--- title: "United States — Pennsylvania (US-PA) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/united-states-pennsylvania/ source_html: /jurisdictions/united-states-pennsylvania/index.html description: "Financial integrity intelligence for United States – Pennsylvania (US-PA): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: 8bbba261509d55579e5b16769b0db34c507c604d90b3da8ef2ed62d09da71b12 generator: "fe-fleet/md-twin@1.0" --- # United States — Pennsylvania (US-PA) — 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 — Pennsylvania US-PA Domains covered 7 of 8 Sources 126 Role actions 8 Horizon <90d 2 Jurisdiction profile FATF status: Compliant Tier: B Risk direction: Stable Enablement vs enforcement: Mixed PA operates entirely within the federal BSA/AML architecture (FinCEN, OFAC, DOJ EDPA/MDPA/WDPA) layered with state money-transmitter licensing under the PA Department of Banking and Securities. More A March 2025 domestic-company BOI exemption sharply narrowed federal beneficial-ownership visibility into PA-formed entities, while a pending FinCEN AML/CFT program-reform NPRM signals a deregulatory, effectiveness-based supervisory shift. Key deficiencies - Domestic reporting-company BOI exemption removed CTA reporting duty for most PA-formed LLCs/corporations, reopening a beneficial-ownership blind spot - Crypto ATM/kiosk elder-fraud exploitation is nationally rising with uneven, patchwork state-level licensing and consumer-protection coverage - No independently confirmed PA-specific crypto-ATM consumer-protection statute despite ~18 other states enacting such laws - Federal AML/CFT program-reform NPRM proposes to reduce examiner discretion and shift toward reasonably-designed, risk-based programs, with uncertain near-term enforcement-intensity effects Recent developments (18m) - FinCEN domestic reporting-company BOI exemption (interim final rule, March 2025) removed CTA obligations for most PA-formed entities - FinCEN issued a Notice on convertible virtual currency (CVC) kiosk exploitation for scam payments (Aug 2025), citing a 99% rise in FBI IC3 kiosk-fraud complaints - FinCEN proposed a fundamental reform of AML/CFT program rules for banks and other financial institutions (April 2026), comment period closed June 9, 2026 - Treasury published the 2026 National Money Laundering, Terrorist Financing, and Proliferation Financing Risk Assessments (March 2026) - FinCEN granted Account Opening Exceptive Relief (FIN-2026-R001, Feb 13, 2026) narrowing CDD Rule beneficial-ownership verification at new account opening - GENIUS Act stablecoin AML/BSA framework signed into law (July 2025); joint FinCEN/OFAC implementing NPRM issued April 2026 United States federal law that applies in United States – Pennsylvania is covered once, on the [United States](/jurisdictions/us/) page. This page covers United States – Pennsylvania’s own layer: its own law, regulators and enforcement. Brief ## Lead signal #### Lead Signal The Pennsylvania Office of Attorney General moved, on or about 29 October 2026, to launch a voluntary statewide consumer-warning campaign targeting cryptocurrency kiosks, placing signage at kiosk locations to counter a fraud pattern the Office describes as recurring and consistent: victims are told by callers impersonating law enforcement or a court that payment of a fine or debt must be made at a cryptocurrency kiosk. The Office framed the campaign against a baseline of approximately 290 crypto-ATM scam complaints received by its Bureau of Consumer Protection in the prior year, a volume that spans government-impersonation schemes, romance fraud and investment schemes. The measure is a public-education response layered onto a kiosk-operator landscape that remains, structurally, unaddressed by dedicated licensing law. Legislation aimed specifically at virtual-currency kiosk operators, Senate Bill 1015 and its House companion House Bill 2643, remains in committee, with no kiosk-specific operator obligations enacted as of this cycle. The general money-transmission framework amended by the Commonwealth's 2025 virtual-currency statute reaches kiosk operators as transmitters of value, but it does not impose the licensing, disclosure, reporting or transaction-limit conditions that a dedicated kiosk statute would carry. Read full brief #### Lead Signal The Pennsylvania Office of Attorney General moved, on or about 29 October 2026, to launch a voluntary statewide consumer-warning campaign targeting cryptocurrency kiosks, placing signage at kiosk locations to counter a fraud pattern the Office describes as recurring and consistent: victims are told by callers impersonating law enforcement or a court that payment of a fine or debt must be made at a cryptocurrency kiosk. The Office framed the campaign against a baseline of approximately 290 crypto-ATM scam complaints received by its Bureau of Consumer Protection in the prior year, a volume that spans government-impersonation schemes, romance fraud and investment schemes. The measure is a public-education response layered onto a kiosk-operator landscape that remains, structurally, unaddressed by dedicated licensing law. Legislation aimed specifically at virtual-currency kiosk operators, Senate Bill 1015 and its House companion House Bill 2643, remains in committee, with no kiosk-specific operator obligations enacted as of this cycle. The general money-transmission framework amended by the Commonwealth's 2025 virtual-currency statute reaches kiosk operators as transmitters of value, but it does not impose the licensing, disclosure, reporting or transaction-limit conditions that a dedicated kiosk statute would carry. The juxtaposition is the analytically significant element: a state consumer-protection office addressing the symptom of kiosk-enabled fraud through voluntary signage while the architecture that would address the underlying operator-level exposure sits unmoved in committee. This is not an enforcement story; no action has been taken against any kiosk operator, and no operator-facing obligation has changed. It is a story about a gap between visible harm and binding safeguard, and about which lever of state authority (consumer-protection messaging versus banking and securities licensing law) has moved first. #### Other Developments No other developments met the bar for material findings this cycle. #### Cross-Monitor Connections The pattern of kiosk-facilitated fraud intersects with financial-innovation oversight more broadly: a consumer-facing campaign addressing scam typologies at the point of cash-to-crypto conversion is a response to a retail fraud vector rather than to an institutional money-laundering control gap, but the absence of kiosk-specific licensing means the operator layer carries less structured obligation than full money-services-business coverage would otherwise imply. Where a kiosk licensing framework is eventually enacted, routing between consumer-protection authorities and banking and securities regulators over supervisory responsibility is a foreseeable downstream question, though nothing in the current record indicates that question has yet been engaged. #### Outlook The trajectory to watch is whether Senate Bill 1015 or House Bill 2643 advances out of committee. As scheduled, Pennsylvania's dedicated kiosk-licensing framework remains in consultation stage with no confirmed timeline beyond a general expectation of continued committee consideration into late 2026; whether either bill reaches a floor vote before the legislative session's attention shifts elsewhere is not yet determinable from the record. Absent enactment, the Commonwealth's posture toward kiosk operators will likely continue to rest on the general virtual-currency transmission licensing regime adopted in 2025 plus voluntary public-education measures, rather than on kiosk-specific binding safeguards. Earlier periodic briefs (6) 4 Nov 2026 · fim-2026-11-04 #### Lead Signal The Pennsylvania Office of Attorney General moved, on or about 29 October 2026, to launch a voluntary statewide consumer-warning campaign targeting cryptocurrency kiosks, placing signage at kiosk locations to counter a fraud pattern the Office describes as recurring and consistent: victims are told by callers impersonating law enforcement or a court that payment of a fine or debt must be made at a cryptocurrency kiosk. The Office framed the campaign against a baseline of approximately 290 crypto-ATM scam complaints received by its Bureau of Consumer Protection in the prior year, a volume that spans government-impersonation schemes, romance fraud and investment schemes. The measure is a public-education response layered onto a kiosk-operator landscape that remains, structurally, unaddressed by dedicated licensing law. Legislation aimed specifically at virtual-currency kiosk operators, Senate Bill 1015 and its House companion House Bill 2643, remains in committee, with no kiosk-specific operator obligations enacted. The general money-transmission framework amended by the Commonwealth's 2025 virtual-currency statute reaches kiosk operators as transmitters of value, but it does not impose the licensing, disclosure, reporting or transaction-limit conditions that a dedicated kiosk statute would carry. The juxtaposition is the analytically significant element: a state consumer-protection office addressing the symptom of kiosk-enabled fraud through voluntary signage while the architecture that would address the underlying operator-level exposure sits unmoved in committee. This is not an enforcement story; no action has been taken against any kiosk operator, and no operator-facing obligation has changed. It is a story about a gap between visible harm and binding safeguard, and about which lever of state authority (consumer-protection messaging versus banking and securities licensing law) has moved first. #### Other Developments No other developments met the bar for material findings. #### Cross-Monitor Connections The pattern of kiosk-facilitated fraud intersects with financial-innovation oversight more broadly: a consumer-facing campaign addressing scam typologies at the point of cash-to-crypto conversion is a response to a retail fraud vector rather than to an institutional money-laundering control gap, but the absence of kiosk-specific licensing means the operator layer carries less structured obligation than full money-services-business coverage would otherwise imply. Where a kiosk licensing framework is eventually enacted, routing between consumer-protection authorities and banking and securities regulators over supervisory responsibility is a foreseeable downstream question, though nothing in the current record indicates that question has yet been engaged. #### Outlook The trajectory to watch is whether Senate Bill 1015 or House Bill 2643 advances out of committee. As scheduled, Pennsylvania's dedicated kiosk-licensing framework remains in consultation stage with no confirmed timeline beyond a general expectation of continued committee consideration into late 2026; whether either bill reaches a floor vote before the legislative session's attention shifts elsewhere is not yet determinable from the record. Absent enactment, the Commonwealth's posture toward kiosk operators will likely continue to rest on the general virtual-currency transmission licensing regime adopted in 2025 plus voluntary public-education measures, rather than on kiosk-specific binding safeguards. 