--- title: "United States — Rhode Island (US-RI) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/united-states-rhode-island/ source_html: /jurisdictions/united-states-rhode-island/index.html description: "Financial integrity intelligence for United States – Rhode Island (US-RI): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: e968819e4d5cdd864a0e8c59d176b123ceac50b46e437ea518dcf9ef70dc6a32 generator: "fe-fleet/md-twin@1.0" --- # United States — Rhode Island (US-RI) — 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 — Rhode Island US-RI Domains covered 7 of 8 Sources 175 Role actions 8 Horizon <90d 0 Jurisdiction profile FATF status: Largely Compliant Tier: B Risk direction: Increasing Enablement vs enforcement: Mixed RI operates under the federal BSA/AML/OFAC framework administered by FinCEN and Treasury, plus state money-transmitter licensing (incl. More virtual currency) via the RI Department of Business Regulation, Division of Banking. Casino BSA compliance covers the state's two commercial casinos. RI is excluded from FinCEN's Residential Real Estate GTO program, and the March 2025 CTA rollback exempted RI-formed entities from federal beneficial-ownership reporting. Key deficiencies - Rhode Island is not among the metropolitan areas covered by FinCEN's Residential Real Estate Geographic Targeting Orders, leaving all-cash shell-company property purchases structurally under-monitored ahead of the nationwide RRE Rule's phase-in - March 2025 federal exemption of domestic reporting companies from Corporate Transparency Act BOI reporting removed beneficial-ownership disclosure for RI-formed LLCs/corporations - No dedicated state-level financial-crimes/AML enforcement unit distinct from federal DOJ/FinCEN channels, limiting independently verifiable state-specific enforcement data - State money-transmitter/virtual-currency licensing regime operates in a 50-state patchwork with no unified national VASP standard, creating potential regulatory-arbitrage seams Recent developments (18m) - FinCEN interim final rule (March 21/26, 2025) exempted all U.S.-formed ('domestic reporting company') entities, including RI-formed LLCs, from Corporate Transparency Act beneficial-ownership reporting - FATF February 2026 plenary added Kuwait and Papua New Guinea to the Jurisdictions Under Increased Monitoring list; the United States remains off the FATF grey list, requiring RI-regulated financial institutions to apply enhanced due diligence per FinCEN guidance - FinCEN renewed Residential Real Estate GTOs (effective Oct 10, 2025) with Rhode Island still outside the covered metropolitan areas; the nationwide Anti-Money Laundering Regulations for Residential Real Estate Transfers Rule took effect March 1, 2026, newly capturing RI title/settlement agents - GENIUS Act (July 2025) established the first federal payment-stablecoin framework, subjecting any RI-licensed money transmitter engaged in stablecoin issuance to BSA/AML and OFAC screening obligations - Bally's Corporation, headquartered at 100 Westminster Street, Providence, RI, continued expansion of NYSE-listed casino/online-gaming operations carrying standard BSA/AML casino-industry compliance exposure United States federal law that applies in United States – Rhode Island is covered once, on the [United States](/jurisdictions/us/) page. This page covers United States – Rhode Island’s own layer: its own law, regulators and enforcement. Brief ## Lead signal #### Lead Signal Rhode Island has enacted a standalone cybersecurity statute for nonbank financial institutions licensed by its Department of Business Regulation. Senate Bill 603, effective 2 July 2025, requires covered firms to maintain a written information-security program, an incident-response plan, and a defined set of technical controls, including multi-factor authentication, access controls, encryption, annual penetration testing and biannual vulnerability scanning. The structural significance is that Rhode Island has chosen to legislate its own cybersecurity regime for nonbank licensees rather than simply incorporating an existing federal or sister-state template, and reporting converges on the point that the requirements are modeled on, but diverge from, the New York Department of Financial Services Part 500 framework that has become the de facto national benchmark for nonbank financial cybersecurity rules. Read full brief #### Lead Signal Rhode Island has enacted a standalone cybersecurity statute for nonbank financial institutions licensed by its Department of Business Regulation. Senate Bill 603, effective 2 July 2025, requires covered firms to maintain a written information-security program, an incident-response plan, and a defined set of technical controls, including multi-factor authentication, access controls, encryption, annual penetration testing and biannual vulnerability scanning. The structural significance is that Rhode Island has chosen to legislate its own cybersecurity regime for nonbank licensees rather than simply incorporating an existing federal or sister-state template, and reporting converges on the point that the requirements are modeled on, but diverge from, the New York Department of Financial Services Part 500 framework that has become the de facto national benchmark for nonbank financial cybersecurity rules. Because the law reached the market through a state legislative act rather than a supervisory circular, it sits as a durable statutory floor rather than a guidance document that a regulator could quietly revise. That durability matters more than any single enforcement action would: a permissive compliance-technology environment that later tightens into statute changes the baseline expectation for every DBR-licensed nonbank going forward, independent of whether an examiner ever cites the law against a specific firm this cycle. #### Other Developments Virtual-currency licensing perimeter remains anchored to the general money-transmitter statute. Rhode Island continues to bring virtual-currency business activity within its existing Money Transmitters Act rather than adopting a bespoke digital-asset licensing track, and the 2025 amendment extending that perimeter to virtual-currency kiosk operators was the most recent structural move. No new instrument altering this posture was identified this cycle, and the arrangement stands as the stable baseline against which any future kiosk-specific or token-specific rule would represent a genuine departure. A reported anti-money-laundering reporting threshold could not be corroborated. A commercial-advisory source describes a money-transmitter suspicious-activity reporting threshold of two thousand dollars, well below the five-thousand-dollar threshold that applies generally to money services businesses at the federal level. The claim rests on a single vendor source and has not been corroborated against a Division of Banking bulletin or a statutory citation. Until a primary instrument is located, the claim stands as reported rather than established, and no compliance posture should be built on it. #### Cross-Monitor Connections The compliance-technology statute has an evident institutional parallel in the growing pattern of individual US states writing their own cybersecurity frameworks for nonbank financial licensees rather than waiting on a uniform federal standard, which carries implications for how multi-state payment and money-transmission licensees build security programs that must simultaneously satisfy Rhode Island's technical control list and New York's longer-established Part 500 regime. Divergence between those two regimes, particularly around breach-notification timelines, is itself a compliance-technology signal worth tracking across any other state that follows Rhode Island's path. The virtual-currency kiosk licensing perimeter also bears directly on how kiosk operators are treated for money-services-business purposes nationally, a question that recurs wherever a US state extends its money-transmitter statute to cover a new channel for virtual-currency activity. #### Outlook The near-term question is less whether Rhode Island's cybersecurity statute will be enforced in the coming months and more whether other nonbank-heavy states follow its example of a bespoke statutory framework rather than adopting the Part 500 template wholesale. Firms licensed in Rhode Island as nonbank financial institutions should expect the written information-security program, incident-response plan and technical control requirements to form part of ordinary supervisory expectations from mid-2025 forward, with the divergence from New York's breach-notification timeline a specific point of operational attention for multi-state compliance programs. The unverified suspicious-activity-reporting threshold claim remains an open item: if a future cycle locates a Division of Banking bulletin or statutory citation confirming or disproving the two-thousand-dollar figure, that would resolve a materially relevant compliance question for every money-transmitter licensee operating in the state. Earlier periodic briefs (2) 3 Nov 2026 · fim-2026-11-03 #### Lead Signal Rhode Island has enacted a standalone cybersecurity statute for nonbank financial institutions licensed by its Department of Business Regulation. Senate Bill 603, effective 2 July 2025, requires covered firms to maintain a written information-security program, an incident-response plan, and a defined set of technical controls, including multi-factor authentication, access controls, encryption, annual penetration testing and biannual vulnerability scanning. The structural significance is that Rhode Island has chosen to legislate its own cybersecurity regime for nonbank licensees rather than simply incorporating an existing federal or sister-state template, and reporting converges on the point that the requirements are modeled on, but diverge from, the New York Department