01-G001: US-ND-specific D2-D8 domain findings are thin this cycle; the DR run was JID-bound and pooled against a union search budget, leaving beneficial-ownership, enabler-jurisdiction, conflict-finance, crypto/digital-asset, compliance-technology and D7 AML/CTF regime domains unresearched at the subnational level this cycle. [open]
fim-int-2026-11-01-G002: Tier D watch jurisdictions (KH, LA,…
fim-int-2026-11-01-G002: Tier D watch jurisdictions (KH, LA, MX, CO) were not actively searched this cycle; coverage logged as awaiting_primary_source rather than asserted no-change. [open]
fim-int-2026-11-01-G003: EU AML Package / AMLA (T2) applicat…
fim-int-2026-11-01-G003: EU AML Package / AMLA (T2) application-date and transposition detail was not independently re-verified against the Official Journal this cycle. [open]
FIM-GAP-001 (D2): The March 2025 CTA rollback exempts all US…
FIM-GAP-001 (D2): The March 2025 CTA rollback exempts all US-formed entities, including ND-registered LLCs and corporations, from federal beneficial ownership reporting, and North Dakota maintains no independent state-level beneficial ownership registry to fill the resulting gap.
FIM-GAP-002 (D3): Public-record enforcement actions specific…
FIM-GAP-002 (D3): Public-record enforcement actions specifically attributable to North Dakota (as opposed to national-framework actions merely applicable within the state) are sparse across FinCEN, OFAC, DOJ and investigative-journalism sources for the 18-month window, unlike the well-documented South Dakota trust industry.
FIM-GAP-003 (D5): Standalone cryptocurrency-mining operation…
FIM-GAP-003 (D5): Standalone cryptocurrency-mining operations, including the flared-gas Bitcoin mining facilities operating in the Bakken shale, are not classified as money transmitters or MSBs under current FinCEN rules and therefore fall outside routine BSA/AML reporting obligations despite the sector's rapid growth.
FIM-GAP-004 (D6): No ND-specific CTF or CPF financing scheme…
FIM-GAP-004 (D6): No ND-specific CTF or CPF financing scheme, or RegTech/SupTech supervisory initiative distinct from the national FinCEN framework, was identified in available Tier 1/2 sources for this baseline window; this baseline therefore assesses North Dakota's CTF/CPF and Compliance-Technology posture solely through inheritance of the national US framework.

Evidence

Confidence-tiered claims

Roughrider Coin, a wholesale dollar-backed interbank stablecoin, went live Oct 1, 2026 on Fiserv's digital asset platform; VersaBank (OCC-chartered) is issuer, Fireblocks provides tokenization, settlement on Solana [Source 1]
Probable · 1 source
OFAC blocked all property and interests in property of A7 Network (Russia; Kyrgyzstan; Nigeria; Zimbabwe) under EO 13581 as amended [Source 1]
Probable · 1 source
OFAC designated Ismael Zambada Sicairos (alleged leader of 'Los Mayos') and associated laundering-facilitator businesses and corrupt Mexican officials tied to the Mexicali trafficking corridor [Source 1]
Probable · 1 source
OFAC amended CACR to expand the Cuba Restricted List, eliminate the U-turn general license, remove the independent-entrepreneur account-maintenance authorization, and narrow educational/professional travel GLs, effective Sept 29, 2026 [Source 1]
Probable · 1 source
Order of suspension from employment or participation in the affairs of any ND-licensed financial corporation, financial institution, credit union, or other licensed entity against a former bank employee [Source 1]
Probable · 1 source
OFAC/Treasury must begin delegating SDN designations under the Act by Oct 18, 2026, with review every 180 days thereafter [Source 1]
Probable · 1 source
Coinme Inc. (NMLS ID 1185542) agreed in a 2026-10-08 multistate consent settlement led by a 34-state coalition to pay $2.5M (ND's allocated share $10,000), terminate ND kiosk operations by 2027-01-01 or face a further $4M penalty, and undergo independent BSA/AML compliance review. [Source 1]
Probable · 1 source
NDDFI Commissioner Lise Kruse issued orders on or about 2026-10-16 perpetually prohibiting Monica Trevino Trousdale and Brianna Ricks from employment or participation in the affairs of any NDDFI-licensed bank, credit union or financial institution. [Source 1]
Probable · 1 source
ND has no separate state AML/CFT statute distinct from licensing; AML obligations on ND-licensed money transmitters, including virtual-currency kiosk operators, flow from the federal Bank Secrecy Act (31 U.S.C. ch. 53) enforced by FinCEN, with NDDFI as the state licensing/supervisory authority under N.D.C.C. ch. 13-09.1. Crypto-kiosk-specific anti-fraud duties were added by HB 1447, in force since 2025-08-01. [Source 1]
Probable · 1 source
Coinme Inc. will terminate its approximately 66 North Dakota virtual-currency kiosk locations by 2027-01-01 under the 2026-10-08 multistate consent settlement; a market-exit event for a licensed ND crypto/payments participant. [Source 1]
Probable · 1 source
N.D.C.C. §13-09.1-52 requires virtual-currency kiosk operators to use blockchain analytics to detect and prevent suspicious activity, and to designate and employ a full-time compliance officer and a full-time customer-protection officer. [Source 1]
Probable · 1 source
34-state $2.5M settlement for BSA/AML violations at virtual-currency kiosks; ND receives $10,000. [Source 1]
Probable · 1 source
Perpetually prohibited from employment or participation in any NDDFI-licensed entity. [Source 1]
Probable · 1 source
Roughrider Coin, a USD-backed tokenized interbank-settlement asset, live since 2026-10-01, available to ~90 ND banks/credit unions. [Source 1]
Probable · 1 source
HB1127 (NDCC ch. 13-01.2, GLBA-Safeguards-styled 45-day/500-consumer notification) and HB1447 (NDCC §§13-09.1-50 to -54, virtual-currency kiosk EDD/analytics/$2000-daily-cap) remain in force unchanged. [Source 1]
Probable · 1 source
Published Crypto ATM FAQ resource warning that scammers increasingly use kiosks as part of fraud schemes. [Source 1]
Probable · 1 source
Bulgaria, Cote d'Ivoire, DRC and Monaco removed from grey list at 30 Oct 2026 Plenary; list now 18 jurisdictions with no additions. [Source 1]
Probable · 1 source
Grey list reduced from 22 to 18 jurisdictions at the 30 October 2026 Plenary (Bulgaria, Cote d'Ivoire, DRC, Monaco removed; none added); black list of Iran, Myanmar, North Korea unchanged. [Source 1]
Probable · 1 source