--- title: "United States — Ohio (US-OH) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/united-states-ohio/ source_html: /jurisdictions/united-states-ohio/index.html description: "Financial integrity intelligence for United States – Ohio (US-OH): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: cc4eaeb375c256b4398e74ae0f39be66e747bfce482ed3f7fa68758cf3793ea5 generator: "fe-fleet/md-twin@1.0" --- # United States — Ohio (US-OH) — 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 — Ohio US-OH Domains covered 8 of 8 Sources 132 Role actions 8 Horizon <90d 1 Jurisdiction profile FATF status: Largely Compliant Tier: B Risk direction: Increasing Enablement vs enforcement: Mixed Ohio has no state-level AML/BO regime distinct from federal BSA/CTA framework; state financial institutions and MSBs are supervised by the Ohio Division of Financial Institutions alongside federal regulators (FinCEN, OCC, Fed, FDIC). More Federal 2025 CTA rollback exempted Ohio-formed LLCs from BOI reporting, widening opacity around the state's large small-business/shell-formation base. Active federal prosecutorial engagement (USAO-NDOH/SDOH) on crypto fraud forfeitures partly offsets state-level regulatory gaps, especially around unregulated crypto ATM kiosks. Key deficiencies - No Ohio state-level beneficial ownership registry; reliant on now-narrowed federal CTA regime exempting domestic reporting companies - No Ohio-specific crypto ATM/kiosk consumer-protection statute (transaction caps, fraud warnings, ID verification) despite documented elder-fraud exploitation via Ohio-linked kiosk operators - Regional bank HQ concentration (Fifth Third, KeyCorp, Huntington) creates correspondent-banking and BSA/AML supervisory complexity requiring sustained OCC/Fed/FinCEN coordination Recent developments (18m) - March 2025: FinCEN interim final rule exempted all US-formed entities (including Ohio LLCs) and their beneficial owners from CTA BOI reporting, narrowing the federal transparency backstop for Ohio-registered shell entities - February 2025: USAO for the Northern District of Ohio filed an $8.2M USDT civil forfeiture complaint against a cross-border pig-butchering laundering network that victimized Cleveland-area residents - August 2025: FinCEN issued a first-of-its-kind Notice (FIN-2025-NTC1) on CVC kiosk-enabled scam and laundering typologies, directly responsive to patterns previously documented in Ohio-linked crypto ATM cases United States federal law that applies in United States – Ohio is covered once, on the [United States](/jurisdictions/us/) page. This page covers United States – Ohio’s own layer: its own law, regulators and enforcement. Brief ## Lead signal #### Lead Signal Ohio's legislature is pulling its digital-asset posture in two directions at once. House Bill 648, the ELDER Act, would codify a requirement that owners, operators, and facilitators of digital-asset kiosks hold an Ohio money-transmitter licence and make pre-transaction risk disclosures to customers, formalising a treatment the Division of Financial Institutions already applies under its own guidance, which states that a business buying or selling cryptocurrency in Ohio generally must hold a licence under the Ohio Money Transmitters Act. A Legislative Service Commission fiscal note on the bill confirms that thirteen cryptocurrency kiosk operators already hold such licences under existing law, meaning HB 648 would entrench current administrative practice in statute rather than create a wholly new regime. At the same time, House Bill 116, the Blockchain Basics Act, has passed the Ohio House 70-26 and would exempt mining, staking, node operation, and like-kind token-swap activity from money-transmitter licensure altogether. Read together, the two bills describe a deliberately split posture: tightening the custodial, consumer-facing edge of the crypto economy (kiosks handling retail funds) while deregulating the infrastructure layer (validators, stakers, node operators) that does not touch consumer funds directly. Read full brief #### Lead Signal Ohio's legislature is pulling its digital-asset posture in two directions at once. House Bill 648, the ELDER Act, would codify a requirement that owners, operators, and facilitators of digital-asset kiosks hold an Ohio money-transmitter licence and make pre-transaction risk disclosures to customers, formalising a treatment the Division of Financial Institutions already applies under its own guidance, which states that a business buying or selling cryptocurrency in Ohio generally must hold a licence under the Ohio Money Transmitters Act. A Legislative Service Commission fiscal note on the bill confirms that thirteen cryptocurrency kiosk operators already hold such licences under existing law, meaning HB 648 would entrench current administrative practice in statute rather than create a wholly new regime. At the same time, House Bill 116, the Blockchain Basics Act, has passed the Ohio House 70-26 and would exempt mining, staking, node operation, and like-kind token-swap activity from money-transmitter licensure altogether. Read together, the two bills describe a deliberately split posture: tightening the custodial, consumer-facing edge of the crypto economy (kiosks handling retail funds) while deregulating the infrastructure layer (validators, stakers, node operators) that does not touch consumer funds directly. This is a structural finding, not an incident. Ohio is not responding to a specific enforcement failure; it is pre-emptively drawing a licensing boundary around custodial consumer-facing crypto activity while carving out the technical infrastructure layer. That distinction, if it holds through the legislative session, would give Ohio one of the more granular state-level treatments of digital-asset activity in the United States, separating the money-transmission question from the underlying technology question rather than treating all crypto-adjacent activity as a single category. #### Other Developments FATF's October plenary trimmed the grey list. The Financial Action Task Force removed Bulgaria, Cote d'Ivoire, the Democratic Republic of the Congo, and Monaco from its list of jurisdictions under increased monitoring, taking the list from twenty-two to eighteen jurisdictions with no new additions this round. This is a global architecture movement rather than an Ohio-specific one, but it sits directly above the state-level licensing conversation: jurisdictions move off the grey list as their AML/CFT frameworks are assessed as sufficiently remediated, and the pace of removals without replacements this cycle is itself a signal about the current state of the list's churn. Ohio's underlying AML regime remains the federal backdrop. The Division of Financial Institutions guidance treating cryptocurrency as money or its equivalent for licensing purposes under the Money Transmitters Act continues to govern in the absence of a bespoke state AML statute. Ohio layers its money-transmitter licensing, audited-financials, and bonding requirements on top of the federal Bank Secrecy Act and FinCEN framework rather than maintaining an independent state AML regime, which is why the HB 648 and HB 116 fight is being conducted through money-transmission licensing law rather than through a standalone anti-money-laundering statute. #### Cross-Monitor Connections The kiosk-licensure question in Ohio is a natural companion to payments-regulation tracking elsewhere in the same jurisdiction, since both HB 648 and HB 116 operate through the same money-transmitter licensing chokepoint that governs non-bank payment activity generally. A conflict-finance or sanctions-evasion reading of crypto kiosks — their historical association with structuring and third-party facilitation — is not evidenced in Ohio this cycle, but the licensing tightening HB 648 proposes is the kind of structural control that would make such a finding easier to detect if it emerged later, since licensed kiosk operators carry recordkeeping and reporting obligations that unlicensed cash-based alternatives do not. #### Outlook HB 648 and HB 116 are both still pending, with HB 648 at an earlier stage than HB 116, which has already cleared the Ohio House. Whether both bills proceed to enactment, or whether the Senate reconciles them into a single framework, will determine whether Ohio ends up with a genuinely bifurcated regime (tight at the custodial retail edge, loose at the infrastructure edge) or whether one philosophy prevails over the other. The FATF grey-list movement is a standing architecture update with no immediate Ohio-specific follow-on expected, but a jurisdiction's grey-list status is a recurring input to correspondent-banking and de-risking decisions that eventually touch US-based money-service businesses, including crypto kiosk operators, when their transaction counterparties sit in the affected jurisdictions. Earlier periodic briefs (6) 4 Nov 2026 · fim-2026-11-01 #### Lead Signal Ohio's legislature is pulling its digital-asset posture in two directions at once. House Bill 648, the ELDER Act, would codify a requirement that owners, operators, and facilitators of digital-asset kiosks hold an Ohio money-transmitter licence and make pre-transaction risk disclosures to customers, formalising a treatment the Division of Financial Institutions already applies under its own guidance, which states that a business buying or selling cryptocurrency in Ohio generally must hold a licence under the Ohio Money Transmitters Act. A Legislative Service Commission fiscal note on the bill confirms that thirteen cryptocurrency kiosk operators already hold such licences under existing law, meaning HB 648 would entrench current administrative practice in statute rather than create a wholly new regime. At the same time, House Bill 116, the Blockchain Basics Act, has passed the Ohio House 70-26 and would exempt mining, staking, node operation, and like-kind token-swap activity from money-transmitter licensure altogether. Read together, the two bills describe a deliberately split posture: tightening the custodial, consumer-facing edge of the crypto economy (kiosks handling retail funds) while deregulating the infrastructure layer (validators, stakers, node operators) that does not touch consumer funds directly. This is a structural finding, not an incident. Ohio is not responding to a specific enforcement failure; it is pre-emptively drawing a licensing boundary around custodial consumer-facing crypto activity while carving out the technical infrastructure layer. That distinction, if it holds through the legislative session, would give Ohio one of the more granular state-level treatments of digital-asset activity in the United States, separating the money-transmission question from the underlying technology question rather than treating all crypto-adjacent activity as a single category. #### Other Developments FATF's October plenary trimmed the grey list. The Financial Action Task Force removed Bulgaria, Cote d'Ivoire, the Democratic Republic of the Congo, and Monaco from its list of jurisdictions under increased monitoring, taking the list from twenty-two to eighteen jurisdictions with no new additions this round. This is a global architecture movement rather than an Ohio-specific one, but it sits directly above the state-level licensing conversation: jurisdictions move off the grey list as their AML/CFT frameworks are assessed as sufficiently remediated, and the pace of removals without replacements is itself a signal about the current state of the list's churn. Ohio's