3 Nov 2026 · fim-2026-11-03 #### Lead Signal Pennsylvania moved on the consumer-protection side of the digital-asset problem rather than on the statutory side. The Office of the Attorney General launched a statewide warning campaign, including physical STOP-sign placards at cryptocurrency kiosks, timed to National Cryptocurrency Month and framed around a reported volume of roughly 290 scam complaints tied to kiosk transactions over the prior year. The campaign is explicit and voluntary in character: it instructs the public that no legitimate law enforcement agency or court will ever direct a person to pay a fine, bail or debt through a cryptocurrency kiosk. This is an awareness and signage exercise conducted under existing consumer-protection authority, not a new anti-money-laundering or counter-terrorist-financing obligation, and it creates no licensing, reporting or transaction-limit requirement for kiosk operators. The architectural significance sits beside, not inside, the warning campaign. Pennsylvania has had kiosk-specific licensing legislation before its General Assembly in the form of Senate Bill 1015 and a companion House Bill 2643, both of which would have imposed registration, disclosure, reporting and transaction-limit obligations specific to virtual-currency kiosk operators. Neither bill has advanced out of committee. The practical effect is that kiosk operators in the Commonwealth continue to be governed only by the general money-transmission licensing regime, with no kiosk-specific control layer, at the same time as the Attorney General is treating kiosk-enabled fraud as significant enough to warrant a dedicated statewide public-awareness response. The gap between enforcement-adjacent messaging and the absence of a tailored statutory framework is itself the structural story: a permissive regulatory default persists even as the harm it is meant to address is visibly rising. #### Other Developments No material movement was identified in sanctions exposure, beneficial ownership and corporate transparency, enabler-jurisdiction dynamics, conflict finance, compliance technology, the general anti-money-laundering and counter-terrorist-financing regime, or commercial-activity typologies for this jurisdiction. Those areas remain on their established baseline and are not addressed further here. #### Cross-Monitor Connections The crypto-kiosk fraud pattern described above sits at the boundary between financial-integrity and digital-asset-infrastructure risk reporting elsewhere in the fleet: kiosks function as a cash-to-crypto on-ramp frequently exploited in romance, impersonation and extortion scams, and the absence of a kiosk-specific licensing layer in Pennsylvania is the kind of enablement-by-omission finding that a crypto-infrastructure tracker would read as a structural permissiveness signal rather than as an isolated consumer-fraud episode. Where a kiosk operator also offers services across state lines, the stalled state-level bill is relevant context for any multi-state regulatory-patchwork assessment being carried elsewhere in the fleet, since Pennsylvania-domiciled kiosks will continue to operate under general money-transmission coverage alone for as long as the dedicated bills remain in committee. #### Outlook The near-term path runs through the legislature rather than through enforcement. Senate Bill 1015 and House Bill 2643 remain in committee as of the most recent reporting, with no indication of a scheduled floor vote, and an estimated impact window of the fourth quarter of 2026 reflects the consultation stage the legislation has sat at rather than any announced timetable for passage. Should either bill advance, kiosk operators would face new licensing, disclosure, reporting and transaction-limit obligations layered onto the existing money-transmission framework, closing the gap the Attorney General's awareness campaign is currently compensating for through signage rather than statute. Absent that legislative movement, the Commonwealth's posture through the remainder of 2026 is likely to continue combining general money-transmission oversight with public-facing fraud-prevention messaging, leaving kiosk-specific obligations unresolved. 18 Oct 2026 · fim-2026-10-18 #### Lead Signal Sanctions activity this period centers on a cluster of designations touching Mexican cartel finance and the ongoing US national-emergency architecture against Colombia-centered narcotics trafficking, alongside a notable instance of allied-country divergence from a US designation tied to the International Criminal Court. OFAC designated individuals under Executive Order 14059 and Executive Order 13224 for supporting Cartel del Noreste's financial operations, including an allegation that cash was delivered to fund political candidates preferred by the cartel in Mexico; this finding was read through a Tier-4 aggregator reproducing a Treasury release rather than independently re-fetched from the primary OFAC page, so it carries probable rather than confirmed confidence. Separately, the United States continued the national emergency under Executive Order 12978 regarding significant narcotics traffickers centered in Colombia for one year beyond October 21, 2026, a routine architectural continuation rather than a new designation event. A third thread, carrying probable confidence from third-party reporting, describes G7 partners publicly objecting to a US International Criminal Court-related OFAC designation issued around October 13, 2026, even as OFAC concurrently issued general licenses intended to limit the designation's disruptive effect. #### Other Developments Cambodia's casino-sector enforcement push continued this period, with the Cambodia Commission for Combating Online Scams and the Commercial Gambling Management Commission suspending casino-linked online and proxy gambling and launching nationwide multi-agency inspections of physical casinos. This extends a post-2023 effort to sever casinos from cyber-scam-compound financing, a vulnerability flagged in Cambodia's 2017 FATF mutual evaluation, and reflects a structural rather than episodic enforcement posture. Pennsylvania's virtual-currency licensing framework carries a standing correction worth noting this period: Act 7 of 2025 imposes a standalone fee-based virtual-currency-transmission licensing trigger under 7 P.S. §6102(a)(2), in force since August 26, 2025, and the Department of Banking and Securities has formally rescinded its 2024 policy statement that had characterized virtual currency as outside the definition of money. This is a standing fact surfaced to correct an outdated characterization rather than a new deterioration signal; Pennsylvania has closed what had been a historical crypto-money-transmission-licensing gap. #### Cross-Monitor Connections The Pennsylvania crypto-licensing correction is directly relevant to world-payments' coverage of market-access conditions for virtual-currency transmission businesses in the Commonwealth, since the same licensing trigger that closes an AML/CTF gap also functions as a payments-market-access requirement. The Cambodia casino enforcement action connects to broader financial-integrity concerns about the use of casino and proxy-betting infrastructure to launder proceeds tied to cyber-scam compounds, a typology with cross-border financial-flow dimensions relevant to enabler-jurisdiction analysis. The G7-US sanctions divergence over the ICC-related designation is a architecture-level signal worth monitoring for any firm with cross-border sanctions-screening obligations spanning US and allied jurisdictions, since divergent listing regimes can create conflicting compliance obligations for multinational institutions. #### Outlook The FATF's October 26-30, 2026 plenary is the most consequential near-term date on the sanctions and grey-list horizon, with Monaco, Bulgaria, and Cote d'Ivoire reported as tipped for potential delisting, while the Democratic Republic of Congo's delisting is flagged as unlikely in this round; no decision has been made as of this cycle. Continued G7-US sanctions-architecture divergence, if it persists beyond the ICC-related episode, would be a structural development worth escalating rather than a one-off friction point. For Pennsylvania specifically, the crypto-MTL licensing trigger being now correctly reflected in the standing record closes an identified gap, and the Commonwealth's current posture is one of a described, in-force requirement rather than one that is still-emerging. 