--- title: "United States — South Dakota (US-SD) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/united-states-south-dakota/ source_html: /jurisdictions/united-states-south-dakota/index.html description: "Financial integrity intelligence for United States – South Dakota (US-SD): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T17:53:23Z content_sha256: 507cd466ac363dfa171dece717662a39248aa11d23f7c293c2271bd18ce3a19c generator: "fe-fleet/md-twin@1.0" --- # United States — South Dakota (US-SD) — 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 — South Dakota US-SD Domains covered 8 of 8 Sources 127 Role actions 8 Horizon <90d 0 Jurisdiction profile FATF status: Largely Compliant Tier: A Risk direction: Increasing Enablement vs enforcement: Enabler South Dakota trust law (perpetual/dynasty trusts, directed-trust and trust-protector statutes) creates near-absolute secrecy for trust settlors/beneficiaries. More AML obligations attach federally via BSA/FinCEN to state-chartered trust companies; the SD Division of Banking licenses and biennially audits trust companies but there is no state or federal public beneficial-ownership registry covering trusts, and the March 2025 CTA rollback exempted virtually all US-formed entities from federal BOI reporting. Key deficiencies - No state or federal beneficial-ownership registry for South Dakota trusts or the LLCs that often sit beneath them - March 2025 FinCEN interim final rule exempted all US-formed ('domestic') entities and their beneficial owners from Corporate Transparency Act reporting, removing the only nascent federal transparency mechanism that could have reached SD trust-linked entities - Trust and company service providers (TCSPs)/registered agents are not subject to BSA-style customer due diligence obligations equivalent to banks; the federal ENABLERS Act that would have imposed such duties has repeatedly failed to pass Congress - State trust-secrecy statutes (creditor/court-access barriers upheld by the SD Supreme Court) impede law enforcement and civil discovery into trust beneficial ownership Recent developments (18m) - FinCEN's March 26, 2025 interim final rule exempted domestic reporting companies (including SD-formed trusts/LLCs) and US persons from BOI reporting under the CTA - IRS-Criminal Investigation publicly confirmed (per SDPB/ICIJ reporting) a dedicated team investigating sanctioned Russian oligarchs' and other foreign nationals' assets held in South Dakota trust structures - OCC granted conditional national trust bank charters (Dec 12, 2025) to five digital-asset firms, including BitGo's conversion of its South Dakota-chartered trust company into a federally chartered national trust bank, moving crypto custody out of state-level supervision - FATF's 7th Enhanced Follow-up Report on the United States continued to flag serious gaps impeding timely access to beneficial ownership information United States federal law that applies in United States – South Dakota is covered once, on the [United States](/jurisdictions/us/) page. This page covers United States – South Dakota’s own layer: its own law, regulators and enforcement. Brief ## Lead signal #### Lead Signal South Dakota has closed a kiosk-specific supervisory gap for virtual-currency transmission while leaving its trust-secrecy architecture untouched, producing a mixed structural picture this period. Senate Bill 98, effective July 1, 2026, requires virtual-currency kiosk operators to hold a money-transmitter license under SDCL chapter 51A-17, and adds kiosk-specific annual and quarterly reporting covering transaction amounts and values, complaints, refunds, kiosk locations within the state, and Bank Secrecy Act reporting data. The bill responds to a cited exposure figure of roughly $246 million per year in virtual-currency fraud losses for South Dakota residents, across an estimated 170 kiosks statewide. A $1,000 daily and $10,000 thirty-day per-user transaction cap, together with a seventy-two-hour fraud-refund duty and enhanced receipt disclosures, accompanies the licensing requirement. This narrows a supervisory gap that was specific to kiosk operators; the state's general money-transmission framework had already covered non-kiosk virtual-currency transmission since at least a 2019 Division of Banking guidance position. Read full brief #### Lead Signal South Dakota has closed a kiosk-specific supervisory gap for virtual-currency transmission while leaving its trust-secrecy architecture untouched, producing a mixed structural picture this period. Senate Bill 98, effective July 1, 2026, requires virtual-currency kiosk operators to hold a money-transmitter license under SDCL chapter 51A-17, and adds kiosk-specific annual and quarterly reporting covering transaction amounts and values, complaints, refunds, kiosk locations within the state, and Bank Secrecy Act reporting data. The bill responds to a cited exposure figure of roughly $246 million per year in virtual-currency fraud losses for South Dakota residents, across an estimated 170 kiosks statewide. A $1,000 daily and $10,000 thirty-day per-user transaction cap, together with a seventy-two-hour fraud-refund duty and enhanced receipt disclosures, accompanies the licensing requirement. This narrows a supervisory gap that was specific to kiosk operators; the state's general money-transmission framework had already covered non-kiosk virtual-currency transmission since at least a 2019 Division of Banking guidance position. #### Other Developments Trust-law update leaves confidentiality intact. South Dakota's near-annual pattern of task-force-drafted trust-law refinement continued with Senate Bill 100, effective July 1, 2026, which revises trustor tax-reimbursement powers, decanting and termination cross-references, and attorney-client privilege resting with the fiduciary. The bill adds no beneficial-ownership disclosure requirement; the state's existing trust confidentiality provision, SDCL 51A-6A-2, and automatically-sealed trust court records remain unchanged. This continues a structurally similar pattern to a prior episode in 2023 involving digital-signature provisions for trusts, where the same observation applied: incremental modernization of trust administration without a transparency reform. Historical multistate enforcement context. A twenty-five-state multistate settlement dated June 26, 2024, in which South Dakota participated, required Plutus Financial, Inc. and Abra Trading, LLC to cease virtual-asset services to US customers and return remaining customer assets, for operating a cryptocurrency business without the required state money-transmitter licensing. This is background context for South Dakota's standing posture on unlicensed virtual-asset activity rather than a new development this period. #### Cross-Monitor Connections The SB 98 kiosk-licensing and BSA-linked reporting extension bears directly on payments-focused monitoring of nonbank money-transmission conduct, since the new reporting and consumer-facing duties attach to the same money-transmitter license that payments regulation already tracks for this jurisdiction. The unchanged trust-confidentiality architecture under SDCL 51A-6A-2 is a standing structural feature relevant to beneficial-ownership and corporate-transparency analysis generally, though South Dakota sits outside any EU beneficial-ownership architecture; its relevance there is as a domestic enabler-jurisdiction profile rather than as a point of EU-regime interaction. #### Outlook The open question for next observation is whether South Dakota's legislature revisits beneficial-ownership disclosure for private trust companies in a future session, given the now-multi-year pattern of trust-law refinement bills that consistently omit such a requirement. On the crypto side, whether the kiosk-specific SB 98 reporting regime generates enforcement activity, and whether it measurably reduces the cited $246 million annual fraud-exposure figure, are the clearest items to track going forward. Earlier periodic briefs (4) 11 Oct 2026 · fim-2026-10-11 #### Lead Signal South Dakota entered into force a new virtual-currency kiosk statute, SB 98, on 1 July 2026, requiring kiosk operators to be licensed as money transmitters under SDCL Chapter 51A-17. The statute layers daily and thirty-day per-user transaction caps of 1,000 USD and 10,000 USD respectively onto the states standing money-transmission framework, and the regulators own memorandum confirms the requirement is now in force. The same window produced two trust-charter developments bearing on the states digital-asset custody infrastructure: the Office of the Comptroller of the Currency granted preliminary conditional approval for BitGo Trust Company, currently operating as a South Dakota state trust company, to convert into a national bank and trust association offering digital-asset and fiat fiduciary custody, staking, and stablecoin-issuance services, and North Capital Trust Company announced receipt of a South Dakota Public Trust Company charter to expand digital-asset-securities custody. Taken together, these developments mark a confirmed, structural tightening of the states digital-asset financial-innovation perimeter even as its underlying enabler-jurisdiction posture remains otherwise unchanged. The kiosk statute and the trust-charter activity sit side by side with a persistent structural finding: an ICIJ five-year Pandora Papers retrospective reports that South Dakota remains a top US trust-secrecy destination, with trust companies overseeing more than 360 billion dollars in assets, and that the Corporate Transparency Act has largely left such trusts untouched because Treasury will not enforce the beneficial-ownership rule. That finding is sourced to Tier-2 investigative journalism rather than a primary federal instrument, and is read here as probable rather than confirmed. #### Other Developments Trust-industry scale. South Dakotas trust-company sector continues to be characterised, per the same ICIJ reporting, as overseeing in excess of 360 billion dollars in assets under management, reinforcing the states standing position as a disclosure-light wealth-management hub operating alongside the new digital-asset chartering activity. Beneficial-ownership enforcement posture. The ICIJ retrospective states that the Treasury Department will not enforce the Corporate Transparency Acts beneficial-ownership rule, a non-enforcement posture that, if sustained, leaves South Dakotas trust structures outside the transparency regime the Act was designed to reach. No Tier-1 Treasury or FinCEN primary instrument was located this cycle confirming the current status of that posture, so it is treated as probable. Standing AML-adjacent regime. South Dakotas trust-company chartering regime (SDCL Chapter 51A-6A) and money-transmitter licensing regime (SDCL Chapter 51A-17) remain the operative