--- title: "United States — North Dakota (US-ND) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/united-states-north-dakota/ source_html: /jurisdictions/united-states-north-dakota/index.html description: "Financial integrity intelligence for United States – North Dakota (US-ND): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: ea8d040735fa04f8177288cdfb6771864c050a47c995d15d690d5a974900ea12 generator: "fe-fleet/md-twin@1.0" --- # United States — North Dakota (US-ND) — Financial-Integrity Intelligence · Sentinel Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved. Financial Integrity Monitor # United States — 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). More No 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](/jurisdictions/us/) 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) #### 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 Judgment: No US-ND-specific beneficial-ownership development identified this cycle; coverage thin. Uncertain #### 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. Continue reading 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 #### 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. Continue reading 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 #### 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. Continue reading 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 #### 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. Continue reading 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 #### 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. Continue reading 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 #### 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 Proposed 2027-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](https://ndlegis.gov/assembly/69-2025/regular/bill-actions/ba1239.html) 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) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture no_change No material change identified in the window. T2 · EU AML Package / AMLA no_change No new application-date or transposition-deadline movement identified; not independently re-verified this cycle. T3 · FATF Grey List material_change Grey list fell from 22 to 18 jurisdictions on 30 October 2026 (Bulgaria, Cote d'Ivoire, DRC, Monaco removed; none added). T4 · Beneficial-Ownership Register Status no_change No material global BO-registry development identified in the window. T5 · Crypto & Digital-Asset Integrity watch Secondary 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 Divergence no_change No 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 - [https://www.nd.gov/dfi/news/north-dakota-enacts-money-transmission-modernization-act](https://www.nd.gov/dfi/news/north-dakota-enacts-money-transmission-modernization-act) - [https://ndlegis.gov/cencode/t13c09-1.pdf](https://ndlegis.gov/cencode/t13c09-1.pdf) - [https://www.mayerbrown.com/en/insights/publications/2025/06/north-dakota-broadens-licensing-law-to-include-alternative-financing](https://www.mayerbrown.com/en/insights/publications/2025/06/north-dakota-broadens-licensing-law-to-include-alternative-financing) - [https://www.coindesk.com/policy/2025/03/19/north-dakota-senate-passes-crypto-atm-bill-to-create-licensing-regime](https://www.coindesk.com/policy/2025/03/19/north-dakota-senate-passes-crypto-atm-bill-to-create-licensing-regime) - [https://www.govtech.com/policy/n-d-bill-to-regulate-cryptocurrency-kiosks-clears-house](https://www.govtech.com/policy/n-d-bill-to-regulate-cryptocurrency-kiosks-clears-house) - [https://www.nd.gov/dfi/enforcement-actions](https://www.nd.gov/dfi/enforcement-actions) - [https://amluae.com/fatf-grey-list-countries-update-19th-june-2026/](https://amluae.com/fatf-grey-list-countries-update-19th-june-2026/) - [https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) - [https://cambodianess.com/article/cambodia-removed-from-the-fatfs-grey-list](https://cambodianess.com/article/cambodia-removed-from-the-fatfs-grey-list) - [https://home.treasury.gov/news/press-releases/sb0564](https://home.treasury.gov/news/press-releases/sb0564) - [https://ofac.treasury.gov/recent-actions](https://ofac.treasury.gov/recent-actions) - [https://ndlegis.gov/cencode/t13c09.pdf](https://ndlegis.gov/cencode/t13c09.pdf) - [https://www.hunton.com/privacy-and-cybersecurity-law-blog/north-dakota-enacts-financial-data-security-and-data-breach-notification-requirements](https://www.hunton.com/privacy-and-cybersecurity-law-blog/north-dakota-enacts-financial-data-security-and-data-breach-notification-requirements) - [North