4 Oct 2026 · fim-2026-10-04 #### Lead Signal The Federal Reserve Board moved on two fronts to implement the GENIUS Act's stablecoin regime on 24 September 2026, issuing NPRM Docket R-1899, which sets eligible reserve assets for payment-stablecoin issuers at cash, Federal Reserve balances, insured deposits, Treasuries of 93 days or less remaining maturity, and repo, and Docket R-1900, governing application procedures, each opening a 60-day comment period. Six days later the Treasury Department published what is reported as the first binding, effective-upon-publication GENIUS Act interim final rule. This is the most significant financial-integrity-relevant development of the cycle: it bears on the crypto-laundering and sanctions-evasion risk architecture underlying dollar-denominated stablecoin rails, and it interacts with subnational money-transmission licensing regimes, including Pennsylvania's own Act 7 of 2025 virtual-currency-transmission licensing law, though no Pennsylvania-specific development was located this cycle addressing that interaction directly. #### Other Developments Cambodia reports enforcement figures ahead of anticipated reassessment. Cambodia's Ad-Hoc Commission for Combating Online Scams reports $300 million frozen and 86 scam compounds closed between July 2025 and August 2026, including 27 sanctioned casinos, ahead of an anticipated FATF/APG reassessment. These are self-reported government figures not yet independently confirmed by FATF or APG, and analysts have expressed skepticism given reports of compound relocation into Laos. OFAC continues its established designation pattern. OFAC's 2 October 2026 SDN list update designates Mexico-nationality individuals and entities under SDGT and Illicit-Drugs Executive Order 14059 authorities, continuing the established pattern of cartel-linked financial-facilitator designations. No divergence from the standing pattern was identified. #### Cross-Monitor Connections The GENIUS Act rulemaking is the architectural development to watch for its bearing on crypto and digital-asset regulatory monitoring broadly: reserve-asset composition and bank-subsidiary approval standards shape the integrity of the stablecoin issuance channel in ways that connect directly to crypto-market-structure tracking. For a subnational jurisdiction such as Pennsylvania, the federal rulemaking sits above an existing state money-transmission licensing perimeter, and the open question of how the Pennsylvania Department of Banking and Securities will reconcile its Act 7 of 2025 licensing regime with the federal stablecoin-issuer framework remains unresearched as of this cycle. #### Outlook The federal GENIUS Act rulemaking's 60-day comment periods, opened 24 September 2026, will run into late November 2026, ahead of a tri-agency implementation trajectory expected around the first quarter of 2027. Whether Pennsylvania issues state-level guidance addressing the interaction between its existing Act 7 licensing regime and the federal stablecoin framework before full federal implementation is the open item for this jurisdiction. Separately, Cambodia's anticipated FATF/APG reassessment remains a marker to watch for independent confirmation of the self-reported enforcement figures. 28 Sep 2026 · fim-2026-09-28 #### Lead Signal Pennsylvania has closed a state-level licensing gap for virtual-currency transmission. Act 7 of 2025 (SB 202), signed by Governor Shapiro on June 27, 2025, amended the 1965 Money Transmission Business Licensing Law to require licensure for virtual-currency transmission on the same basis as fiat money transmission, effective August 26, 2025, with no grace period. The Pennsylvania Department of Banking and Securities has confirmed that the transmission of virtual currency is now treated the same as traditional money transmission, meaning unlicensed crypto exchanges and custodians serving Pennsylvania residents have been in a compliance-exposed posture since the third quarter of 2025. #### Other Developments Standing AML/CTF architecture confirmed. Pennsylvania's AML/CTF regime of record remains 10 Pa. Code Chapter 19 (Money Transmitters), administered by the Department of Banking and Securities, which governs licensure, annual reporting, agent registration, and compliance with federal AML requirements for money and virtual-currency transmitters. Act 7's extension of this framework to virtual-currency transmission is a structural update to that standing record rather than a freestanding new regime, layering a state licensing and AML-compliance obligation atop the federal Bank Secrecy Act and FinCEN baseline that already governs money-services businesses nationally. #### Cross-Monitor Connections This development sits squarely at the intersection of state payments regulation and financial-crime compliance architecture: a state money-transmission statute extended to reach virtual-currency transmission is simultaneously a licensing-and-market-access event for payments-sector monitoring and an AML/CTF-exposure event for financial-integrity monitoring, since licensure under the amended statute now carries with it the annual reporting and agent-registration obligations that anchor the state's AML compliance posture for this sector. #### Outlook Watch for Pennsylvania Department of Banking and Securities enforcement activity against unlicensed virtual-currency transmitters now that the no-grace-period licensure requirement has been in force since August 26, 2025, and for any further guidance clarifying scope or exemptions under the amended Money Transmitter Act. 16 Jul 2026 · fim-2026-07-16 #### Lead Signal The most consequential development for Pennsylvania this cycle is not a discrete enforcement action but a structural narrowing of beneficial-ownership visibility into the entity population formed under state law. An interim final rule issued by FinCEN exempting domestic reporting companies from Corporate Transparency Act beneficial-ownership reporting has been in effect since March 26, 2025, with the underlying comment period closed on May 27, 2025 and a final rule not expected until 2026. That narrowing is compounded by an exceptive relief order issued by FinCEN on February 13, 2026, designated FIN-2026-R001, which permits, but does not require, covered institutions to limit customer due diligence beneficial-ownership verification to the first account opening plus risk-based triggers rather than at every new account opening. Pennsylvania has no state-level beneficial-ownership registry of its own, so the federal narrowing translates directly and fully into the corporate-transparency posture of the Commonwealth, with no local backstop available. The same architecture-over-incident lens applies to the digital-asset exposure of the Commonwealth. The FBI Internet Crime Complaint Center recorded a 99 percent year-on-year rise in complaints tied to convertible virtual currency kiosks, with more than 10,956 complaints reported nationally and the largest national kiosk operator, Bitcoin Depot, filing for bankruptcy in 2026. The statutory response of Pennsylvania is more developed than an earlier baseline characterization suggested: Act 7 of 2025 has required virtual currency transmitters to be licensed under the Pennsylvania Money Transmitter Act since August 26, 2025, giving the Commonwealth an operative state-level VASP-licensing framework. A separate bill, House Bill 2643, which would add kiosk-specific consumer protections, remains pending and is confirmed only by a single tier-three source, leaving the consumer-protection gap facing elderly kiosk-fraud victims open pending enactment. #### Other Developments Cartel and Iranian sanctions activity expands sanctions exposure specific to the United States. An Executive Order of January 20, 2025 designating major cartels and fentanyl-trafficking organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists materially broadens sanctions and material-support compliance exposure for financial institutions across the United States, a designation not mirrored at comparable scale by the European Union or the United Kingdom. Treasury separately sanctioned Iranian regime officials on January 30, 2026 as part of a continued maximum-pressure campaign that touches IRGC-linked crypto and stablecoin flows; European Union and United Kingdom Iran sanctions lists diverge in scope from the OFAC list, creating cross-jurisdictional compliance friction for institutions maintaining international correspondent relationships. A legal-gatekeeper settlement illustrates trust-services exposure. OFAC reached a civil settlement with a United States attorney and former government official who continued administering trust structures for a Russian oligarch after that oligarch had been designated on the SDN list, a settlement reflecting a non-egregious, non-voluntarily-disclosed violation. Two national gatekeeper-failure enforcement actions carry direct relevance to firms licensed in Pennsylvania. A consent order issued by FinCEN in March 2026 found that Canaccord Genuity willfully failed to implement adequate anti-money-laundering trade surveillance and customer due diligence in its microcap and over-the-counter market-making business, prompting the exit of the firm from that line of business. Separately, Brinks Global Services paid a 17 million dollar civil penalty after FinCEN found the company had operated as an unregistered money transmitter, conducting bulk cross-border and domestic currency shipments without Bank Secrecy Act compliance. Chinese money-laundering networks intersect with newly designated cartel proceeds. These networks function as unregistered money services businesses executing mirror transactions that launder fentanyl-trafficking proceeds moving through communities such as the Kensington corridor in Philadelphia, while simultaneously facilitating Chinese capital flight through underground banking channels. A federal stablecoin compliance architecture is taking shape. The GENIUS Act, signed into law in July 2025, established the first federal stablecoin anti-money-laundering framework, treating permitted payment stablecoin issuers as Bank Secrecy Act financial institutions, with a joint FinCEN and OFAC implementing rulemaking issued in April 2026 to finalize sanctions-screening obligations. FinCEN has proposed a fundamental reform of AML program supervision. The proposed rule issued in April 2026 would refocus financial-institution AML and counter-terrorist-financing programs on effectiveness rather than paperwork volume and would reduce examiner discretion; the comment period closed June 9, 2026 and a final rule is expected in the fourth quarter of 2026. Treasury published its 2026 national risk assessments. The Department of the Treasury issued the National Money Laundering, Terrorist Financing, and Proliferation Financing Risk Assessments in March 2026, providing the primary national-level benchmark against which sub-national exposure in Pennsylvania is assessed this cycle. #### Cross-Monitor Connections The attorney-trust settlement carries significance beyond the sanctions-compliance scope of this monitor: continued administration of trust structures for a sanctioned Russian oligarch after designation is a facilitation architecture relevant to kleptocracy and wealth-defense monitoring conducted by WDM, which examines how professional intermediaries preserve the access of a designated person to assets rather than whether a single transaction breached sanctions rules in isolation. Separately, the Chinese money-laundering-network architecture identified this cycle, which absorbs fentanyl-trafficking proceeds while independently servicing Chinese capital-flight demand, has been flagged for the cross-border commodity and cash-flow monitoring conducted by ERM, given the intersection of the network with trade-based value-transfer channels that also carry resource-flow significance. Neither flag changes the underlying financial-integrity assessment produced here; both indicate that the same architecture generates signal read differently by adjacent monitors. #### Outlook Several federal rulemakings enter finalization windows over the second half of 2026 and will jointly determine whether the compliance environment facing Pennsylvania institutions tightens or loosens. The final rule on the domestic beneficial-ownership-information exemption is expected in 2026 and could retain, narrow, or reverse the current interim exemption. The proposed AML program reform is expected to reach a final rule in the fourth quarter of 2026, with an uncertain near-term effect on enforcement intensity pending finalization and practical application. The joint FinCEN and OFAC rulemaking finalizing sanctions-screening obligations for permitted payment stablecoin issuers under the GENIUS Act is also expected in the fourth quarter of 2026, ahead of the full statutory implementation deadline in January 2027. Enactment status for Pennsylvania House Bill 2643 remains unconfirmed, and the next Financial Action Task Force Plenary review of United States posture is estimated for October 2026 following the transition of the FATF presidency to the United Kingdom. None of these outcomes is yet determined; each is a live variable rather than a settled trajectory. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion This period's sanctions signal has three distinct components, each illustrating a different architectural layer. First, OFAC designated individuals under Executive Order 14059 and Executive Order 13224 for supporting Cartel del Noreste's financial operations, with an allegation that cash was delivered to fund political candidates the cartel preferred in Mexico. This finding was surfaced via a Tier-4 aggregator reproducing a Treasury release rather than an independently re-fetched primary OFAC page, so the underlying designation detail carries probable rather than confirmed confidence, and the PEP-adjacent political-financing allegation in particular warrants independent primary-source verification before being treated as settled. Second, the United States continued the national emergency under Executive Order 12978 regarding significant narcotics traffickers centered in Colombia for one year beyond October 21, 2026; this is architecture-over-incident by design, a routine annual continuation of a standing sanctions programme rather than a new designation event, and Colombia's new government is separately advancing a draft Anti-Terrorism Statute domestically, a parallel but distinct development. Third, and most structurally significant, G7 partners publicly objected to a US International Criminal Court-related OFAC designation issued around October 13, 2026, while OFAC concurrently issued general licenses intended to limit the designation's disruptive effect on allied institutions; this is read at probable confidence from third-party reporting and corroborates an ongoing pattern of EU and UK autonomous-listing drift relative to US sanctions policy. A sanctions-architecture reading of this cycle treats the G7 divergence as the most consequential thread, since persistent allied disagreement over designation scope creates genuine compliance friction for institutions operating across both US and G7 sanctions regimes, distinct from the routine designation and continuation activity against cartel and narco-trafficking networks. Continue reading #### Outlook The FATF's October 26-30, 2026 plenary carries the nearest-term architectural significance, with Monaco, Bulgaria, and Cote d'Ivoire reported as tipped for potential delisting from the grey list, while the Democratic Republic of Congo's delisting is flagged as unlikely this round; no plenary decision has been made as of this cycle. Separately, whether the G7-US sanctions divergence over the ICC-related designation persists or resolves will determine whether this cycle's episode becomes a durable architectural fault line or remains a one-off friction point; continued monitoring of subsequent OFAC general-license activity is the most direct indicator to watch. #### Conflict Finance and Extractive-Industry Integrity The conflict-finance signal touching Pennsylvania this cycle runs through a single but analytically dense architecture: Chinese money-laundering networks functioning as unregistered money-services businesses that execute near-instant mirror transactions, delivering peso or convertible-virtual-currency equivalent value to Mexico-based accounts in exchange for United States dollar cash generated by fentanyl trafficking, while simultaneously laundering Chinese nationals capital through the same underground banking infrastructure. This is a dual money-laundering demand structure, absorbing United States-dollar cartel proceeds on one side and delivering Chinese capital-flight value on the other, with a documented nexus to opioid-affected communities such as the Kensington corridor in Philadelphia. Because the cartel and fentanyl-trafficking organizations whose proceeds these networks absorb were separately designated as Foreign Terrorist Organizations and Specially Designated Global Terrorists under the January 2025 Executive Order, this architecture is properly classified as conflict-finance-adjacent rather than as an ordinary trade-based money-laundering or enabler-network issue alone, a reclassification with direct significance for how Pennsylvania institutions should weigh exposure to money-services-business or correspondent counterparties operating in this corridor. Continue reading The statutory hook for this architecture is explicit and directly maps to institutional obligations: the Bank Secrecy Act definition of a money-services business, 31 U.S.C. Section 5312(a)(2) and 31 C.F.R. Section 1010.100(t), applies to these Chinese money-laundering networks even though they operate unregistered, meaning any Pennsylvania bank, payment company, or cross-sector institution with a customer due diligence obligation touching a counterparty in this network is exposed to a partial control-gap signal on customer due diligence specifically, per the FinCEN advisory underlying this finding. No extractive-industry or war-economy financial nexus specific to Pennsylvania has been identified this cycle; the domain trajectory is assessed as watch rather than worsening or improving, reflecting that this is a newly surfaced architecture for this jurisdiction rather than an escalating or de-escalating trend with sufficient history to characterize direction. The absence of an extractive-industry finding is itself worth stating plainly rather than omitting, consistent with the honesty-over-coverage principle that governs this monitor treatment of thin domains. #### Outlook The principal open question for this domain is whether the expanded Southwest Border Geographic Targeting Order, which lowers the currency transaction reporting threshold to 1,000 dollars for money-services businesses across additional border counties, generates enforcement action against the Chinese money-laundering-network architecture comparable in scale to the Canaccord and Brinks precedents tracked under enabler jurisdictions. This monitor will also watch for any extension of the Foreign Terrorist Organization and Specially Designated Global Terrorist designation architecture to additional cartel-linked entities, which would further deepen the conflict-finance classification of downstream laundering networks touching Pennsylvania. #### Crypto / Digital Assets / Financial Innovation Pennsylvania's digital-asset exposure this cycle concentrates entirely on retail-facing fraud mediated through cryptocurrency kiosks, rather than on institutional-level crypto-asset-operator compliance architecture. The Office of Attorney General, through its Bureau of Consumer Protection, launched a voluntary statewide warning campaign at or around kiosk locations on 29 October 2026, placing signage advising the public that no legitimate law enforcement agency or court will ever direct a person to pay a fine or debt at a cryptocurrency kiosk. The campaign responds to a baseline of roughly 290 scam complaints involving cryptocurrency received by the Bureau over the prior year, spanning government-impersonation schemes, romance fraud and investment fraud typologies that use kiosks as the final cash-out or value-transfer step. Continue reading The structural counterpoint is the continued absence of dedicated kiosk-operator licensing. Senate Bill 1015 and House Bill 2643, both aimed at imposing regulation and reporting requirements specific to virtual-currency kiosk operators, remain in committee with no indication of imminent advancement. This leaves Pennsylvania's kiosk operators subject only to the general money-transmission licensing regime established by the Commonwealth's 2025 virtual-currency statute, which brings transmission-for-a-fee activity under licensing but was not drafted with kiosk-specific transaction limits, fraud-disclosure obligations or reporting duties in mind. The gap is one of instrument design rather than regulatory vacuum: Pennsylvania has general coverage of virtual-currency transmission, but not the kiosk-specific layer that practice in other states with enacted kiosk statutes would suggest is the more targeted tool against this fraud vector. The analytical significance lies in the sequencing. A consumer-protection authority has moved to address the visible harm (victims losing funds at kiosks) while the banking and securities regulatory apparatus that would impose binding operator-level safeguards has not yet moved the dedicated bills forward. This is not evidence of regulatory failure so much as evidence of where the Commonwealth's institutional attention has landed first: disclosure and public education ahead of licensing reform. Whether that sequencing reflects a considered legislative strategy or simply the ordinary pace of committee process is not something the record supports concluding either way. #### Outlook The operative question going into the next reporting period is whether Senate Bill 1015 or House Bill 2643 moves out of committee. As scheduled for 2026 Q4 consideration, with a wide uncertainty band around that estimate, neither bill carries a confirmed enactment timeline. Should either advance, the resulting framework would be expected to impose licensing, disclosure, reporting and transaction-limit requirements specific to kiosk operators, closing the gap the Attorney General's voluntary campaign currently addresses only through signage. Until then, the Commonwealth's practical defense against kiosk-facilitated fraud rests on public warning rather than on a