AML-adjacent architecture against which the new kiosk statute and trust-charter events sit. A companion trust-law maintenance package, SB 100, also took effect on 1 July 2026, though its eight sections have not been individually itemised for beneficial-ownership or AML relevance this cycle. #### Cross-Monitor Connections The BitGo and North Capital trust-charter events, together with the SB 98 kiosk statute, bear directly on the crypto and digital-asset financial-innovation architecture monitored elsewhere in this cycle: a state trust charter converting toward a nationally chartered bank-and-trust structure, paired with new kiosk-level money-transmission licensure, extends the regulatory perimeter around custody, staking and stablecoin-issuance activity based in South Dakota. The enabler-jurisdiction finding on trust-secrecy scale and stalled federal beneficial-ownership enforcement is relevant to any assessment of South Dakotas standing as a destination for opaque wealth structures operating alongside, rather than displaced by, its newly tightened digital-asset licensing regime. #### Outlook The near-term picture is one of structural divergence: South Dakotas digital-asset custody and kiosk-licensing architecture is tightening in a confirmed and primary-sourced way, while its enabler-jurisdiction trust-secrecy profile, read from Tier-2 reporting, appears structurally stable and possibly reinforced by stalled federal beneficial-ownership enforcement. Final licensing and registration status for BitGo Bank & Trust and North Capital Trust Company with the South Dakota Division of Banking, following the OCC approval, had not been confirmed as at this cycle, and the full beneficial-ownership relevance of the SB 100 trust-law maintenance package remains unitemised. Both gaps bear watching as the custody and chartering activity matures. 28 Sep 2026 · fim-2026-09-28 #### Lead Signal South Dakota's financial-integrity posture moved on two distinct tracks this cycle. The state legislature enacted a pair of crypto-specific statutes, SB43 and SB98, both signed in March 2026, with SB98 entering force on 1 July 2026. SB43 adds digital currency to South Dakota's search-and-seizure and forfeiture property definitions, giving law enforcement explicit statutory footing to seize crypto tied to criminal proceeds. SB98 creates a new Title 51A licensing chapter for virtual-currency kiosk operators, layering fee-disclosure, daily transaction limits, fraud warnings and mandatory fraud refunds onto the states general money-transmitter framework. Testimony associated with the bill disclosed roughly ten licensed kiosk operators running approximately 172 machines statewide, which filed 158 currency transaction reports and seven suspected fraud or money-laundering reports over a two-year span. Separately, the Office of the Comptroller of the Currency terminated its July 2024 amendment to the October 2020 consent order against Citibank, N.A., whose national charter is domiciled in Sioux Falls, South Dakota. The underlying 2020 order, covering enterprise risk management, compliance risk management, data governance and internal controls, remains in force; only the 2024 amendment, which had added a seventy-five million dollar civil money penalty for insufficient remediation progress, was terminated. The two tracks are analytically distinct but jointly diagnostic of South Dakotas dual character as both an enabler jurisdiction, through its bank-charter-friendly corporate law, and a state now actively tightening its own crypto-specific statutory perimeter. #### Other Developments Kiosk licensing volume data surfaces enforcement baseline. The legislative record behind SB98 disclosed operational figures rarely visible outside supervisory channels: approximately ten licensed virtual-currency kiosk operators running roughly 172 machines statewide, with 158 currency transaction reports and seven suspected fraud or money-laundering reports filed over a two-year period. This gives the state, and outside observers, a rare quantified baseline against which the new licensing chapters fraud-refund and disclosure requirements can be measured going forward. Consent-order termination is partial, not full, remediation closure. The OCC's December 2025 order terminated only the 2024 amendment to Citibank's 2020 BSA/AML and risk-governance consent order; the base 2020 order remains separately in force. The termination reflects progress against the narrower 2024 supplemental findings rather than a clean exit from supervisory scrutiny. #### Cross-Monitor Connections The SB43 and SB98 enactments sit squarely on the crypto-asset and digital-innovation axis, and the underlying statutory text and licensing mechanics are the primary subject of parallel analysis in the crypto-focused monitor for this jurisdiction; this brief treats them here strictly through the AML/enabler-jurisdiction lens rather than duplicating that analysis. The Citibank consent-order development touches the payments-infrastructure axis insofar as Citibank operates as a major correspondent-banking and payments participant, though the OCC order itself concerns enterprise-wide governance deficiencies rather than payments-specific conduct. #### Outlook The kiosk-licensing regime under SB98, in force since 1 July 2026, will generate an operational track record over the coming reporting cycles that should clarify whether the fraud-refund and disclosure mechanics measurably reduce the suspected fraud and money-laundering reports the industry itself has been filing. Whether the SB43 forfeiture provision sees active law-enforcement use, and when its effective date is confirmed in the public record, remains an open item for a future cycle. The Citibank consent-order matter bears watching for whether the underlying 2020 order itself progresses toward termination in a later cycle, which would be the more structurally significant milestone than the amendment closure recorded here. 22 Sep 2026 · fim-2026-08-05 #### Lead Signal South Dakota tightened its digital-asset financial-crime perimeter this cycle through two companion statutes signed on the same day, March 11, 2026, in a pairing that reads as structural rather than incidental. Senate Bill 98 classifies virtual-currency kiosk transactions as money transmission requiring licensure, with the statute entering force on July 1, 2026. The measure layers a $1,000 daily transaction cap, mandatory fraud warnings posted at the point of transaction, a 72-hour fraud-refund obligation for verified victims, and quarterly reporting -- including suspicious-activity-report data -- onto kiosk operators who were previously subject only to the state's general money-transmission licensing regime. Companion Senate Bill 43, signed the same day, amends South Dakota's asset-forfeiture statute to classify digital currency as a seizable criminal asset, closing what the state Attorney General's office itself described as an arguable gap under the prior tangible-asset forfeiture standard -- a gap that, left unaddressed, would have meant digital proceeds of crime routed through the state's kiosk network sat outside the reach of the forfeiture regime that already applies to cash and physical property. Both measures are assessed at High confidence. SB 98's terms are drawn from a Tier 1 South Dakota Division of Banking memorandum; SB 43's are drawn directly from the state Attorney General's own press release, also a Tier 1 source. Read together rather than separately, the two statutes close the loop between detection and consequence: SB 98 builds the reporting and fraud-control infrastructure at the point of transaction, while SB 43 ensures that criminal proceeds identified through that infrastructure -- or through any other investigative channel -- can actually be seized once identified as digital rather than tangible assets. This is the kind of paired, architecture-level move this monitor weights more heavily than a single enforcement action would warrant, because it changes the standing rules of the system rather than resolving one case within it. The existing base to which SB 98's overlay now applies is not small: South Dakota already licensed ten kiosk operators across 172 machines statewide as of March 2026, an assessed-confidence figure that frames the practical reach of the new licensing and reporting requirements from day one of implementation. #### Other Developments A trust-law amendment of unconfirmed substance. The South Dakota Division of Banking issued a June 1, 2026 guidance memorandum titled "Trust Law Legislation," confirming -- at Tier 1 source quality -- that a legislative change to the state's trust code occurred during this session. What the memo does not yet establish is the direction or substance of that change: whether it expands, narrows, or leaves intact South Dakota's beneficial-ownership disclosure posture and its non-discretionary permanent seal on trust records for the dynasty-trust structures the state is known for. This is logged as a coverage gap rather than resolved by inference, and the finding is accordingly held at Low confidence and watch status. Given the weight this monitor places on beneficial-ownership and corporate-transparency architecture as a durable rather than episodic signal, confirming the substance of this amendment is a priority item rather than a routine follow-up. #### Cross-Monitor Connections South Dakota's crypto-kiosk licensing overlay sits directly at the intersection of this monitor's AML/CFT reading and the payments-regulation reading applied elsewhere in the fleet: the same SB 98 text that this monitor reads as a suspicious-activity-reporting and fraud-forfeiture instrument is, from a payments-licensing perspective, an extension of the state's money-transmission-licence perimeter to a previously under-specified kiosk channel. The architecture-over-incident principle this monitor applies throughout is directly on display here: a state adding a kiosk-specific money-transmission and SAR-reporting layer on top of an existing base of ten licensed operators and 172 machines is a more durable signal of the evolving digital-asset risk environment than any single kiosk-fraud incident would be on its own, however newsworthy that incident might be. The unconfirmed trust-law amendment likewise warrants a structural rather than incident-level read once its substance clarifies: South Dakota's trust regime is a standing beneficial-ownership-adjacent architecture used well beyond the state's own borders by settlors seeking privacy and asset protection, and a legislative change to it -- in either direction -- would itself be a structural development worth tracking across monitors that touch corporate and trust transparency, not merely a local statutory footnote. The AML and anti-fraud dimensions surfaced here are this monitor's own lens; illicit-finance use of either statute's covered instruments is a matter for this monitor's typology tracking, not a conclusion any other fleet monitor draws independently. #### Outlook The clearest near-term resolution point is confirmation of what the June 2026 Trust Law Legislation memo actually changed; until the substantive text is retrieved, South Dakota's beneficial-ownership and corporate-transparency trajectory for trust structures remains a watch-status open question rather than a scored finding, and this monitor will prioritise closing that gap ahead of drawing a directional judgment. On the digital-asset side, the operative question moving forward is one of implementation rather than further legislation: SB 98's quarterly reporting and 72-hour fraud-refund obligations took effect July 1, 2026, and the compliance behavior of the state's existing ten-operator, 172-machine kiosk base under the new licensing overlay is the natural marker of whether the statute achieves its stated fraud-prevention and AML-reporting aims in practice, or whether gaps emerge at the point of enforcement that a purely statutory reading could not anticipate. 