Dakota Legislative Branch](https://ndlegis.gov/cencode/t13c09-1.pdf) - [North Dakota Legislative Branch](https://ndlegis.gov/assembly/69-2025/regular/bill-actions/ba1239.html) - [CryptoSlate](https://cryptoslate.com/crypto-laws/north-dakota-virtual-currency-kiosk-licensing-law/) - [https://bnd.nd.gov/bank-of-north-dakota-and-fiserv-partner-to-launch-roughrider-coin/](https://bnd.nd.gov/bank-of-north-dakota-and-fiserv-partner-to-launch-roughrider-coin/) - [https://northdakotamonitor.com/2026/10/05/bank-of-north-dakota-announces-stablecoin-pilot-program-with-local-partners/](https://northdakotamonitor.com/2026/10/05/bank-of-north-dakota-announces-stablecoin-pilot-program-with-local-partners/) - [https://www.pymnts.com/blockchain/2026/fiserv-digital-asset-platform-goes-live-with-bank-of-north-dakota-stablecoin/](https://www.pymnts.com/blockchain/2026/fiserv-digital-asset-platform-goes-live-with-bank-of-north-dakota-stablecoin/) - [https://www.federalregister.gov/documents/2026/10/06/2026-20395/notice-of-ofac-sanctions-action](https://www.federalregister.gov/documents/2026/10/06/2026-20395/notice-of-ofac-sanctions-action) - [https://substack.steptoe.com/p/sanctions-update-october-5-2026](https://substack.steptoe.com/p/sanctions-update-october-5-2026) - [North Dakota Department of Financial Institutions](https://www.nd.gov/dfi/) - [North Dakota Department of Financial Institutions (via EIN Presswire)](https://www.einnews.com/pr_news/950251731/trevino-trousdale-and-ricks-prohibited-from-further-participation) - [Conference of State Bank Supervisors](https://www.csbs.org/newsroom/state-financial-regulators-reach-25-million-settlement-crypto-kiosk-operator) - [North Dakota Department of Financial Institutions (via EIN Presswire)](https://www.einnews.com/pr_news/948293073/north-dakota-joins-2-5m-settlement-with-cryptocurrency-kiosk-operator) - [North Dakota Department of Financial Institutions](https://www.nd.gov/dfi/crypto-atms) - [North Dakota Department of Financial Institutions](https://www.nd.gov/dfi/news-and-publications/press-releases) - [KXNET](https://www.kxnet.com/north-dakota-news/north-dakota-joins-2-5-million-cryptocurrency-settlement/) - [National Law Review](https://natlawreview.com/article/north-dakota-expands-data-security-requirements-and-issues-new-licensing) - [PYMNTS](https://www.pymnts.com/blockchain/2026/north-dakota-lenders-report-faster-settlement-with-state-banks-stablecoin/) - [North Dakota Department of Financial Institutions](https://www.nd.gov/dfi/news/department-financial-institutions-releases-crypto-atm-faqs-boost-financial-literacy-and-scam) - [FATF](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [Bytes Europe](https://www.byteseu.com/2486791/) - [Malay Mail](https://www.malaymail.com/news/money/2026/10/31/monaco-exits-global-money-laundering-watchlist-the-playground-for-the-rich-is-officially-less-grey/241380) - [U.S. Department of the Treasury OFAC](https://ofac.treasury.gov/recent-actions/sanctions-list-updates) - [North Dakota Department of Financial Institutions](https://www.nd.gov/dfi/enforcement-actions) - [My Dakotan](https://mydakotan.com/2026/10/north-dakota-joins-2-5-million-crypto-settlement-coinme-bitcoin-kiosks-face-shutdown/) - [United States Department of the Treasury Financial Crimes Enforcement Network - Home | FinCEN.gov](https://www.fincen.gov/) - [Enforcement Actions | FinCEN.gov](https://www.fincen.gov/news/enforcement-actions) - [Guidance | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance) - [1 The U.S. Department of the Treasury’s (Treasury) Financial](https://www.fincen.gov/system/files/2026-03/FinCEN-Advisory-Health-Care-Fraud.pdf) - [Treasury Convenes Financial Institutions and Law Enforcement to Identify and Dismantle Money Laundering Networks | FinCEN.gov](https://www.fincen.gov/news/news-releases/treasury-convenes-financial-institutions-and-law-enforcement-identify-and) - [Advisories | FinCEN.gov](https://www.fincen.gov/resources/advisoriesbulletinsfact-sheets/advisories) - [Special Measures | FinCEN.gov](https://www.fincen.gov/resources/statutes-and-regulations/special-measures) - [Alerts/Advisories/Notices/Bulletins/Fact