--- title: "United States — Texas (US-TX) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/united-states-texas/ source_html: /jurisdictions/united-states-texas/index.html description: "Financial integrity intelligence for United States – Texas (US-TX): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: ab557b39c95149cb4f106b3e626db14104ba98ae28764ec5a5eb16c7cf04b45f generator: "fe-fleet/md-twin@1.0" --- # United States — Texas (US-TX) — 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 — Texas US-TX Domains covered 8 of 8 Sources 141 Role actions 8 Horizon <90d 1 Jurisdiction profile FATF status: Compliant Tier: B Risk direction: Increasing Enablement vs enforcement: Mixed Texas AML/CFT rests on the federal BSA/FinCEN regime, with the Texas Department of Banking as state MSB/state-bank supervisor coordinating with OFAC via MOU. More Texas is FinCEN's principal GTO testbed: Southwest Border cash-MSB orders and residential-real-estate title-company orders (Houston, Laredo, San Antonio, DFW) both concentrate here, alongside intense cartel-finance and oil-smuggling enforcement. Key deficiencies - Domestic beneficial-ownership reporting to FinCEN under the CTA has been suspended nationwide following Eastern District of Texas litigation, removing a transparency layer for Texas-registered shell entities - Persistent Southwest border bulk-cash smuggling and unlicensed/under-supervised MSB and armored-carrier channels despite repeated GTOs - Large-scale fiscal fuel/crude-oil smuggling and trade-based laundering exploiting Texas Gulf Coast and Permian Basin energy infrastructure Recent developments (18m) - Texas Top Cop Shop, Inc. v. Garland (E.D. Tex., Sherman Div.) nationwide injunction against CTA enforcement (Dec 2024), followed by FinCEN's March 2025 interim final rule exempting domestic reporting companies - FinCEN Southwest Border GTOs issued/expanded/renewed (Mar 2025, Sept 2025, Mar 2026) covering Texas MSB ZIP codes at lowered CTR thresholds - FinCEN Residential Real Estate GTOs renewed for Houston, Laredo, San Antonio (Bexar) and Dallas-Fort Worth, transitioning to the nationwide RRE reporting rule (postponed to March 1, 2026) - FinCEN Cartel Oil Smuggling Alert (May 2025) and Fiscal Fuel Theft supplemental Alert (June 2026) tied to the South Texas High-Intensity Financial Crime Area task force - FinCEN $37,000,000 consent order against Brink's Global Services USA for Southwest-border bulk-cash BSA violations (Feb 2025) - OFAC designations under E.O. 14157 against CJNG-linked fuel theft network operating on the Texas-Mexico border (May 2025); DOJ SDTX terrorism/material-support indictment (May 2025) United States federal law that applies in United States – Texas is covered once, on the [United States](/jurisdictions/us/) page. This page covers United States – Texas’s own layer: its own law, regulators and enforcement. Brief ## Lead signal #### Lead Signal Texas has become a working illustration of how a federal preemption event lands on an actively enforced state gateway before that gateway's reach has actually narrowed. On 23 October 2026 the Office of the Comptroller of the Currency published implementing regulations for the GENIUS Act, confirming that from 18 January 2027 a federally qualified payment stablecoin issuer -- and an approved subsidiary of an insured depository institution -- will be licensed, regulated and supervised exclusively at the federal level, with Section 5(h) of the Act (12 U.S.C. 5904(h)) expressly preempting any state charter, licence or other authorisation requirement for that category of firm. That commencement sits alongside, rather than replacing, continued Texas enforcement: in September 2026 the Texas Department of Banking issued consent orders against two cryptocurrency and payment firms resolving allegations that they conducted money transmission involving stablecoin activity in Texas without the required licence under the state's Money Services Modernization Act (Chapter 152). The two developments describe one coherent story -- a state regulator still actively policing its general money-transmission gateway against stablecoin activity in the months immediately before a large slice of that gateway's future relevance is removed by federal law. Read full brief #### Lead Signal Texas has become a working illustration of how a federal preemption event lands on an actively enforced state gateway before that gateway's reach has actually narrowed. On 23 October 2026 the Office of the Comptroller of the Currency published implementing regulations for the GENIUS Act, confirming that from 18 January 2027 a federally qualified payment stablecoin issuer -- and an approved subsidiary of an insured depository institution -- will be licensed, regulated and supervised exclusively at the federal level, with Section 5(h) of the Act (12 U.S.C. 5904(h)) expressly preempting any state charter, licence or other authorisation requirement for that category of firm. That commencement sits alongside, rather than replacing, continued Texas enforcement: in September 2026 the Texas Department of Banking issued consent orders against two cryptocurrency and payment firms resolving allegations that they conducted money transmission involving stablecoin activity in Texas without the required licence under the state's Money Services Modernization Act (Chapter 152). The two developments describe one coherent story -- a