14 Jul 2026 · fim-2026-07-14 #### Lead Signal South Dakota presents this cycle as a structural case study in how sub-national trust law, federal beneficial-ownership retrenchment, and a widening federal transparency gap can compound into a durable enabler-jurisdiction architecture. The state maintains no registry, state or federal, covering the beneficial ownership of its trusts, and the South Dakota Supreme Court has repeatedly upheld trust secrecy against creditor and court-access claims, a foundational structural condition rather than an episodic gap. Compounding this, FinCEN issued an interim final rule, effective 2025-03-21 with Federal Register publication on 2025-03-26, exempting all United States-formed entities and United States persons from Corporate Transparency Act beneficial-ownership reporting. Transparency advocates assess that this exemption removes reporting obligations for an estimated 99.98 percent of previously mandated entities, a scale of rollback that converts what was already a sub-national secrecy architecture into a near-total federal one as it applies to domestically formed entities, including South Dakota trust-linked structures. The architecture-over-incident read is that no single enforcement action defines this cycle; the significant finding is the widening gap between designation authority and asset-tracing capability. IRS Criminal Investigation confirmed, via a September 2023 interview reported in June 2024, a dedicated team tracing sanctioned Russian oligarch assets held in South Dakota trust structures, but no public update has surfaced in the twelve to thirty-three months since, and this evidence is carried forward with an explicit staleness caveat rather than treated as a fresh development. Trust secrecy compounded by the CTA domestic exemption creates a de facto enforcement gap between OFAC designation power and the practical ability to trace assets held in trust vehicles, a structural condition that outlasts any individual case. #### Other Developments A parallel but narrower transparency channel persists. FinCEN's October 2025 FAQ update reaffirmed nationwide Residential Real Estate Geographic Targeting Order obligations, requiring beneficial-ownership identification for legal-entity and trust purchasers in non-financed residential real-estate transactions, including South Dakota-domiciled purchasers. This obligation operates independently of the narrowed Corporate Transparency Act regime and stands as one of the few remaining active beneficial-ownership identification requirements touching South Dakota-linked entities. The professional-enabler due-diligence gap remains unaddressed. South Dakota trust and company service providers, the actual point of contact for foreign wealth entering trust structures, continue to operate outside Bank Secrecy Act-equivalent customer due-diligence and suspicious-activity reporting obligations. The ENABLERS Act, which would impose such duties on trust and company service providers and registered agents, has repeatedly failed to pass the United States Senate since 2021, a persistent legislative gap that FATF's 2024 Horizontal Review of Gatekeepers Technical Compliance identifies as a core deficiency under Recommendations 22 and 23. A completed regulatory-perimeter shift reframes South Dakota's role in digital-asset custody. BitGo has completed its conversion from a South Dakota state trust charter to a federally chartered OCC national trust bank, with full and unconditional approval granted on 2025-12-12; BitGo now operates as BitGo Bank and Trust, National Association, under unified federal oversight, exiting state-level supervision entirely. This corrects an earlier framing of the conversion as evolving or conditional; the shift is complete and strengthens rather than diminishes the regulatory-arbitrage significance of the underlying pattern, which extends to Circle, Ripple, Fidelity Digital Assets, and Paxos in December 2025, and Stripe Bridge in February 2026, consolidating crypto custody oversight under a single federal regulator. State supervisors and industry bodies have publicly opposed this consolidation. The Conference of State Bank Supervisors and the Bank Policy Institute argue that the shift from multi-state, layered anti-money-laundering supervision to a single federal regulator reduces consolidated oversight capacity for a fast-growing, technology-intensive custody sector, a live supervisory-perimeter debate rather than a settled matter. The United States faces a heightened risk of adverse FATF re-rating. FATF rates the United States largely compliant nationally, but the 7th Enhanced Follow-up Report continues to flag serious beneficial-ownership access gaps, and the scale of the CTA domestic exemption is assessed by transparency advocates as materially worsening the starting position for the next Enhanced Follow-up Report on Recommendations 24 and 25. #### Cross-Monitor Connections The sanctioned-asset dimension of this cycle is directly relevant to WDM's state-capture and kleptocratic-asset tracking: sanctioned Russian oligarchs parking assets in South Dakota trusts, with confirmed but stale investigative interest from IRS Criminal Investigation, illustrates how enabler-jurisdiction architecture can shelter assets independent of any state-direction dimension. Separately, the widening divergence between the United States domestic beneficial-ownership rollback and the European Union's AMLR and 6AMLD registry requirements is relevant to ESA's third-country equivalence assessments; South Dakota functions as a recurring negative comparator in European discussions of United States AML equivalence even though it falls entirely outside the EU AML Package perimeter as a non-EU, sub-national jurisdiction. #### Outlook The near-term watch list centers on whether FinCEN finalizes the March 2025 interim rule, a step that would cement the current domestic exemption absent litigation or reversal, and on whether the FATF Enhanced Follow-up Report process produces a formal re-rating on Recommendations 24 and 25. On the crypto-custody front, further OCC approvals extending the BitGo pattern, or banking-industry litigation challenging it, would signal whether the state-to-federal arbitrage becomes an entrenched norm or faces institutional pushback. Any new OFAC designation naming a South Dakota trust structure directly, or a DOJ or IRS-CI filing arising from the confirmed but stale investigation, would substantially firm up what is currently an assessed rather than confirmed sanctions-evasion nexus. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion South Dakota's relevance to sanctions architecture is not as a transit or correspondent-banking node but as an asset-parking back office for Russia-linked wealth once it has already entered the United States financial system. IRS Criminal Investigation confirmed, in a September 2023 interview publicly reported in June 2024, a dedicated investigative team tracing sanctioned Russian oligarch and other foreign national assets held in South Dakota trust structures. No public update on this investigation has been located as of the current baseline, meaning the underlying evidence is between twelve and thirty-three months stale; confidence in an actively ongoing investigation is accordingly assessed rather than high, and the finding is carried forward with an explicit staleness caveat rather than treated as a fresh development. Continue reading The structural significance of this finding exceeds any single case outcome. South Dakota's trust secrecy architecture, compounded by the March 2025 federal exemption of domestic entities from Corporate Transparency Act beneficial-ownership reporting, widens the gap between OFAC's designation authority and investigators' practical ability to trace sanctioned assets once they are held in trust vehicles. This is the architecture-over-incident principle in direct application: the enabling structural gap between naming a sanctioned individual and tracing their assets is analytically more significant than whether any particular IRS-CI matter proceeds to a filing. South Dakota inherits federal OFAC sanctions authority in full, with no independent state sanctions regime, so the exposure runs entirely through federal enforcement capacity meeting state-level trust secrecy. The practical mechanism illustrating this gap involves foreign nationals or their intermediaries routing funds, or shares of foreign operating companies, into South Dakota trusts via intermediary shell structures, a pattern consistent with the trust secrecy architecture already documented for this jurisdiction. Because trust beneficial ownership is not captured in any state or federal registry, and court records concerning trust administration are frequently sealed, the practical investigative pathway for tracing sanctioned assets held this way narrows to subpoena-based discovery rather than routine registry or reporting-based visibility. Whether the confirmed IRS-CI interest ultimately produces a public enforcement action, or whether it remains investigatively dormant, is the single most consequential open question for this domain, since either outcome will materially inform whether the enforcement gap identified here is being actively closed or is instead becoming an entrenched structural feature. #### Outlook The watch items for this domain are narrow and specific: any new OFAC designation naming a South Dakota trust structure directly would substantially firm confidence in an active enforcement trajectory, while continued silence past the current staleness window would strengthen the case that the enforcement gap, rather than any active case, is the durable feature. A DOJ or IRS-CI public