Sheets | FinCEN.gov](https://www.fincen.gov/resources/advisoriesbulletinsfact-sheets) - [Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov](https://www.fincen.gov/news/news-releases/financial-action-task-force-identifies-jurisdictions-anti-money-laundering-4) - [News | FinCEN.gov](https://www.fincen.gov/news) - [Enforcement Actions for Failure to Register as a Money Services Business | FinCEN.gov](https://www.fincen.gov/enforcement-actions-failure-register-money-services-business) - [IRS investigating sanctioned Russian oligarchs' use of South Dakota trusts, agent says - ICIJ](https://www.icij.org/investigations/pandora-papers/irs-investigating-sanctioned-russian-oligarchs-use-of-south-dakota-trusts-agent-says/) - [A Money Services Business Guide Financial Crimes Enforcement Network](https://www.fincen.gov/system/files/shared/prevention_guide.pdf) - [FinCEN Assesses $1.5 Million Civil Money Penalty against Kingdom Trust Company for Violations of the Bank Secrecy Act | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-assesses-15-million-civil-money-penalty-against-kingdom-trust-company) - [Bakken Oil Express LLC - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/0886529D:US) - [Enforcement Actions | FinCEN.gov](https://fincen.gov/news/enforcement-actions?fi=) - [Financial Fraud Enforcement Task Force (FFETF) | FinCEN.gov](https://www.fincen.gov/financial-fraud-enforcement-task-force-ffetf) - [A Quick Reference Guide for Money Services Businesses](https://www.fincen.gov/system/files/shared/report_reference.pdf) - [FinCEN Director’s Law Enforcement Awards Program Recognizes](https://www.fincen.gov/system/files/shared/LEAP2020_State-Local%20LE%20508.pdf) - [North Dakota Bakken Oil Rises Again in Shadow of Mighty Permian - Bloomberg](https://www.bloomberg.com/news/articles/2018-02-01/north-dakota-bakken-oil-rises-again-in-shadow-of-mighty-permian) - [MSB Registrant Search | FinCEN.gov](https://www.fincen.gov/resources/msb-state-selector) - [Money Services Business (MSB) Registration | FinCEN.gov](https://www.fincen.gov/resources/money-services-business-msb-registration) - [Fact Sheet on MSB Registration Rule | FinCEN.gov](https://www.fincen.gov/fact-sheet-msb-registration-rule) - [State Contact Information For MSBs](https://www.fincen.gov/sites/default/files/shared/msbstatecontactsfinal.pdf) - [Definition of Money Transmitter (Merchant Payment Processor) | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/definition-money-transmitter-merchant-payment) - [GUIDANCE TO MONEY SERVICES BUSINESSES ON OBTAINING AND MAINTAINING BANKING SERVICES | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/guidance-money-services-businesses-obtaining-and) - [Important Information for MSBs | FinCEN.gov](https://www.fincen.gov/resources/financial-institutions/money-services-businesses) - [Prepared Remarks of FinCEN Deputy Director Jamal El-Hindi, delivered at the CSBS State Federal Supervisory Forum | FinCEN.gov](https://www.fincen.gov/news/speeches/prepared-remarks-fincen-deputy-director-jamal-el-hindi-delivered-csbs-state-federal) - [Application of the Definition of Money Transmitter to Brokers and Dealers in Currency and Other Commodities | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/application-definition-money-transmitter-brokers-and) - [UPDATED: Notice Regarding National Small Business United v. Yellen, No. 5:22-cv-01448 (N.D. Ala.) | FinCEN.gov](https://www.fincen.gov/news/news-releases/updated-notice-regarding-national-small-business-united-v-yellen-no-522-cv-01448) - [Treasury Department won’t enforce beneficial ownership rule under the Corporate Transparency Act - ICIJ](https://www.icij.org/inside-icij/2025/03/treasury-department-wont-enforce-beneficial-ownership-rule-under-the-corporate-transparency-act/) - [Beneficial Ownership Information Reporting | FinCEN.gov](https://www.fincen.gov/boi) - [Frequently Asked Questions | FinCEN.gov](https://www.fincen.gov/boi-faqs) - [FinCEN Not Issuing Fines or Penalties in Connection with Beneficial Ownership Information Reporting Deadlines | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-not-issuing-fines-or-penalties-connection-beneficial-ownership) - [U.S. Beneficial Ownership Information Registry Now Accepting Reports | FinCEN.gov](https://www.fincen.gov/news/news-releases/us-beneficial-ownership-information-registry-now-accepting-reports) - [Corporate Transparency Act](https://www.fincen.gov/system/files/shared/Corporate_Transparency_Act.pdf) - [FinCEN Issues Notice to Financial Institution Customers on Beneficial Ownership Information Requirements | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-notice-financial-institution-customers-beneficial-ownership) - [Updated: March 2025 1 Financial Crimes Enforcement Network](https://www.fincen.gov/system/files/shared/BOI-FAQs-QA-508C.pdf) - [Beneficial Ownership Information Reporting Rule Fact Sheet | FinCEN.gov](https://www.fincen.gov/beneficial-ownership-information-reporting-rule-fact-sheet) - [ConocoPhillips (COP) Is Supplying a Bitcoin (BTC) Miner With Gas From Bakken - Bloomberg](https://www.bloomberg.com/news/articles/2022-02-15/conocophillips-says-it-s-sending-bakken-gas-to-bitcoin-processor) - [Crypto Sanctions: 2026 Crypto Crime Report](https://www.chainalysis.com/blog/crypto-sanctions-2026/) - [Why Bitcoin Mining Is Being Touted as a Solution to Gas Flaring - Bloomberg](https://www.bloomberg.com/news/articles/2019-12-06/why-bitcoin-mining-is-being-touted-as-a-solution-to-gas-flaring) - [2026 Crypto Crime Report – Illicit Crypto Trends & Typologies | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/2026-crypto-crime-report) - [How Iran Uses Bitcoin Mining to Evade Sanctions](https://www.elliptic.co/blog/how-iran-uses-bitcoin-mining-to-evade-sanctions) - [US Sanctions North Korean Crypto-Laundromat, Indicts Bitcoin Mining CEO | OCCRP](https://www.occrp.org/en/news/us-sanctions-north-korean-crypto-laundromat-indicts-bitcoin-mining-ceo) - [Iran Uses Crypto Mining to Lessen Impact of Sanctions](https://www.elliptic.co/media-center/reuters-iran-uses-crypto-mining-to-lessen-impact-of-sanctions) - [Crypto Mining Can Be Used to Evade Russia Sanctions, IMF Warns - Bloomberg](https://www.bloomberg.com/news/articles/2022-04-19/crypto-mining-can-be-used-to-evade-russia-sanctions-imf-warns) - [DOJ Seizes $15 Billion in Bitcoin](https://www.chainalysis.com/blog/southeast-asia-crypto-scam-network-mining-pig-butchering-october-2025/) - [Sanctions: Iranians Flock to Crypto; Int'l Actions Target Russia - Chainalysis](https://www.chainalysis.com/blog/crypto-crime-sanctions-2025/) - [The DOJ's NCET Disbanded: What This Means for Digital Assets - Chainalysis](https://www.chainalysis.com/blog/ncet-blanche-memo/) - [DOJ Uses Organized Crime Statute in $263 Million Cryptocurrency Theft, Money Laundering and Home Invasion Conspiracy | TRM Labs](https://www.trmlabs.com/resources/blog/doj-uses-organized-crime-statute-in-263-million-cryptocurrency-theft-money-laundering-and-home-invasion-conspiracy) - [Blockchain Legal Library](https://www.trmlabs.com/blockchain-legal-library) - [Suspect foreign money flows into booming American tax havens on promise of eternal secrecy - ICIJ](https://www.icij.org/investigations/pandora-papers/us-trusts-offshore-south-dakota-tax-havens/) - [International Co-operation on Money Laundering Detection, Investigation, and](https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/International-Cooperation-ML-Detection-Investigation-Prosecution.pdf.coredownload.pdf) - [1 1. See 31 U.S.C. § 5312(a)(2); 31 C.F.R. § 1010.100(t). 2.](https://www.fincen.gov/system/files/2026-06/FinCEN-Alert-Fiscal-Fuel-Theft.pdf) - [What Is Asset Seizure and Forfeiture? Definition, Process & Crypto Seizure - Chainalysis](https://www.chainalysis.com/glossary/asset-seizure/) - [United States' progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/united-states-fur-2024.html) - [United States](https://www.fatf-gafi.org/en/countries/detail/United-States.html) - [Consolidated assessment ratings](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Assessment-ratings.html) - [Mutual Evaluation of the United States](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationoftheunitedstates.html) - [Mutual Evaluations](https://www.fatf-gafi.org/en/publications/Mutualevaluations.html) - [Report on the State of Effectiveness and Compliance with the FATF Standards](https://www.fatf-gafi.org/en/publications/Fatfgeneral/Effectiveness-compliance-standards.html) - [U.S. RECEIVES ‘OUTSTANDING’ EVALUATION FOR ANTI-MONEY LAUNDERING EFFORT | FinCEN.gov](https://www.fincen.gov/news/news-releases/us-receives-outstanding-evaluation-anti-money-laundering-effort) - [Madagascar's progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/fur-madagascar-2024.html) - [Assessments](https://www.fatf-gafi.org/en/calendars/assessments.html) - [The FATF Recommendations](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html) - [Fincen](https://www.fincen.gov/system/files/schema/code/FinCENReferenceCodes.xsd) - [Definition of Money Services Business (Money Transmitter/Currency Dealer or Exchanger) | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/definition-money-services-business-money-0) - [Financial Crimes Enforcement Network Registration of Money Services Business](https://www.fincen.gov/system/files/shared/FinCENRMSB_ElectronicFilingInstructions.pdf) - [Application of Money Services Business Regulations to a Company Acting as an Independent Sales Organization and Payment Processor | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/application-money-services-business) - [PPSI-AMLCFT-NPRM.pdf](https://www.fincen.gov/system/files/2026-04/PPSI-AMLCFT-NPRM.pdf) - [The Bank Secrecy Act | FinCEN.gov](https://www.fincen.gov/resources/statutes-and-regulations/bank-secrecy-act) - [1 Financial Crimes Enforcement Network U.S. Department of the Treasury](https://www.fincen.gov/system/files/shared/AML_CFT%20Priorities%20(June%2030,%202021).pdf) - [Administrative Ruling on the Application of FinCEN Regulations to Currency Transporters, Including Armored Car Services, and Exceptive Relief | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/administrative-ruling-application-fincen) - [Key Changes in FinCEN’s Proposed Rule to Refocus AML/CFT Programs on](https://www.fincen.gov/system/files/2026-04/Key-Changes-Program-NPRM.pdf) - [F I N C E N G U I D A N C E 1](https://www.fincen.gov/system/files/2019-05/FinCEN%20CVC%20Guidance%20FINAL.pdf) - [Interagency Interpretive Guidance on Providing Banking Services to Money Services Businesses Operating in the United States | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/interagency-interpretive-guidance-providing-banking) - [FinCEN IA Final Rule Fact Sheet](https://www.fincen.gov/system/files/shared/IAFinalRuleFactSheet-FINAL-508.pdf) - [Fact Sheet: Proposed Rule to Strengthen and Modernize ...](https://www.fincen.gov/system/files/shared/Program-NPRM-FactSheet-508.pdf) - [GUIDANCE FOR A RISK-BASED APPROACH EFFECTIVE SUPERVISION AND ENFORCEMENT BY](https://www.fatf-gafi.org/content/dam/fatf/documents/reports/RBA-Effective-supervision-and-enforcement.pdf) - [Oil on the Fort Berthold Indian Reservation - Bloomberg](https://www.bloomberg.com/news/photo-essays/2012-11-08/oil-on-the-fort-berthold-indian-reservation) - [F I U 's in action](https://www.fincen.gov/sites/default/files/shared/fiuinaction.pdf) - [Williston, North Dakota, Oil Fracking Boom Fueled a Housing Crisis - Bloomberg](https://www.bloomberg.com/news/articles/2024-04-02/williston-north-dakota-oil-fracking-boom-fueled-a-housing-crisis) - [Report a scam website | National Cyber Security Centre](https://www.ncsc.gov.uk/collection/phishing-scams/report-scam-website) - [Ten Fraudsters from Four Financial Services Firms Charged in Different Cryptocurrency Market Manipulation Schemes Out of Northern District of California | TRM Labs](https://www.trmlabs.com/resources/blog/ten-fraudsters-from-four-financial-services-firms-charged-in-different-cryptocurrency-market-manipulation-schemes-out-of-northern-district-of-california) - [CHANGES TO THE Specially Designated Nationals and ...](https://ofac.treasury.gov/system/files/126/sdnew15.pdf) - [Secretary Bessent Announces Initiatives to Combat Rampant Fraud in Minnesota | FinCEN.gov](https://www.fincen.gov/news/news-releases/secretary-bessent-announces-initiatives-combat-rampant-fraud-minnesota) - [Operation Henhouse: 433 arrests and £7.5m seized in national crackdown on fraud - National Crime Agency](https://www.nationalcrimeagency.gov.uk/news/operation-henhouse-422-arrests-and-7-5m-seized-in-national-crackdown-on-fraud) - [Publication of Updates to OFAC's Specially Designated Nationals and Blocked Persons List and 13599 List Removals | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20181105_names) - [North Dakota Oil Production Expected to Take a Month to Recover From Cold Snap - Bloomberg](https://www.bloomberg.com/news/articles/2024-01-19/north-dakota-oil-production-expected-to-take-a-month-to-recover-from-cold-snap) - [STATE CONTACT INFORMATION FOR MSBs](https://www.fincen.gov/system/files/shared/msbstatecontactsfinal.pdf) - [To view or print PDF content, download the free Adobe Acrobat Reader.](https://www.fincen.gov/system/files/federal_register_notice/reg_proposal_comment_detail5.pdf) - [Special Notice RMSB Posting](https://www.fincen.gov/system/files/shared/msbregformDRAFT.pdf) - [The National Money Transmitters Association, Inc. 12 Welwyn Road, Suite C](https://www.fincen.gov/system/files/shared/NMTAComment.pdf) - [North Dakota Grain Growers Association - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/0725784D:US) - [Agriculture - Bloomberg - Bloomberg Markets](https://www.bloomberg.com/markets/commodities/futures/agriculture) - [Sophisticated Farmers Cut Out Trading Giants in Profit Hunt - Bloomberg](https://www.bloomberg.com/news/articles/2017-06-14/sophisticated-farmers-cut-out-trading-giants-in-hunt-for-profits) - [The Chainalysis Approach to Crypto Investigations](https://www.chainalysis.com/blog/approach-to-crypto-investigations/) - [OFAC Consolidated Frequently Asked Questions | Office of Foreign Assets Control](https://ofac.treasury.gov/faqs/all-faqs) - [Illicit Crypto Ecosystem Report](https://www.trmlabs.com/resources/reports/the-illicit-crypto-ecosystem-report-2022) - [Complex Proliferation Financing and Sanctions Evasion Schemes FATF Report](https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/Complex-PF-Sanctions-Evasions-Schemes.pdf.coredownload.inline.pdf) - [Fraud Warning](https://www.fatf-gafi.org/en/pages/fraud-warning.html) - [These 81 Investment Platforms Were Part of a Scam Network. Here’s What We Learned About Them. | OCCRP](https://www.occrp.org/en/project/scam-empire/these-81-investment-platforms-were-part-of-a-scam-network-heres-what-we-learned-about-them) - [North Dakota Department of Financial Institutions](https://www.nd.gov/dfi/) - [FinCEN / U.S. Department of the Treasury](https://www.fincen.gov/system/files/shared/msbstatecontactsfinal.pdf) - [FinCEN / U.S. Department of the Treasury](https://www.fincen.gov/boi) - [Financial Action Task Force](https://www.fatf-gafi.org/en/publications/Mutualevaluations/united-states-fur-2024.html) - [International Consortium of Investigative Journalists (ICIJ)](https://www.icij.org/inside-icij/2025/03/treasury-department-wont-enforce-beneficial-ownership-rule-under-the-corporate-transparency-act/) - [Chainalysis](https://www.chainalysis.com/blog/crypto-sanctions-2026/) - [Bloomberg](https://www.bloomberg.com/news/articles/2022-02-15/conocophillips-says-it-s-sending-bakken-gas-to-bitcoin-processor) - [Chainalysis](https://www.chainalysis.com/blog/southeast-asia-crypto-scam-network-mining-pig-butchering-october-2025/) 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]](#sec-sources) 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]](#sec-sources) 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]](#sec-sources) 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]](#sec-sources) 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]](#sec-sources) 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]](#sec-sources) 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]](#sec-sources) 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]](#sec-sources) 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]](#sec-sources) 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]](#sec-sources) 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]](#sec-sources) Probable · 1 source 34-state $2.5M settlement for BSA/AML violations at virtual-currency kiosks; ND receives $10,000. [[Source 1]](#sec-sources) Probable · 1 source Perpetually prohibited from employment or participation in any NDDFI-licensed entity. [[Source 1]](#sec-sources) 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]](#sec-sources) 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]](#sec-sources) Probable · 1 source Published Crypto ATM FAQ resource warning that scammers increasingly use kiosks as part of fraud schemes. [[Source 1]](#sec-sources) 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]](#sec-sources) 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]](#sec-sources) Probable · 1 source