binding operator obligation, and the scam-complaint volume driving this cycle's signal gives no indication of abating on its own. #### AML/CTF Regime Pennsylvania's AML/CTF-adjacent regulatory record now correctly reflects that 7 P.S. §6102(a)(2) requires a Pennsylvania money-transmitter license for fee-based virtual-currency transmission, in force since August 26, 2025, with the Department of Banking and Securities' superseded 2024 guidance formally rescinded. Because money-transmitter licensing is the primary state-level vehicle through which virtual-currency businesses become subject to registration, recordkeeping, and supervisory oversight in Pennsylvania, this correction is significant for the AML/CTF regime specifically: a virtual-currency transmission business operating in the Commonwealth is now unambiguously within the state's licensing and supervisory perimeter rather than occupying a position where the regulator's own guidance suggested otherwise. This is a baseline-descriptive correction to the standing record rather than a new AML/CTF deterioration or improvement signal in itself, since the underlying statutory trigger has been in force since August 2025; what changed this period is that the public record now accurately reflects that fact. No new suspicious-activity-reporting threshold, customer-due-diligence standard, or AML examination finding specific to Pennsylvania virtual-currency transmitters was identified this period. Continue reading #### Outlook The item to watch is whether Pennsylvania's money-transmitter AML/CTF supervisory framework, now unambiguously applicable to virtual-currency transmission businesses, generates any examination or enforcement activity in subsequent periods; no such activity was identified as of this cycle, and the development remains a standing-record correction rather than an active enforcement signal. Cumulative analysis D7 AML/CTF Regime Cumulative analysis · cross-cycle historical #### AML/CTF Regime Pennsylvania's standing AML/CTF regime of record is 10 Pa. Code Chapter 19, the Money Transmission Business Licensing Law (commonly known as the Money Transmitter Act, Act 249 of 1965), administered by the Pennsylvania Department of Banking and Securities. This regime requires licensure, annual reporting, and agent registration for money-transmission businesses, and incorporates compliance with federal AML requirements as a condition of that licensure. This cycle's material update to that standing record is Act 7 of 2025 (SB 202), signed June 27, 2025 and effective August 26, 2025 with no grace period, which extends the licensure, reporting, and AML-compliance perimeter of the existing statute to cover virtual-currency transmission on the same basis as fiat money transmission. This is best read as a state-level variance layer sitting atop the federal Bank Secrecy Act and FinCEN baseline rather than an independent AML architecture. Pennsylvania has not created a separate virtual-currency-specific AML statute; instead it has amended its general money-transmitter law so that virtual-currency transmitters fall within the same licensure and AML-compliance framework that already governs fiat money transmission businesses in the Commonwealth. The Department of Banking and Securities has been explicit that the transmission of virtual currency is treated the same as traditional money transmission for these purposes, which extends the existing annual-reporting and agent-registration compliance apparatus to a previously unlicensed population of virtual-currency businesses. Three-pillar balance is worth noting explicitly here: the evidence available this cycle speaks to the AML pillar of Pennsylvania's regime (licensure, reporting, agent registration) but surfaces no CTF- or CPF-specific state-level finding distinct from the federal baseline. That absence is not itself evidence of a gap — federal sanctions and counter-terrorist-financing screening obligations apply to money-services businesses nationally regardless of state licensure status — but it does mean this cycle's Pennsylvania-specific finding is properly scoped to the AML licensing dimension rather than to CTF or CPF specifically. #### Outlook Watch for Department of Banking and Securities examination or enforcement activity testing compliance with the extended licensure requirement, and for any published guidance clarifying how the state's AML/CTF compliance expectations for virtual-currency transmitters map onto the federal BSA/FinCEN framework already in place for this sector. Cumulative analysis #### AML/CTF Regime Pennsylvania's standing AML/CTF regime of record is 10 Pa. Code Chapter 19, the Money Transmission Business Licensing Law (commonly known as the Money Transmitter Act, Act 249 of 1965), administered by the Pennsylvania Department of Banking and Securities. This regime requires licensure, annual reporting, and agent registration for money-transmission businesses, and incorporates compliance with federal AML requirements as a condition of that licensure. This cycle's material update to that standing record is Act 7 of 2025 (SB 202), signed June 27, 2025 and effective August 26, 2025 with no grace period, which extends the licensure, reporting, and AML-compliance perimeter of the existing statute to cover virtual-currency transmission on the same basis as fiat money transmission. This is best read as a state-level variance layer sitting atop the federal Bank Secrecy Act and FinCEN baseline rather than an independent AML architecture. Pennsylvania has not created a separate virtual-currency-specific AML statute; instead it has amended its general money-transmitter law so that virtual-currency transmitters fall within the same licensure and AML-compliance framework that already governs fiat money transmission businesses in the Commonwealth. The Department of Banking and Securities has been explicit that the transmission of virtual currency is treated the same as traditional money transmission for these purposes, which extends the existing annual-reporting and agent-registration compliance apparatus to a previously unlicensed population of virtual-currency businesses. Three-pillar balance is worth noting explicitly here: the evidence available this cycle speaks to the AML pillar of Pennsylvania's regime (licensure, reporting, agent registration) but surfaces no CTF- or CPF-specific state-level finding distinct from the federal baseline. That absence is not itself evidence of a gap — federal sanctions and counter-terrorist-financing screening obligations apply to money-services businesses nationally regardless of state licensure status — but it does mean this cycle's Pennsylvania-specific finding is properly scoped to the AML licensing dimension rather than to CTF or CPF specifically. #### Outlook Watch for Department of Banking and Securities examination or enforcement activity testing compliance with the extended licensure requirement, and for any published guidance clarifying how the state's AML/CTF compliance expectations for virtual-currency transmitters map onto the federal BSA/FinCEN framework already in place for this sector. domain_sub_briefs · D7 · Cumulative analysis Periodic updates (1) 25 Oct 2026 · fim-2026-10-25 #### AML/CTF Regime Pennsylvania's AML/CTF-adjacent regulatory record now correctly reflects that 7 P.S. §6102(a)(2) requires a Pennsylvania money-transmitter license for fee-based virtual-currency transmission, in force since August 26, 2025, with the Department of Banking and Securities' superseded 2024 guidance formally rescinded. Because money-transmitter licensing is the primary state-level vehicle through which virtual-currency businesses become subject to registration, recordkeeping, and supervisory oversight in Pennsylvania, this correction is significant for the AML/CTF regime specifically: a virtual-currency transmission business operating in the Commonwealth is now unambiguously within the state's licensing and supervisory perimeter rather than occupying a position where the regulator's own guidance suggested otherwise. This is a baseline-descriptive correction to the standing record rather than a new AML/CTF deterioration or improvement signal in itself, since the underlying statutory trigger has been in force since August 2025; what changed this period is that the public record now accurately reflects that fact. No new suspicious-activity-reporting threshold, customer-due-diligence standard, or AML examination finding specific to Pennsylvania virtual-currency transmitters was identified this period. #### Outlook The item to watch is whether Pennsylvania's money-transmitter AML/CTF supervisory framework, now unambiguously applicable to virtual-currency transmission businesses, generates any examination or enforcement activity in subsequent periods; no such activity was identified, and the development remains a standing-record correction rather than an active enforcement signal. Baseline-Tracked Domains with No Current-Cycle Escalation (1 of 8) - D8 Commercial Activity: Standing coverage — no activity this cycle. Regulatory horizon Consultation 2026-Q4 · ±half_year ### Virtual Currency Kiosk Regulation (SB1015 / HB2643) If enacted, SB1015/HB2643 would impose licensing, disclosure, reporting and transaction-limit requirements specific to virtual-currency kiosk operators; as of this cycle neither bill has advanced out of committee. [Source](https://www.palegis.us/legislation/bills/2025/sb1015) Consultation 2026-Q4 · ±half_year ### Virtual Currency Kiosk Regulation (SB1015/HB2643) If enacted, SB1015/HB2643 would impose licensing, disclosure, reporting and transaction-limit requirements specific to virtual-currency kiosk operators. [Pennsylvania General Assembly / Dept. of Banking and Securities Source](https://www.palegis.us/legislation/bills/2025/sb1015) 2 dated · 3 pending date · baseline fim-2026-07-10 Role action cards MLRO ### Pennsylvania kiosk-fraud campaign highlights a retail typology without a new reporting trigger. The Attorney General's signage campaign addresses a consumer fraud pattern routed through cryptocurrency kiosks; it does not alter any suspicious-activity reporting threshold or obligation for money-services businesses operating kiosks in the Commonwealth, since dedicated kiosk legislation remains in committee. 2 evidence refs Compliance ### Dedicated kiosk-operator licensing remains stalled, leaving general money-transmission coverage as the only binding framework. Firms operating or servicing cryptocurrency kiosks in Pennsylvania continue to be governed only by the general virtual-currency transmission licensing regime; no kiosk-specific disclosure, transaction-limit or reporting obligation has been enacted this cycle, and Senate Bill 1015 and House Bill 2643 remain in committee. 