of Financial Services Part 500 framework that has become the de facto national benchmark for nonbank financial cybersecurity rules. Because the law reached the market through a state legislative act rather than a supervisory circular, it sits as a statutory floor rather than a guidance document that a regulator could quietly revise. That durability matters more than any single enforcement action would: a permissive compliance-technology environment that later tightens into statute changes the baseline expectation for every DBR-licensed nonbank going forward, independent of whether an examiner ever cites the law against a specific firm. #### Other Developments Virtual-currency licensing perimeter remains anchored to the general money-transmitter statute. Rhode Island continues to bring virtual-currency business activity within its existing Money Transmitters Act rather than adopting a bespoke digital-asset licensing track, and the 2025 amendment extending that perimeter to virtual-currency kiosk operators was the most recent structural move. No new instrument altering this posture was identified, and the arrangement stands as the stable baseline against which any future kiosk-specific or token-specific rule would represent a genuine departure. A reported anti-money-laundering reporting threshold could not be corroborated. A commercial-advisory source describes a money-transmitter suspicious-activity reporting threshold of two thousand dollars, well below the five-thousand-dollar threshold that applies generally to money services businesses at the federal level. The claim rests on a single vendor source and has not been corroborated against a Division of Banking bulletin or a statutory citation. Until a primary instrument is located, the claim stands as reported rather than established, and no compliance posture should be built on it. #### Cross-Monitor Connections The compliance-technology statute has an evident institutional parallel in the growing pattern of individual US states writing their own cybersecurity frameworks for nonbank financial licensees rather than waiting on a uniform federal standard, which carries implications for how multi-state payment and money-transmission licensees build security programs that must simultaneously satisfy Rhode Island's technical control list and New York's longer-established Part 500 regime. Divergence between those two regimes, particularly around breach-notification timelines, is itself a compliance-technology signal worth tracking across any other state that follows Rhode Island's path. The virtual-currency kiosk licensing perimeter also bears directly on how kiosk operators are treated for money-services-business purposes nationally, a question that recurs wherever a US state extends its money-transmitter statute to cover a new channel for virtual-currency activity. #### Outlook The near-term question is less whether Rhode Island's cybersecurity statute will be enforced in the coming months and more whether other nonbank-heavy states follow its example of a bespoke statutory framework rather than adopting the Part 500 template wholesale. Firms licensed in Rhode Island as nonbank financial institutions should expect the written information-security program, incident-response plan and technical control requirements to form part of ordinary supervisory expectations from mid-2025 forward, with the divergence from New York's breach-notification timeline a specific point of operational attention for multi-state compliance programs. The unverified suspicious-activity-reporting threshold claim remains an open item: if a future cycle locates a Division of Banking bulletin or statutory citation confirming or disproving the two-thousand-dollar figure, that would resolve a materially relevant compliance question for every money-transmitter licensee operating in the state. 14 Jul 2026 · fim-2026-07-14 #### Lead Signal The dominant signal this cycle for the financial-integrity posture of Rhode Island is a correction, not a new event: baseline reporting had characterized the nationwide Residential Real Estate Rule as having taken effect on 2026-03-01, closing the historical Geographic Targeting Order coverage gap for shell-company real estate purchases in Rhode Island. That characterization is now understood to be superseded. The U.S. District Court for the Eastern District of Texas vacated the Residential Real Estate Rule by order dated 2026-03-19, and the rule carries no legal effect as of this review. Rhode Island, which was never covered by the legacy Geographic Targeting Order program, remains structurally outside federal real-estate beneficial-ownership disclosure. The correction compounds an existing gap rather than opening a new one. The domestic-reporting-company exemption issued by FinCEN from Corporate Transparency Act beneficial-ownership-information reporting, covering Rhode Island-formed limited liability companies among others, remains only an interim final rule; the comment period closed 2025-05-27 and a final rule has not been issued, meaning the permanence of the exemption is not yet settled. Taken together, the vacated real-estate rule and the still-interim corporate exemption place beneficial-ownership transparency for Rhode Island-formed entities and Rhode Island property purchases closer to an opacity baseline than an improving trajectory would suggest, and the overall AML, CTF, and CPF risk trajectory of the jurisdiction this cycle is assessed as increasing, driven primarily by this beneficial-ownership disclosure rollback despite stable federal FATF standing. #### Other Developments A Financial Action Task Force plenary recalibrated correspondent due-diligence obligations. At its February 2026 plenary, FATF added Kuwait and Papua New Guinea to its Jurisdictions Under Increased Monitoring list, while the United States remained off the grey list altogether. OFAC executed a routine but consequential list-maintenance cycle. Effective 2026-06-18, OFAC processed a Cuba-related designation alongside Russia-related designation removals, a designation update, and amended Russia-related general licenses, a cycle whose timing and scope continue to diverge from EU and UK equivalents. That divergence also touches the Rhode Island-headquartered Ballys Corporation through its UK Gambling Commission-licensed subsidiary, which must navigate OFAC, EU, and UK OFSI regimes simultaneously. FinCEN proposed extending Section 311 special-measures scrutiny beyond a single designated entity. A proposed amendment dated 2026-01-15 would extend the special-measures designation applied to Huione Group to successor crypto-marketplace entities linked to pig-butchering laundering networks. The implementation horizon of the GENIUS Act acquired a fixed outer bound. The federal payment-stablecoin framework takes effect the earlier of eighteen months after its 2025-07-18 enactment, no later than 2027-01-18, or 120 days after final implementing regulations are issued, fixing a backstop date independent of rulemaking pace for any Rhode Island-licensed stablecoin-issuing money transmitter. The cash-intensive casino sector of Rhode Island continues to carry standing Bank Secrecy Act exposure. The two commercial casinos of the state, operated under Ballys Corporation, are Bank Secrecy Act-defined financial institutions subject to currency-transaction-report and suspicious-activity-report filing, with FinCEN-documented typologies including chip-walking and structuring below the ten-thousand-dollar threshold. The virtual-currency and money-transmitter licensing regime of Rhode Island sits inside a fragmented fifty-state patchwork with no unified national standard for virtual asset service providers. The state also continues to lack a dedicated state-level financial-crimes enforcement unit distinct from federal Department of Justice and FinCEN channels, and the Division of Banking does not separately publish Rhode Island-specific AML enforcement outcome data, a monitoring-visibility gap rather than a demonstrated firm-level control failure. FinCEN advanced two compliance-technology-relevant initiatives. The agency has proposed reforming AML program requirements toward a risk-based, effectiveness-oriented standard for Bank Secrecy Act-covered institutions, with finalization expected around 2027, and issued an advisory directing financial institutions nationwide, including Rhode Island-based banks and money services businesses, to enhance suspicious-activity-report monitoring following a 330 percent rise in health-care-fraud-related Bank Secrecy Act reporting since 2020. Proliferation-financing-relevant crypto theft continues at scale. DPRK-linked cyber actors are assessed to have attributed approximately two billion dollars of the 3.4 billion dollars in cryptocurrency stolen globally during 2025. #### Cross-Monitor Connections The DPRK-attributed crypto-theft figure carries a proliferation-financing dimension that intersects with sanctions-evasion and conflict-finance monitoring scope, and has been flagged to SCEM at an assessed, medium cross-monitor scale. No Rhode Island-specific nexus to that theft pattern has been identified this cycle; the flag reflects the national crypto-asset landscape within which Rhode Island-licensed virtual asset service providers sit rather than a jurisdiction-specific finding. Separately, the cross-jurisdiction sanctions exposure carried by the UK-licensed subsidiary of Ballys Corporation illustrates how the international footprint of a Rhode Island-headquartered entity imports OFAC, EU, and OFSI regime-divergence risk that is architecturally distinct from, but adjacent to, the domestic AML posture of the state. #### Outlook Several forward-looking items will determine whether the increasing-risk trajectory identified this cycle holds, worsens, or reverses. The appeal status of FinCEN regarding the Eastern District of Texas vacatur of the Residential Real Estate Rule has not been established this cycle, and its outcome will determine whether the real-estate beneficial-ownership gap of Rhode Island is durable or transitional. The Corporate Transparency Act domestic-reporting-company exemption remains interim rather than final, and the timing and content of the eventual final rule from FinCEN will directly affect the beneficial-ownership posture assessed here. The fixed statutory backstop of the GENIUS Act, no later than 2027-01-18, sets a hard outer bound for stablecoin-related Bank Secrecy Act, AML, and OFAC obligations regardless of how implementing rulemaking proceeds, while the next FATF plenary, expected in the fourth quarter of 2026, will recalibrate correspondent enhanced-due-diligence obligations again. The proposed shift by FinCEN toward a risk-based, effectiveness-oriented AML program standard, expected to finalize around 2027, represents the clearest signal this cycle of a structural move toward outcomes-oriented supervision rather than a checklist model. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion Rhode Island inherits the federal sanctions architecture in full; no state-level sanctions authority exists, and the analytically significant developments this cycle sit at the federal and multilateral level with only indirect state-level transmission. The February 2026 FATF plenary added Kuwait and Papua New Guinea to the Jurisdictions Under Increased Monitoring list, while the United States remained off the grey list altogether. This is architecture, not incident: a grey-list addition recalibrates the enhanced-due-diligence baseline that every Rhode Island-regulated financial institution must apply to correspondent and counterparty relationships touching the newly listed jurisdictions, independent of whether any single transaction or account is ever flagged. Continue reading OFAC continued its routine list-maintenance cadence, processing a Cuba-related designation effective 2026-06-18 alongside Russia-related designation removals, a designation update, and amended Russia-related general licenses. Read in isolation, list maintenance of this kind is unremarkable; read structurally, it is evidence of a sanctions architecture that moves on its own cadence, independent of and often out of step with EU Council and UK OFSI timing and scope. That divergence is not merely an observation about regime design. It becomes a live compliance variable for any entity operating across the three regimes simultaneously, and Rhode Island supplies exactly such an entity: Ballys Corporation, headquartered in Providence, operates a UK Gambling Commission-licensed subsidiary that must screen against OFAC, EU, and UK OFSI lists that do not move in lockstep. This is an inferential, corporate-structure-based linkage rather than a documented enforcement event this cycle, and it is assessed at a correspondingly lower confidence tier, but it illustrates a structural point central to the sanctions-architecture domain: regime divergence among allied jurisdictions is itself an evasion-relevant variable, because it creates timing and scope seams that a sophisticated intermediary can exploit even where no single regime has a gap. Enablement as signal is worth stating explicitly here. No Rhode Island-specific sanctions-evasion enforcement action has been independently verified this cycle, and the state has no dedicated sanctions-enforcement capacity distinct from federal Treasury and Department of Justice channels. The absence of enforcement activity in a well-regulated, federally-supervised jurisdiction is not itself evidence of an evasion architecture; it is, however, a reminder that Rhode Island-level visibility into sanctions-compliance effectiveness is structurally limited to what federal authorities choose to publish, and that state-level financial-integrity monitoring of sanctions matters is, in this jurisdiction, entirely dependent on federal disclosure practice rather than independent state capacity. The FinCEN proposal to extend Section 311 special-measures scrutiny to successor entities of Huione Group, while formally a D5 crypto-marketplace matter, has a sanctions-architecture dimension worth flagging here: special-measures designation under 31 U.S.C. 5318A functions as a quasi-sanctions tool, imposing correspondent-account restrictions that mimic blocking-style consequences without requiring formal SDN listing. Its extension to successor entities reflects an evasion-architecture pattern familiar from the sanctions domain proper: designated infrastructure is replaced by successor infrastructure, and the regulatory response has to chase the network rather than the node. #### Outlook The next FATF plenary, expected in the fourth quarter of 2026, is the clearest forward marker in this domain; any further grey-list additions or removals will directly recalibrate the enhanced-due-diligence obligations FinCEN imposes on Rhode Island-regulated institutions. Whether the timing divergence between OFAC and EU/UK sanctions cycles narrows or widens will also bear watching, particularly for entities such as Ballys Corporation with simultaneous exposure to all three regimes. No Rhode Island-specific sanctions enforcement action is currently pending or anticipated based on available sourcing this cycle. #### Beneficial Ownership and Corporate Transparency Rhode Island sits outside the European Union AML Package direct supervisory perimeter; the jurisdiction under review here is a United States state, not an EEA member state, and no AMLR, sixth AML Directive, or AMLA Regulation transposition obligation applies to it. The developments directly relevant to the beneficial-ownership perimeter of Rhode Island are domestic, and they are, this cycle, the most consequential findings in the entire monitoring corpus. Continue reading Baseline research had characterized the nationwide Residential Real Estate Rule as having taken effect on 2026-03-01, a development that would have closed the historical Geographic Targeting Order coverage gap for shell-company real estate purchases in Rhode Island. That characterization is now understood to be superseded: the U.S. District Court for the Eastern District of Texas vacated the Residential Real Estate Rule by order dated 2026-03-19, and the rule carries no legal effect as of this review. Rhode Island, which was never covered by the legacy Geographic Targeting Order program in the first instance, remains structurally outside federal real-estate beneficial-ownership disclosure. This is the kind of structural reversal that architecture-over-incident framing exists to surface: it is not a transient legal dispute but a change in the operative legal state of a rule that a full jurisdictional risk assessment had assumed to be in force. The correction compounds an existing exemption rather than standing alone. The domestic-reporting-company exemption issued by FinCEN from Corporate Transparency Act beneficial-ownership-information reporting, covering Rhode Island-formed limited liability companies among others, remains only an interim final rule; the comment period closed 2025-05-27 and FinCEN has stated an intent to issue a final rule without having done so. The permanence of this exemption is therefore not yet settled, and its eventual finalization, modification, or reversal is a live variable for beneficial-ownership transparency in Rhode Island. Globally, the EU AML Package sets the structural direction for beneficial-ownership and corporate-transparency supervision even where it does not directly bind Rhode Island. That package comprises three distinct instruments: the AML Regulation, directly applicable across EEA member states without national transposition; the sixth AML Directive, which each member state transposes into domestic law individually; and the AMLA Regulation, which establishes the Anti-Money Laundering Authority and, through its emerging direct and indirect supervision perimeter, is shifting beneficial-ownership and obliged-entity supervision from purely national authorities toward a hybrid EU-level regime. This architecture is durable structural backdrop rather than a single-cycle development, and it is presented here because it is the comparator against which the fragmented, litigation-exposed, and interim-rule-dependent beneficial-ownership regime of the United States can be read: where the EU trajectory is toward centralized, harmonized supervision, the trajectory in Rhode Island this cycle is toward reduced federal beneficial-ownership disclosure through both judicial vacatur and an unfinished exemption rulemaking. The composite jurisdictional judgment for Rhode Island this cycle is that beneficial-ownership and corporate-transparency risk is increasing, driven primarily by this disclosure rollback, notwithstanding the stable federal FATF standing of the United States. This is a structural rather than episodic finding: it reflects the operative legal status of two federal instruments, not a single enforcement gap. #### Outlook The appeal status of FinCEN regarding the Eastern District of Texas vacatur of the Residential Real Estate Rule has not been established this cycle and is the single most important variable for this domain going forward; its resolution will determine whether the current beneficial-ownership gap for Rhode Island real estate is durable or transitional. Equally material is the timing and content of the eventual final rule from FinCEN on the Corporate Transparency Act domestic-reporting-company exemption, which will either confirm or narrow the current opacity baseline for Rhode Island-formed entities. #### Enabler Jurisdictions and Professional Facilitators Rhode Island functions less as a permissive enabler jurisdiction in the classical FIM sense and more as a jurisdiction whose enabler-relevant exposure is concentrated in a single cash-intensive sector and