underlying AML regime remains the federal backdrop. The Division of Financial Institutions guidance treating cryptocurrency as money or its equivalent for licensing purposes under the Money Transmitters Act continues to govern in the absence of a bespoke state AML statute. Ohio layers its money-transmitter licensing, audited-financials, and bonding requirements on top of the federal Bank Secrecy Act and FinCEN framework rather than maintaining an independent state AML regime, which is why the HB 648 and HB 116 fight is being conducted through money-transmission licensing law rather than through a standalone anti-money-laundering statute. #### Cross-Monitor Connections The kiosk-licensure question in Ohio is a natural companion to payments-regulation tracking elsewhere in the same jurisdiction, since both HB 648 and HB 116 operate through the same money-transmitter licensing chokepoint that governs non-bank payment activity generally. A conflict-finance or sanctions-evasion reading of crypto kiosks — their historical association with structuring and third-party facilitation — is not evidenced in Ohio, but the licensing tightening HB 648 proposes is the kind of structural control that would make such a finding easier to detect if it emerged later, since licensed kiosk operators carry recordkeeping and reporting obligations that unlicensed cash-based alternatives do not. #### Outlook HB 648 and HB 116 are both still pending, with HB 648 at an earlier stage than HB 116, which has already cleared the Ohio House. Whether both bills proceed to enactment, or whether the Senate reconciles them into a single framework, will determine whether Ohio ends up with a genuinely bifurcated regime (tight at the custodial retail edge, loose at the infrastructure edge) or whether one philosophy prevails over the other. The FATF grey-list movement is a standing architecture update with no immediate Ohio-specific follow-on expected, but a jurisdiction's grey-list status is a recurring input to correspondent-banking and de-risking decisions that eventually touch US-based money-service businesses, including crypto kiosk operators, when their transaction counterparties sit in the affected jurisdictions. 3 Nov 2026 · fim-2026-11-03 #### Lead Signal Ohio is in the process of codifying, through House Bill 648 (the ELDER Act), a licensing posture toward digital-asset kiosks that the state Division of Financial Institutions has already applied through interpretive guidance. The bill, still pending before the Ohio General Assembly, would require owners, operators and facilitators of virtual-currency kiosks to hold an Ohio money-transmitter licence under the existing Ohio Money Transmitters Act, and would add mandatory pre-transaction risk disclosures to consumers. This is a codification rather than a creation of obligation: Ohio Legislative Service Commission materials note that thirteen cryptocurrency kiosk operators already hold Ohio money-transmitter licences, meaning the current population of the sector is already operating inside the licensing perimeter the bill would put into statute. The architectural significance is that Ohio is closing the gap between guidance-based supervisory treatment and an explicit statutory basis, which narrows the room for a kiosk operator to argue that licensure was merely an administrative expectation rather than a legal requirement. #### Other Developments A parallel, opposite-direction bill sits alongside HB 648. Separate legislative activity working through infrastructure-layer crypto activity, such as mining, staking, node operation and token-for-token exchange, points toward narrowing rather than widening the money-transmitter perimeter for non-custodial functions. Read together with HB 648, the pattern is a split legislative posture: tightening consumer-facing kiosk duties while loosening scope for activity that does not touch consumer funds directly. This divergence is itself the signal worth tracking, rather than either bill in isolation, because it shows Ohio drawing a functional line between custodial consumer-facing services and infrastructure-layer participation. Existing audited-financials obligations continue to apply without change. Ohio money transmitters, including the current population of licensed kiosk operators, must maintain audited financial statements and file them within 120 days of fiscal year-end under the Ohio Money Transmitters Act. HB 648 would not alter this existing solvency and reporting backbone; it would extend the licensing trigger more explicitly to kiosk-specific business models rather than changing the underlying prudential requirement. #### Cross-Monitor Connections The Ohio kiosk-licensing development connects to the broader architecture of how financial-innovation oversight is organized at the state level in the United States: a single generalist money-transmitter statute, rather than a bespoke crypto regime, is being asked to absorb kiosk-specific risk through amendment rather than through a parallel standalone law. This is a structural pattern worth watching across other states with similar generalist money-transmission statutes, since the same legislative technique, closing an interpretive gap by statute rather than by new regime, could recur elsewhere. Separately, and without any Ohio-specific nexus, the FATF October 2026 Plenary removed Bulgaria, Cote d'Ivoire, the Democratic Republic of the Congo and Monaco from increased monitoring, reducing the list from twenty-two to eighteen jurisdictions with no additions. This is a global architecture development relevant to how enhanced due diligence obligations are triggered for obliged entities generally, including money-service businesses of the kind Ohio's kiosk operators are regulated as, even though no obligor-level nexus to Ohio was identified. #### Outlook HB 648 remains pending, and its effective date, if enacted, is not yet fixed. As scheduled, the practical effect for the thirteen already-licensed kiosk operators would be limited, since they already hold the licence the bill would require; the more material effect would fall on any future entrant that might otherwise have relied on ambiguity in the guidance-based regime. The global grey-list movement from the October 2026 Plenary is a separate, confirmed development whose Ohio-specific implications, if any, are not yet identified. 18 Oct 2026 · fim-2026-10-18 #### Lead Signal Ohio's Division of Financial Institutions acted as one of several lead examining states in a thirty-four-state, 2.5 million dollar BSA/AML settlement with Coinme Inc., a Seattle-based cryptocurrency money transmitter and kiosk operator. The settlement, reached over BSA/AML program deficiencies, requires Coinme to exit the crypto-kiosk business nationwide by 1 January 2027 or pay a further 4 million dollars. Six days after the settlement closed, Polygon completed its acquisition of Coinme on 14 October 2026, assuming both the Ohio-licensed entity's money-transmitter registration and its unresolved AML remediation obligations. This is a structural signal as much as an enforcement one: a state examiner network identified and resolved a program-level BSA/AML deficiency at a nationally operating crypto-kiosk business, and the business was then absorbed by an acquirer that now carries the remediation forward under new ownership. #### Other Developments A national enforcement surge reached Ohio this cycle through the US Attorney's Office for the Northern District of Ohio, which joined the Department of Justice's first National Tax Enforcement Surge, running September through October 2026, alongside the Secret Service Cleveland Field Office's Money Laundering Task Force and IRS Criminal Investigation. The nationwide effort alleges over 490 million dollars in intended federal revenue loss; the Northern Ohio component is part of this federal initiative rather than a state-specific action. Ohio's underlying AML statutory baseline remains Ohio Revised Code Chapter 1315, the state's Money Transmitters Act, with reporting and money-laundering definitions at section 1315.51, bank transaction-reporting duties at 1315.53, and Attorney General investigatory power at 1315.54; this framework applies in parallel with federal BSA/FinCEN money-services-business registration requirements, and no amendment to it was identified this cycle. #### Cross-Monitor Connections The Coinme settlement and Polygon acquisition connect directly to the crypto monitor's licensing coverage of the same Ohio money-transmitter registration, and to the world-payments monitor's commercial-intelligence tracking of the acquisition itself, including Polygon's stated plan to use the assumed licenses for stablecoin settlement and local-currency payouts. The national tax enforcement surge reaching Northern Ohio is part of a broader federal pattern that other state financial-integrity pages in this cycle's wave may also reflect where the surge touched their jurisdiction. #### Outlook The 1 January 2027 deadline for Coinme's kiosk-business exit, now a Polygon obligation, is the clearest dated marker to watch, alongside whether Polygon's remediation of the BSA/AML program deficiencies identified in the settlement is completed and verified by the lead examining states, Ohio among them. Whether the Northern Ohio component of the national tax enforcement surge yields public charging documents naming Ohio-based entities is a secondary marker worth monitoring given the scale of the alleged nationwide revenue loss. 11 Oct 2026 · fim-2026-10-11 #### Lead Signal Ohio's digital-asset legal architecture moved on two tracks this cycle without touching the state's underlying AML/CFT gateway. House Bill 195, signed July 7, 2026 and effective October 6, 2026, amended the Ohio Uniform Commercial Code to add Article 12, creating a commercial-law classification of controllable electronic records that governs control, transfer and security-interest perfection for cryptocurrency, NFTs and similar digital assets. This is a property and secured-lending instrument, not an AML rule, but it is directly relevant to asset-tracing and civil-forfeiture practice around illicit crypto holdings, since it now gives Ohio courts and creditors a defined commercial-law hook for establishing control over a digital asset. Separately, House Bill 648 (the ELDER Act), introduced February 5, 2026 and still sitting in the House Financial Institutions Committee since a third hearing on May 20, 2026, would bring digital-asset kiosk operators within Ohio's general money-transmitter licensure under Revised Code Chapter 1315, adding senior-protection disclosures and transaction holds for customers aged 60 and above. Neither instrument has altered the state's standing AML gateway: absent HB 648 or the related HB 116 reaching enactment, Ohio's general-purpose Money Transmitter Law, administered by the Division of Financial Institutions, remains the default licensing and AML test applied to virtual-currency businesses, as illustrated by the 2023 consent order against Metallicus, Inc. #### Other Developments The commercial-law and AML layers are moving at different speeds. HB 195 is now in force and creates durable new rights around digital-asset control and perfection; HB 648 remains a proposal, with its path out of committee unconfirmed as of this cycle. The kiosk-specific gap that HB 648 would close is senior-protection controls at the point of a physical digital-asset kiosk transaction, a gap the current general MTL regime does not specifically address. The standing AML