1 evidence refs Legal ### No enforcement action accompanies the kiosk-fraud warning campaign. The Attorney General's campaign is a public-education measure, not an enforcement or investigative action against any kiosk operator; counsel should note the absence of operator liability exposure arising from this specific development while tracking the stalled licensing bills for future obligation changes. 1 evidence refs Board ### A state consumer-protection response to crypto-kiosk fraud has outpaced legislative licensing reform. The Commonwealth's visible response to kiosk-enabled fraud is currently limited to voluntary public warnings, while the legislative framework that would impose binding operator safeguards remains in committee; this sequencing is a governance signal worth monitoring rather than an immediate material risk. 2 evidence refs CTO ### No new technical or platform obligation attaches to kiosk operators this cycle. The warning campaign is a physical-signage measure at kiosk locations; it carries no data, platform or system-architecture requirement. Should Senate Bill 1015 or House Bill 2643 eventually advance, a reporting or transaction-monitoring system requirement for kiosk operators becomes a foreseeable future consideration. 1 evidence refs Risk ### Crypto-kiosk fraud remains a recurring exposure in Pennsylvania absent binding operator safeguards. Approximately 290 scam complaints involving cryptocurrency in the prior year, spanning government-impersonation, romance and investment-fraud typologies, indicate a persistent exposure concentration at the kiosk layer that current voluntary measures do not structurally close. 1 evidence refs Operations ### No new screening or monitoring threshold applies to kiosk transactions this cycle. Operational teams servicing or monitoring kiosk-adjacent transactions should note the public warning campaign as contextual fraud-typology information rather than as a new compliance workflow trigger, since no kiosk-specific operator obligation has been enacted. 1 evidence refs Audit ### No control or evidentiary standard has changed for kiosk-related activity this cycle. Audit scope for kiosk-related money-transmission activity remains anchored to the general virtual-currency transmission licensing regime; the stalled kiosk-specific bills, if enacted, would introduce new documentation and reporting requirements that audit would need to scope separately. 1 evidence refs Scenario sketches ### Kiosk licensing enactment and supervisory handoff Were Senate Bill 1015 or House Bill 2643 to advance to enactment, a plausible illustrative path involves the Department of Banking and Securities assuming direct licensing and examination authority over kiosk operators, with the Office of Attorney General retaining a referral role for consumer complaints. Under this illustration, a kiosk operator could be required to display point-of-sale fraud warnings, impose transaction limits on first-time users, and file periodic reports with the Department, converting the current voluntary signage approach into a binding condition of operation. This is an illustration of how the architecture could evolve, not a forecast of legislative outcome. Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact. Standing trackers (T1–T6) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture no_change T2 · EU AML Package / AMLA no_change Not applicable to a US sub-national jurisdiction-bound pass this cycle. T3 · FATF Grey List no_change T4 · Beneficial-Ownership Register Status no_change T5 · Crypto & Digital-Asset Integrity watch PA AG crypto-ATM fraud-warning campaign (2026-10-29) and continued stalling of SB1015/HB2643. T6 · Sanctions Regime Divergence no_change Not applicable to a US sub-national jurisdiction-bound pass this cycle. Registers ### Enforcement actions - 6 Feb 2025 - 1 Mar 2026 - 9 Dec 2025 - 30 Jun 2026 - FinCEN consent order finding Brink's operated as an unregistered money transmitter, conducting bulk cross-border and domestic currency shipments between MSBs (including a New Jersey-registered money transmitter) without BSA/AML compliance, resolved alongside a DOJ non-prosecution agreement. 6 Feb 2025 - Consent order finding Canaccord willfully failed to implement adequate AML trade-surveillance and CDD processes in its microcap/OTC market-making business over multiple years, despite repeated FINRA warnings dating to 2014, 2017 and 2018, enabling securities-fraud and market-manipulation proceeds to pass unreported. 1 Mar 2026 - OFAC settlement with an attorney who maintained a professional relationship administering trust structures for a Russian oligarch after the oligarch became a Specially Designated National, illustrating how trust and legal-services gatekeepers can be used to conceal a blocked person's property interest. 9 Dec 2025 - FinCEN granted exceptive relief (FIN-2026-R001) from the CDD Rule's requirement to identify and verify beneficial owners of legal-entity customers at each new account opening, narrowing a key backstop for beneficial-ownership visibility left vulnerable by the 2025 CTA domestic-company exemption. 13 Feb 2026 ### Sanctions changes - 20 Jan 2025 - 30 Jan 2026 - 1 Jul 2025 - 2 Oct 2026 - 13 Oct 2026 - 15 Oct 2026 - Executive Order (Jan 20, 2025) designated major cartels and other criminal organizations (including fentanyl-trafficking organizations active in the Mexico-US corridor affecting Pennsylvania communities) as Foreign Terrorist Organizations and Specially Designated Global Terrorists, materially expanding sanctions/material-support exposure for US financial institutions. 20 Jan 2025 - Treasury sanctioned Iranian regime officials for violent repression and corruption (Jan 30, 2026), part of a continued maximum-pressure campaign that also touches IRGC-linked crypto/stablecoin flows flagged in FinCEN's 2026 IRGC alert. 30 Jan 2026 - The GENIUS Act (signed July 2025) establishes the first federal stablecoin framework, treating permitted payment stablecoin issuers as BSA financial institutions and mandating OFAC sanctions-screening and AML programs; a joint FinCEN/OFAC implementing NPRM followed in April 2026. 1 Jul 2025 ### Regulatory horizon (register) - FinCEN domestic BOI exemption — pending final rule - GENIUS Act full implementation (Fed/OCC/FDIC tri-agency stablecoin rules) - FATF October 2026 Plenary outcomes (grey-list review) - Virtual Currency Kiosk Regulation (SB1015/HB2643) - Virtual Currency Kiosk Regulation (SB1015 / HB2643) - FinCEN AML/CFT Program Reform final rule - GENIUS Act stablecoin regime full implementation deadline - Next FATF Plenary review of US AML/CFT posture - Joint FinCEN/OFAC PPSI AML rule finalization ### Active schemes - [HIGH] Domestic BOI exemption reopens PA shell-entity opacity - [HIGH] Crypto ATM/kiosk elder-fraud money-mule pipeline - [HIGH] Chinese money-laundering mirror-transaction cartel-cash networks - Broker-dealer trade-surveillance gatekeeper failure typology Sources - [PA Department of Banking and Securities](https://www.pa.gov/agencies/dobs/newsroom/dobs-regulating-virtual-currency-transmitters-thanks-to-new-bipa) - [Pennsylvania General Assembly](https://www.legis.state.pa.us/cfdocs/legis/PN/Public/btCheck.cfm?txtType=HTM&sessYr=2025&sessInd=0&billBody=S&billTyp=B&billNbr=0202&pn=0474) - [Pennsylvania Code and Bulletin](https://www.pacodeandbulletin.gov/Display/pacode?file=%2Fsecure%2Fpacode%2Fdata%2F010%2Fchapter19%2Fchap19toc.html&d=) - [https://www.coindesk.com/policy/2026/09/24/u-s-federal-reserve-moves-on-proposals-to-implement-genius-act-for-stablecoins](https://www.coindesk.com/policy/2026/09/24/u-s-federal-reserve-moves-on-proposals-to-implement-genius-act-for-stablecoins) - [https://finance.yahoo.com/markets/crypto/articles/treasury-first-genius-act-rule-073833593.html](https://finance.yahoo.com/markets/crypto/articles/treasury-first-genius-act-rule-073833593.html) - [https://www.inkl.com/news/300-million-frozen-86-compounds-closed-the-real-scorecard-on-cambodias-scam-crackdown](https://www.inkl.com/news/300-million-frozen-86-compounds-closed-the-real-scorecard-on-cambodias-scam-crackdown) - [https://www.treasury.gov/ofac/downloads/sdnlist.pdf](https://www.treasury.gov/ofac/downloads/sdnlist.pdf) - [Pennsylvania Bulletin (official)](https://www.pacodeandbulletin.gov/Display/pabull?file=/secure/pabulletin/data/vol55/55-32/1057.html) - [Agence Kampuchea Presse](https://www.akp.gov.kh/post/detail/383280) - [MR Sanctions](https://mrsanctions.com/2026/10/13/october-13-2026-ofac-adds-to-counter-terror-and-counter-narcotics-sanctions/) - [Federal Register](https://www.federalregister.gov/documents/2026/10/19/2026-21430/continuation-of-the-national-emergency-with-respect-to-significant-narcotics-traffickers-centered-in) - [https://www.gibsondunn.com/mid-year-developments-in-anti-money-laundering-in-2026/](https://www.gibsondunn.com/mid-year-developments-in-anti-money-laundering-in-2026/) - [https://www.pa.gov/agencies/dos/programs/business/types-of-filings-and-registrations/annual-reports](https://www.pa.gov/agencies/dos/programs/business/types-of-filings-and-registrations/annual-reports) - [https://thehill.com/business/6025347-treasury-repeals-beneficial-ownership-reporting/](https://thehill.com/business/6025347-treasury-repeals-beneficial-ownership-reporting/) - [https://www.pa.gov/agencies/dobs/securities/compliance-conference](https://www.pa.gov/agencies/dobs/securities/compliance-conference) - [Pennsylvania Office of Attorney General](https://www.attorneygeneral.gov/taking-action/ag-sunday-warns-pennsylvanians-of-scams-involving-crypto-bitcoin-atms-during-national-cryptocurrency-month/) - [Pennsylvania General Assembly](https://www.palegis.us/legislation/bills/2025/sb1015) - [Route Fifty](https://www.route-fifty.com/emerging-tech/2026/10/pa-ag-dave-sunday-launches-effort-prevent-cryptocurrency-scams-bitcoin-atms/416939/) - [Enforcement Actions | FinCEN.gov](https://www.fincen.gov/news/enforcement-actions) - [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) - [Enforcement Actions for Failure to Register as a Money Services Business | FinCEN.gov](https://www.fincen.gov/enforcement-actions-failure-register-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 Notice, FIN-2025-NTC1, August 4, 2025](https://www.fincen.gov/system/files/2025-08/FinCEN-Notice-CVCKIOSK.pdf) - [1 FinCEN Advisory United States Department of the Treasury](https://www.fincen.gov/system/files/advisory/advissu7.pdf) - [Application of FinCEN’s Regulations to Persons