case filing arising from the confirmed investigation is the most direct signal to watch for; absent that, the analytically correct posture is to treat the gap between designation power and asset-tracing capability as the standing condition rather than an anomaly awaiting resolution. Judgment: No US-SD-specific sanctions material surfaced this cycle. Uncertain #### Beneficial Ownership and Corporate Transparency South Dakota's beneficial-ownership transparency posture regressed materially this cycle, compounding an already opaque baseline. The state maintains no registry, state or federal, covering the beneficial ownership of trusts, and its Supreme Court has repeatedly upheld trust secrecy against creditor and court-access claims, a durable structural condition rather than a temporary gap. Against this backdrop, FinCEN's interim final rule, effective 2025-03-21 with Federal Register publication on 2025-03-26, exempted all United States-formed entities and United States persons from Corporate Transparency Act beneficial-ownership reporting. Transparency advocates assess this exemption removes reporting obligations for an estimated 99.98 percent of previously mandated entities, effectively eliminating the only nascent federal transparency mechanism that had any bearing on South Dakota trust-linked LLCs. Continue reading Globally, the EU AML Package sets the structural direction against which beneficial-ownership regimes elsewhere are increasingly benchmarked. That package comprises three distinct instruments: the AML Regulation, or AMLR (Regulation (EU) 2024/1624), which is directly applicable across member states without national transposition; the sixth AML Directive, or 6AMLD, which each member state transposes individually into domestic law; and the AMLA Regulation (Regulation (EU) 2024/1620), which establishes the Anti-Money Laundering Authority and shifts supervision of high-risk cross-border obliged entities from purely national authorities toward a hybrid EU-level direct and indirect supervisory perimeter. South Dakota sits entirely outside this perimeter as a non-EU, sub-national jurisdiction, and 6AMLD transposition tracking is not applicable to it. Its relevance to the European framework is not as a subject of it but as a recurring negative benchmark cited in European third-country equivalence discussions: a jurisdiction whose trust secrecy architecture is unmatched by, and diverges structurally from, the EU's centralized beneficial-ownership register requirements. One parallel transparency channel persists independent of the narrowed CTA regime. FinCEN's October 2025 FAQ update reaffirmed nationwide Residential Real Estate Geographic Targeting Order obligations, requiring title companies to identify beneficial ownership for legal-entity and trust purchasers in non-financed residential real-estate transactions, including South Dakota-domiciled purchasers. This is one of the few remaining active beneficial-ownership identification requirements touching South Dakota-linked entities, though it applies only to a narrow transaction type rather than functioning as a general-purpose registry. The United States faces material risk of a negative FATF re-rating on Recommendations 24 and 25 as a consequence of the domestic CTA rollback. FATF rates the United States largely compliant nationally, but the 7th Enhanced Follow-up Report continues to flag serious beneficial-ownership access gaps, and the scale of the March 2025 exemption is assessed by transparency advocates as materially worsening the country's position ahead of its next FATF review. #### Outlook The principal near-term event to watch is whether FinCEN finalizes the March 2025 interim rule, which would cement the current exemption absent successful litigation or a reversing rulemaking; no South Dakota legislative reform proposal addressing trust beneficial ownership is currently pending. On the multilateral track, the timing and outcome of FATF's next Enhanced Follow-up Report on the United States, addressing Recommendations 24 and 25, is the clearest test of whether the backsliding-risk assessment carried in this cycle converts into a formal re-rating. Judgment: SB 100 (2026) continues SD's near-annual trust-law refinement without adding beneficial-ownership disclosure; SDCL 51A-6A-2 confidentiality and sealed trust-court records persist unchanged. Probable #### Enabler Jurisdictions and Professional Facilitators South Dakota's status as an enabler jurisdiction rests on a durable combination of trust-law design and an unaddressed professional-gatekeeper due-diligence gap. Trust officers and registered agents, who are the actual point of contact for foreign wealth entering South Dakota trust structures, remain outside Bank Secrecy Act-equivalent customer due-diligence and suspicious-activity reporting obligations. The legislative remedy for this gap, the ENABLERS Act, which would impose customer due-diligence duties on trust and company service providers and registered agents, has been introduced repeatedly since 2021 and has failed to pass the United States Senate on each occasion. FATF's 2024 Horizontal Review of Gatekeepers Technical Compliance identifies precisely this class of due-diligence gap as a core deficiency under Recommendations 22 and 23, situating South Dakota's condition within a recognized, named category of international standard-setting concern rather than treating it as a novel or idiosyncratic finding. Continue reading The compounding effect with the domain's beneficial-ownership picture is direct: the same trust secrecy architecture and directed-trust bifurcation of fiduciary powers that obscure beneficial ownership from registries also mean that the professionals administering these structures face no independent federal due-diligence obligation to look behind the structure themselves. This is a structural rather than episodic enabler condition; it does not depend on any individual trust company's conduct, but on the absence of a legal duty applying to the entire class of service providers operating in this space. The scheme most directly illustrating this gap involves the use of directed-trust bifurcation, separating investment, distribution, and administrative powers among multiple fiduciaries, as a mechanism for obscuring beneficial ownership at the point of onboarding, precisely where a customer due-diligence obligation, had one existed, would have had the greatest practical effect. This domain intersects directly with the sanctions and beneficial-ownership pictures already described: the enabler gap identified here is the mechanism by which the trust secrecy architecture is operationally exploitable, and the ENABLERS Act's repeated Senate failures represent the clearest available near-term legislative lever that has consistently not been pulled. No competing state-level reform proposal addressing this gap is pending in South Dakota itself, reinforcing that the ENABLERS Act, or a functional equivalent, remains the primary federal avenue through which this structural condition could be altered. #### Outlook The clearest indicator to watch in this domain is any reintroduction or renewed floor vote on the ENABLERS Act; its continued Senate failure should be read as reinforcing rather than merely maintaining the enabler-jurisdiction assessment, since each failed attempt further entrenches the absence of a federal due-diligence baseline for this professional class. Absent legislative movement, the analytically sound expectation is that South Dakota's professional-enabler gap persists as a stable, structural condition rather than one poised for near-term change. Judgment: SD's standing enabler-jurisdiction profile (trust secrecy) is reaffirmed, not changed, by SB 100. Probable Judgment: No conflict-finance material specific to US-SD surfaced this cycle. Uncertain #### Crypto / Digital Assets / Financial Innovation South Dakota's most material financial-innovation development this period is the closing of a kiosk-specific gap in its virtual-currency supervisory perimeter. Senate Bill 98, effective July 1, 2026, requires virtual-currency kiosk operators to obtain a money-transmitter license under SDCL chapter 51A-17, and layers kiosk-specific annual and quarterly reporting on top of that licence, covering transaction amounts and values, complaints received, refunds issued, the locations of kiosks operating within the state, and Bank Secrecy Act reporting data. The bill was introduced against a cited exposure figure of approximately $246 million per year in virtual-currency fraud losses affecting South Dakota residents, across roughly 170 kiosks statewide, framing the kiosk channel as a disproportionate driver of consumer-facing crypto fraud relative to other virtual-currency transmission activity in the state. Continue reading The licensing requirement is accompanied by a package of consumer and transaction-level controls: a $1,000 daily transaction cap and a $10,000 thirty-day cap per user, a seventy-two-hour duty to refund a fraud victim once statutory conditions are satisfied, and enhanced receipt disclosures. These are best understood as a targeted hardening of an existing framework rather than the creation of a new one. South Dakota's general money-transmission regime already reached non-kiosk virtual-currency transmission activity, including exchange and custody operations, under a Division of Banking guidance position dating to at least 2019 that treats receipt of virtual currency for transmission as money transmission under the statute's monetary-value definition. What SB 98 adds is a kiosk-specific overlay of reporting and consumer-protection conditions that did not previously exist for that particular channel. This development sits alongside standing background context on the state's engagement with multistate crypto enforcement: South Dakota was one of twenty-five states that, in a settlement dated June 26, 2024, required Plutus Financial, Inc. and its Abra Trading, LLC brand to cease virtual-asset services to US customers and return remaining customer assets, for operating a cryptocurrency business without the required state money-transmitter licensing. That action predates this period and is not a new development, but it evidences that South Dakota's Division of Banking participates in coordinated multistate licensing enforcement against unlicensed virtual-asset businesses, a posture consistent with the kiosk-specific tightening seen in SB 98. The kiosk-specific BSA reporting-data requirement under SB 98 is the clearest point of integration between South Dakota's crypto-licensing perimeter and its broader AML/CFT reporting architecture: rather than creating a parallel or separate AML regime for crypto kiosks, the bill channels kiosk-level data into the existing BSA reporting framework that already governs money transmitters generally