compounded by a structural visibility gap. The two commercial casinos of the state, operated under Ballys Corporation, are Bank Secrecy Act-defined financial institutions subject to currency-transaction-report and suspicious-activity-report filing obligations. FinCEN-documented casino typologies, chip-walking, in which chips are moved off the gaming floor without wagering, and structuring of buy-ins or redemptions below the ten-thousand-dollar currency-transaction-report threshold, represent a persistent, architecture-level exposure for the sector rather than a newly identified risk. This is a standing feature of the state economy rather than a cycle-specific development, and it is presented here because cash-intensive gaming floors remain among the more durable enabler-adjacent exposures in any jurisdiction that hosts them, regardless of the sophistication of the parent corporate group. Continue reading The capacity dimension of this domain is where Rhode Island presents its most distinctive feature. The state has no dedicated state-level financial-crimes or AML enforcement unit distinct from federal Department of Justice and FinCEN channels, and the Division of Banking of the Rhode Island Department of Business Regulation does not separately publish Rhode Island-specific AML enforcement outcome data. Applying the capacity-versus-choice test central to enabler-jurisdiction assessment, this appears to be a genuine capacity deficit rather than a deliberate policy choice to under-enforce: Rhode Island is a small state that has elected to rely on federal enforcement infrastructure rather than build a duplicative state-level apparatus, a rational allocation of limited state resources rather than evidence of permissiveness. The analytical consequence, however, is real regardless of intent: independent verification of state-level enforcement effectiveness is structurally limited, and financial-integrity monitoring of this jurisdiction depends almost entirely on what federal authorities choose to disclose. The money-transmitter and virtual-currency licensing regime operated by the Division of Banking sits within a fifty-state patchwork that lacks a unified national standard for virtual asset service providers. This is not a Rhode Island-specific failing so much as a feature of the entire United States regulatory landscape for money transmission, but it does mean that the licensing perimeter Rhode Island applies to virtual-asset businesses is only as strong as the weakest state in a network any multi-state operator can route through, a structural point relevant to enabler-jurisdiction assessment even where Rhode Island itself has not been identified as the weak link. #### Outlook No dated Rhode Island-specific civil-penalty or enforcement action against a named licensed money services business, bank, or casino could be independently verified this cycle, a gap in available sourcing rather than a finding of non-enforcement. The persistence of the state-level AML enforcement capacity deficit and the continued absence of independently published Rhode Island-specific enforcement outcome data are the two features of this domain most likely to remain unchanged absent a deliberate state-level policy shift. #### Conflict Finance and Extractive-Industry Integrity No Rhode Island-specific conflict-finance or extractive-industry-integrity findings were identified this cycle. The state inherits the generic federal United States sanctions and AML framework covering conflict-finance-relevant activity, including the sanctions programs and general-license architecture maintained by OFAC, but no jurisdiction-specific nexus, corporate exposure, or enforcement action tying Rhode Island to conflict-finance flows or extractive-industry corruption has been surfaced by research this cycle. This is a coverage gap rather than a substantive null finding: Rhode Island is a small state with no domestically-headquartered extractive-industry sector and no documented conflict-finance corridor running through it, and the absence of signal here is consistent with that underlying economic and jurisdictional profile rather than indicative of any change in risk. Continue reading Honesty over coverage governs this entry: rather than construct a narrative where none is supported by evidence, this domain is flagged as limited-signal for the cycle. The one indirectly relevant thread available in the broader monitoring corpus, the DPRK-linked cryptocurrency-theft attribution tracked under the crypto and digital-assets domain, carries a proliferation-financing dimension that intersects conceptually with conflict-finance monitoring scope, but no Rhode Island-specific nexus to that pattern has been established, and it is treated substantively under the digital-assets domain rather than here. #### Outlook Absent a Rhode Island-specific extractive-industry exposure or a documented conflict-finance corridor, this domain is expected to remain quiet in subsequent cycles unless new sourcing surfaces a jurisdiction-specific nexus. The domain will continue to be monitored as a standing element of the fixed six-domain set even during quiet cycles. #### Crypto, Digital Assets, and Financial Innovation The developments directly relevant to the digital-asset regulatory perimeter of Rhode Island this cycle are domestic and federal rather than driven by global standard-setting bodies, and they center on the money-transmitter and virtual-currency licensing regime operated by the Division of Banking of the Rhode Island Department of Business Regulation. That regime sits within a fragmented fifty-state patchwork with no unified national standard for virtual asset service providers, a structural condition that creates potential regulatory-arbitrage seams for any multi-state-operating digital-asset business licensed in, or routing through, Rhode Island. Continue reading Against that state-licensing backdrop, the most consequential federal development this cycle is the clarification of the implementation horizon for the GENIUS Act, the federal payment-stablecoin framework. The statute takes effect the earlier of eighteen months after its 2025-07-18 enactment, no later than 2027-01-18, or 120 days after final implementing regulations are issued. This fixed statutory backstop matters directly to any Rhode Island-licensed money transmitter engaged in stablecoin issuance, because it establishes a hard outer bound on Bank Secrecy Act, AML, and OFAC screening obligations independent of how quickly, or slowly, the primary federal stablecoin regulators finalize implementing rules. For a Rhode Island-licensed entity, this converts an open-ended rulemaking-dependent timeline into a fixed compliance-readiness deadline. The proposed FinCEN extension of Section 311 special-measures scrutiny to successor entities of the designated Huione Group network is directly relevant to any Rhode Island-domiciled bank or money services business with exposure to that network or its successors. Because this is a uniquely United States Treasury tool with no direct European Union or United Kingdom equivalent, it is not comparable to any EU digital-asset instrument such as the Markets in Crypto-Assets Regulation, and it should be assessed on its own domestic terms. Globally, standard-setting instruments such as the Markets in Crypto-Assets Regulation and the FATF virtual-asset standards continue to shape the international direction of digital-asset regulation, and the widening fifth-round FATF mutual evaluations are increasing pressure on crypto-sector AML/CFT effectiveness worldwide. These are contextual backdrop for Rhode Island rather than directly binding instruments; the state-licensed virtual-asset sector in Rhode Island is governed by the domestic patchwork described above and by federal Bank Secrecy Act obligations, not by European or FATF instruments directly. The broader threat environment within which the Rhode Island virtual-asset sector sits includes a proliferation-financing dimension worth noting: DPRK-linked cyber actors are assessed to have attributed approximately two billion dollars of the 3.4 billion dollars in cryptocurrency stolen globally during 2025. No Rhode Island-specific nexus to this theft pattern has been identified, but it is relevant context for any Rhode Island-licensed virtual asset service provider assessing counterparty risk. #### Outlook The fixed 2027-01-18 statutory backstop of the GENIUS Act is the clearest forward marker for this domain and establishes a compliance-readiness deadline for any Rhode Island-licensed stablecoin issuer independent of implementing-rule pace. The final scope of the proposed Section 311 extension to Huione Group successor entities, and its practical application to any Rhode Island-domiciled institution with exposure, is the second variable to track going forward. #### Compliance Technology & Active Defence Rhode Island has moved its compliance-technology baseline for nonbank financial institutions from the general and largely implicit expectations that previously governed Division of Business Regulation licensees to an explicit statutory framework. Senate Bill 603, effective 2 July 2025, requires every DBR-licensed nonbank financial institution to maintain a written information-security program and an incident-response plan, and to implement a defined set of technical controls: multi-factor authentication, access controls, encryption, annual penetration testing and biannual vulnerability scanning. This is the clearest active-defence signal to emerge from the state this cycle, and its structural character is the point worth foregrounding: a legislature, not a regulator's internal guidance, has now fixed the floor. Continue reading Two independent secondary sources converge on the core description of the law and on its relationship to the New York Department of Financial Services Part 500 regime, which has functioned as