state regulator still actively policing its general money-transmission gateway against stablecoin activity in the months immediately before a large slice of that gateway's future relevance is removed by federal law. The practical reading for firms operating in or into Texas is that the state licensing requirement does not disappear on the Federal Register's publication date; it disappears, for a defined category of issuer, only once the implementing regulations take effect in January 2027. Until then, and for any issuer that does not qualify as a federal qualified payment stablecoin issuer thereafter, the Chapter 152 gateway remains the operative control, and the Texas Banking Commissioner has just demonstrated a willingness to use it. #### Other Developments Beneficial ownership exposure confirmed stable, closing a prior gap. Reporting reviewed this cycle confirms that FinCEN's March 2025 interim final rule exempts domestically formed companies -- including Texas-formed LLCs and corporations -- from Corporate Transparency Act beneficial-ownership reporting, leaving only foreign entities registered to do business in the United States within scope. The residual nationwide injunction in the litigation brought by Texas-forming plaintiffs in the Eastern District of Texas (Smith v. U.S. Department of the Treasury) remains the live venue for any further challenge, but it addresses a narrower question than the exemption itself. This closes a beneficial-ownership coverage gap that had been outstanding in prior assessment of the jurisdiction. Multistate AML/CFT supervision continuing on the standing examination framework. A joint consent order entered on 22 June 2026 between the Texas Department of Banking and the Colorado Division of Banking addressed alleged deficiencies in a licensed multistate money transmitter's anti-money-laundering and countering-the-financing-of-terrorism programme, including allegations touching currency transaction reporting timeliness and agent monitoring. The action illustrates that the standing Bank Secrecy Act examination regime -- applied to money services businesses under the risk-rated 12/18/24-month examination cycle referenced in Texas Department of Banking supervisory guidance -- continues to generate active multistate enforcement, independent of the stablecoin-specific gateway questions raised above. #### Cross-Monitor Connections The GENIUS Act implementing regulations are a payments-infrastructure event as much as a financial-integrity one: the same federal preemption that narrows Texas's money-transmission gateway for qualified stablecoin issuers also reshapes how those issuers' access to settlement and banking infrastructure will be supervised going forward, a question more squarely in the remit of payments-market analysis than of illicit-finance typology. The beneficial-ownership exemption finding likewise has a structural-transparency dimension that extends beyond financial-crime risk into the broader corporate-transparency and registry-architecture questions tracked elsewhere; a jurisdiction's withdrawal of domestic beneficial-ownership reporting is a fact relevant to any analysis of how ownership information is or is not available to counterparties and regulators outside the financial-integrity lens specifically. #### Outlook The period between now and 18 January 2027 is the operative window to watch: any federally qualified payment stablecoin issuer currently navigating or avoiding the Texas Chapter 152 gateway has a defined, near-term date on which that calculus changes, while non-qualifying issuers and other money transmitters will continue to face the state gateway exactly as the OKX and Triple A consent orders illustrate it is currently being applied. Separately, the beneficial-ownership position is better characterised as settled for domestic Texas entities than as actively moving, though the Eastern District of Texas litigation remains a venue where that could change. Firms should treat the Texas Department of Banking's demonstrated willingness to enforce the general money-transmission licence against stablecoin activity as the present reality, with the federal preemption date as a known, dated inflection point rather than an immediate relief. Earlier periodic briefs (6) 25 Oct 2026 · fim-2026-10-25 #### Lead Signal Texas has become a working illustration of how a federal preemption event lands on an actively enforced state gateway before that gateway's reach has actually narrowed. On 23 October 2026 the Office of the Comptroller of the Currency published implementing regulations for the GENIUS Act, confirming that from 18 January 2027 a federally qualified payment stablecoin issuer -- and an approved subsidiary of an insured depository institution -- will be licensed, regulated and supervised exclusively at the federal level, with Section 5(h) of the Act (12 U.S.C. 5904(h)) expressly preempting any state charter, licence or other authorisation requirement for that category of firm. That commencement sits alongside, rather than replacing, continued Texas enforcement: in September 2026 the Texas Department of Banking issued consent orders against two cryptocurrency and payment firms resolving allegations that they conducted money transmission involving stablecoin activity in Texas without the required licence under the state's Money Services Modernization Act (Chapter 152). The two developments