in the state. #### Outlook The clearest item to track going forward is whether the SB 98 reporting regime and transaction caps measurably reduce the cited $246 million annual fraud-exposure figure, and whether the Division of Banking brings any kiosk-specific enforcement action under the new licensing and reporting conditions. Given the state's participation in the 2024 multistate Abra/Plutus settlement, continued multistate coordination on unlicensed virtual-asset activity remains a plausible avenue for future enforcement, though no such action specific to the kiosk channel was evidenced this period. Judgment: SB 98 (effective 2026-07-01) brings SD virtual-currency kiosk operators under the state MTL regime with BSA-linked reporting, closing a kiosk-specific supervisory gap. Probable #### Compliance Technology and Active Defence The most direct D6 signal this cycle is institutional rather than technological: the Conference of State Bank Supervisors and the Bank Policy Institute have publicly opposed the Office of the Comptroller of the Currency's national trust bank charter approvals for digital-asset custody firms, arguing that the shift from multi-state, layered anti-money-laundering supervision to a single federal regulator reduces consolidated oversight capacity for a fast-growing, technology-intensive sector. This opposition followed the December 2025 OCC charter approvals extending to BitGo, Circle, Ripple, Fidelity Digital Assets, and Paxos, and continued as the pattern extended to Stripe Bridge in February 2026. Continue reading The underlying tension is a genuine active-defence and supervisory-technology question rather than a purely jurisdictional turf dispute: layered, multi-state supervision has historically meant that a technology-intensive custody sector faces multiple independent points of regulatory scrutiny, each potentially deploying its own compliance-technology standards, examination cadence, and enforcement posture. Consolidation under a single federal regulator, whatever its efficiency benefits, concentrates that scrutiny into one supervisory relationship, and the state supervisors' and industry bodies' argument is precisely that this concentration reduces the aggregate compliance-technology and active-defence capacity previously distributed across multiple regulators. BitGo's completed exit from South Dakota state-level trust supervision, now confirmed via full and unconditional OCC approval on 2025-12-12, is the clearest concrete instance of this consolidation to date, illustrating in practice what the opposition statements describe in the abstract. This domain's significance is best read in conjunction with the D5 crypto-custody arbitrage pattern: the compliance-technology question is not whether federal supervision is inherently weaker than state supervision, but whether a single supervisory relationship, however well resourced, can replicate the aggregate scrutiny previously distributed across South Dakota and other state banking regulators plus the OCC. No public data has yet emerged, in the material reviewed this cycle, quantifying whether examination frequency, technology standards, or enforcement posture have measurably changed for BitGo or any of the other converted entities since their federal conversion; this is accordingly a domain to watch rather than one where a definitive assessment can currently be rendered. #### Outlook The key indicator for this domain going forward is whether the public opposition from state supervisors and industry bodies produces any concrete institutional response, whether litigation, a formal OCC policy adjustment, or documented changes in examination practice for the converted entities. Absent such a response, the current cycle should be read as establishing a live but unresolved supervisory-perimeter debate rather than a closed question. Judgment: No RegTech/compliance-technology development specific to US-SD surfaced this cycle. Uncertain Judgment: SD's AML/CTF regime for money transmitters continues via SDCL ch. 51A-17 and BSA-linked federal reporting; no structural change this cycle beyond the kiosk-specific SB 98 reporting addition already captured under D5. Probable Judgment: No commercial transaction involving financial-integrity infrastructure firms in US-SD was identified this cycle. Uncertain Regulatory horizon No dated horizon items this cycle. 4 items tracked without a confirmed date. 4 pending date · baseline financial-integrity-2026-07-05 Role action cards MLRO ### South Dakota now requires BSA-linked reporting data from virtual-currency kiosk operators under a new state money-transmitter licensing overlay. An MLRO overseeing counterparty or correspondent exposure to South Dakota-licensed kiosk operators should note that kiosk-specific reporting now folds BSA data into the state's existing annual/quarterly filing cycle, effective July 1, 2026, which may affect the documentation trail available for SAR-supporting due diligence on kiosk-channel counterparties. 1 evidence refs Compliance ### A kiosk-specific money-transmitter licensing and reporting regime took effect in South Dakota on July 1, 2026. Compliance functions with exposure to South Dakota virtual-currency kiosk operators should track the new SDCL chapter 51A-17 licensing requirement, transaction caps, and reporting obligations as a condition-of-business change for any counterparty operating kiosks in the state. 1 evidence refs Legal ### South Dakota's trust-law update leaves beneficial-ownership disclosure and trust confidentiality unchanged. Legal counsel advising on South Dakota private trust company structures should note that SB 100's 2026 amendments to trustor powers and fiduciary privilege do not alter SDCL 51A-6A-2 confidentiality protections or sealed trust court records, so the jurisdiction's standing trust-secrecy profile is unaffected by this cycle's legislative activity. 1 evidence refs Board ### South Dakota is tightening virtual-currency kiosk oversight while its trust-secrecy architecture remains structurally unchanged. At a governance level, this represents a mixed regulatory-direction signal for the jurisdiction: enablement persists on the beneficial-ownership/trust-confidentiality side even as enforcement perimeter narrows on the crypto-kiosk side, relevant to any board-level jurisdictional risk assessment involving South Dakota entities. 2 evidence refs CTO ### New BSA-linked reporting data requirements apply to South Dakota virtual-currency kiosk operators from July 1, 2026. Technology teams supporting kiosk operations or integrations in South Dakota should anticipate system changes needed to capture and report transaction amounts/values, complaints, refunds, kiosk locations, and BSA data on the new annual/quarterly cadence required under SB 98. 1 evidence refs Risk ### South Dakota's kiosk-specific crypto tightening responds to a cited $246 million annual fraud-exposure estimate. Risk functions should treat the scale of the cited fraud-exposure figure as context for why the kiosk channel specifically, rather than virtual-currency transmission generally, was the subject of this period's regulatory tightening, and should calibrate exposure models to the kiosk channel accordingly. 1 evidence refs Operations ### Kiosk operators now face transaction caps, a 72-hour refund duty, and enhanced receipt disclosures in South Dakota. Operations teams processing or monitoring South Dakota kiosk transactions should build the $1,000 daily / $10,000 thirty-day caps and the 72-hour fraud-refund window into transaction-monitoring and customer-service workflows effective July 1, 2026. 1 evidence refs Scenario sketches ### Illustrative AMLA transition and cross-border obliged-entity supervision Illustrative orientation only: as the EU AML Package architecture matures, the shift from purely national AML supervision toward AMLA direct and indirect supervision of cross-border obliged entities, operating alongside the directly-applicable AML Regulation and per-Member-State transposition of the sixth AML Directive, could reshape how enabler-jurisdiction structures located outside the EU, such as US state-level trust and money-transmission regimes, are assessed by EU-supervised obliged entities conducting cross-border due diligence. A hypothetical scenario: an EU-supervised financial institution's enhanced due diligence on a US-state private trust company structure could, under a more harmonized AMLA-era supervisory expectation, face more consistent scrutiny criteria across EU home-state supervisors than under the current fragmented national-supervisor model. This is architecture-over-incident illustration, not an observed development specific to South Dakota this period. 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 T3 · FATF Grey List no_change T4 · Beneficial-Ownership Register Status watch T5 · Crypto & Digital-Asset Integrity watch T6 · Sanctions Regime Divergence no_change Registers ### Enforcement actions - 21 Mar 2025 - 9 Oct 2025 - 12 Dec 2025 - 16 Jan 2026 - 30 Jun 2026 - 16 Jun 2026 - OCC terminated the July 2024 amendment (AA-ENF-2025-64) to Citibank's October 2020 consent order (AA-EC-2020-64); the underlying order's Articles I-XVI remain in force. 18 Dec 2025 - 18 Dec 2025 - 26 Jun 2024 - 21 Mar 2024 - FinCEN issued an interim final rule revising the CTA's 'reporting company' definition to cover only foreign entities registered to do business in the US, formally exempting all domestic entities and US persons from beneficial-ownership reporting. 26 Mar 2025 - FinCEN issued updated FAQs (Oct. 9, 2025) on the nationwide Residential Real Estate Geographic Targeting Orders (GTOs), requiring covered businesses to identify and record beneficial owners of legal-entity purchasers in non-financed residential real-estate transactions, applicable to transactions involving South Dakota-domiciled entities acting as purchasers. 9 Oct 2025 - The OCC granted conditional national trust bank charter approval to five digital-asset firms, enabling BitGo to convert its South Dakota state trust charter into a federally chartered national trust bank able to operate custody, settlement and fiduciary services nationwide under a single federal regulator. 12 Dec 2025 ### Sanctions changes - 16 Jan 2026 - 16 Jun 2026 - 29 Jun 2026 - Consistent with a March 2, 2025 U.S. Treasury announcement, FinCEN stated it would not enforce BOI reporting penalties or fines against U.S. citizens, domestic reporting companies (including South Dakota-formed trusts/LLCs), or their beneficial owners pending rulemaking. 2 Mar 2025 - FinCEN's March 26, 2025 interim final rule formally codified the domestic-entity exemption, permanently reclassifying South Dakota-formed trusts, LLCs and trust companies out of the CTA 'reporting company' definition unless they are foreign-formed. 