the template most multi-state nonbank financial institutions build toward in the absence of a uniform federal cybersecurity rule for their sector. The reporting is explicit that Rhode Island's statute was modeled on Part 500 but diverges from it, with one source specifically noting that the Rhode Island law gives covered institutions more leeway relative to the New York breach-notification requirement. That divergence is the operationally material detail: a compliance program built to satisfy Part 500 alone cannot be assumed to satisfy Rhode Island's SB603 without a specific comparison of the two breach-notification timelines, and the reverse is equally true for a firm that built to Rhode Island's standard first and later licenses in New York. No primary statutory text for SB603 was retrieved this cycle; the record rests on two Tier 3 secondary accounts rather than a Tier 1 citation to the enacted text, the Rhode Island General Laws codification, or any Division of Business Regulation guidance interpreting it. That gap does not undermine the core finding, which the two sources corroborate independently, but it does mean that technical particulars beyond the headline control list -- exact penetration-testing scope, any size-based exemption thresholds, or the precise incident-response notification deadline -- cannot yet be stated with confidence from the material available this cycle. The active-defence reading of this development is that Rhode Island has signalled it intends nonbank financial licensees to maintain a demonstrable, auditable security posture rather than relying on general-purpose state data-breach law, which in most states imposes notification obligations only after a breach has occurred rather than mandating the preventive architecture SB603 specifies. That shift from reactive breach notification to mandated preventive controls -- a written program, tested defences, and a documented incident-response plan in advance of any incident -- is the kind of structural change that a well-regulated centre produces quietly, without a single enforcement action to mark it, and its absence from enforcement data this cycle should not be read as absence of material change. The statute is in force; whether the Division of Business Regulation has yet examined a licensee against it is a separate and currently unanswered question. #### Outlook The compliance-technology trajectory in Rhode Island is now one of implementation rather than legislative uncertainty: the statute is in force, and the open questions are operational rather than legal. Firms licensed as nonbank financial institutions in the state should expect their written information-security programs and incident-response plans to be treated as a baseline supervisory expectation from mid-2025 forward. The specific divergence from the New York Part 500 breach-notification timeline is the most actionable item for any multi-state compliance function mapping overlapping obligations, and a future cycle that locates the primary statutory text or a Division of Business Regulation examination manual reference would sharpen the picture considerably. Whether other states follow Rhode Island toward a standalone statutory cybersecurity regime for nonbank licensees, rather than continuing to rely on Part 500's gravitational pull, is the broader structural question this development raises for the compliance-technology domain as a whole. Baseline-Tracked Domains with No Current-Cycle Escalation (1 of 8) - D8 Commercial Activity: Standing coverage — no activity this cycle. Regulatory horizon Proposed 2027-Q1 · ±year ### RI S 3075 - amendment to RIGL Chapter 19-14 (Licensed Activities) definitions Proposed amendment to definitions in RIGL Chapter 19-14 'Licensed Activities', introduced 13 Mar 2026, referred to Senate Commerce. [Rhode Island General Assembly / Dept. of Business Regulation Source](https://webserver.rilegislature.gov/Billtext/BillText26/SenateText26/S3075.htm) 1 dated · 3 pending date · baseline financial-integrity-2026-07-05 Role action cards MLRO ### A reported Rhode Island money-transmitter SAR threshold of two thousand dollars could not be corroborated against a primary source this cycle. If accurate, a lower state-level reporting threshold would require reporting-officer attention distinct from the federal five-thousand-dollar money-services-business threshold, but the claim rests on a single uncorroborated vendor source and should not yet be treated as established. 1 evidence refs Compliance ### Rhode Island now requires DBR-licensed nonbank financial institutions to maintain a written information-security program and defined technical controls under Senate Bill 603. Compliance functions with Rhode Island nonbank licenses should map existing cybersecurity programs against the statute's specific control list and reconcile the breach-notification timeline against any New York Part 500 program already in place, given the two regimes diverge on that point. 1 evidence refs Board ### Rhode Island has codified a standalone cybersecurity statute for nonbank financial licensees rather than relying on guidance alone. The statutory character of the obligation signals a durable regulatory expectation that will not be revised through informal supervisory discretion, which has governance implications for any institution with Rhode Island nonbank licensing exposure. 1 evidence refs CTO ### Senate Bill 603 fixes specific technical controls, including multi-factor authentication, encryption, annual penetration testing and biannual vulnerability scanning, for Rhode Island nonbank financial licensees. Technology functions supporting Rhode Island-licensed nonbank entities should verify that penetration-testing cadence and vulnerability-scanning frequency already meet or exceed the statute's stated minimums, and should specifically reconcile breach-notification timelines against any parallel New York Part 500 build. 1 evidence refs Risk ### Rhode Island's cybersecurity statute diverges from the New York Part 500 template on breach-notification timing, creating a cross-state compliance-mapping exposure. Risk functions tracking multi-state regulatory-technology exposure should flag the Rhode Island-New York divergence as a concrete instance of the broader pattern of state-level cybersecurity frameworks diverging from a common template, with potential for further divergence as other states legislate. 1 evidence refs Audit ### Rhode Island's SB603 record this cycle rests on secondary sources; the statute's primary text has not yet been retrieved for citation purposes. Audit functions documenting the evidentiary basis for Rhode Island cybersecurity-control compliance should note that the current record traces to two convergent secondary accounts rather than a primary statutory citation, pending retrieval of the enacted text or Division of Business Regulation guidance. 1 evidence refs Standing trackers (T1–T6) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture stable No RI-specific nexus found this cycle. T2 · EU AML Package / AMLA stable Not applicable to a US subnational JID. T3 · FATF Grey List stable Not applicable to a US subnational JID. T4 · Beneficial-Ownership Register Status stable Federal CTA/BOI layer reported at the US parent JID; no RI-specific variance. T5 · Crypto & Digital-Asset Integrity stable RI regulates virtual-currency activity via its general MTL and 2025 kiosk amendment; no new instrument this cycle. T6 · Sanctions Regime Divergence stable Not applicable to a US subnational JID. Registers ### Enforcement actions - 26 Mar 2025 - 20 Feb 2026 - 1 Mar 2026 - 15 Jan 2026 - 1 Mar 2026 - FinCEN issued an interim final rule revising the CTA 'reporting company' definition to cover only foreign entities registered to do business in the U.S., formally exempting all previously-designated 'domestic reporting companies' and their beneficial owners from BOI reporting. 26 Mar 2025 - Following the FATF's February 2026 plenary, FinCEN issued a notice directing all covered U.S. financial institutions to apply enhanced due diligence obligations toward newly-listed Jurisdictions Under Increased Monitoring (Kuwait, Papua New Guinea) and reiterated Iran/DPRK/Burma call-for-action countermeasures. 20 Feb 2026 - FinCEN issued an Advisory on health care fraud schemes targeting Medicare, Medicaid and other federal/state benefit programs, directing financial institutions nationwide (including RI-based banks and MSBs) to enhance SAR monitoring for a documented 330% rise in health-care-fraud-related BSA reporting since 2020. 1 Mar 2026 - FinCEN issued a proposed amendment to its October 2025 Huione Group Section 311 designation, extending special-measures scrutiny to successor entities used in crypto-enabled 'pig-butchering' and laundering networks; binding on all U.S. financial institutions, including any RI-domiciled banks or MSBs with exposure to the designated network. 15 Jan 2026 ### Sanctions changes - 18 Jun 2026 - 24 Apr 2026 - 30 Jun 2026 - 1 Jul 2026 - 1 Jul 2026 - 13 Jul 2026 - 30 Jun 2026 - OFAC issued a Cuba-related designation alongside Russia-related designation removals, a designation update, and amended Russia-related general licenses, part of the continuous cycle of SDN list changes binding on all U.S. persons and financial institutions, including those in Rhode Island. 18 Jun 2026 - FATF's February 2026 plenary added Kuwait and Papua New Guinea to its list of Jurisdictions Under Increased Monitoring; FinCEN issued a corresponding notice requiring U.S. financial institutions, including those in RI, to apply enhanced due diligence obligations for foreign financial institutions under 31 C.F.R. correspondent account rules. 13 Feb 2026 - FinCEN proposed an amendment to its October 2025 Section 311 designation of Huione Group as a financial institution of primary money laundering concern, expanding coverage to successor crypto-marketplace entities linked to laundering of romance/pig-butchering scam proceeds. 