architecture itself saw no delta this cycle: Ohio Revised Code sections 1315.01 through 1315.18, administered by the Division of Financial Institutions, continue to function as the designated state AML/CFT supervisory counterpart to the federal BSA/FinCEN layer, with the Metallicus consent order remaining the operative enforcement precedent for virtual-currency money transmission. #### Cross-Monitor Connections The UCC Article 12 commercial-law classification bears on crypto-asset tracing and licensing questions tracked elsewhere in this union: a crypto-focused reading of the same HB 195 development addresses how the new controllable-electronic-records classification interacts with token-classification questions, while a payments-focused reading addresses how the same instrument affects legal and litigation exposure around digital-asset collateral. None of this reclassifies digital assets for AML purposes; the money-transmission licensing question raised by HB 648 remains the operative AML-adjacent thread, and it has not advanced to enactment. #### Outlook The principal items to watch are whether HB 648 is reported out of the House Financial Institutions Committee following its May 2026 hearing, and whether the related HB 116 advances in parallel. Enactment of either would extend Ohio's money-transmission licensure perimeter to cover additional digital-asset business models, but as of this cycle both remain pending and the state's general MTL regime continues to serve as the default AML gateway for virtual-currency businesses operating in Ohio. 28 Aug 2026 · fim-2026-08-21 #### Lead Signal Ohio House Bill 648 has emerged as this cycle's material financial-integrity development in Ohio, and it is best read as architecture rather than incident. The bill, introduced on January 20, 2026 and currently before the House Financial Institutions Committee, would require any person who owns, operates, or facilitates a digital-asset kiosk in Ohio to register as a money transmitter under the state's existing Money Transmitters Act, bringing the kiosk channel inside the same BSA/AML licensing perimeter that already governs conventional money-services businesses in the state. The proposal is assessed, not confirmed, since it has not advanced past committee, but the underlying policy rationale is well evidenced: it is understood to respond to the bankruptcy and cessation of operations of a nationwide crypto-ATM kiosk operator, a failure that exposed the absence of a distinct licensed category for kiosk operators under Ohio's money-transmitter framework. Structurally, HB648 would close that gap by extending registration, and by extension AML program and OFAC-screening obligations administered by the Division of Financial Institutions, to a channel used disproportionately to target elderly victims. This is the kind of structural gap-closure this monitor treats as more analytically significant than any single enforcement action, because it changes what the regulatory perimeter covers going forward rather than sanctioning a single past violation. The jurisdiction's broader financial-integrity posture, as tracked this cycle, is assessed as structural rather than episodic, and mixed between enforcement and enablement postures: Ohio's designated regulator, the Division of Financial Institutions, already requires money-transmitter licensees to maintain a BSA/AML program and screen against the OFAC Specially Designated Nationals list, and HB648 would simply extend that same designated-regulator architecture to a channel not currently captured by it, rather than creating a new regulatory body or standard. #### Other Developments No additional Ohio-specific development met this cycle's materiality threshold beyond the kiosk-registration signal detailed above. This cycle's dispatch scope was limited to Ohio, and the standing federal-baseline posture across the balance of this monitor's typology domains for the jurisdiction is unchanged from the prior cycle. #### Cross-Monitor Connections HB648's kiosk-registration requirement sits directly on the boundary between this monitor's financial-integrity lens and the payments-infrastructure lens that the World Payments Monitor applies to the same bill and the same kiosk-operator failure: where this monitor reads HB648 as an AML/CTF perimeter-closure measure, the payments monitor reads the identical instrument as a licensing and market-access development. The crypto-specific consumer-protection and product dimensions of the same bill and the same kiosk-operator failure are likewise tracked independently by the crypto monitor, which assesses the elder-focused disclosure and transaction-hold provisions as consumer-protection architecture rather than AML architecture. Readers following the full picture around Ohio's digital-asset kiosk channel should treat these three monitor lenses as complementary rather than duplicative: the same instrument, the same failure, and the same regulator, viewed through three distinct analytical frames. #### Outlook HB648 remains in committee, and its path to enactment is not yet determinable from current sourcing; the regulatory horizon places its expected resolution in 2026 Q4 with a half-year uncertainty band. If enacted, the practical effect would be to require kiosk operators to obtain money-transmitter licensure, implement KYC and AML disclosures, and apply elder-protection transaction holds, closing a gap this monitor assesses as structurally significant regardless of the bill's ultimate legislative fate, since its introduction alone confirms that Ohio's regulator and legislature have identified the kiosk channel as an AML/CTF perimeter gap worth closing. The next cycle should watch for committee action and any parallel movement by the Division of Financial Institutions to address the same gap through guidance rather than statute. 14 Jul 2026 · fim-2026-07-14 #### Lead Signal The defining development of this baseline cycle is a scope correction with structural consequences for Ohio beneficial-ownership transparency. An interim final rule issued by FinCEN, effective March 26, 2025, exempted all United States-formed entities nationwide, together with their US-person beneficial owners, from Corporate Transparency Act beneficial-ownership-information reporting obligations; only foreign entities registering to do business in US states now remain subject to federal disclosure (fim-2026-07-05-001). This is a national policy choice rather than an Ohio-specific carve-out, and an earlier characterization of this exemption as state-limited is corrected in this cycle. The correction matters because Ohio, unlike a majority of peer states, maintains no state-level beneficial-ownership registry; Ohio relies entirely on the now-narrowed federal backstop for beneficial-ownership visibility into entities formed within its borders (fim-2026-07-05-002). Set against this, Ohio also carries above-average exposure in the crypto-asset channel: a crypto-ATM kiosk network associated with elder-targeted and romance-investment fraud operated in the state until its 2023 cessation, and no Ohio statute currently imposes the transaction limits or identity-verification requirements that eighteen or more peer states have adopted for kiosk operators (fim-2026-07-05-003, fim-2026-07-05-004). Layered onto both threads is the Section 311 special measure severing Huione Group, the Cambodia-based conglomerate at the center of a documented pig-butchering laundering architecture, from the US financial system, with direct correspondent-banking consequences for the super-regional banks headquartered in Ohio (fim-2026-07-05-009). A parallel federal rulemaking track, the joint FinCEN and OFAC implementing rule for GENIUS Act stablecoin AML and sanctions obligations, is expected to finalize ahead of the January 2027 statutory deadline and directly affects Ohio-headquartered banks exploring stablecoin issuance or custody (fim-2026-07-05-012). #### Other Developments Iran sanctions posture reaffirmed. National Security Presidential Memorandum-2, issued February 4, 2025, reaffirmed blocked-property status for Iranian financial institutions designated under Executive Order 13599 and reiterated correspondent-account prohibitions binding on all US financial institutions, a continuing architecture rather than a new designation (fim-2026-07-05-010). Sanctions-list divergence creates correspondent friction. EU and UK sanctions regimes have pursued parallel but non-identical designation timing and scope relative to OFAC and FinCEN action against the Prince Group and Huione-linked network, a divergence functioning as friction for Ohio-headquartered multinational banks reconciling three lists rather than merely an administrative inconvenience (fim-2026-07-05-011). FinCEN sharpens kiosk-scam supervisory expectations. Notice FIN-2025-NTC1, issued August 4, 2025, details tech-support, bank-imposter, and elder-targeted kiosk scam typologies and raises Bank Secrecy Act reporting and red-flag expectations for institutions banking kiosk operators nationwide, including deployments in Ohio (fim-2026-07-05-007). Interagency strike force targets scam-compound infrastructure. A coordinated DOJ Scam Center Strike Force action with OFAC and the State Department, announced April 23, 2026, targeted Southeast Asian scam-compound financial infrastructure matching the typology identified in the Northern District of Ohio pig-butchering case, though this data point rests on a single lower-tier source this cycle and has not been independently corroborated by a stronger source (fim-2026-07-05-008). Civil forfeiture evidences the laundering architecture. The Office of the United States Attorney for the Northern District of Ohio and the FBI filed a civil forfeiture complaint on February 27, 2025 against 8.2 million dollars in USDT traced through DeFi platforms, cross-chain swaps, and unhosted wallets to Southeast Asian scam-compound operators; the individual forfeiture is the data point, the layering pathway is the structural finding (fim-2026-07-05-005, fim-2026-07-05-006). Ohio bank concentration compounds supervisory complexity. Fifth Third, KeyCorp, and Huntington, all headquartered in Ohio, concentrate correspondent-banking and Bank Secrecy Act supervisory exposure requiring sustained coordination among the OCC, the Federal Reserve, and FinCEN not present in most other states (fim-2026-07-05-017). State-level enforcement visibility remains thin. Public, systematically searchable records of Ohio Division of Financial Institutions money-services-business enforcement activity, distinct from federal FinCEN and DOJ action, remain limited, constraining independent assessment of whether the state supervisory layer meaningfully supplements federal oversight (fim-2026-07-05-015). United States retains clean FATF standing. The February 13, 2026 FATF plenary added Kuwait and Papua New Guinea to increased monitoring while leaving Iran, North Korea, and Burma unchanged on the call-for-action list; the United States, and by extension Ohio, remains outside both lists, though a possible subsequent mid-2026 plenary update has not been independently verified this cycle (fim-2026-07-05-016). #### Cross-Monitor Connections Two cross-monitor routings apply this cycle. The pig-butchering laundering architecture identified in the Northern District of Ohio forfeiture action routes proceeds to Southeast Asian scam-compound operators reported to be intertwined with forced-labor trafficking infrastructure in Cambodia and Myanmar, a medium-strength flag