describe one coherent story -- a state regulator still actively policing its general money-transmission gateway against stablecoin activity in the months immediately before a large slice of that gateway's future relevance is removed by federal law. The practical reading for firms operating in or into Texas is that the state licensing requirement does not disappear on the Federal Register's publication date; it disappears, for a defined category of issuer, only once the implementing regulations take effect in January 2027. Until then, and for any issuer that does not qualify as a federal qualified payment stablecoin issuer thereafter, the Chapter 152 gateway remains the operative control, and the Texas Banking Commissioner has just demonstrated a willingness to use it. #### Other Developments Beneficial ownership exposure confirmed stable, closing a prior gap. Reporting reviewed confirms that FinCEN's March 2025 interim final rule exempts domestically formed companies -- including Texas-formed LLCs and corporations -- from Corporate Transparency Act beneficial-ownership reporting, leaving only foreign entities registered to do business in the United States within scope. The residual nationwide injunction in the litigation brought by Texas-forming plaintiffs in the Eastern District of Texas (Smith v. U.S. Department of the Treasury) remains the live venue for any further challenge, but it addresses a narrower question than the exemption itself. This closes a beneficial-ownership coverage gap that had been outstanding in prior assessment of the jurisdiction. Multistate AML/CFT supervision continuing on the standing examination framework. A joint consent order entered on 22 June 2026 between the Texas Department of Banking and the Colorado Division of Banking addressed alleged deficiencies in a licensed multistate money transmitter's anti-money-laundering and countering-the-financing-of-terrorism programme, including allegations touching currency transaction reporting timeliness and agent monitoring. The action illustrates that the standing Bank Secrecy Act examination regime -- applied to money services businesses under the risk-rated 12/18/24-month examination cycle referenced in Texas Department of Banking supervisory guidance -- continues to generate active multistate enforcement, independent of the stablecoin-specific gateway questions raised above. #### Cross-Monitor Connections The GENIUS Act implementing regulations are a payments-infrastructure event as much as a financial-integrity one: the same federal preemption that narrows Texas's money-transmission gateway for qualified stablecoin issuers also reshapes how those issuers' access to settlement and banking infrastructure will be supervised going forward, a question more squarely in the remit of payments-market analysis than of illicit-finance typology. The beneficial-ownership exemption finding likewise has a structural-transparency dimension that extends beyond financial-crime risk into the broader corporate-transparency and registry-architecture questions tracked elsewhere; a jurisdiction's withdrawal of domestic beneficial-ownership reporting is a fact relevant to any analysis of how ownership information is or is not available to counterparties and regulators outside the financial-integrity lens specifically. #### Outlook The period between now and 18 January 2027 is the operative window to watch: any federally qualified payment stablecoin issuer currently navigating or avoiding the Texas Chapter 152 gateway has a defined, near-term date on which that calculus changes, while non-qualifying issuers and other money transmitters will continue to face the state gateway exactly as the OKX and Triple A consent orders illustrate it is currently being applied. Separately, the beneficial-ownership position is better characterised as settled for domestic Texas entities than as actively moving, though the Eastern District of Texas litigation remains a venue where that could change. Firms should treat the Texas Department of Banking's demonstrated willingness to enforce the general money-transmission licence against stablecoin activity as the present reality, with the federal preemption date as a known, dated inflection point rather than an immediate relief. 11 Oct 2026 · fim-2026-10-11 #### Lead Signal Texas Department of Banking enforcement actions resolved in September 2026 against OKX, Inc. and Triple A Technologies Pte Ltd. confirm that state money-transmission licensing in Texas continues to operate as a live supervisory backstop for stablecoin activity, independent of the federal GENIUS Act framework. OKX accepted a consent order and a 95,000 dollar administrative penalty, effective 11 September 2026, over conduct alleged to span 2018 to 2024, in which the firm received sovereign currency and stablecoins for transmission and provided custody services to Texas customers without a Chapter 152 money transmitter licence. Triple A Technologies accepted a parallel consent order and a 20,000 dollar penalty, effective 23 September 2026, for processing merchant payments in stablecoins and non-convertible cryptocurrency without the same licence. Both matters were resolved under the Texas Money Services Modernization Act, Texas Finance Code Chapter 152, and both rest on Texas DOB Supervisory Memorandum 1037, which treats a sovereign-currency-pegged, fully reserve-backed, issuer-redeemable