15 Jan 2026 ### Regulatory horizon (register) - AMLR / 6AMLD Single Rulebook application and AMLA direct supervision - RI S 3075 - amendment to RIGL Chapter 19-14 (Licensed Activities) definitions - Next FATF plenary review affecting US correspondent due diligence - GENIUS Act stablecoin implementing regulations rollout - FinCEN AML program 'reasonably designed' rule reform ### Active schemes - Domestic LLC beneficial-ownership opacity post-CTA rollback - Cash-intensive casino structuring risk at RI commercial casinos - Non-GTO-covered real estate as a laundering vehicle — RRE Rule vacated, gap unresolved - State-patchwork VASP/money-transmitter licensing exposure Sources - [TRM Labs](https://www.trmlabs.com/resources/blog/ofac-sanctions-cambodian-senator-and-scam-center-network-targeting-americans-with-digital-asset-fraud) - [iGamiX/igamist](https://igamist.com/news/cambodia-intensifies-casino-and-fraud-crackdown) - [Amnesty International](https://www.amnesty.org/en/latest/news/2026/04/cambodia-casinos-get-state-approval-despite-links-to-human-rights-abuse-at-scamming-compounds/) - [FinCEN (U.S. Treasury)](https://www.fincen.gov/system/files/2026-06/FinCEN-Alert-Fiscal-Fuel-Theft.pdf) - [Steptoe](https://www.steptoe.com/en/news-publications/international-compliance-blog/weekly-sanctions-update-july-6-2026.html) - [AML UAE (FATF plenary summary)](https://amluae.com/fatf-grey-list-countries-update-19th-june-2026/) - [AMLA (EU)](https://www.amla.europa.eu/amla-takes-major-step-toward-harmonised-eu-supervision_en) - [FinCEN (U.S. Treasury)](https://www.fincen.gov/system/files/2026-04/Program-NPRM-FactSheet.pdf) - [FinCEN (U.S. Treasury)](https://www.fincen.gov/) - [U.S. Department of the Treasury](https://home.treasury.gov/news/press-releases/sb0509) - [AML Intelligence](https://www.amlintelligence.com/2026/02/news-cambodia-shuts-nearly-200-scam-centers-in-fraud-crackdown/) - [UK Home Office](https://www.gov.uk/government/publications/offence-of-failure-to-prevent-fraud-introduced-by-eccta) - [Chainalysis](https://www.chainalysis.com/blog/isis-designation-crypto-addresses-july-2026/) - [TRM Labs](https://www.trmlabs.com/resources/blog/ofac-sanctions-firstvpn-and-ransomware-enablers-behind-attacks-on-americans) - [https://webserver.rilegislature.gov/BillText25/HouseText25/H5121.pdf](https://webserver.rilegislature.gov/BillText25/HouseText25/H5121.pdf) - [https://webserver.rilegislature.gov/Billtext/BillText26/SenateText26/S3075.htm](https://webserver.rilegislature.gov/Billtext/BillText26/SenateText26/S3075.htm) - [https://infobytes.orrick.com/2025-06-27/rhode-island-enacts-new-virtual-currency-kiosk-provisions/](https://infobytes.orrick.com/2025-06-27/rhode-island-enacts-new-virtual-currency-kiosk-provisions/) - [Alston Privacy](https://www.alstonprivacy.com/rhode-islands-new-cybersecurity-law-for-nonbank-financial-institutions/) - [American Banker](https://www.americanbanker.com/news/rhode-island-writes-its-own-cybersecurity-rules-for-nonbanks) - [faisalkhan.com](https://faisalkhan.com/solutions/licensing/money-transmitter-license/rhode-island-money-transmitter-license) - [Rhode Island Department of Business Regulation](https://dbr.ri.gov/media/23641/download) - [Rhode Island General Assembly](https://webserver.rilegislature.gov/BillText25/HouseText25/H5121.pdf) - [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) - [The Bank Secrecy Act | FinCEN.gov](https://www.fincen.gov/resources/statutes-and-regulations/bank-secrecy-act) - [United States Department of the Treasury Financial Crimes Enforcement Network - Home | FinCEN.gov](https://www.fincen.gov/) - [Enforcement Actions for Failure to Register as a Money Services Business | FinCEN.gov](https://www.fincen.gov/enforcement-actions-failure-register-money-services-business) - [FinCEN Exchange | FinCEN.gov](https://fincen.gov/resources/financial-crime-enforcement-network-exchange) - [MSB Registrant Search | FinCEN.gov](https://www.fincen.gov/resources/msb-state-selector) - [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) - [FinCEN Assesses $3.5 Million Penalty Against Paxful for Facilitating Suspicious Activity Involving Illicit Actors | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-assesses-35-million-penalty-against-paxful-facilitating-suspicious) - [FinCEN Year In Review | FinCEN.gov](https://www.fincen.gov/about-fincen/fincen-year-review) - [Guidance | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance) - [What is crypto AML compliance?](https://www.elliptic.co/blockchain-basics/what-is-crypto-aml-compliance) - [Virtual Currencies: Key Definitions and Potential AML/CFT Risks](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Virtual-currency-definitions-aml-cft-risk.html) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [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/) - [The Complete Crypto Compliance Program Guide for Financial Institutions | TRM Labs](https://www.trmlabs.com/guides/crypto-compliance-program-guide-for-financial-institutions) - [Cryptocurrency Regulation: How Governments Around the World Regulate Crypto](https://www.chainalysis.com/blog/cryptocurrency-regulation-explained/) - [From trading bans to total embrace, a global guide to crypto regulation](https://www.icij.org/investigations/coin-laundry/cryptocurrency-regulations-global-explainer/) - [anti-money laundering (AML)](https://www.trmlabs.com/glossary/anti-money-laundering-aml) - [Introduction to Cryptocurrency Exchange Compliance - Chainalysis](https://www.chainalysis.com/blog/introduction-to-cryptocurrency-exchange-compliance-crypto-businesses-2024/) - [What is AML and KYC for Crypto? - Chainalysis](https://www.chainalysis.com/blog/what-is-aml-and-kyc-for-crypto/) - [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) - [STATE CONTACT INFORMATION FOR MSBs](https://www.fincen.gov/system/files/shared/msbstatecontactsfinal.pdf) - [Special Notice RMSB Posting](https://www.fincen.gov/system/files/shared/msbregformDRAFT.pdf) - [Application of Money Services Business regulations to the rental of computer systems for mining virtual currency | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/application-money-services-business-0) - [Definition of Money Transmitter (Merchant Payment Processor) | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/definition-money-transmitter-merchant-payment) - [Definition of Money Services Business (Money Transmitter/Currency Dealer or Exchanger) | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/definition-money-services-business-money-0) - [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) - [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) - [1 Financial Crimes Enforcement Network (FinCEN)](https://www.fincen.gov/system/files/2026-05/FinCEN-Year-in-Review-2025.pdf) - [Press Releases | FinCEN.gov](https://www.fincen.gov/news/press-releases) - [Home](https://www.fatf-gafi.org/en/home.html) - [Financial Fraud Enforcement Task Force (FFETF) | FinCEN.gov](https://www.fincen.gov/financial-fraud-enforcement-task-force-ffetf) - [Advisories | FinCEN.gov](https://www.fincen.gov/resources/advisoriesbulletinsfact-sheets/advisories) - [FinCEN Exchange | FinCEN.gov](https://www.fincen.gov/resources/fincen-exchange) - [UNITED STATES OF AMERICA FINANCIAL CRIMES ENFORCEMENT NETWORK](https://www.fincen.gov/system/files/2026-03/Canaccord-Consent-Order-No-2026-01.pdf) - [News | FinCEN.gov](https://www.fincen.gov/news) - [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) - [Financial Crimes Enforcement Network Registration of Money Services Business](https://www.fincen.gov/system/files/shared/FinCENRMSB_ElectronicFilingInstructions.pdf) - [Federal Register/Vol. 89, No. 244/Thursday, December 19, ...](https://ofac.treasury.gov/media/933751/download?inline=) - [Money Services Business (MSB) Registration | FinCEN.gov](https://www.fincen.gov/resources/money-services-business-msb-registration) - [fincen logo MONEY SERVICES BUSINESS REGISTRATION FACT SHEET](https://www.fincen.gov/system/files/shared/FinCENfactsheet.pdf) - [Bally's Corp - Form 10-K - FY2023](https://www.sec.gov/Archives/edgar/data/0001747079/000174707924000020/ex991-2023descriptionofgov.htm) - [Bally's Corp - Form 10-K - FY2024](https://www.sec.gov/Archives/edgar/data/0001747079/000174707925000039/ex991-2024descriptionofgov.htm) - [Bally's Corp - Form 10-K - FY2021](https://www.sec.gov/Archives/edgar/data/0001747079/000174707922000107/baly-20211231.htm) - [CAESARS ENTERTAINMENT Corp - Form 8-K - FY2013](https://www.sec.gov/Archives/edgar/data/0000858339/000085833913000052/a2013q3ex992preparedremarks.htm) - [FinCEN Guidance-FIN-2008-G007 | FinCEN.gov](https://www.fincen.gov/resources/advisories/fincen-guidance-fin-2008-g007) - [Casino or Card Club Compliance Program Assessment | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/casino-or-card-club-compliance-program-assessment) - [Recognizing Suspicious Activity - Red Flags for Casinos and Card Clubs | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/recognizing-suspicious-activity-red-flags-casinos-and-card) - [Frequently Asked Questions Casino Recordkeeping, Reporting, and Compliance Program Requirements | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/frequently-asked-questions-casino-recordkeeping-reporting-0) - [Bally's Corp - Form 8-K - FY2024 (Quarterly Earnings Tables - quarter ended Mar 2024)](https://www.sec.gov/Archives/edgar/data/0001747079/000174707924000017/Financial_Report.xlsx) - [Bally's Corp - Form 8-K - FY2024 (Quarterly Earnings Tables - quarter ended Jul 2024)](https://www.sec.gov/Archives/edgar/data/0001747079/000174707924000082/Financial_Report.xlsx) - [Bally's Corp - Form 8-K - FY2024 (Quarterly Earnings Tables - quarter ended Oct 2024)](https://www.sec.gov/Archives/edgar/data/0001747079/000174707924000092/Financial_Report.xlsx) - [Bally's Corp - Form 8-K - FY2024 (Quarterly Earnings Tables - quarter ended Feb 2024)](https://www.sec.gov/Archives/edgar/data/0001747079/000174707924000007/Financial_Report.xlsx) - [Bally's Corp - Form 8-K - FY2024 (Quarterly Earnings Tables - quarter ended Jul 2024)](https://www.sec.gov/Archives/edgar/data/0001747079/000174707924000086/Financial_Report.xlsx) - [Bally's Interactive LLC - Premises](https://www.gamblingcommission.gov.uk/public-register/business/detail/premises/64864) - [Bally's Interactive LLC - Trading names](https://www.gamblingcommission.gov.uk/public-register/business/detail/trading-names/64864) - [Bally's Interactive LLC - Licence summary](https://www.gamblingcommission.gov.uk/public-register/business/detail/64864) - [Bally's Management Group LLC - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/3328128Z:US) - [Bally's Corp - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/BALY:US) - [Frequently Asked Questions | FinCEN.gov](https://www.fincen.gov/boi-faqs) - [Beneficial Ownership Information Reporting | FinCEN.gov](https://www.fincen.gov/boi) - [Fact Sheet: Beneficial Ownership Information Reporting Notice of Proposed Rulemaking (NPRM) | FinCEN.gov](https://www.fincen.gov/news/news-releases/fact-sheet-beneficial-ownership-information-reporting-notice-proposed-rulemaking) - [Treasury Department won’t enforce beneficial ownership rule under the Corporate Transparency Act - ICIJ](https://www.icij.org/inside-icij/2025/03/treasury-department-wont-enforce-beneficial-ownership-rule-under-the-corporate-transparency-act/) - [Beneficial Ownership Information Reporting Rule Fact Sheet | FinCEN.gov](https://www.fincen.gov/beneficial-ownership-information-reporting-rule-fact-sheet) - [U.S. Beneficial Ownership Information Registry Now Accepting Reports | FinCEN.gov](https://www.fincen.gov/news/news-releases/us-beneficial-ownership-information-registry-now-accepting-reports) - [Corporate Transparency Act](https://www.fincen.gov/system/files/shared/Corporate_Transparency_Act.pdf) - [U.S. Department of the Treasury Financial Crimes Enforcement Network](https://www.fincen.gov/system/files/shared/BOI_FinCEN_Brochure_508C.pdf) - [Beneficial Ownership Reporting Outreach and Education Toolkit | FinCEN.gov](https://www.fincen.gov/boi/toolkit) - [FinCEN Issues Proposed Rule for Beneficial Ownership Reporting to Counter Illicit Finance and Increase Transparency | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-proposed-rule-beneficial-ownership-reporting-counter-illicit) - [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [Sanctions List Service | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-list-service) - [Sanctions List Search Tool | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-list-search-tool) - [Sanctions List Updates](https://ofac.treasury.gov/recent-actions/sanctions-list-updates) - [Specially Designated Nationals (SDNs) and the SDN List](https://ofac.treasury.gov/faqs/topic/1631) - [Home | Office of Foreign Assets Control](https://ofac.treasury.gov/) - [Program Tag Definitions for OFAC Sanctions Lists | Office of Foreign Assets Control](https://ofac.treasury.gov/specially-designated-nationals-list-sdn-list/program-tag-definitions-for-ofac-sanctions-lists) - [OFAC - Sanctions List Site](https://ofac.treasury.gov/specially-designated-nationals-and-blocked-persons-list-sdn-human-readable-lists) - [OFAC Related Press Releases | Office of Foreign Assets Control](https://ofac.treasury.gov/press-releases) - [Archive of Changes to OFAC's Sanctions Lists | Office of Foreign Assets Control](https://ofac.treasury.gov/specially-designated-nationals-list-sdn-list/archive-of-changes-to-the-sdn-list) - [Compilation of Award Recipient and Nominated Cases](https://www.fincen.gov/system/files/shared/Compilation%20of%20Award%20Recipient%20and%20Nominated%20Cases%20FINAL%20508C.pdf) - [FinCEN Renews Residential Real Estate Geographic Targeting Orders | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-renews-residential-real-estate-geographic-targeting-orders-0) - [FinCEN Advisory - FIN-2017-A003 | FinCEN.gov](https://www.fincen.gov/resources/advisories/fincen-advisory-fin-2017-a003) - [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 Fact Sheet: FinCEN Issues Notice of Proposed Rulemaking to Increase](https://www.fincen.gov/system/files/shared/RRE_NPRM_FactSheet_FINAL_02.06.24_508.pdf) - [FinCEN Launches Regulatory Process for New Real Estate Sector Reporting Requirements to Curb Illicit Finance | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-launches-regulatory-process-new-real-estate-sector-reporting-requirements) - [1 Fact Sheet: FinCEN Issues Final Rule to](https://www.fincen.gov/system/files/shared/RREFactSheet.pdf) - [FinCEN Renews Real Estate Geographic Targeting Orders | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-renews-real-estate-geographic-targeting-orders-0) - [FREQUENTLY ASKED QUESTIONS Issued: October 9, 2025](https://www.fincen.gov/system/files/2025-10/RRE-GTO-FAQs.pdf) - [FinCEN Targets Shell Companies Purchasing Luxury Properties in Seven Major Metropolitan Areas | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-targets-shell-companies-purchasing-luxury-properties-seven-major) - [United States Attorney's Office for the District of Rhode Island - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/1340242D:US) - [1340242D: United States Attorney's Office for the District of Rhode Island Stock Price Quote - - Bloomberg](https://www.bloomberg.com/quote/1340242D:US) - [Application of FinCEN’s Regulations to Virtual Currency Software Development and Certain Investment Activity | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/application-fincens-regulations-virtual) - [Guidance for a Risk-Based Approach to Virtual Currencies](https://www.fatf-gafi.org/en/publications/Fatfgeneral/Guidance-rba-virtual-currencies.html) - [Application of FinCEN’s Regulations to Persons Issuing Physical or Digital Negotiable Certificates of Ownership of Precious Metals | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/application-fincens-regulations-persons) - [www.fincen.gov Guidance FIN-2013-G001 Issued: March 18, 2013 Subject:](https://www.fincen.gov/system/files/shared/FIN-2013-G001.pdf) - [Administrative Ruling on the Application of FinCEN Regulations to Currency Transporters, Including Armored Car Services, and Exceptive Relief | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/administrative-ruling-application-fincen) - [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) - [Questions on Virtual Currency](https://ofac.treasury.gov/faqs/topic/1626) - [U.S. Convicts Woman Involved in Jamaican Lottery Scam | OCCRP](https://www.occrp.org/en/news/us-convicts-woman-involved-in-jamaican-lottery-scam) - [1 In light of a nationwide surge in check fraud schemes](https://www.fincen.gov/system/files/shared/FinCEN%20Alert%20Mail%20Theft-Related%20Check%20Fraud%20FINAL%20508.pdf) - [Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Countering the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov](https://www.fincen.gov/news/news-releases/financial-action-task-force-identifies-jurisdictions-anti-money-laundering-3) - [1st Review of the Suspicious Activity Reporting System (SARS) | FinCEN.gov](https://www.fincen.gov/1st-review-suspicious-activity-reporting-system-sars) - [FinCEN Year in Review for FY 2024](https://www.fincen.gov/system/files/2025-08/FinCEN-Infographic-Public-2025-508.pdf) - [Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering and Combating the Financing of Terrorism and Counter-Proliferation Deficiencies | FinCEN.gov](https://www.fincen.gov/news/news-releases/financial-action-task-force-identifies-jurisdictions-anti-money-laundering-and-5) - [USA PATRIOT Act | FinCEN.gov](https://www.fincen.gov/resources/statutes-and-regulations/usa-patriot-act) - [Money laundering – Summary](https://cdn.websitebuilder.service.justice.gov.uk/uploads/sites/54/2025/12/6.5612_LC_Anti-money-laundering-summary_v6.pdf) - [Enforcement Actions | FinCEN.gov](https://www.fincen.gov/news/enforcement-actions) - [Bank Rhode Island - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/403752Z:US) - [Administrative Rulings | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings) - [UNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY](https://www.fincen.gov/system/files/enforcement_action/riggsassessment3.pdf) - [Law Enforcement Overview | FinCEN.gov](https://www.fincen.gov/resources/law-enforcement) - [U.S. Convicts Woman Involved in Jamaican Lottery Scam](https://www.occrp.org/en/daily/8593-u-s-convicts-woman-involved-in-jamaican-lottery-scam) - [Mega Millions Winners Lost Riches After Using Lottery Lawyer - Bloomberg](https://www.bloomberg.com/news/features/2022-07-01/mega-millions-winners-lost-riches-after-using-lottery-lawyer) - [Lottery scams and fraud](https://www.gamblingcommission.gov.uk/public-and-players/guide/lottery-scams-and-fraud) - [June 9, 2003 VIA E-MAIL Financial Crimes Enforcement ...](https://www.fincen.gov/sites/default/files/shared/belcher.pdf) - [Case Law Database](https://www.unodc.org/cld/en/v3/sherloc/cldb/search.html) - [Fraudster Jailed for Multi-Million Pound Betting Syndicate Scam | The Crown Prosecution Service](https://www.cps.gov.uk/cps/news/fraudster-jailed-multi-million-pound-betting-syndicate-scam) - [Jamaican Economy Panel Commends Reduction in Youth Unemployment and Debates Options for its Continued Decline | United Nations in Jamaica](https://jamaica.un.org/en/248782-jamaican-economy-panel-commends-reduction-youth-unemployment-and-debates-options-its) - [Pages and content](https://gamblingcommission.gov.uk/search/?index=50&q=A) - [News](https://www.gamblingcommission.gov.uk/news-action-and-statistics/News/jail-for-woman-who-defrauded-employers-of-almost-1-million) - [Casino Industry Currency Transaction Reporting](https://www.fincen.gov/sites/default/files/shared/CasinoIndustryCTRFilings.pdf) - [Frequently Asked