to the conflict-finance monitor given the human-exploitation dimension underlying the financial layering (fim-2026-07-05-005, fim-2026-07-05-008). Separately, the continued Iran maximum-pressure sanctions posture under NSPM-2 and the Section 311 special measure against Huione Group both register as low-strength but relevant data points for macro-variable sanctions tracking, with the documented EU/UK divergence on Prince Group and Huione designations adding a regime-friction dimension to that read (fim-2026-07-05-009, fim-2026-07-05-010, fim-2026-07-05-011). Neither flag rises to a state-capture reading for Ohio itself; Ohio functions in this cycle as an enabler and target jurisdiction for these architectures rather than as a locus of state-directed capture. #### Outlook The near-term trajectory for Ohio financial-integrity exposure is best read as mixed-to-deteriorating. On the compliance-technology axis, the joint FinCEN and OFAC GENIUS Act stablecoin rule is expected to finalize within roughly six months and would tighten AML and sanctions-compliance obligations for Ohio-headquartered banks exploring stablecoin issuance (fim-2026-07-05-012). On the market-structure axis, the CLARITY Act digital-asset legislation, advanced by the Senate Banking Committee in May 2026 after contentious markup, faces uncertain passage before the November 2026 midterms; failure would risk a multi-year regulatory delay for the market-structure rules bearing on Ohio-based exchanges and crypto-ATM operators (fim-2026-07-05-013). At the state level, the absence of any filed Ohio crypto-kiosk consumer-protection bill, despite the trend among eighteen or more peer states, remains a live but unconfirmed legislative-pressure signal rather than a scheduled development (fim-2026-07-05-014). The state-level beneficial-ownership gap and the thin visibility into Ohio Division of Financial Institutions enforcement activity are structural rather than episodic conditions and are unlikely to resolve absent new state legislation. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion The clearest sanctions-architecture signal this cycle is the divergence opened by OFAC's designation of the International Criminal Court under Executive Order 14203 on 9 October 2026. Eight allied governments, the United Kingdom, Canada, Denmark, Germany, France, Italy, Japan and the Netherlands, issued public statements that they regret and strongly disagree with the designation. This is not a technical enforcement footnote; it is a visible fracture in what has historically been treated as a broadly coordinated Western sanctions posture, and it sits alongside OFAC's continued extension of Russia-related general licenses, suggesting a sanctions programme that is simultaneously tightening in some directions and loosening in others depending on the designation target. Continue reading A second sanctions-architecture thread this cycle is narcotics-focused: OFAC designated four individuals and 11 entities linked to Cartel del Noreste's commercial network and horse-racing operations on 13 October 2026. This designation extends, though does not itself evidence in full, the trade-based-laundering and fiscal-fuel-theft typology that FinCEN's own June 2026 advisory identified as the cartels' most significant non-drug illicit revenue source. The continuation of the underlying national emergency declared under Executive Order 12978, confirmed as extending beyond 21 October 2026 by the Federal Register notice of 19 October, underscores that this designation track sits within a decades-old, still-active sanctions architecture rather than a new initiative. Taken together, these two threads illustrate the structural tension in the sanctions architecture at present: an expansive and occasionally internationally contested designation practice (the ICC action) sitting alongside a narrower, allegedly well-corroborated typology-driven designation practice (the cartel network). Both operate under the same legal authority structure but draw very different reactions from the international compliance community, a distinction compliance functions tracking OFAC's SDN list additions should not collapse into a single undifferentiated signal. #### Outlook Watch for further allied statements or coordinated response to the ICC designation, which could affect multilateral sanctions-list harmonization efforts going forward. On the narcotics-sanctions track, watch for whether additional designations follow the Cartel del Noreste action as FinCEN's fiscal-fuel-theft typology continues to generate enforcement referrals. The outcome of the FATF's scheduled October 2026 plenary, including any Pakistan grey-list determination, remains unconfirmed in available sources and should be checked against the published communique once it is issued. Judgment: No Ohio-specific sanctions-evasion finding this cycle. Uncertain #### Beneficial Ownership and Corporate Transparency For Ohio specifically, the corporate-transparency picture this cycle turns on a single but consequential federal scope correction rather than any state-level reform. An interim final rule issued by FinCEN, effective March 26, 2025, exempted all United States-formed entities nationwide, and their US-person beneficial owners, from Corporate Transparency Act beneficial-ownership-information reporting; only foreign entities registering to do business in US states, Ohio included, remain subject to federal disclosure (fim-2026-07-05-001). This corrects an earlier mischaracterization of the exemption as Ohio-specific: the policy choice is national in scope, and its consequence for Ohio derives from the size of Ohio relative shell-formation base rather than from any distinct Ohio carve-out. Ohio permits rapid, low-friction LLC and corporation formation through the Secretary of State with no state-level beneficial-ownership disclosure requirement, leaving Ohio reliant entirely on the now-narrowed federal backstop for any visibility into who beneficially owns entities formed within its borders (fim-2026-07-05-002). This is a structural gap rather than an episodic one: it does not depend on any single enforcement failure but on the durable absence of a state-level registry layered onto a federal regime that has itself just narrowed. Continue reading Applying the enabler-jurisdiction filter, the relevant question for Ohio is not one of enforcement capacity being absent by incapacity, but of political choice: Ohio has for decades marketed itself as a low-friction formation state, and no bill is currently before the Ohio General Assembly to impose beneficial-ownership disclosure at company formation. The severity of this gap should be read as elevated precisely because it compounds with the newly narrowed federal backstop rather than existing against a still-broad federal disclosure baseline; the interaction of the two conditions, not either alone, constitutes the structural finding for this cycle (fim-2026-07-05-001, fim-2026-07-05-002). For Ohio-based and Ohio-facing financial institutions, the practical consequence of this scope narrowing falls most heavily on customer due-diligence programs built around an assumption of federal registry corroboration. Where compliance functions previously could cross-reference a beneficial-ownership filing against a customer declared ownership structure for domestic entities, that cross-reference is now unavailable for the large majority of US-formed corporate and fund-structure customers, leaving institutions more dependent on their own onboarding-stage verification for entities carrying corporate or politically-exposed-person risk typologies (fim-2026-07-05-001, fim-2026-07-05-002). Globally, the European Union AML Package sets the structural direction for beneficial-ownership transparency architecture, though Ohio sits entirely outside its direct perimeter. The package comprises three distinct instruments: the directly applicable AML Regulation, known as the AMLR, under Regulation (EU) 2024/1624; the sixth AML Directive, transposed at the discretion of each EU member state; and the AMLA Regulation, Regulation (EU) 2024/1620, which establishes the Anti-Money Laundering Authority and shifts supervision of high-risk cross-border obliged entities from purely national authorities toward a hybrid direct-and-indirect EU-level supervisory regime. None of these instruments reaches Ohio directly, and no AMLA-related development altering Ohio domestic standing was identified this cycle; the architecture is noted here as durable global backdrop against which the narrower, US-specific beneficial-ownership picture for Ohio should be read, not as a development bearing directly on this jurisdiction. #### Outlook The beneficial-ownership trajectory for Ohio is best read as deteriorating rather than stable. The narrowed federal CTA regime removes the principal existing mechanism for domestic beneficial-ownership visibility, and no legislative signal currently indicates that Ohio intends to establish a state-level registry to backstop that narrowing. Absent new state legislation, the corporate-formation channel in Ohio is likely to remain structurally opaque to beneficial-ownership scrutiny beyond the residual federal disclosure obligation applicable only to foreign entities registering in the state (fim-2026-07-05-001, fim-2026-07-05-002). The EU AML Package trajectory, while not directly applicable to Ohio, continues to move toward operational AMLA supervision and should be monitored for any future US-EU reciprocal-recognition or correspondent-transparency implications relevant to Ohio-headquartered banks with EU-facing subsidiaries. Judgment: No Ohio- or US-specific BO-registry development this cycle. Uncertain #### Enabler Jurisdictions and Professional Facilitators Cambodia's asset-freeze action against the Prince Group scam network is this cycle's defining enabler-jurisdiction signal. Cambodian authorities froze assets worth almost one billion US dollars linked to the network and sought INTERPOL assistance for 29 fugitive ringleaders, coordinating with the FBI and China's Ministry of Public Security. On its face this reads as an enforcement success against a scam-compound operation of significant scale; read architecturally, it sits alongside continued reporting that the US State Department placed Cambodia in Tier 3, its lowest category, in its 2026 trafficking report, and alongside investigative allegations that official protection for scam-compound operations continues despite the crackdown. Enablement as signal applies directly here: a single large asset freeze does not, by itself, establish that the enabling conditions, weak oversight, alleged official complicity, cross-border labour trafficking into scam compounds, have been structurally addressed. Continue reading The jurisdictional risk reading for Cambodia should therefore separate the enforcement event from the structural question it sits inside. The enforcement event is real and well-evidenced: a near-billion-dollar freeze, an active INTERPOL request, and genuine multinational law-enforcement coordination. The structural question, whether Cambodia's broader scam-compound ecosystem is being dismantled or whether this is a visible action against one network while others continue under alleged official protection, remains open and is not resolved by this cycle's reporting. Professional facilitators and financial institutions with correspondent or customer exposure to Cambodia-linked entities should weight the Tier 3 trafficking designation and the