Administering, Exchanging, or Using Virtual Currencies | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/application-fincens-regulations-persons-administering) - [Fact Sheet on MSB Registration Rule | FinCEN.gov](https://www.fincen.gov/fact-sheet-msb-registration-rule) - [READOUT: FinCEN Director’s Travel to Philadelphia Area for Beneficial Ownership Outreach Event | FinCEN.gov](https://www.fincen.gov/news/news-releases/readout-fincen-directors-travel-philadelphia-area-beneficial-ownership-outreach) - [FinCEN Consent Order Imposing Civil Money Penalty](https://www.fincen.gov/system/files/enforcement_action/2025-02-06/FinCEN-Brinks-FINALv508.pdf) - [UNITED STATES OF AMERICA FINANCIAL CRIMES ENFORCEMENT NETWORK](https://www.fincen.gov/system/files/2026-03/Canaccord-Consent-Order-No-2026-01.pdf) - [CDD Rule FAQs | FinCEN.gov](https://www.fincen.gov/resources/statutes-and-regulations/cdd-rule-faqs) - [FinCEN Proposes Rule to Fundamentally Reform Financial Institution Programs Designed to Fight Illicit Finance | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-proposes-rule-fundamentally-reform-financial-institution-programs) - [1 Section 314(b) Fact Sheet Issue Date: June 12, 2026](https://www.fincen.gov/system/files/shared/314bfactsheet.pdf) - [Key Changes in FinCEN’s Proposed Rule to Refocus AML/CFT Programs on](https://www.fincen.gov/system/files/2026-04/Key-Changes-Program-NPRM.pdf) - [Press Releases | FinCEN.gov](https://www.fincen.gov/news/press-releases) - [What is crypto AML compliance?](https://www.elliptic.co/blockchain-basics/what-is-crypto-aml-compliance) - [Fact Sheet: Proposed Rule to Fundamentally Reform Financial](https://www.fincen.gov/system/files/2026-04/Program-NPRM-FactSheet.pdf) - [1 Financial Crimes Enforcement Network (FinCEN)](https://www.fincen.gov/system/files/2026-05/FinCEN-Year-in-Review-2025.pdf) - [Civil Penalties and Enforcement Information | Office of Foreign Assets Control](https://ofac.treasury.gov/civil-penalties-and-enforcement-information) - [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [Recent Actions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/enforcement-actions) - [2025 Civil Penalties and Enforcement Information | Office of Foreign Assets Control](https://ofac.treasury.gov/civil-penalties-and-enforcement-information/2025-enforcement-information) - [Basic Information on OFAC and Sanctions](https://ofac.treasury.gov/faqs/topic/1501) - [Sanctions List Search Tool | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-list-search-tool) - [Sanctions List Service | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-list-service) - [U.S. DEPARTMENT OF THE TREASURY OFFICE OF FOREIGN ASSETS CONTROL](https://ofac.treasury.gov/media/934806/download?inline=) - [2023 Civil Penalties and Enforcement Information | Office of Foreign Assets Control](https://ofac.treasury.gov/civil-penalties-and-enforcement-information/2023-enforcement-information) - [2024 Civil Penalties and Enforcement Information | Office of Foreign Assets Control](https://ofac.treasury.gov/civil-penalties-and-enforcement-information/2024-enforcement-information) - [READOUT: FinCEN and IRS-CI Convene Public-Private Sector Meeting in Philadelphia to Discuss Combating Illicit Finance Related to Fentanyl Trafficking | FinCEN.gov](https://www.fincen.gov/news/news-releases/readout-fincen-and-irs-ci-convene-public-private-sector-meeting-philadelphia) - [The DOJ's NCET Disbanded: What This Means for Digital Assets - Chainalysis](https://www.chainalysis.com/blog/ncet-blanche-memo/) - [United States Attorney's Office for the Eastern District of Pennsylvania - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/1334329D:US) - [DOJ Uses Organized Crime Statute in $263 Million Cryptocurrency Theft, Money Laundering and Home Invasion Conspiracy | TRM Labs](https://www.trmlabs.com/resources/blog/doj-uses-organized-crime-statute-in-263-million-cryptocurrency-theft-money-laundering-and-home-invasion-conspiracy) - [Blockchain Legal Library](https://www.trmlabs.com/blockchain-legal-library) - [News | FinCEN.gov](https://www.fincen.gov/news?field_date_from_date=&field_date_to_date=&page=216) - [United States Department of the Treasury Financial Crimes Enforcement Network - Home | FinCEN.gov](https://www.fincen.gov/?var=v100002) - [UNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY](https://www.fincen.gov/system/files/enforcement_action/2023-04-05/WUFSI_Assessment_of_Civil_Money_Penalty_1_19_2017.pdf) - [The Value of FinCEN Data - Law Enforcement ...](https://www.fincen.gov/resources/law-enforcement/case-examples) - [Financial Fraud Enforcement Task Force (FFETF) | FinCEN.gov](https://www.fincen.gov/financial-fraud-enforcement-task-force-ffetf) - [1 The U.S. Department of the Treasury’s (Treasury) Financial](https://www.fincen.gov/system/files/2026-03/FinCEN-Advisory-Health-Care-Fraud.pdf) - [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) - [PPSI-AMLCFT-NPRM.pdf](https://www.fincen.gov/system/files/2026-04/PPSI-AMLCFT-NPRM.pdf) - [1 1. See 31 U.S.C. § 5312(a)(2); 31 C.F.R. § 1010.100(t). 2.](https://www.fincen.gov/system/files/2026-06/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) - [1 The U.S. Department of the Treasury’s (Treasury)](https://www.fincen.gov/system/files/2025-08/FinCEN-Advisory-CMLN-508.pdf) - [FinCEN Notice on the Use of Counterfeit U.S. Passport ...](https://www.fincen.gov/system/files/shared/FinCEN_Notice_Counterfeit_US_Passport_FINAL508.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) - [FinCEN Alert, FIN-2024-Alert005, December 18, 2024](https://www.fincen.gov/system/files/2024-12/Alert-FinCEN-Scams-FINAL508.pdf) - [Advisory on Kleptocracy and Foreign Public Corruption](https://www.fincen.gov/system/files/advisory/2022-04-14/FinCEN%20Advisory%20Corruption%20FINAL%20508.pdf) - [Money Services Business (MSB) Registration | FinCEN.gov](https://www.fincen.gov/resources/money-services-business-msb-registration) - [MSB Registrant Search | FinCEN.gov](https://www.fincen.gov/resources/msb-state-selector) - [F I N C E N G U I D A N C E 1](https://www.fincen.gov/system/files/2019-05/FinCEN%20CVC%20Guidance%20FINAL.pdf) - [Fincen](https://www.fincen.gov/system/files/schema/code/FinCENReferenceCodes.xsd) - [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/) - [2026 Crypto Crime Report: Scams](https://www.chainalysis.com/blog/crypto-scams-2026/) - [Retailers keep cashing in on crypto ATMs as scams surge - ICIJ](https://www.icij.org/investigations/coin-laundry/retailers-keep-cashing-in-on-crypto-atms-as-scams-surge/) - [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) - [Elder Financial Exploitation: Threat Pattern & Trend ...](https://www.fincen.gov/system/files/shared/FTA_Elder_Financial_Exploitation_508Final.pdf) - [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) - [Fraud and scams involving Bitcoin ATMs](https://www.elliptic.co/blog/analysis/fraud-and-scams-involving-bitcoin-atms) - [Flip Book: Investigating Crypto Scams | TRM Labs](https://www.trmlabs.com/guides/investigating-crypto-scams-flip-book) - [Crypto ATM operator Bitcoin Depot files for bankruptcy - ICIJ](https://www.icij.org/investigations/coin-laundry/crypto-atm-operator-bitcoin-depot-files-for-bankruptcy/) - [BANK5 2025-5YR19 - Form 10-K - FY2025](https://www.sec.gov/Archives/edgar/data/2098810/000188852426005581/bak25y19_35-6.htm) - [BANK5 2025-5YR15 - Form 10-K - FY2025](https://www.sec.gov/Archives/edgar/data/2071746/000188852426005541/bak25y15_35-6.htm) - [BANK 2025-BNK51 - Form 10-K - FY2025](https://www.sec.gov/Archives/edgar/data/0002098047/000188852426004464/bak25b51_35-1.htm) - [BANK5 2024-5YR7 - Form 10-K - FY2025](https://www.sec.gov/Archives/edgar/data/2022503/000188852426005043/bak24yr7_35-6.htm) - [BANK5 2024-5YR11 - Form 10-K - FY2025](https://www.sec.gov/Archives/edgar/data/2041680/000188852426005224/bak24y11_35-5.htm) - [BANK 2025-BNK50 - Form 10-K - FY2025](https://www.sec.gov/Archives/edgar/data/2062966/000188852426004866/bak25b50_35-6.htm) - [BANK5 2023-5YR2 - Form 10-K - FY2025](https://www.sec.gov/Archives/edgar/data/1979748/000188852426005047/bak23yr2_35-6.htm) - [BANK 2024-BNK48 - Form 10-K - FY2025](https://www.sec.gov/Archives/edgar/data/2036193/000188852426005038/bak24b48_35-8.htm) - [Digital Assets in Digital Finance Regulatory Standards and Law](https://uncitral.un.org/sites/uncitral.un.org/files/media-documents/uncitral/en/castellano_updated.pdf) - [TRM Labs Resources | Crypto Investigations, Compliance, and Policy Insights](https://www.trmlabs.com/resources) - [Crypto regulatory affairs: US regulators issue comprehensive guidance on tokenized securities](https://www.elliptic.co/blog/crypto-regulatory-affairs-us-regulators-issue-comprehensive-guidance-on-tokenized-securities) - [From trading bans to total embrace, a global guide to crypto regulation](https://www.icij.org/investigations/coin-laundry/cryptocurrency-regulations-global-explainer/) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [2025 Regulatory outlook: It’s crunch time for the US Congress on crypto legislation](https://www.elliptic.co/blog/2025-regulatory-outlook-its-crunch-time-for-the-us-congress-on-crypto-legislation) - [Elliptic's 2026 regulatory and policy outlook: 5 crypto trends to expect in 2026](https://www.elliptic.co/blog/regulatory-and-policy-crypto-trends-to-except-in-2026) - [Crypto regulatory affairs: US Congress starts work on stablecoin and digital asset legislation](https://www.elliptic.co/blog/crypto-regulatory-affairs-us-congress-starts-work-on-stablecoin-digital-asset-legislation) - [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/) - [Potential Money Laundering Risks Related to Shell Companies | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/potential-money-laundering-risks-related-shell-companies) - [Financial Crimes Enforcement Network The Role of Domestic Shell Companies in](https://www.fincen.gov/system/files/shared/LLCAssessment_FINAL.