26 Mar 2025 ### Regulatory horizon (register) - UK ECCTA 2023 - failure-to-prevent-fraud offence - UK ECCTA 2023 - failure-to-prevent-fraud offence - SB 98 - Virtual Currency Kiosk Fraud Prevention Act - SB 100 - South Dakota trust-law update package - Finalization of FinCEN's domestic BOI exemption rule - FinCEN's pending third CTA rulemaking: revised CDD rule - Final OCC national trust bank charter for BitGo's SD entity - FATF's next Enhanced Follow-up Report on the United States ### Active schemes - South Dakota dynasty-trust secrecy architecture - Sanctioned-individual asset parking via South Dakota trusts - Crypto custody regulatory arbitrage via South Dakota trust charters Sources - [IRS investigating sanctioned Russian oligarchs' use of South Dakota trusts, agent says - ICIJ](https://www.icij.org/investigations/pandora-papers/irs-investigating-sanctioned-russian-oligarchs-use-of-south-dakota-trusts-agent-says/) - [National Law Review](https://natlawreview.com/article/south-dakota-enacts-licensing-framework-virtual-currency-kiosks) - [South Dakota Attorney General](https://atg.sd.gov/OurOffice/Media/pressreleasesdetail.aspx?id=2991) - [South Dakota Searchlight](https://southdakotasearchlight.com/2026/03/03/digital-currency-regulation-bills-head-to-south-dakota-governors-desk/) - [SD Division of Banking](https://dlr.sd.gov/banking/default.aspx) - [Office of the Comptroller of the Currency](https://www.occ.treas.gov/news-issuances/news-releases/2025/nr-occ-2025-131.html) - [Banking Dive](https://www.bankingdive.com/news/occ-withdraws-amendment-citi-2020-consent-order-900-million-revlon-manual-transfer/808355/) - [Bridgeford Trust Company](https://bridgefordtrust.com/south-dakota-dynasty-trust-jurisdiction-matters/) - [SD Division of Banking](https://dlr.sd.gov/banking/legal/documents/20-035-Crypto-Kiosk-Bill-Memo.pdf) - [https://www.occ.gov/static/enforcement-actions/eaAA-ENF-2025-64.pdf](https://www.occ.gov/static/enforcement-actions/eaAA-ENF-2025-64.pdf) - [https://www.occ.treas.gov/news-issuances/news-releases/2025/nr-occ-2025-131.html](https://www.occ.treas.gov/news-issuances/news-releases/2025/nr-occ-2025-131.html) - [https://dlr.sd.gov/banking/money_transmitters/default.aspx](https://dlr.sd.gov/banking/money_transmitters/default.aspx) - [https://dlr.sd.gov/banking/legal/documents/11_002_virtual_currency_transmission_in_sd.pdf](https://dlr.sd.gov/banking/legal/documents/11_002_virtual_currency_transmission_in_sd.pdf) - [https://finance.yahoo.com/news/occ-withdraws-amendment-citi-consent-083304939.html](https://finance.yahoo.com/news/occ-withdraws-amendment-citi-consent-083304939.html) - [https://mylrc.sdlegislature.gov/api/Documents/Bill/306051.pdf?Year=2026](https://mylrc.sdlegislature.gov/api/Documents/Bill/306051.pdf?Year=2026) - [https://dlr.sd.gov/banking/legal/documents/20-035-Crypto-Kiosk-Bill-Memo.pdf](https://dlr.sd.gov/banking/legal/documents/20-035-Crypto-Kiosk-Bill-Memo.pdf) - [https://natlawreview.com/article/south-dakota-enacts-licensing-framework-virtual-currency-kiosks](https://natlawreview.com/article/south-dakota-enacts-licensing-framework-virtual-currency-kiosks) - [https://checklynx.com/en/resources/knowledge-base/fatf-grey-list](https://checklynx.com/en/resources/knowledge-base/fatf-grey-list) - [https://www.icij.org/investigations/pandora-papers/five-years-after-the-pandora-papers-transparency-laws-lose-their-teeth/](https://www.icij.org/investigations/pandora-papers/five-years-after-the-pandora-papers-transparency-laws-lose-their-teeth/) - [https://www.icij.org/investigations/pandora-papers/us-trusts-offshore-south-dakota-tax-havens/](https://www.icij.org/investigations/pandora-papers/us-trusts-offshore-south-dakota-tax-havens/) - [https://dlr.sd.gov/banking/legal/documents/20-036-Trust-Memo-2026.pdf](https://dlr.sd.gov/banking/legal/documents/20-036-Trust-Memo-2026.pdf) - [https://www.occ.gov/topics/charters-and-licensing/interpretations-and-decisions/2026/ca1353.pdf](https://www.occ.gov/topics/charters-and-licensing/interpretations-and-decisions/2026/ca1353.pdf) - [https://www.newmediawire.com/news/north-capital-trust-company-receives-south-dakota-public-trust-company-charter-7086195](https://www.newmediawire.com/news/north-capital-trust-company-receives-south-dakota-public-trust-company-charter-7086195) - [South Dakota Division of Banking](https://dlr.sd.gov/banking/legal/documents/20-036-Trust-Memo-2026.pdf) - [South Dakota Public Broadcasting](https://www.sdpb.org/politics/2023-07-11/concern-raised-about-first-update-to-trust-industry-since-2021) - [South Dakota Division of Banking](https://dlr.sd.gov/banking/legal/documents/20-035-Crypto-Kiosk-Bill-Memo.pdf) - [Dakota News Now](https://www.dakotanewsnow.com/2026/03/26/future-state-law-requires-more-regulation-virtual-currency/) - [South Dakota Division of Banking](https://dlr.sd.gov/banking/default.aspx) - [Conference of State Bank Supervisors](https://www.csbs.org/newsroom/state-financial-regulators-settle-abra-return-cryptocurrency-assets) - [American lawmakers denounce South Dakota, other US states as hubs for financial secrecy - ICIJ](https://www.icij.org/investigations/pandora-papers/american-lawmakers-denounce-south-dakota-other-us-states-as-hubs-for-financial-secrecy/) - [Suspect foreign money flows into booming American tax havens on promise of eternal secrecy - ICIJ](https://www.icij.org/investigations/pandora-papers/us-trusts-offshore-south-dakota-tax-havens/) - [IRS investigating sanctioned Russian oligarchs' use of South Dakota trusts, agent says - ICIJ](https://www.icij.org/investigations/pandora-papers/irs-investigating-sanctioned-russian-oligarchs-use-of-south-dakota-trusts-agent-says/) - [Pandora Papers: An offshore data tsunami - ICIJ](https://www.icij.org/investigations/pandora-papers/about-pandora-papers-leak-dataset/) - [Lawmakers in US push to uncover riches shielded by state secrecy laws - ICIJ](https://www.icij.org/investigations/pandora-papers/lawmakers-in-us-push-to-uncover-riches-shielded-by-state-secrecy-laws/) - [SOUTH DAKOTA TRUST COMPANY LLC overview - Find and update company information - GOV.UK](https://find-and-update.company-information.service.gov.uk/company/OE007200) - [CDD Final Rule | FinCEN.gov](https://www.fincen.gov/resources/statutes-and-regulations/cdd-final-rule) - [TRIDENT TRUST COMPANY (SOUTH DAKOTA) INC overview - Find and update company information - GOV.UK](https://find-and-update.company-information.service.gov.uk/company/OE020209) - [Frequently Asked Questions | FinCEN.gov](https://www.fincen.gov/boi-faqs) - [SOUTH DAKOTA TRUST COMPANY LLC persons with significant control - Find and update company information - GOV.UK](https://find-and-update.company-information.service.gov.uk/company/OE007200/persons-with-significant-control) - [FinCEN Assesses $1.5 Million Civil Money Penalty against Kingdom Trust Company for Violations of the Bank Secrecy Act | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-assesses-15-million-civil-money-penalty-against-kingdom-trust-company) - [Where Rich People Stash Money to Avoid Taxes: South Dakota Holds $500 Billion - Bloomberg](https://www.bloomberg.com/news/features/2021-10-14/where-rich-people-stash-money-to-avoid-taxes-south-dakota-holds-500-billion) - [Offshore havens and hidden riches of world leaders and billionaires exposed in unprecedented leak - ICIJ](https://www.icij.org/investigations/pandora-papers/global-investigation-tax-havens-offshore/) - [FATF](https://www.fatf-gafi.org/en/home.html) - [Money Laundering Using Trust and Company Service Providers October 2010](https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/Money%20Laundering%20Using%20Trust%20and%20Company%20Service%20Providers..pdf) - [Money Laundering Using Trust and Company Service Providers](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Moneylaunderingusingtrustandcompanyserviceproviders.html) - [FATF guidance TRANSPARENCY AND BENEFICIAL OWNERSHIP October 2014](https://www.fatf-gafi.org/content/dam/fatf-gafi/guidance/Guidance-transparency-beneficial-ownership.pdf) - [South Dakota as a Tax Haven for Trusts May Be Overrated - Bloomberg](https://www.bloomberg.com/opinion/articles/2021-10-14/south-dakota-as-a-tax-haven-for-trusts-may-be-overrated) - [Beneficial Ownership Information Reporting Rule Fact Sheet | FinCEN.gov](https://www.fincen.gov/beneficial-ownership-information-reporting-rule-fact-sheet) - [FREQUENTLY ASKED QUESTIONS Issued: October 9, 2025](https://www.fincen.gov/system/files/2025-10/RRE-GTO-FAQs.pdf) - [Watch BitGo Wins Approval To Become National Trust Bank - Bloomberg](https://www.bloomberg.com/news/videos/2025-12-12/bitgo-wins-approval-to-become-national-trust-bank-video) - [US Congressional Committee Chips Away at Corporate Transparency Act | OCCRP](https://www.occrp.org/en/news/us-congressional-committee-chips-away-at-corporate-transparency-act) - [FinCEN Removes Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Persons, Sets New Deadlines for Foreign Companies | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-removes-beneficial-ownership-reporting-requirements-us-companies-and-us) - [Beneficial Ownership Information Reporting | FinCEN.gov](https://www.fincen.gov/boi) - [Small Entity Compliance Guide | FinCEN.gov](https://www.fincen.gov/boi/small-entity-compliance-guide) - [Reference Materials | FinCEN.gov](https://www.fincen.gov/boi/Reference-materials) - [Fact Sheet: Beneficial Ownership Information Access and Safeguards Final Rule | FinCEN.gov](https://www.fincen.gov/news/news-releases/fact-sheet-beneficial-ownership-information-access-and-safeguards-final-rule) - [Financial Crimes Enforcement Network U.S. Department of the Treasury](https://www.fincen.gov/system/files/shared/BOI_Small_Compliance_Guide.v1.1-FINAL.pdf) - [Interim Final Rule: Questions and Answers | FinCEN.gov](https://www.fincen.gov/boi/ifr-qa) - [Beneficial Ownership Information Frequently Asked Questions | FinCEN.gov](https://www.fincen.gov/boi/beneficial-ownership-information-frequently-asked-questions) - [SOUTH DAKOTA TRUST COMPANY LLC people - Find and update company information - GOV.UK](https://find-and-update.company-information.service.gov.uk/company/OE007200/officers) - [SOUTH DAKOTA TRUST COMPANY LLC more information - Find and update company information - GOV.UK](https://find-and-update.company-information.service.gov.uk/company/OE007200/more) - [Memorandum of Understanding](https://ofac.treasury.gov/media/31326/download) - [TRIDENT TRUST COMPANY (SOUTH DAKOTA) INC more information - Find and update company information - GOV.UK](https://find-and-update.company-information.service.gov.uk/company/OE020209/more) - [Crypto regulatory affairs: OCC gives US banks go-ahead on riskless crypto transfers](https://www.elliptic.co/blog/crypto-regulatory-affairs-occ-gives-us-banks-go-ahead-on-riskless-crypto-transfers) - [Five Crypto Firms Get Coveted US Bank-Charter Nod - Bloomberg](https://www.bloomberg.com/news/articles/2025-12-12/occ-greenlights-five-charters-for-firms-including-circle-ripple) - [Watch Banks Slam OCC’s Initial Blessing for Crypto Trust US Charters - Bloomberg](https://www.bloomberg.com/news/videos/2025-12-16/banks-slam-occ-s-blessing-for-crypto-trust-us-charters-video) - [BitGo, Ripple Join Wave of Firms Applying for US Bank Charters - Bloomberg](https://www.bloomberg.com/news/articles/2025-07-02/ripple-joins-wave-of-firms-applying-for-national-bank-charters) - [Watch Five Crypto Firms Get Coveted US Bank-Charter Nod - Bloomberg](https://www.bloomberg.com/news/videos/2025-12-12/five-crypto-firms-get-coveted-us-bank-charter-nod-video) - [Crypto’s Bid for Trust Charters Sparks Alarm in Banking Industry - Bloomberg](https://www.bloomberg.com/news/articles/2025-11-05/crypto-s-bid-for-trust-charters-sparks-alarm-in-banking-industry) - [BitGo Trust Company, Inc. - LEI: 254900QXDWGM1T0HGF47](https://lei.bloomberg.com/leis/view/254900QXDWGM1T0HGF47) - [Trump administration curbs state oversight of crypto industry - ICIJ](https://www.icij.org/investigations/coin-laundry/trump-administration-curbs-state-oversight-of-crypto-industry/) - [Stripe’s Bridge Joins Crypto Firms Securing Nod for Bank Charter - Bloomberg](https://www.bloomberg.com/news/articles/2026-02-17/stripe-s-bridge-joins-crypto-firms-securing-nod-for-bank-charter) - [HB HOPE FOUNDATION overview - Find and update company information - GOV.UK](https://find-and-update.company-information.service.gov.uk/company/08148531) - [The Old Courthouse, Jaycroft Road, Burnham on Sea, TA8 1LE 9th December 2025](https://burnham-highbridge-tc.gov.uk/wp-content/uploads/2025/12/TC-Agenda-Bundle-15.12.2025.pdf) - [South Downs National Park Authority](https://www.southdowns.gov.uk/app/uploads/2026/04/LAA-Appendix-Bi-%E2%80%93-BH-East-Sussex-Area-2026-Update-1.pdf) - [Don’t Panic: Distrusting Government Is an American Tradition](https://www.bloomberg.com/graphics/2024-opinion-history-government-trust/) - [Check your Council Tax banding and see where your money goes - South Cambs District Council](https://www.scambs.gov.uk/council-tax/check-your-council-tax-banding-and-see-where-your-money-goes) - [Public trust and transparency – Responsible Technology Adoption Unit Blog](https://rtau.blog.gov.uk/2020/12/01/public-trust-and-transparency/) - [Guidance notes for form R43 These notes will help you to claim](https://assets.publishing.service.gov.uk/media/69bc066f8006048065f73d03/R43_Notes.pdf) - [Supreme Court’s Partisan Politics Lost Americans’ Trust](https://www.bloomberg.com/graphics/2024-opinion-supreme-court-data-partisan-politics-lost-trust/) - [Social Security’s Finances Are In Dire Need of Repair - Bloomberg](https://www.bloomberg.com/opinion/articles/2025-04-10/social-security-s-finances-are-in-dire-need-of-repair) - [Consolidated assessment ratings](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Assessment-ratings.html) - [Mutual Evaluations](https://www.fatf-gafi.org/en/publications/Mutualevaluations.html) - [Mutual Evaluation of the United States](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationoftheunitedstates.html) - [Jurisdictions under Increased Monitoring - 13 June 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2025.html) - [Publications](https://www.fatf-gafi.org/en/publications.html) - [FATF Annual Report 2024-2025](https://www.fatf-gafi.org/en/publications/Fatfgeneral/FATF-Annual-report-2024-2025.html) - [United States](https://www.fatf-gafi.org/en/countries/detail/United-States.html) - [FATF changes its grey listing criteria to further focus on risk](https://www.fatf-gafi.org/content/fatf-gafi/en/publications/Fatfgeneral/FATF-grey-listing-criteria.html) - [Outcomes FATF Plenary, 22-24 October 2025](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-FATF-plenary-october-2025.html) - [Jurisdictions under Increased Monitoring - 21 February 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2025.html) - [US Senate blocks major anti-money laundering bill, the Enablers Act - ICIJ](https://www.icij.org/investigations/pandora-papers/us-senate-blocks-major-anti-money-laundering-bill-the-enablers-act/) - [House committee advances ‘once in a generation’ crackdown on enablers of financial crime - ICIJ](https://www.icij.org/investigations/pandora-papers/congress-advances-once-in-a-generation-crackdown-on-enablers-of-financial-crime/) - [Major anti-money-laundering reform passes US House - ICIJ](https://www.icij.org/investigations/pandora-papers/major-anti-money-laundering-reform-passes-us-house/) - [US: Experts Urge ENABLERS Act Passage Despite Senate Setback | OCCRP](https://www.occrp.org/en/news/us-experts-urge-enablers-act-passage-despite-senate-setback) - [US lawmakers call for crackdown on financial 'enablers' ...](https://www.icij.org/investigations/pandora-papers/us-lawmakers-call-for-crackdown-on-financial-enablers-after-pandora-papers/) - [October 2025 Reform of the Anti-Money Laundering and Counter-](https://assets.publishing.service.gov.uk/media/68f609dc2f0fc56403a3d0c7/AML_Supervision_Reform_Response_Document_FINAL.pdf) - [FATF REPORT Horizontal Review of Gatekeepers’ Technical Compliance Related](https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/HRGTC.pdf.coredownload.inline.pdf) - [U.S. Advances Legislation to Stop Enablers of Money Laundering | OCCRP](https://www.occrp.org/en/news/us-advances-legislation-to-stop-enablers-of-money-laundering) - [The gatekeepers who help open America to oligarchs and scammers - ICIJ](https://www.icij.org/investigations/pandora-papers/the-gatekeepers-who-help-open-america-to-oligarchs-and-scammers/) - [Horizontal Review of Gatekeepers’ Technical Compliance Related to Corruption](https://www.fatf-gafi.org/en/publications/Fatfgeneral/Gatekeeper-TC-Corruption.html) - [US lands top spot as world’s biggest enabler of financial secrecy in new index - ICIJ](https://www.icij.org/investigations/pandora-papers/us-lands-top-spot-as-worlds-biggest-enabler-of-financial-secrecy-in-new-index/) - [Financial Secrecy Index | Indice profile](https://composite-indicators.jrc.ec.europa.eu/explorer/explorer/indices/fsi/financial-secrecy-index) - [Index: US State Most Secretive | OCCRP](https://www.occrp.org/en/news/index-us-state-most-secretive) - [Financial Secrecy Index | Indice profile | Composite Indicators and Scoreboards Explorer](https://composite-indicators.jrc.ec.europa.eu/explorer/indices/fsi/financial-secrecy-index) - [World’s Top Enabler of Financial Secrecy Is the United States](https://www.bloomberg.com/news/articles/2022-05-16/world-s-top-enabler-of-financial-secrecy-is-the-united-states) - [1 The U.S. Department of the Treasury’s (Treasury) Financial](https://www.fincen.gov/system/files/2026-03/FinCEN-Advisory-Health-Care-Fraud.pdf) - [US, Switzerland singled out for financial secrecy by new index - ICIJ](https://www.icij.org/inside-icij/2018/01/us-switzerland-singled-financial-secrecy-new-index/) - [Corporate Tax Haven Index | Indice profile | Composite Indicators and Scoreboards Explorer](https://composite-indicators.jrc.ec.europa.eu/explorer/indices/cthi/corporate-tax-haven-index) - [New US sanctions target trust companies and corporate service providers for the first time - ICIJ](https://www.icij.org/investigations/pandora-papers/new-us-sanctions-target-trust-companies-and-corporate-service-providers-for-the-first-time/) - [South Dakota Dynasty Trusts: Tax Haven for Rich Families - Bloomberg](https://www.bloomberg.com/news/articles/2014-01-09/south-dakota-dynasty-trusts-tax-haven-for-rich-families) - [Inside the Secret World of Offshore Mega-Trusts - ICIJ](https://www.icij.org/investigations/paradise-papers/secret-world-offshore-mega-trusts/) - [South Dakota Trust Company, LLC as | ICIJ Offshore Leaks Database](https://offshoreleaks.icij.org/nodes/80126785) - [FinCEN Issues Final Rule Regarding Access to Beneficial Ownership Information | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-final-rule-regarding-access-beneficial-ownership-information) - [Fact Sheet: Beneficial Ownership Information Access and Safeguards Notice of Proposed Rulemaking (NPRM) | FinCEN.gov](https://www.fincen.gov/nprm-fact-sheet) - [FinCEN Issues Final Rule for Beneficial Ownership Reporting to Support Law Enforcement Efforts, Counter Illicit Finance, and Increase Transparency | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-final-rule-beneficial-ownership-reporting-support-law-enforcement) - [Beneficial Ownership Information Access and Safeguards | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/federal-register-notices/beneficial-ownership-information-access-0) - [First Bank & Trust/Brookings SD - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/FNOO:US) - [First Bank & Trust/Sioux Falls SD - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/435512Z:US) - [Financial Crimes Enforcement Network (FinCEN), U.S. Department of the Treasury](https://www.fincen.gov/news/news-releases/fincen-removes-beneficial-ownership-reporting-requirements-us-companies-and-us) - [International Consortium of Investigative Journalists (ICIJ)](https://www.icij.org/investigations/pandora-papers/us-trusts-offshore-south-dakota-tax-havens/) - [Bloomberg News](https://www.bloomberg.com/news/articles/2025-12-12/occ-greenlights-five-charters-for-firms-including-circle-ripple) - [Financial Action Task Force (FATF)](https://www.fatf-gafi.org/en/countries/detail/United-States.html) - [International Consortium of Investigative Journalists (ICIJ)](https://www.icij.org/investigations/pandora-papers/us-senate-blocks-major-anti-money-laundering-bill-the-enablers-act/) - [Elliptic](https://www.elliptic.co/blog/crypto-regulatory-affairs-occ-gives-us-banks-go-ahead-on-riskless-crypto-transfers) - [International Consortium of Investigative Journalists (ICIJ), reporting on Tax Justice Network Financial Secrecy Index](https://www.icij.org/investigations/pandora-papers/us-lands-top-spot-as-worlds-biggest-enabler-of-financial-secrecy-in-new-index/) - [International Consortium of Investigative Journalists (ICIJ)](https://www.icij.org/investigations/pandora-papers/irs-investigating-sanctioned-russian-oligarchs-use-of-south-dakota-trusts-agent-says/) Coverage gaps fim-int-2026-07-05-G001: No direct South Dakota state-govern… fim-int-2026-07-05-G001: No direct South Dakota state-government primary source (for example a dlr.sd.gov Division of Banking rule page or South Dakota Codified Laws Title 55 citation) was located this cycle; South Dakota Division of Banking positions are evidenced only via secondary ICIJ and Bloomberg quotation. [resolved] fim-int-2026-07-05-G002: No confirmed post-2024 update on IR… fim-int-2026-07-05-G002: No confirmed post-2024 update on IRS Criminal Investigation dedicated South Dakota trust asset-tracing team activity; underlying evidence dates to September 2023 and June 2024 and is 12 to 33 months stale as of this