continued-protection allegations at least as heavily as the headline freeze figure. #### Outlook Watch for Cambodian government primary-source confirmation of the asset freeze's legal basis and disposition, which was not directly retrieved this cycle, only secondary reporting. Watch also for any follow-on US Treasury or State Department action that would indicate whether Washington treats this as sufficient progress against Cambodia's enabler-jurisdiction profile or as insufficient given the Tier 3 trafficking designation and continued-protection allegations. Judgment: No enabler-jurisdiction finding for Ohio this cycle. Uncertain Judgment: No conflict-finance finding for Ohio this cycle. Uncertain #### Crypto / Digital Assets / Financial Innovation Ohio is running two parallel legislative tracks for digital-asset activity this cycle, and the split between them is the analytically significant fact. House Bill 648, the ELDER Act, would formally require owners, operators, and facilitators of digital-asset kiosks to hold an Ohio money-transmitter licence and to make pre-transaction risk disclosures to customers before a kiosk transaction completes. This is less a new imposition than a codification: the Division of Financial Institutions already treats cryptocurrency as money or its equivalent for money-transmission licensing purposes under its published guidance, and a Legislative Service Commission fiscal note confirms that thirteen cryptocurrency kiosk operators have already obtained a money-transmitter licence in Ohio under that existing interpretive framework. HB 648's main substantive addition is the pre-transaction risk-disclosure duty, which targets a documented vector in kiosk-based fraud — operators taking a transaction to completion before a customer is warned, or is warned too generically to act on it. Continue reading Running in the opposite direction, House Bill 116, the Blockchain Basics Act, has already passed the Ohio House on a 70-26 vote and would carve mining, staking, node operation, and like-kind crypto-to-crypto swap activity out of the money-transmitter licensing perimeter entirely. This is a deregulatory move aimed squarely at the infrastructure layer of the crypto economy — activity that does not involve custody of a counterparty's funds in the way a kiosk transaction does. The two bills are not contradictory so much as they reflect a considered line-drawing exercise: licence the custodial, consumer-facing layer where a customer hands over cash or value to an operator; exempt the non-custodial, protocol-level layer where no counterparty funds changes hands. Whether that line survives Senate consideration intact, or gets blurred in reconciliation, is the open question for the next several legislative cycles. For a financial-integrity reading, the kiosk side is the one that matters most directly. Cryptocurrency kiosks have been a recurring vector in elder-fraud and romance-scam typologies nationally, which is presumably why HB 648 travels under the ELDER Act label; a licensing-plus-disclosure regime is a control response to that typology rather than a response to a specific Ohio enforcement action. The thirteen operators already licensed under current guidance demonstrate that the licensing mechanism itself is not new — what HB 648 adds is statutory durability (removing reliance on administrative guidance that could shift) and the specific disclosure obligation. #### Outlook Both bills remain pending, with HB 116 further along in the process than HB 648. If HB 648 passes substantially as introduced, Ohio's kiosk operators would move from an interpretive-guidance basis for licensure to a statutory one, a change that matters for enforcement durability even though the practical licensing requirement for most existing operators would not change. If HB 116 also passes, Ohio would have formally exempted the infrastructure layer while tightening the custodial layer — a bifurcation worth tracking as a template other states may look to, given how few state legislatures have attempted this granularity rather than treating crypto activity as a single undifferentiated category for licensing purposes. Judgment: HB 648 would codify crypto-kiosk money-transmitter licensure; HB 116 would deregulate non-custodial crypto activity — a split legislative posture. Probable #### Compliance Technology and Active Defence Two developments this cycle illustrate a compliance-technology and active-defence posture that is improving even as the underlying threat surface, discussed in the crypto domain, continues to expand. FinCEN issued Notice FIN-2025-NTC1 on August 4, 2025, a first-of-its-kind notice detailing convertible-virtual-currency kiosk scam and laundering typologies, including tech-support, bank-imposter, and elder-targeted schemes, which raises Bank Secrecy Act reporting and red-flag expectations for financial institutions banking kiosk operators nationwide, including deployments in Ohio (fim-2026-07-05-007). The notice functions as supervisory and regulatory-technology guidance development: it raises supervisory expectations across the sector without itself imposing a direct penalty, and it is best read as sharpening the detection and reporting apparatus available to institutions rather than as an enforcement action in its own right. Continue reading Separately, blockchain-analytics support was directly embedded in the DOJ and FBI enforcement workflow against the pig-butchering scam-network proceeds discussed in the crypto domain, underpinning both the 8.2 million dollar Northern District of Ohio forfeiture and the broader interagency Scam Center Strike Force action. This illustrates the operational integration of commercial blockchain analytics into active federal enforcement against transnational laundering infrastructure, a genuine active-defence development distinct from the underlying scam typology itself (fim-2026-07-05-006, fim-2026-07-05-008). #### Outlook The compliance-technology trajectory for institutions with Ohio exposure is one of rising supervisory expectations layered onto a threat surface that is itself still expanding. The FIN-2025-NTC1 typology notice is likely to be followed, in the ordinary course of FinCEN practice, by increased examiner attention to whether institutions banking kiosk operators have adjusted red-flag monitoring and Suspicious Activity Report filing practices to reflect the newly documented typologies; institutions that have not done so face a widening gap between supervisory expectation and demonstrated control (fim-2026-07-05-007). The embedding of blockchain-analytics tooling into DOJ and FBI enforcement workflows is likely to continue and expand to further cases sharing the DeFi and stablecoin layering profile documented in the Northern District of Ohio matter, reinforcing the case for institutions to adopt comparable analytics capability defensively rather than relying solely on ex-post law-enforcement recovery (fim-2026-07-05-006, fim-2026-07-05-008). Judgment: No RegTech/compliance-technology development identified for Ohio this cycle. Uncertain Judgment: Ohio's AML/CFT regime remains the federal BSA/FinCEN framework layered under the state MTL regime; no bespoke state AML statute beyond audited-financials and bonding requirements. Probable #### Commercial Activity Viewed as a commercial event, Polygon's acquisition of Coinme Inc., which closed on 14 October 2026, is financial-integrity-adjacent precisely because of its timing: it closed only six days after Coinme's thirty-four-state, 2.5 million dollar BSA/AML settlement, with Ohio named among the lead examining states that reached that settlement. The deal consideration was not publicly disclosed in the sources reviewed. What is confirmed is the substantive consequence of the timing: Polygon, as acquirer, assumes Coinme's Ohio money-transmitter license and the obligation to exit the crypto-kiosk business nationwide by 1 January 2027 or pay an additional 4 million dollars, along with whatever BSA/AML program remediation the settlement requires. For a financial-integrity reading of M&A activity in the digital-asset space, this transaction is a useful marker of how compliance liabilities transfer with licensed entities in crypto-sector consolidation, rather than being extinguished or renegotiated at the point of sale. Continue reading #### Outlook Tracking whether Polygon discloses deal consideration, and whether it meets the 1 January 2027 kiosk-exit deadline and completes the inherited BSA/AML remediation, will indicate whether this acquisition model of absorbing a settlement's compliance burden becomes a template for other crypto-sector consolidation or proves to be a one-off complication for the acquirer. Judgment: No commercial event among integrity-infrastructure firms identified for Ohio this cycle. Uncertain Regulatory horizon Proposed 2026-Q4 · ±half_year ### HB648 Digital Asset Kiosk regulation Kiosk operators would need money-transmitter licensure, KYC/AML disclosures, and elder-protection transaction holds. [Ohio General Assembly / Ohio Division of Financial Institutions Source](https://www.legislature.ohio.gov/legislation/136/hb648) Consultation 30 Jun 2027 · ±multi_year ### Ohio House Bill 648 (ELDER Act) digital-asset kiosk licensure Would require digital-asset kiosk owners/operators/facilitators to hold an Ohio money-transmitter licence and make pre-transaction risk disclosures. [Source](https://search-prod.lis.state.oh.us/api/v2/general_assembly_136/legislation/hb648/00_IN/attachments/fiscal_notes/) Proposed 2027-Q1 · ±half_year ### Ohio HB 116 (Blockchain Basics Act) - MTL carve-outs for mining/staking/node operation Would exempt certain crypto activities from MTL/securities licensure and create tax carve-outs for small digital-asset payments. [Ohio General Assembly Source](https://cryptoslate.com/crypto-laws/ohio-blockchain-basics-act-hb-116/) 3 dated · 2 pending date · baseline financial-integrity-2026-07-05 Role action cards MLRO ### Ohio is moving to put crypto-kiosk licensure and pre-transaction disclosure duties into statute rather than guidance. A statutory basis for kiosk licensure under HB 648 would reduce ambiguity about whether a kiosk operator's current licence rests on guidance that could change, and the pre-transaction disclosure duty is a direct control against kiosk-facilitated fraud typologies. 2 evidence refs Compliance ### A split legislative posture is emerging between kiosk licensure (tightening) and infrastructure-layer crypto activity (loosening) in Ohio. Firms operating both kiosk and non-custodial infrastructure lines in Ohio face two different regulatory trajectories under HB 648 and HB 116 respectively, requiring separate tracking rather than a single crypto-compliance posture. 2 evidence refs Legal ### HB 648 would formalise existing DFI licensing guidance for crypto kiosks into statute. Thirteen operators already hold licences under current guidance, so the statutory change mainly affects the durability and enforceability of the licensing basis rather than creating a new obligation for currently-compliant operators. 3 evidence refs Board ### Ohio is drawing a regulatory line between custodial consumer-facing crypto activity and non-custodial infrastructure activity. The bifurcated approach, if enacted, would give Ohio a more granular digital-asset regulatory framework than most states, with strategic implications for where crypto-adjacent business lines are sited. 