Questions Casino Record keeping, Reporting, and Compliance Program Requirements | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/frequently-asked-questions-casino-record-keeping-reporting) - [FinCEN Form 102 Suspicious Activity Report by Casinos and Card Clubs](https://www.fincen.gov/system/files/shared/fin102_sar-c.pdf) - [Casino SAR Guidance](https://www.fincen.gov/system/files/guidance/casinosarguidancefinal1203.pdf) - [Guidance | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance?field_tags_financial_institution_target_id=659&page=0) - [FinCEN Advisory – FIN-2009-A003 | FinCEN.gov](https://www.fincen.gov/resources/advisories/fincen-advisory-fin-2009-a003) - [Important Information for Casinos | FinCEN.gov](https://www.fincen.gov/resources/financial-institutions/casinos) - [Currency Transaction Reporting: Aggregation by Casinos at Slot Machines | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/currency-transaction-reporting-aggregation) - [Full register of gambling premises](https://www.gamblingcommission.gov.uk/public-register/premises/full/145) - [Gambling licences – City of Lincoln Council](https://www.lincoln.gov.uk/gambling/gambling-licenses) - [Casino or Card Club Risk-Based Compliance Indicators | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/casino-or-card-club-risk-based-compliance-indicators) - [NY Senator Behind Casino Push Urges Swift Awarding of Licenses - Bloomberg](https://www.bloomberg.com/news/articles/2025-10-15/ny-senator-behind-casino-push-urges-swift-awarding-of-licenses) - [Gambling Act 2005 Statement of Principles 2025 - 2028](https://www.rctcbc.gov.uk/EN/Business/LicencesandPermits/Otherlicences/RelatedDocuments/GamblingAct2005StatementofPrinciples20252028.pdf) - [States and Territories | FinCEN.gov](https://www.fincen.gov/states-and-territories) - [FinCEN -Financial Crimes Enforcement Network | FinCEN.gov](https://www.fincen.gov/fincen-financial-crimes-enforcement-network) - [Fincen](https://www.fincen.gov/sites/default/files/enforcement_action/2020-05-21/Michael%20LaFontaine-Assessment-02.26.20_508.pdf) - [1 Financial Crimes Enforcement Network U.S. Department of the Treasury](https://www.fincen.gov/system/files/shared/FinCEN%20Enforcement%20Statement_FINAL%20508.pdf) - [Penalties | FinCEN.gov](https://www.fincen.gov/penalties) - [Requirements for Certain Transactions Involving Convertible Virtual Currency or Digital Assets (reopening of comment period) | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/federal-register-notices/requirements-certain-transactions-0) - [Special Measures | FinCEN.gov](https://www.fincen.gov/resources/statutes-and-regulations/special-measures) - [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) - [Requirements for Certain Transactions Involving Convertible Virtual Currency or Digital Assets (Extension Notice) | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/federal-register-notices/requirements-certain-transactions-1) - [Proposal of Special Measure Regarding Convertible Virtual Currency Mixing, as a Class of Transactions of Primary Money Laundering Concern | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/federal-register-notices/proposal-special-measure-regarding) - [U.S. Department of the Treasury](https://home.treasury.gov/system/files/246/2026-NMLRA.pdf) - [FinCEN / RI Department of Business Regulation](https://www.fincen.gov/system/files/shared/msbstatecontactsfinal.pdf) - [FinCEN, U.S. Department of the Treasury](https://www.fincen.gov/boi) - [FinCEN, U.S. Department of the Treasury](https://www.fincen.gov/news/news-releases/financial-action-task-force-identifies-jurisdictions-anti-money-laundering-5) - [FinCEN, U.S. Department of the Treasury](https://www.fincen.gov/news/news-releases/fincen-renews-residential-real-estate-geographic-targeting-orders-0) - [U.S. Securities and Exchange Commission (EDGAR filing by Bally's Corporation)](https://www.sec.gov/Archives/edgar/data/0001747079/000174707925000039/ex991-2024descriptionofgov.htm) - [Organized Crime and Corruption Reporting Project (OCCRP)](https://www.occrp.org/en/news/us-convicts-woman-involved-in-jamaican-lottery-scam) - [Chainalysis](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) Coverage gaps fim-int-2026-07-05-G001: No RI-specific, dated FinCEN civil-… fim-int-2026-07-05-G001: No RI-specific, dated FinCEN civil-penalty or RI DBR enforcement action against a named RI-licensed MSB, bank, or casino could be independently verified this cycle. [resolved] fim-int-2026-07-05-G002: Rhode Island does not publish indep… fim-int-2026-07-05-G002: Rhode Island does not publish independently verifiable state-level AML enforcement outcome data distinct from federal DOJ/FinCEN channels. [resolved] fim-int-2026-07-05-G003: FinCEN's appeal status and outcome … fim-int-2026-07-05-G003: FinCEN's appeal status and outcome regarding the Eastern District of Texas RRE Rule vacatur (order dated 2026-03-19) is not established this cycle. [resolved] fim-int-2026-07-05-G004: GENIUS Act implementing regulations… fim-int-2026-07-05-G004: GENIUS Act implementing regulations' final text and RI money-transmitter-specific application have not yet been published, limiting precise compliance-burden assessment. [resolved] fim-int-2026-07-05-G005: FinCEN's final Corporate Transparen… fim-int-2026-07-05-G005: FinCEN's final Corporate Transparency Act rule, following the interim rule's comment period closing 2025-05-27, has not yet been confirmed, leaving the domestic BO-reporting exemption's permanence unresolved. [resolved] fim-int-2026-07-14-G001: No conflict-finance/extractive-indu… fim-int-2026-07-14-G001: No conflict-finance/extractive-industry finding surfaced this cycle (Sahel, DRC, oil-revenue corruption). [resolved] fim-int-2026-07-14-G002: No Laos-specific substantive findin… fim-int-2026-07-14-G002: No Laos-specific substantive finding beyond generic FATF grey-list context this cycle. [resolved] fim-int-2026-07-14-G003: No Colombia-specific substantive fi… fim-int-2026-07-14-G003: No Colombia-specific substantive finding beyond generic narco-finance context this cycle. [resolved] fim-int-2026-07-14-G004: No concrete EU/UK delisting-asymmet… fim-int-2026-07-14-G004: No concrete EU/UK delisting-asymmetry example surfaced this cycle to evidence sanctions-regime divergence beyond the aligned FirstVPN action. [resolved] fim-int-2026-07-14-G005: Per-Member-State 6AMLD transpositio… fim-int-2026-07-14-G005: Per-Member-State 6AMLD transposition status not established this cycle. [resolved] fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): RI DBR Division of Banking's own bulletins/guidance were not directly reachable this cycle; reliance on third-party statute mirrors and law-firm commentary instead of primary regulator text. [open] fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): Final legislative disposition of S 3075 at end of the 2026 RI General Assembly session was not confirmed this cycle. [open] fim-int-2026-10-25-G003: Tier D jurisdiction watch (KH, LA, … fim-int-2026-10-25-G003: Tier D jurisdiction watch (KH, LA, MX, CO) was not independently re-run this cycle given shared pooled search budget allocated to US-RI. [open] fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): No RI-specific D1 (Sanctions), D2 (Beneficial Ownership), D3 (Enabler Jurisdictions), or D4 (Conflict Finance) variance against the federal baseline was located within this cycle's search budget. [open] fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): RI MTL $2,000 SAR threshold claim rests on a single Tier-4 commercial-advisory source and could not be corroborated against a DBR bulletin or statute this cycle. [open] FIM-GAP-001 (D2): Rhode Island has never been included among… FIM-GAP-001 (D2): Rhode Island has never been included among the metropolitan areas covered by FinCEN's Residential Real Estate Geographic Targeting Orders, leaving all-cash shell-company residential property purchases in RI structurally outside federal beneficial-ownership disclosure until the nationwide RRE Rule took effect March 1, 2026. FIM-GAP-002 (D2): FinCEN's March 2025 interim final rule exe… FIM-GAP-002 (D2): FinCEN's March 2025 interim final rule exempting all domestic reporting companies from CTA BOI reporting reversed beneficial-ownership transparency gains for RI-formed LLCs and corporations, restoring pre-2024 anonymity for domestic shell structures. FIM-GAP-003 (D3): Rhode Island lacks a dedicated state-level… FIM-GAP-003 (D3): Rhode Island lacks a dedicated state-level financial-crimes/AML enforcement unit distinct from federal DOJ/FinCEN channels; RI DBR Division of Banking licenses money transmitters but does not separately publish RI-specific AML enforcement outcome data. FIM-GAP-004 (D3): No RI-specific, dated (within the 18-month… FIM-GAP-004 (D3): No RI-specific, dated (within the 18-month window) FinCEN civil-penalty or RI DBR enforcement action against a named RI-licensed MSB, bank, or casino could be independently verified via available research; national-level FinCEN/OFAC actions with binding effect on RI-regulated entities were used as the best available proxy. ## Evidence #### Confidence-tiered claims H 5121 (signed 23 Jun 2025) requires virtual-currency kiosk operators to be licensed as money transmitters and imposes blockchain-analytics, disclosure and daily transaction-limit duties. [[Source 1]](#sec-sources) Probable · 1 source Pending amendment to RIGL Chapter 19-14 definitions; introduced 13 Mar 2026; referred to Senate Commerce; final disposition not confirmed this cycle. [[Source 1]](#sec-sources) Uncertain · 1 source DBR-licensed nonbank financial institutions [[Source 1]](#sec-sources) Probable · 1 source $2,000 (unverified, below federal $5,000 MSB threshold) [[Source 1]](#sec-sources) Uncertain · 1 source virtual-currency business activity and virtual-currency kiosk operation [[Source 1]](#sec-sources) Probable · 1 source