baseline. [resolved] fim-int-2026-07-05-G003: FinCEN has not yet finalized the Ma… fim-int-2026-07-05-G003: FinCEN has not yet finalized the March 2025 interim final rule exempting domestic reporting companies from Corporate Transparency Act beneficial-ownership reporting; the outcome of finalization or potential litigation remains open. [resolved] fim-int-2026-07-05-G004: No direct primary confirmation was … fim-int-2026-07-05-G004: No direct primary confirmation was located of the specific timing or scope of the next FATF Enhanced Follow-up Report addressing United States Recommendation 24 and 25 compliance beyond the 7th report. [resolved] fim-int-2026-07-05-G005: No public confirmation was located … fim-int-2026-07-05-G005: No public confirmation was located of whether the four other digital-asset firms approved alongside BitGo (Circle, Ripple, Fidelity Digital Assets, Paxos) have completed final unconditional charter conversion versus conditional approval only; cross-firm verification would strengthen the D5 regulatory-arbitrage assessment. [resolved] fim-int-2026-07-14-G001: No OFSI primary notice was located … fim-int-2026-07-14-G001: No OFSI primary notice was located for the UK's 16 June 2026 Russia designation package; corroboration rests on a Tier-3 law-firm tracker. [resolved] fim-int-2026-07-14-G002: No direct EUR-Lex/AMLA.europa.eu Ti… fim-int-2026-07-14-G002: No direct EUR-Lex/AMLA.europa.eu Tier-1 source was retrieved for the EU AML Package application/transposition timeline this cycle. [resolved] fim-int-2026-07-14-G003: The Huione laundering-persistence f… fim-int-2026-07-14-G003: The Huione laundering-persistence finding rests solely on a Tier-4 secondary characterisation; the underlying Chainalysis report was not directly retrieved. [resolved] fim-int-2026-07-14-G004: D6 (Compliance Technology and Activ… fim-int-2026-07-14-G004: D6 (Compliance Technology and Active Defence) coverage remains thin this cycle; no dedicated FinCEN model-risk or FCA/JMLSG search pass was performed. [resolved] fim-int-2026-08-05-G001: The mandatory Yemen/Houthi sanction… fim-int-2026-08-05-G001: The mandatory Yemen/Houthi sanctions sub-check under T1 was not actively queried this cycle given the jurisdiction-scoped research budget. [resolved] fim-int-2026-08-05-G002: The substantive content of SD's 202… fim-int-2026-08-05-G002: The substantive content of SD's 2026 Trust Law Legislation amendment (memo 20-036) has not been confirmed. [resolved] fim-int-2026-08-05-G003: The Tier D mandatory watch jurisdic… fim-int-2026-08-05-G003: The Tier D mandatory watch jurisdictions (Cambodia, Laos, Mexico, Colombia) were not independently searched this cycle. [resolved] fim-int-2026-08-05-G004: No primary source URL was located f… fim-int-2026-08-05-G004: No primary source URL was located for the standing UK ECCTA 2023 regulatory_horizon anchor. [resolved] fim-int-2026-08-05-G005: SB 43's specific statutory in-force… fim-int-2026-08-05-G005: SB 43's specific statutory in-force date has not been separately confirmed from its 2026-03-11 signing date. [resolved] fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): SD-specific sanctions-evasion signal (D1) not identified this cycle; no dedicated D1 primary source queried for South Dakota. [resolved] fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', 'value': 'D2'}): SD-specific beneficial-ownership development (D2) not identified this cycle; no source available. [resolved] fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', 'value': 'D4'}): SD-specific conflict-finance development (D4) not identified this cycle; no source available. [resolved] fim-int-2026-09-28-G004 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G004 ({'scheme': 'financial_integrity', 'value': 'D6'}): SD-specific compliance-technology / active-defence development (D6) not identified this cycle; no source available. [resolved] fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): US-SD-specific sanctions-evasion, beneficial-ownership, enabler-jurisdiction and conflict-finance signals (D1-D4) were not actively searched this cycle under the operator's single-JID binding; standing Tier-D (KH/LA/MX/CO) sweep and Russian/Houthi-Yemen check were not performed, consistent with the JID lock but a deviation from the base FIM methodology's mandatory global sweep. [resolved] fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): Exact original commencement date of the NMLS-filing requirement for SD money transmitters, and whether SB 98 imposes a kiosk-specific capital add-on distinct from the general surety-bond regime, were not located this cycle. [resolved] fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): Full text and all eight sections of SB 100 (2026 SD trust-law maintenance package) were not individually itemised for AML/beneficial-ownership relevance this cycle. [open] fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): Final licensing/registration status of North Capital Trust Company and BitGo Bank & Trust with the SD Division of Banking (post-OCC approval) not confirmed this cycle. [open] fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): No primary-source confirmation obtained this cycle for any SDCoG sports-betting enforcement events in the Oct 11-25 window. [open] fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', 'value': 'D3'}): Tribal compact amendments for South Dakota's nine tribal nations were not re-verified this cycle; NIGC compact index not re-pulled. [open] fim-int-2026-10-25-G003: Tier D watch jurisdictions (KH, LA,… fim-int-2026-10-25-G003: Tier D watch jurisdictions (KH, LA, MX, CO) were not actively searched this cycle due to the union single-JID binding to US-SD. [open] FIM-GAP-001 (D2): No state or federal beneficial-ownership r… FIM-GAP-001 (D2): No state or federal beneficial-ownership registry covers South Dakota trusts; the SD Supreme Court has upheld trust secrecy against creditor/court-access claims, and trust companies are not obligated to disclose settlor, trustee or beneficiary identity to any public or centralized law-enforcement-accessible database. FIM-GAP-002 (D2): FinCEN's March 2025 interim final rule eli… FIM-GAP-002 (D2): FinCEN's March 2025 interim final rule eliminated the CTA's already-limited (non-public) federal BOI reporting requirement for all US-formed entities, including South Dakota trust-linked LLCs, removing the sole nascent federal transparency mechanism that could have reached these structures. FIM-GAP-003 (D3): Trust companies, registered agents and oth… FIM-GAP-003 (D3): Trust companies, registered agents and other TCSPs operating in South Dakota are not subject to BSA-style customer due diligence and suspicious-activity-reporting obligations equivalent to banks; the federal ENABLERS Act, which would impose such duties, has been introduced repeatedly since 2021 but has never passed the Senate. FIM-GAP-004 (D3): This baseline pass did not locate a direct… FIM-GAP-004 (D3): This baseline pass did not locate a direct South Dakota state-government primary source (e.g., a dlr.sd.gov Division of Banking rule page or South Dakota Codified Laws Title 55 citation); South Dakota Division of Banking positions are evidenced only via secondary quotation in ICIJ/Washington Post reporting. ## Evidence #### Confidence-tiered claims Any operator of a virtual-currency kiosk in South Dakota must be licensed under SDCL Chapter 51A-17 (money transmission). [[Source 1]](#sec-sources) Probable · 1 source Daily transaction cap of $1,000 per user and 30-day cap of $10,000 per user for virtual-currency kiosk transactions. [[Source 1]](#sec-sources) Probable · 1 source Expanded annual/quarterly reports to the Division of Banking covering transaction volumes, complaints, refunds, kiosk locations and BSA reporting. [[Source 1]](#sec-sources) Probable · 1 source Federal BSA/FinCEN MSB registration regime layered with SDCL Chapter 51A-17 state money-transmitter licensing, administered via NMLS by the SD Division of Banking. [[Source 1]](#sec-sources) Probable · 1 source Not on the FATF grey list or call-for-action list as of the June 2026 plenary. [[Source 1]](#sec-sources) Probable · 1 source South Dakota remains a top US trust-secrecy destination; the Corporate Transparency Act 'largely left such trusts untouched' and Treasury will not enforce the CTA beneficial-ownership rule, per ICIJ's five-year Pandora Papers retrospective. [[Source 1]](#sec-sources) Probable · 1 source South Dakota trust companies oversee more than $360 billion in assets. [[Source 1]](#sec-sources) Probable · 1 source Virtual-currency kiosk operators in South Dakota must be licensed as money transmitters under SDCL Chapter 51A-17, effective 2026-07-01. [[Source 1]](#sec-sources) Probable · 1 source OCC granted preliminary conditional approval (Corporate Decision, Charter No. 25366) for BitGo Trust Company, a South Dakota state trust company, to convert into BitGo Bank & Trust, National Association, proposing digital-asset/fiat fiduciary custody, staking and stablecoin-issuance services. [[Source 1]](#sec-sources) Probable · 1 source North Capital Trust Company received a South Dakota Public Trust Company charter (announced 2026-04-02) to expand digital-asset-securities custody. [[Source 1]](#sec-sources) Probable · 1 source SB 100, effective 2026-07-01, revises trustor tax-reimbursement powers, decanting/termination cross-references, and attorney-client privilege resting with the fiduciary, without adding beneficial-ownership disclosure requirements; SD trust confidentiality under SDCL 51A-6A-2 and automatically-sealed trust court records remain unchanged. [[Source 1]](#sec-sources) Probable · 1 source SB 98, effective 2026-07-01, requires virtual-currency kiosk operators to hold an SDCL ch. 51A-17 money-transmitter license and imposes kiosk-specific annual/quarterly reporting including Bank Secrecy Act reporting data, a $1,000 daily/$10,000 30-day per-user transaction cap, a 72-hour fraud-refund duty, and enhanced receipt disclosures, responding to a cited ~$246 million/year virtual-currency fraud exposure for SD residents and roughly 170 statewide kiosks. [[Source 1]](#sec-sources) Probable · 1 source 25-state multistate settlement (SD among participants), dated 2024-06-26, requiring Abra to cease virtual-asset services to US customers and return remaining assets, for operating cryptocurrency services without required state money-transmitter licensing. [[Source 1]](#sec-sources) Probable · 1 source Virtual currency kiosk operators in South Dakota are required to be licensed as money transmitters under SDCL Chapter 51A-17 per Senate Bill 98, in force since 2026-07-01. [[Source 1]](#sec-sources) Probable · 1 source SB 43 amends South Dakota's criminal search-and-seizure/forfeiture statute to bring digital currency within its scope, effective 2026-07-01. [[Source 1]](#sec-sources) Probable · 1 source