2 evidence refs CTO ### Non-custodial infrastructure activity (mining, staking, node operation) would be exempted from Ohio money-transmitter licensure under HB 116, while kiosk-facing systems face tightened licensure under HB 648. Platform architecture that separates custodial kiosk-facing functions from non-custodial infrastructure functions would align with the direction Ohio's two bills are taking, though neither has yet passed. 2 evidence refs Risk ### Kiosk-based crypto conversion remains a flagged typology nationally, and Ohio's HB 648 responds to it directly through disclosure requirements. The pre-transaction disclosure duty is a concentration-specific control aimed at the kiosk channel rather than a generalised crypto restriction, which should inform how exposure to that channel specifically is weighted. 1 evidence refs Operations ### Thirteen Ohio kiosk operators already operate under existing money-transmitter licences; HB 648 would not change that population if enacted as introduced. Existing kiosk screening and licensing workflows tied to Ohio operators should remain stable under HB 648, since the bill largely codifies the status quo rather than introducing a new licensing population. 1 evidence refs Audit ### DFI guidance currently forms the evidentiary basis for Ohio's crypto-kiosk licensing treatment; HB 648 would shift that basis to statute. Audit trails currently citing guidance documents as the basis for kiosk-licensing control testing would need to be updated to cite statute once HB 648 is enacted, if it is enacted as introduced. 2 evidence refs Typology observations Exposure: {'total_matched_typologies': 1, 'by_typology': {'fim-typ-001': {'observation_count': 1, 'peak_confidence': 'Probable'}}, 'exposure_note': None} - Standing trackers (T1–T6) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture no_change T2 · EU AML Package / AMLA no_change T3 · FATF Grey List improving T4 · Beneficial-Ownership Register Status no_change T5 · Crypto & Digital-Asset Integrity mixed T6 · Sanctions Regime Divergence no_change Registers ### Enforcement actions - 27 Feb 2025 - 4 Aug 2025 - 26 Mar 2025 - 23 Apr 2026 - 23 Apr 2026 - 25 Jun 2025 - 1 Nov 2025 - 23 Jun 2026 - 14 Oct 2025 - 20 Jan 2025 - 8 Oct 2026 - Civil forfeiture complaint filed against over $8.2 million in USDT tied to a cross-border pig-butchering scheme that victimized at least 30 identified individuals, including a Cleveland-area retiree who liquidated a $650,000 retirement account into the scheme. 27 Feb 2025 - FinCEN issued Notice FIN-2025-NTC1 on the use of convertible virtual currency kiosks for scam payments and other illicit activity, reminding financial institutions of BSA reporting obligations and detailing typologies including tech-support, bank-imposter, and elder-targeted scams. 4 Aug 2025 - FinCEN issued an interim final rule removing BOI reporting requirements under the Corporate Transparency Act for all US-formed entities and US-person beneficial owners, narrowing the rule to apply only to foreign entities registering to do business in US states including Ohio. 26 Mar 2025 - Coordinated multi-agency action targeting the lifecycle of transnational scam-compound operations — compounds, digital infrastructure, and laundering networks — of the type shown to have victimized Ohio residents in the NDOH USDT forfeiture case. 23 Apr 2026 ### Sanctions changes - 14 Oct 2025 - 4 Feb 2025 - 23 Apr 2026 - 19 Jun 2026 - 14 Oct 2025 - 23 Apr 2026 - FinCEN imposed a Section 311 special measure severing Huione Group (Cambodia) from the U.S. financial system as a foreign financial institution of primary money laundering concern, requiring Ohio-headquartered banks and MSBs to apply enhanced due diligence/correspondent restrictions against the designated network. 14 Oct 2025 - Presidential National Security Presidential Memorandum (NSPM)-2 (Feb. 4, 2025) reimposed a 'maximum pressure' campaign on Iran, reaffirming blocked-property status for Iranian financial institutions under Executive Order 13599 and reiterating correspondent-account prohibitions applicable to all U.S. financial institutions, including Ohio-headquartered regional banks. 4 Feb 2025 ### Regulatory horizon (register) - 2026 US National Money Laundering Risk Assessment (NMLRA) - HB648 Digital Asset Kiosk regulation - Ohio HB 648 (ELDER Act) - digital-asset kiosk money-transmitter registration - Ohio HB 116 (Blockchain Basics Act) - MTL carve-outs for mining/staking/node operation - HB 648 (ELDER Act) crypto-kiosk MTL codification - GENIUS Act final stablecoin AML/sanctions implementing regulations - Potential Ohio state crypto-ATM consumer-protection legislation - CLARITY Act market-structure legislation Senate passage window ### Active schemes - [HIGH] Ohio-linked crypto ATM kiosk elder-fraud and cash-in pipeline - [HIGH] Pig-butchering DeFi/stablecoin laundering targeting Ohio victims - Ohio LLC shell-formation opacity post-CTA domestic exemption Sources - [1 1. See 31 U.S.C. § 5312(a)(2); 31 C.F.R. § 1010.100(t).](https://www.fincen.gov/system/files/2026-05/FinCEN-Alert-IRGC.pdf) - [https://com.ohio.gov/divisions-and-programs/financial-institutions/money-transmitters/money-transmitters](https://com.ohio.gov/divisions-and-programs/financial-institutions/money-transmitters/money-transmitters) - [https://com.ohio.gov/divisions-and-programs/financial-institutions/money-transmitters/guides-and-resources/money-transmitter-resources](https://com.ohio.gov/divisions-and-programs/financial-institutions/money-transmitters/guides-and-resources/money-transmitter-resources) - [https://www.legislature.ohio.gov/legislation/136/hb648](https://www.legislature.ohio.gov/legislation/136/hb648) - [https://com.ohio.gov/](https://com.ohio.gov/) - [https://www.fincen.gov/money-services-business-msb-registration](https://www.fincen.gov/money-services-business-msb-registration) - [https://home.treasury.gov/news/press-releases/sb0278](https://home.treasury.gov/news/press-releases/sb0278) - [https://home.treasury.gov/news/press-releases/sb0469](https://home.treasury.gov/news/press-releases/sb0469) - [https://www.fincen.gov/system/files/2026-08/FinCEN-Alert-Scam-Centers.pdf](https://www.fincen.gov/system/files/2026-08/FinCEN-Alert-Scam-Centers.pdf) - [https://www.jdsupra.com/topics/office-of-foreign-assets-control-ofac/fincen](https://www.jdsupra.com/topics/office-of-foreign-assets-control-ofac/fincen) - [https://www.billtrack50.com/billdetail/1942179](https://www.billtrack50.com/billdetail/1942179) - [https://www.legislature.ohio.gov/legislation/136/hb18](https://www.legislature.ohio.gov/legislation/136/hb18) - [https://highlandcountypress.com/headlines/ohio-department-commerce-divisions-securities-financial-institutions-announce-multistate](https://highlandcountypress.com/headlines/ohio-department-commerce-divisions-securities-financial-institutions-announce-multistate) - [https://orders.fdic.gov/sfc/servlet.shepherd/document/download/0693d00000CTBl4AAH](https://orders.fdic.gov/sfc/servlet.shepherd/document/download/0693d00000CTBl4AAH) - [https://www.legislature.ohio.gov/download?key=27458](https://www.legislature.ohio.gov/download?key=27458) - [https://www.keglerbrown.com/publications/ohio-hb-195-digital-assets-ucc](https://www.keglerbrown.com/publications/ohio-hb-195-digital-assets-ucc) - [https://dam.assets.ohio.gov/image/upload/com.ohio.gov/documents/fiin_Enf2023_Metallicus.pdf](https://dam.assets.ohio.gov/image/upload/com.ohio.gov/documents/fiin_Enf2023_Metallicus.pdf) - [https://www.csbs.org/newsroom/state-financial-regulators-reach-25-million-settlement-crypto-kiosk-operator](https://www.csbs.org/newsroom/state-financial-regulators-reach-25-million-settlement-crypto-kiosk-operator) - [https://www.troutman.com/insights/digital-assets-blockchain-newsletter-october-16-2026/](https://www.troutman.com/insights/digital-assets-blockchain-newsletter-october-16-2026/) - [https://www.justice.gov/usao-ndoh/pr/us-attorneys-office-northern-ohio-joins-doj-fraud-division-and-irs-partners-national](https://www.justice.gov/usao-ndoh/pr/us-attorneys-office-northern-ohio-joins-doj-fraud-division-and-irs-partners-national) - [https://fclawlib.libguides.com/fintech/ohiolaws](https://fclawlib.libguides.com/fintech/ohiolaws) - [Ohio Department of Commerce](https://com.ohio.gov/wps/portal/gov/com/divisions-and-programs/financial-institutions/money-transmitters/guides-and-resources/money-transmitter-resources) - [Ohio Legislative Service Commission, Office of Research](https://search-prod.lis.state.oh.us/api/v2/general_assembly_136/legislation/hb648/00_IN/attachments/fiscal_notes/) - [Ohio House of Representatives](https://ohiohouse.gov/members/matt-huffman/news/reps-kishman-miller-announce-elder-act-141935) - [Financial Action Task Force](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2026.html) - [RegReportingDesk](https://regreportingdesk.com/fatf-october-2026-plenary-list-updates/) - [Ohio Legislative Service Commission](https://search-prod.lis.state.oh.us/api/v2/general_assembly_136/legislation/hb648/00_IN/attachments/fiscal_notes/) - [READOUT: Treasury Officials Visit Kentucky and Ohio to Meet with Financial Institutions, Hold FinCEN Exchange on Combatting Fentanyl Trafficking | FinCEN.gov](https://www.fincen.gov/news/news-releases/readout-treasury-officials-visit-kentucky-and-ohio-meet-financial-institutions) - [Ohio](https://www.fincen.gov/sites/default/files/SARStats_files/SAR03/BSAR_O_States/Ohio.xls) - [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) - [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-5) - [United States Department of the Treasury Financial Crimes Enforcement Network - Home | FinCEN.gov](https://www.fincen.gov/?var=v100002) - [1 The U.S. Department of the Treasury’s (Treasury)](https://www.fincen.gov/system/files/2025-08/FinCEN-Advisory-CMLN-508.pdf) - [1 Financial Crimes Enforcement Network (FinCEN)](https://www.fincen.gov/system/files/2026-05/FinCEN-Year-in-Review-2025.pdf) - [STATE CONTACT INFORMATION FOR MSBs](https://www.fincen.gov/system/files/shared/msbstatecontactsfinal_old.pdf) - [Press Releases | FinCEN.gov](https://www.fincen.gov/news/press-releases) - [Enforcement Actions | FinCEN.gov](https://www.fincen.gov/news/enforcement-actions) - [Fincen](https://www.fincen.gov/sites/default/files/SARStats_files/SAR03/BSAR_MSB_States/Ohio.xls) - [Prepared Remarks of FinCEN Director Andrea Gacki During Beneficial Ownership Information Reporting Event in Columbus, Ohio | FinCEN.gov](https://www.fincen.gov/news/speeches/prepared-remarks-fincen-director-andrea-gacki-during-beneficial-ownership-0) - [News | FinCEN.gov](https://www.fincen.gov/news) - [United States Department of the Treasury Financial Crimes Enforcement Network - Home | FinCEN.gov](https://www.fincen.gov/) - [Ohio](https://www.fincen.gov/sites/default/files/SARStats_files/SAR03/BSAR_C_States/Ohio.xls) - [Advisories | FinCEN.gov](https://www.fincen.gov/resources/advisoriesbulletinsfact-sheets/advisories) - [2026 Crypto Crime Report – Illicit Crypto Trends & Typologies | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/2026-crypto-crime-report) - [Civil Penalties and Enforcement Information | Office of Foreign Assets Control](https://ofac.treasury.gov/civil-penalties-and-enforcement-information) - [FinCEN, Advance notice of proposed rulemaking, RIN ...](https://www.fincen.gov/system/files/2021-12/RE_ANPRM_FRN_120321_FINAL_508.pdf) - [Questions swirl around US plans for record $15B Prince Group crypto seizure - ICIJ](https://www.icij.org/investigations/coin-laundry/questions-swirl-around-us-plans-for-record-15b-prince-group-crypto-seizure/) - [FinCEN-Advisory-CMLN-508.pdf](https://www.fincen.gov/sites/default/files/advisory/2025-08-28/FinCEN-Advisory-CMLN-508.pdf) - [Report