stablecoin as money or monetary value for licensing purposes. The Commissioner's own June 2026 testimony states plainly that Texas does not currently have a framework substantially similar to the federal GENIUS Act, meaning the state has no certification pathway for GENIUS Act state-qualified payment-stablecoin issuers and continues to rely on the pre-existing Chapter 152 licensing route to reach stablecoin transmission activity. The practical reading is that federal stablecoin legislation has not displaced state money-transmission authority in Texas; it has instead left two regimes running in parallel, with the state licensing regime doing the enforcement work in the interim. #### Other Developments A joint multi-state AML consent order against Ramad Pay, Inc. was entered by the Texas Department of Banking together with the Colorado Division of Banking, effective 18 June 2026, carrying a 200,000 dollar penalty for deficiencies in the firm's AML/CFT program, including conduct alleged to touch Bank Secrecy Act implementing regulations and the FTC Safeguards Rule. The order was stated directly in the Texas DOB's own press release and sits within the standing Chapter 152 supervisory architecture administered by the Department, reflecting continued multi-state coordination on money-services-business oversight. A federal beneficial-ownership reporting rule took effect on 14 August 2026 when FinCEN issued a final rule permanently removing the requirement for United States companies and United States persons to report beneficial-ownership information, narrowing the federal Corporate Transparency Act register to foreign reporting companies only. No Texas state-level beneficial-ownership registry has been identified that fills the gap this creates for domestic entities formed or operating in the state. #### Cross-Monitor Connections The OKX and Triple A Technologies matters sit at the intersection of financial-integrity and world-payments concerns: the underlying conduct is a payments-licensing failure, but the consent orders rest on Chapter 152, the same statute that anchors Texas's AML/CFT supervisory architecture for money-services businesses, so the enforcement record informs both monitors' read of state-level stablecoin oversight. The Ramad Pay consent order is more squarely an AML/CFT matter, given its explicit BSA and Safeguards Rule grounding, but it was entered through the same Chapter 152 channel and the same Department of Banking that licenses and polices payment firms more broadly, reinforcing the reading that Texas treats payments licensing and financial-crime compliance as a single supervisory perimeter rather than two distinct tracks. The federal BOI exemption is a cross-cutting development with no Texas-specific financial-integrity angle beyond the standing observation that the state has no registry of its own to substitute for the narrowed federal one. #### Outlook Texas DOB enforcement against unlicensed MSBs and crypto firms has been sustained rather than escalating or receding, and the Commissioner's testimony that the state currently lacks a GENIUS Act-equivalent certification framework signals that Chapter 152 licensing, not a new stablecoin-specific regime, will remain the operative enforcement lever through at least the next legislative session, with the Department stating it looks forward to working with the Legislature on a future framework. The federal beneficial-ownership exemption leaves a visible transparency gap at the Texas state level that, absent a state registry, is likely to persist as a standing observation rather than a near-term legislative fix. 28 Sep 2026 · fim-2026-09-28 #### Lead Signal The most consequential development touching Texas this cycle is federal, not state, in origin, but it lands squarely on the states baseline corporate-transparency posture. FinCENs interim final rule exempting essentially all United States-formed companies from Corporate Transparency Act beneficial ownership information reporting was finalized effective August 14, 2026. That change removes the federal backstop that had, in principle, sat behind Texas own manager-only LLC disclosure practice, under which a Texas certificate of formation and the annual Public Information Report disclose only the managers of a manager-managed limited liability company, not its underlying members or beneficial owners. With the federal reporting requirement narrowed to foreign reporting companies, Texas existing entity-formation opacity now carries more independent analytical weight than it did a cycle ago, because there is materially less federal disclosure sitting behind it for U.S.