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/) - [The Role of Domestic Shell Companies in Financial Crime ...](https://www.fincen.gov/sites/default/files/shared/LLCAssessment_FINAL.pdf) - [Jurisdictions under Increased Monitoring - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) - ["Black and grey" lists](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [High-Risk Jurisdictions subject to a Call for Action - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/Call-for-action-february-2026.html) - [FATF changes its grey listing criteria to further focus on risk](https://www.fatf-gafi.org/en/publications/Fatfgeneral/FATF-grey-listing-criteria.html) - [Jurisdictions under Increased Monitoring - 19 June 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions.html) - [Outcomes FATF Plenary, 11-13 February 2026](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-FATF-plenary-february-2026.html) - [Joint African Development Bank - Financial Action Task Force webinar: Exiting the FATF Grey List – Success Stories and Pathways to Sustainable Compliance](https://www.fatf-gafi.org/en/publications/Fatfgeneral/joint-AfDB-FATF-webinar.html) - [Publications](https://www.fatf-gafi.org/en/publications.html) - [The FATF](https://www.fatf-gafi.org/en/the-fatf.html) - [State Contact Information For MSBs](https://www.fincen.gov/sites/default/files/shared/msbstatecontactsfinal.pdf) - [Proactive Bank Secrecy Act Searches Lead to Crackdown on Unlicensed Money Remitters | FinCEN.gov](https://www.fincen.gov/resources/law-enforcement/case-examples/proactive-bank-secrecy-act-searches-lead-crackdown) - [Registration and De-Registration of Money Services Businesses | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/registration-and-de-registration-money-services-businesses) - [Title 18b | FinCEN.gov](https://www.fincen.gov/title-18b) - [U.S. Department of the Treasury](https://home.treasury.gov/system/files/246/2026-NMLRA.pdf) - [FinCEN](https://www.fincen.gov/?var=v100002) - [FinCEN](https://www.fincen.gov/system/files/2025-08/FinCEN-Notice-CVCKIOSK.pdf) - [FinCEN](https://www.fincen.gov/system/files/2025-08/FinCEN-Advisory-CMLN-508.pdf) - [FinCEN](https://www.fincen.gov/system/files/2026-03/Canaccord-Consent-Order-No-2026-01.pdf) - [FinCEN](https://www.fincen.gov/system/files/enforcement_action/2025-02-06/FinCEN-Brinks-FINALv508.pdf) - [OFAC](https://ofac.treasury.gov/media/934806/download?inline=) - [Financial Action Task Force](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) - [FinCEN](https://www.fincen.gov/news/news-releases/fincen-proposes-rule-fundamentally-reform-financial-institution-programs) - [International Consortium of Investigative Journalists (ICIJ)](https://www.icij.org/investigations/coin-laundry/retailers-keep-cashing-in-on-crypto-atms-as-scams-surge/) - [Pennsylvania Department of Banking and Securities](https://www.dobs.pa.gov/) Coverage gaps fim-int-2026-07-07-G001: Enactment status and text of Pennsy… fim-int-2026-07-07-G001: Enactment status and text of Pennsylvania House Bill 2643 (crypto-kiosk consumer protections) has not been independently confirmed beyond a single T3 press source. [resolved] fim-int-2026-07-07-G002: PA Department of Banking and Securi… fim-int-2026-07-07-G002: PA Department of Banking and Securities enforcement-action statistics specific to virtual-currency-transmitter licensees under Act 7 of 2025 have not been retrieved. [resolved] fim-int-2026-07-07-G003: The substantive content of FinCEN's… fim-int-2026-07-07-G003: The substantive content of FinCEN's eventual 2026 final BOI rule (retain, narrow, or reverse the domestic-company exemption) is not yet knowable and would materially change the D2/T4 trajectory. [resolved] fim-int-2026-07-07-G004: Whether any PA-headquartered or PA-… fim-int-2026-07-07-G004: Whether any PA-headquartered or PA-based entity is a permitted payment stablecoin issuer subject to the GENIUS Act/PPSI NPRM has not been established in available sourcing. [resolved] fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): No PA-specific T1 source located for D1 (sanctions), D2 (beneficial ownership), D3 (enabler jurisdictions), or D4 (conflict finance); these domains are federally governed with no identified state-level delta this cycle. [resolved] fim-int-2026-09-28-G002: Tier-D global watch (KH/LA/MX/CO) c… fim-int-2026-09-28-G002: Tier-D global watch (KH/LA/MX/CO) could not be assessed under the single-jurisdiction binding of this dispatch, which forbids importing findings from outside US-PA. [resolved] fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): No US-PA-specific financial-integrity development was located this cycle beyond the federal GENIUS Act layer interacting with Act 7 of 2025; the interaction itself (DoBS guidance reconciling state and federal stablecoin treatment) has not been researched. [resolved] fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', 'value': 'D1'}): FATF/APG primary-source confirmation of Cambodia's grey-list status or reassessment outcome was not located this cycle. [resolved] fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', 'value': 'D3'}): No second TBML corridor was researched this cycle; the minimum-coverage requirement of two distinct corridors was not met given the pooled search budget. [resolved] fim-int-2026-10-18-G002: Laos (LA) Tier D watch jurisdiction… fim-int-2026-10-18-G002: Laos (LA) Tier D watch jurisdiction was not independently searched this cycle. [resolved] fim-int-2026-10-18-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G003 ({'scheme': 'financial_integrity', 'value': 'D2'}): EU AML Package tracker (T2) was not actively re-queried against US-PA this cycle; its no_change status should be read as awaiting_primary_source in substance. [resolved] fim-int-2026-10-25-G001: No PGCB/PA-specific bank-AML-superv… fim-int-2026-10-25-G001: No PGCB/PA-specific bank-AML-supervisory distinction from federal BSA supervision was independently established; D1/D3/D4/D5/D6/D8 remain thinly covered for this sub-national jurisdiction this cycle. [resolved] fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): Virtual Currency Kiosk Regulation bills (SB1015/HB2643) status after 2026-10-25 was not independently confirmed; committee action window unclear. [open] fim-int-2026-11-01-G002: D1-D4, D6-D8 PA-specific developmen… fim-int-2026-11-01-G002: D1-D4, D6-D8 PA-specific developments were not researched this cycle due to single-JID dispatch budget constraints. [open] FIM-GAP-001 (D2): FinCEN's March 2025 exemption of domestic … FIM-GAP-001 (D2): FinCEN's March 2025 exemption of domestic reporting companies from CTA beneficial-ownership reporting removed federal BO visibility into the large stock of PA-formed LLCs and corporations; Pennsylvania itself does not maintain a state-level beneficial-ownership registry, leaving no substitute mechanism. FIM-GAP-002 (D5): Approximately 18 US states have passed cry… FIM-GAP-002 (D5): Approximately 18 US states have passed crypto-ATM consumer-protection laws or regulations as of late 2025, per AARP tracking cited in ICIJ reporting; available sourcing for this baseline could not independently confirm whether Pennsylvania is among them, nor locate PA Department of Banking and Securities enforcement statistics specific to crypto kiosk operators. FIM-GAP-003 (D6): FinCEN's proposed AML/CFT program-reform r… FIM-GAP-003 (D6): FinCEN's proposed AML/CFT program-reform rule explicitly reframes supervisory posture toward reduced compliance burden and examiner deference to institutions' own risk-based judgment, with a stated general presumption against enforcement action where a program is properly established. FIM-GAP-004 (D3): No PA-specific FATF Mutual Evaluation, ICR… FIM-GAP-004 (D3): No PA-specific FATF Mutual Evaluation, ICRG follow-up, or independently published PA Department of Banking and Securities enforcement-action log was located within the available research window; FATF evaluates the United States only at the national level, and PA-specific state supervisory enforcement statistics were not independently retrievable. ## Evidence #### Confidence-tiered claims NPRM Docket R-1899 sets eligible reserve assets for payment stablecoin issuers (cash, Fed balances, insured deposits, Treasuries <=93 days maturity, repo) with a 60-day comment period. [[Source 1]](#sec-sources) Probable · 1 source Treasury published its first binding, effective-upon-publication GENIUS Act interim final rule (Fed. Reg. 2026-19966) on Sept 30, 2026. [[Source 1]](#sec-sources) Probable · 1 source Cambodia reports $300M frozen and 86 scam compounds closed (Jul 2025-Aug 2026), including 27 sanctioned casinos, ahead of an anticipated FATF/APG reassessment. [[Source 1]](#sec-sources) Probable · 1 source OFAC's Oct 2, 2026 SDN list update designates Mexico-nationality individuals and entities under SDGT/ILLICIT-DRUGS-EO14059 authorities, continuing the cartel-linked financial-facilitator designation pattern. [[Source 1]](#sec-sources) Probable · 1 source 7 P.S. §6102(a)(2) imposes a standalone fee-based virtual-currency-transmission licensing trigger, in force since Aug 26, 2025; the Department's 2024 'virtual currency is not money' policy statement has been formally rescinded. [[Source 1]](#sec-sources) Probable · 1 source Suspended casino-linked online/proxy gambling and launched nationwide multi-agency casino inspections across 16 provinces, October 2026. [[Source 1]](#sec-sources) Probable · 1 source OFAC designated individuals under E.O. 14059 and E.O. 13224 for supporting Cartel del Noreste's financial operations, including alleged cash delivery funding preferred Mexican political candidates. [[Source 1]](#sec-sources) Probable · 1 source Continued the national emergency under E.O. 12978 regarding significant narcotics traffickers centered in Colombia for one year beyond Oct 21, 2026. [[Source 1]](#sec-sources) Probable · 1 source Publicly objected to a US ICC-related OFAC designation issued around Oct 13, 2026, while OFAC concurrently issued general licenses to limit disruption. Probable PA's state Annual Report filing duty (effective Jan 6, 2025) is separate from, and unaffected by, the federal CTA Beneficial Ownership Information regime administered by FinCEN. [[Source 1]](#sec-sources) Probable · 1 source Non-prosecution agreement entered June 30, 2026 with USAO MDPA and DOJ MNF Section for willful failure to establish an effective AML/CFT program. [[Source 1]](#sec-sources) Probable · 1 source Treasury officially repealed the CTA BOI reporting requirement for American companies/individuals to FinCEN. [[Source 1]](#sec-sources) Probable · 1 source PA AG launched statewide STOP-sign campaign at crypto kiosks, citing ~290 scam complaints in prior year [[Source 1]](#sec-sources) Probable · 1 source Kiosk-specific licensing bills SB1015 and HB2643 have not advanced out of committee [[Source 1]](#sec-sources) Probable · 1 source Launched a voluntary statewide 'STOP' sign campaign at cryptocurrency kiosks on or about 2026-10-29, citing ~290 crypto-ATM scam complaints in the prior year (government-impersonation, romance, investment schemes). [[Source 1]](#sec-sources) Probable · 1 source Dedicated virtual-currency-kiosk licensing legislation remains stalled in committee as of this cycle, with no kiosk-specific operator safeguards enacted. [[Source 1]](#sec-sources) Probable · 1 source