Describes Crypto’s $350 Billion Shadow War | OCCRP](https://www.occrp.org/en/news/report-describes-cryptos-350-billion-shadow-war) - [Enforcement Actions for Failure to Register as a Money Services Business | FinCEN.gov](https://www.fincen.gov/enforcement-actions-failure-register-money-services-business) - [Fact Sheet on MSB Registration Rule | FinCEN.gov](https://www.fincen.gov/fact-sheet-msb-registration-rule) - [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) - [Important Information for MSBs | FinCEN.gov](https://www.fincen.gov/resources/financial-institutions/money-services-businesses) - [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) - [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) - [Definition of Money Transmitter (Merchant Payment Processor) | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/definition-money-transmitter-merchant-payment) - [Fincen](https://www.fincen.gov/system/files/schema/code/FinCENReferenceCodes.xsd) - [FinCEN Notice, FIN-2025-NTC1, August 4, 2025](https://www.fincen.gov/system/files/2025-08/FinCEN-Notice-CVCKIOSK.pdf) - [How Crypto ATMs in the U.S. Became A Favorite Tool for Scammers | OCCRP](https://www.occrp.org/en/feature/how-crypto-atms-in-the-us-became-a-favorite-tool-for-scammers) - [Retailers keep cashing in on crypto ATMs as scams surge - ICIJ](https://www.icij.org/investigations/coin-laundry/retailers-keep-cashing-in-on-crypto-atms-as-scams-surge/) - [2026 Crypto Crime Report: Scams](https://www.chainalysis.com/blog/crypto-scams-2026/) - [FBI Cleveland and US Attorney’s Office for Northern District of Ohio Freeze and Seize Illicit Crypto Proceeds | TRM Blog](https://www.trmlabs.com/resources/blog/fbi-cleveland-and-us-attorneys-office-for-northern-district-of-ohio-freeze-and-seize-illicit-crypto-proceeds) - [Amid a scam crackdown, crypto giants keep fueling bitcoin ATMs - ICIJ](https://www.icij.org/investigations/coin-laundry/amid-a-scam-crackdown-crypto-giants-keep-fueling-bitcoin-atms/) - [How Crypto ATMs in the U.S. Became A Favorite Tool for Scammers](https://www.occrp.org/en/37-ccblog/ccblog/18883-how-crypto-atms-in-the-u-s-became-a-favorite-tool-for-scammers) - [FinCEN Issues Notice on the Use of Convertible Virtual Currency Kiosks for Scam Payments and Other Illicit Activity | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-notice-use-convertible-virtual-currency-kiosks-scam-payments-and) - [Elder Financial Exploitation: Threat Pattern & Trend ...](https://www.fincen.gov/system/files/shared/FTA_Elder_Financial_Exploitation_508Final.pdf) - [FinCEN Calls for Vigilance on Crypto Kiosk Activities | OCCRP](https://www.occrp.org/en/news/fincen-calls-for-vigilance-on-crypto-kiosk-activities) - [FIFTH THIRD BANCORP - Form 8-K - FY2024](https://www.sec.gov/Archives/edgar/data/0000035527/000003552724000186/exhibit991.htm) - [HUNTINGTON BANCSHARES INC/MD - Form 8-K - FY2005](https://www.sec.gov/Archives/edgar/data/0000049196/000129993305001018/exhibit1.htm) - [WASHINGTON FEDERAL INC - Form 8-K - FY2021](https://www.sec.gov/Archives/edgar/data/0000936528/000093652821000084/cmppressreleasefinal.htm) - [UNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY](https://www.fincen.gov/system/files/shared/PamrapoAssessment.pdf) - [FinCEN Recognizes Law Enforcement Cases Significantly Impacted by Bank Secrecy Act Filings | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-recognizes-law-enforcement-cases-significantly-impacted-bank-secrecy-act) - [Survey of the Costs of AML/CFT Compliance | FinCEN.gov](https://www.fincen.gov/survey-costs-amlcft-compliance) - [FinCEN Penalizes U.S. Bank National Association for Violations of Anti-Money Laundering Laws | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-penalizes-us-bank-national-association-violations-anti-money-laundering) - [The 2026 Crypto Crime Report - Chainalysis](https://www.chainalysis.com/reports/crypto-crime-2026/) - [U.S. Crackdown on Southeast Asian Crypto Scam Centers](https://www.chainalysis.com/blog/asian-scam-centers-crypto-fraud-april-2026/) - [2025 Crypto Crime Report](https://go.chainalysis.com/2025-Crypto-Crime-Report.html) - [Massachusetts sues Bitcoin Depot, alleging the crypto ATM operator knowingly facilitated crypto scams - ICIJ](https://www.icij.org/investigations/coin-laundry/massachusetts-sues-bitcoin-depot-alleging-the-crypto-atm-operator-knowingly-facilitated-crypto-scams/) - [Crypto regulatory affairs: CLARITY Act advances from Senate Banking Committee](https://www.elliptic.co/blog/crypto-regulatory-affairs-clarity-act-passes-senate-banking-committee) - [Crypto regulatory affairs: US Crypto Week delivers as GENIUS Act becomes law, CLARITY Act moves to Senate](https://www.elliptic.co/blog/crypto-regulatory-affairs-us-crypto-week-delivers-as-genius-act-becomes-law-clarity-act-moves-to-senate) - [Crypto regulatory affairs: CLARITY Act Senate delay creates uncertainty](https://www.elliptic.co/blog/crypto-regulatory-affairs-clarity-act-senate-delay-creates-uncertainty) - [Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2025-26) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [Crypto Market Structure Bill Clears Senate Banking Panel After Bipartisan Deal - Bloomberg](https://www.bloomberg.com/news/articles/2026-05-14/long-stalled-crypto-market-bill-wins-key-senate-committee-vote) - [Law enforcement, banks warn of money laundering gaps in major US crypto bill - ICIJ](https://www.icij.org/investigations/coin-laundry/law-enforcement-banks-warn-of-money-laundering-gaps-in-major-us-crypto-bill/) - [Landmark cryptocurrency legislation passes US House, to be signed into law by President Trump - ICIJ](https://www.icij.org/news/2025/07/landmark-cryptocurrency-legislation-passes-u-s-house-to-be-signed-into-law-by-president-trump/) - [Frequently Asked Questions | FinCEN.gov](https://www.fincen.gov/boi-faqs) - [Beneficial Ownership Information Reporting | FinCEN.gov](https://www.fincen.gov/boi) - [Beneficial Ownership Information Report (BOIR) - BOI E-FILING](https://boiefiling.fincen.gov/fileboir) - [FinCEN Removes Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Persons, Sets New Deadlines for Foreign Companies | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-removes-beneficial-ownership-reporting-requirements-us-companies-and-us) - [BOI E-FILING - FinCEN](https://boiefiling.fincen.gov/) - [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) - [Beneficial Ownership Information Report Filing Instructions](https://boiefiling.fincen.gov/resources/BOIR_Filing_Instructions.pdf?trk=public_post_comment-text) - [Small Business Resources | FinCEN.gov](https://www.fincen.gov/boi/small-business-resources) - [BOI Newsroom | FinCEN.gov](https://www.fincen.gov/boi/newsroom) - [1. Does my company have to report its beneficial owners?](https://www.fincen.gov/system/files/shared/BOI_Reporting_Key_Questions_Published_508C.pdf) - [Treasury Department Publishes National Money Laundering Risk Assessment and National Terrorist Financing Risk Assessment | FinCEN.gov](https://www.fincen.gov/news/news-releases/treasury-department-publishes-national-money-laundering-risk-assessment-and) - [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) - [US takes aim at real estate money laundering - ICIJ](https://www.icij.org/investigations/pandora-papers/us-takes-aim-at-real-estate-money-laundering/) - [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) - [1 1. See 31 U.S.C. § 5312(a)(2); 31 C.F.R. § 1010.100(t).](https://www.fincen.gov/system/files/2026-05/FinCEN-Alert-IRGC.pdf) - [FinCEN Alert, FIN-2024-Alert005, December 18, 2024](https://www.fincen.gov/system/files/2024-12/Alert-FinCEN-Scams-FINAL508.pdf) - [FinCEN Alert, FIN-2023-Alert002, January 25, 2023](https://www.fincen.gov/system/files/shared/FinCEN%20Alert%20Real%20Estate%20FINAL%20508_1-25-23%20FINAL%20FINAL.pdf) - [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) - [Application of FinCEN’s Regulations to Virtual Currency Mining Operations | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/application-fincens-regulations-virtual-0) - [Bitcoin 'Mixer' Larry Harmon Who Laundered Drug Profits Gets 3-Year Sentence - Bloomberg](https://www.bloomberg.com/news/articles/2024-11-15/bitcoin-mixer-who-laundered-drug-profits-gets-3-year-sentence) - [Jury Convicts Man in Unlicensed Money Transmission Scheme | FinCEN.gov](https://www.fincen.gov/resources/law-enforcement/case-examples/jury-convicts-man-unlicensed-money-transmission-scheme) - [Request for Administrative Ruling on the Application of FinCEN’s Regulations to a Virtual Currency Payment System | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/request-administrative-ruling-application) - [Request for Administrative Ruling on the Application of FinCEN’s Regulations to a Virtual Currency Trading Platform | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/request-administrative-ruling-application-0) - [Pig butchering scam](https://www.trmlabs.com/glossary/pig-butchering-scam) - [DOJ Seizes USD 8.2M Tied to Pig Butchering Scheme | TRM Blog](https://www.trmlabs.com/resources/blog/doj-seizes-usd-8-2m-tied-to-pig-butchering-scheme) - [SAR-FAQs-October-2025.pdf](https://www.fincen.gov/system/files/2025-10/SAR-FAQs-October-2025.pdf) - [CONSENT ORDER IMPOSING CIVIL MONEY PENALTY](https://www.fincen.gov/system/files/enforcement_action/2023-04-05/CBOT_Enf_Action_121621_508_FINAL.pdf) - [FinCEN Consent Order Imposing Civil Money Penalty, ...](https://www.fincen.gov/system/files?file=enforcement_action/2023-04-05/USAA_Consent_Order_Final_508_2.pdf) - [Interagency Statement on Sharing Bank Secrecy Act Resources | FinCEN.gov](https://www.fincen.gov/news/news-releases/interagency-statement-sharing-bank-secrecy-act-resources) - [Federal Register/Vol. 91, No. 69/Friday, April 10, 2026/ ...](https://ofac.treasury.gov/media/935481/download?inline=) - [FIN-2025-G001 Issued: September 5, 2025](https://www.fincen.gov/system/files/2025-09/Crossborderguidance-508C.pdf) - [PPSI-AMLCFT-NPRM.pdf](https://www.fincen.gov/system/files/2026-04/PPSI-AMLCFT-NPRM.pdf) - [Financial Crimes Enforcement Network](https://www.fincen.gov/system/files/guidance/guidance04262005.pdf) - [Bank of America Reaches Anti-Money-Laundering Consent Agreement With OCC](https://www.bloomberg.com/news/articles/2024-12-23/bofa-reaches-anti-money-laundering-consent-agreement-with-occ) - [FinCEN Number 2023-03, CONSENT ORDER IMPOSING ...](https://www.fincen.gov/system/files?file=enforcement_action/2023-09-29/SHBA_9-28_FINAL_508.pdf) - [1 1. See 31 U.S.C. § 5312(a)(2); 31 C.F.R. § 1010.100(t). 2.](https://www.fincen.gov/system/files/2026-05/FinCEN-WCHT-Notice.pdf) - [TRM Labs](https://www.trmlabs.com/resources/blog/doj-seizes-usd-8-2m-tied-to-pig-butchering-scheme) - [FinCEN / U.S. Department of the Treasury](https://www.fincen.gov/system/files/2025-08/FinCEN-Notice-CVCKIOSK.pdf) - [FinCEN / U.S. Department of the Treasury](https://www.fincen.gov/news/news-releases/fincen-removes-beneficial-ownership-reporting-requirements-us-companies-and-us) - [OCCRP](https://www.occrp.org/en/feature/how-crypto-atms-in-the-us-became-a-favorite-tool-for-scammers) - [ICIJ](https://www.icij.org/investigations/coin-laundry/retailers-keep-cashing-in-on-crypto-atms-as-scams-surge/) - [FinCEN / U.S. Department of the Treasury](https://www.fincen.gov/news/news-releases/financial-action-task-force-identifies-jurisdictions-anti-money-laundering-5) - [U.S. Department of the Treasury](https://home.treasury.gov/system/files/246/2026-NMLRA.pdf) - [Elliptic](https://www.elliptic.co/blog/crypto-regulatory-affairs-clarity-act-passes-senate-banking-committee) Coverage gaps fim-int-2026-07-05-G001: The most recent FATF plenary outcom… fim-int-2026-07-05-G001: The most recent FATF plenary outcome (potentially a mid-2026 plenary postdating the February 13, 2026 plenary cited by Research) has not been independently retrieved or verified for currency against the July 2026 baseline date. [resolved] fim-int-2026-07-05-G002: Public, systematically searchable O… fim-int-2026-07-05-G002: Public, systematically searchable Ohio Division of Financial Institutions state-level MSB supervisory/enforcement records are absent, preventing independent verification of state-layer enforcement density distinct from federal FinCEN/DOJ action. [resolved] fim-int-2026-07-05-G003: Court-record confirmation of Sonny … fim-int-2026-07-05-G003: Court-record confirmation of Sonny Meraban's November 2024 guilty-plea outcome and sentencing detail has not been independently cross-verified beyond the single T3 local-news source cited in the corrective finding. [resolved] fim-int-2026-07-05-G004: Confirmation of Bitcoin of America'… fim-int-2026-07-05-G004: Confirmation of Bitcoin of America's current operational status (reported ceased March 2023) against the active_scheme_inventory current_status field has not been re-verified this cycle. [resolved] fim-int-2026-07-05-G005: Reconciliation between this baselin… fim-int-2026-07-05-G005: Reconciliation between this baseline's ELEVATED/HIGH severity framing of the CTA domestic exemption and any prior FIM cross-jurisdiction brief's severity assessment of the same nationwide development has not been established, absent access to prior-cycle persistent state for this monitor. [resolved] fim-int-2026-07-14-G001: EU AML Package (AMLR/6AMLD/AMLA) su… fim-int-2026-07-14-G001: EU AML Package (AMLR/6AMLD/AMLA) supervisory-perimeter and transposition status was not actively resolved this cycle. [resolved] fim-int-2026-07-14-G002: No fresh conflict-mineral or oil-re… fim-int-2026-07-14-G002: No fresh conflict-mineral or oil-revenue-corruption finding surfaced for D4 beyond the FATF Recommendation 6 update. [resolved] fim-int-2026-07-14-G003: No AI/ML transaction-monitoring sup… fim-int-2026-07-14-G003: No AI/ML transaction-monitoring supervisory-gap source retrieved for D6 this cycle. [resolved] fim-int-2026-07-14-G004: Colombia-specific domain updates we… fim-int-2026-07-14-G004: Colombia-specific domain updates were not resolved this cycle beyond historical Black Market Peso Exchange context. [resolved] fim-int-2026-08-20-G001: Tier-D watch jurisdictions (KH, LA,… fim-int-2026-08-20-G001: Tier-D watch jurisdictions (KH, LA, MX, CO) were not independently re-researched this cycle given the single-JID US-OH dispatch scope. [resolved] fim-int-2026-08-20-G002: D1-D4 domains show thin coverage th… fim-int-2026-08-20-G002: D1-D4 domains show thin coverage this cycle; no Ohio-specific variance against the federal baseline was independently verified beyond the delta-only research posture. [resolved] fim-int-2026-09-05-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): Laos-specific sanctions/enforcement action not independently verified this cycle; named only as a secondary Scam Center Strike Force focus alongside Burma/Cambodia. [resolved] fim-int-2026-09-05-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G002 ({'scheme': 'financial_integrity', 'value': 'D1'}): FinCEN Section 311 action against three Mexican financial institutions referenced only via a T4 law-firm aggregator; primary FinCEN order not independently retrieved. [resolved] fim-int-2026-09-05-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G003 ({'scheme': 'financial_integrity', 'value': 'D4'}): Colombia yielded no material this cycle; requires dedicated primary-source follow-up next cycle. [resolved] fim-int-2026-09-05-G004 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G004 ({'scheme': 'financial_integrity', 'value': 'D5'}): Ohio HB648 sourced only to a secondary bill-tracking aggregator; not yet independently verified against primary bill text at legislature.ohio.gov. [resolved] fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): No confirmation obtained this cycle of whether HB 648 has been reported out of the House Financial Institutions Committee following its May 20, 2026 third hearing. [resolved] fim-int-2026-10-11-G002: Tier D jurisdiction checks (Cambodi… fim-int-2026-10-11-G002: Tier D jurisdiction checks (Cambodia, Laos, Mexico, Colombia) were not independently re-verified this cycle owing to shared pooled search-budget constraints. [resolved] fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): No primary OCCC/DFI enforcement-order text retrieved for the Coinme settlement; only secondary/regulator-association reporting available. [resolved] fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', 'value': 'D1'}): No Ohio-specific developments found this cycle in sanctions architecture (D1), beneficial ownership (D2), or conflict finance (D4); recorded as no_source/not_applicable rather than confirmed absence of national activity. [resolved] fim-int-2026-10-25-G001: EU AML Package / AMLA transposition… fim-int-2026-10-25-G001: EU AML Package / AMLA transposition tracking saw no confirmed movement this cycle due to search-budget prioritization toward Tier D jurisdictions. [resolved] fim-int-2026-10-25-G002: No Ohio-specific (subnational) AML/… fim-int-2026-10-25-G002: No Ohio-specific (subnational) AML/CTF development was identified this cycle; research for this chained jurisdiction is delta-only against the US federal parent layer and the absence is expected, not a gap. [resolved] fim-int-2026-10-25-G003: The outcome of the scheduled Octobe… fim-int-2026-10-25-G003: The outcome of the scheduled October 2026 FATF plenary (potential Pakistan re-listing; Canada/Türkiye mutual evaluation publication) could not be confirmed in sources retrieved this cycle. [resolved] fim-int-2026-11-01-G001: Domains D1, D2, D3, D4 and D6 had t… fim-int-2026-11-01-G001: Domains D1, D2, D3, D4 and D6 had thin or no Ohio-specific coverage this cycle; no sanctions-evasion, beneficial-ownership, enabler-jurisdiction or conflict-finance Ohio nexus was identified. [open] fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', 'value': 'D1'}): Statute text for R.C. 1315.08(B) was not independently retrieved this cycle; sourced from DFI's own FAQ summary rather than primary statute text. [open] FIM-GAP-001 (D2): Ohio has no state-level beneficial ownersh… FIM-GAP-001 (D2): Ohio has no state-level beneficial ownership registry, and the March 2025 federal CTA rollback exempted domestic (Ohio-formed) reporting companies from BOI disclosure entirely, leaving only foreign entities registering in Ohio subject to federal transparency requirements. FIM-GAP-002 (D5): Ohio has not enacted a crypto ATM/kiosk co… FIM-GAP-002 (D5): Ohio has not enacted a crypto ATM/kiosk consumer-protection statute (transaction limits, enhanced ID verification, mandatory fraud warnings) despite the state having hosted a documented kiosk-licensing violation network (Bitcoin of America/Meraban) and continuing elder-fraud exploitation nationally, while at least 18 other states have passed such laws. FIM-GAP-003 (D3): Public, systematically searchable records … FIM-GAP-003 (D3): Public, systematically searchable records of Ohio Division of Financial Institutions supervisory/enforcement actions (as distinct from federal FinCEN/DOJ actions) are limited, constraining independent verification of state-level MSB licensing enforcement density for this baseline. ## Evidence #### Confidence-tiered claims Controllable electronic records; effective 2026-10-06 [[Source 1]](#sec-sources) Probable · 1 source Digital-asset kiosk operators would be deemed engaged in money transmission under R.C. Ch. 1315; pending, not enacted [[Source 1]](#sec-sources) Probable · 1 source Default AML/licensing gateway for virtual-currency businesses absent HB 648/HB 116 enactment [[Source 1]](#sec-sources) Probable · 1 source Coinme agreed to a $2.5M multistate settlement (34 states incl. Ohio as a lead examining state) over BSA/AML program deficiencies; must exit crypto-kiosk business nationwide by 2027-01-01 or pay a further $4M. [[Source 1]](#sec-sources) Probable · 1 source USAO-NDOH, with Secret Service Cleveland Field Office Money Laundering Task Force and IRS-CI, joined DOJ's first National Tax Enforcement Surge (Sept-Oct 2026), part of a nationwide effort alleging over $490M in intended federal revenue loss. [[Source 1]](#sec-sources) Probable · 1 source Ohio has no standalone state AML statute; money transmitters (incl. crypto kiosk/exchange operators) are governed by Ohio Rev. Code Ch. 1315, with reporting/money-laundering definitions at ORC 1315.51, bank reporting duties at 1315.53, and AG investigatory power at 1315.54; federal BSA/FinCEN MSB registration applies in parallel. [[Source 1]](#sec-sources) Probable · 1 source OCC issued the first binding federal rule implementing the GENIUS Act's payment-stablecoin requirements (reserves, redemption, custody, capital) on 21 October 2026, effective 18 January 2027; AML and sanctions requirements are explicitly excluded and deferred to a separate Treasury rulemaking. [[Source 1]](#sec-sources) Probable · 1 source OFAC designated the entire International Criminal Court to the SDN List under EO 14203 on 9 October 2026; the UK, Canada, Denmark, Germany, France, Italy, Japan and the Netherlands publicly stated they 'regret and strongly disagree'. [[Source 1]](#sec-sources) Probable · 1 source Cambodian authorities froze almost US$1 billion linked to the Prince Group scam network and sought INTERPOL assistance for 29 fugitive ringleaders, working jointly with the FBI and China's Ministry of Public Security. [[Source 1]](#sec-sources) Probable · 1 source OFAC designated four individuals and 11 entities allegedly linked to Cartel del Noreste's commercial network and horse-racing operations on 13 October 2026, extending the fiscal-fuel-theft/TBML enforcement track opened by FinCEN's June 2026 alert. [[Source 1]](#sec-sources) Probable · 1 source Colombia's Fiscalía, coordinating with US IRS Criminal Investigation, detained eight individuals wanted for extradition on narcotics-trafficking and money-laundering charges; one strand traces roughly $42 million in suspected cryptocurrency transactions since 2018. [[Source 1]](#sec-sources) Probable · 1 source proposed, pending [[Source 1]](#sec-sources) Probable · 1 source 18 jurisdictions [[Source 1]](#sec-sources) Probable · 1 source Digital-asset kiosk owners/operators/facilitators to hold an Ohio money-transmitter licence and make pre-transaction risk disclosures [[Source 1]](#sec-sources) Probable · 1 source 13 cryptocurrency kiosk operators already hold Ohio money-transmitter licences under existing law and DFI interpretive guidance [[Source 1]](#sec-sources) Probable · 1 source Cryptocurrency as "money or its equivalent" under the Money Transmitters Act's definition of money transmission for licensing purposes [[Source 1]](#sec-sources) Probable · 1 source Mining, staking, node operation, and like-kind token swap activity from Ohio money-transmitter licensure; passed Ohio House 70-26, pending Senate [[Source 1]](#sec-sources) Probable · 1 source October 2026 Plenary removed Bulgaria, Côte d'Ivoire, DRC and Monaco from the grey list, reducing it from 22 to 18 jurisdictions with no new additions [[Source 1]](#sec-sources) Probable · 1 source