-person beneficial owners. This is a structural finding, not an incident. Nothing changed in Texas own statute; what changed is the federal architecture around it, and the effect is to elevate a pre-existing structural feature into a more significant enabler-jurisdiction consideration, particularly measured against the Financial Action Task Force Recommendation 24 standard on beneficial ownership transparency for legal persons. #### Other Developments A correction to the standing AML/CTF baseline. Texas Finance Code Chapter 151 was repealed outright and replaced by Chapter 152, the Money Services Modernization Act, effective September 1, 2023, under Senate Bill 895 of the 88th Legislature; House Bill 3833, effective September 1, 2025, made further technical amendments at the Department of Bankings request. The operative money-services and money-transmission licensing chapter for Texas is Chapter 152, not Chapter 151. This is a baseline-descriptive correction: any standing record still citing Chapter 151 as current law describes a repealed statute. Department of Banking reaffirms a narrow stablecoin perimeter. Testimony from the Texas Department of Banking, dated July 30, 2026, confirms that money or monetary value under Chapter 152 includes a stablecoin only where it is pegged to a sovereign currency, fully backed by assets held in reserve, and redeemable for that sovereign currency. Bitcoin and similar non-redeemable tokens sit outside this definition and are therefore excluded from Chapter 152 money-transmission licensing. This is consistent with the Departments own Supervisory Memorandum 1037 and represents a reaffirmation, not a change, of the existing licensing perimeter. The Texas Strategic Bitcoin Reserve moves from statute into implementation. Under the Texas Strategic Bitcoin Reserve and Investment Act (Senate Bill 21), the Comptroller of Public Accounts named a five-person statutory advisory committee on May 28, 2026, and issued a custody and liquidity-services procurement solicitation, SmartBuy solicitation number 908-26-1778WS, posted May 7, 2026 with responses due June 15, 2026. This is a novel form of state-sovereign digital-asset holding and introduces a custody-vendor due-diligence question that compliance-technology functions have not previously had to consider at the level of a U.S. state treasury function. A parallel, non-sanctions economic-pressure architecture continues to operate. The Texas Comptroller of Public Accounts administers statutory scrutinized-companies lists covering energy-sector boycotts, boycotts of Israel, ties to foreign terrorist organizations, and Sudan- and Iran-related exposure, which trigger mandatory state-contract exclusion and public-fund divestment. These lists were updated in August 2026. This mechanism operates under state procurement and investment statute, independent of and parallel to federal OFAC sanctions administration, and functions as a state-level enabler-denial tool even though it is not a sanctions programme in the federal sense. #### Cross-Monitor Connections The beneficial-ownership finding connects directly to World Payments Monitor coverage of the same Chapter 151-to-Chapter 152 recodification, which that monitor reads through a licensing-perimeter lens rather than an enabler-jurisdiction lens; the two readings are complementary rather than duplicative. The Strategic Bitcoin Reserve implementation activity is also relevant to the Crypto monitors licensing coverage, where the same Department of Banking stablecoin-classification testimony is the anchoring source, and to compliance-technology functions assessing custody-vendor risk for a state-sovereign digital-asset holding, a novelty with no close precedent elsewhere in the fleets jurisdiction set. #### Outlook The federal CTA narrowing is now in force and its effect on Texas enabler-jurisdiction standing should be treated as a durable baseline shift rather than a one-cycle event; watch for any state-level legislative response that either tightens Texas own LLC disclosure requirements independent of the federal backstop, or leaves the gap as-is. The Strategic Bitcoin Reserve custody procurement outcome, expected as scheduled around the fourth quarter of 2026, will be the next concrete implementation milestone and will determine which custodian bears responsibility for the states digital-asset holding. No near-term change is expected to the Chapter 152 stablecoin-licensing perimeter, which the Department of Banking has now reaffirmed twice in substance this year. 22 Sep 2026 · fim-2026-09-14 #### Lead Signal Texas closed a previously under-regulated cash-to-crypto laundering vector this cycle by enacting Finance Code Chapter 161 under SB 1705, effective September 1, 2025, which requires virtual-currency-kiosk operators to hold a Chapter 152 money-transmission license, register with the Finance Commission of Texas and the Texas Department of Licensing and Regulation, deploy blockchain-analytics and antifraud policies, and furnish limited transaction-identifying information to law enforcement within a fixed window without subpoena. This is architecture, not incident: a state legislature moving preemptively to bring a physical, cash-facing crypto access channel inside a licensing and analytics perimeter before that channel generated a documented enforcement scandal of its own. Alongside the kiosk regime, HB 4233 amended Finance Code Chapter 160 to consolidate a quarterly customer-accounting requirement for digital-asset custodians, effective the same date. Both statutes sit on top of the confirmed foundation that Texas's core money-services statute was repealed and replaced in 2023 — Chapter 151 succeeded by Chapter 152, the Money Services Modernization Act, with HB 3833 in 2025 making further Department-requested clarifications. Chapter 151 should now be treated as dead law wherever any downstream tracker still cites it. #### Other Developments Lottery Commission abolition carries an explicit money-laundering thread. Following 2023 and 2025 bulk-ticket jackpot controversies, Texas lawmakers voiced explicit concern about the potential for money laundering through couriers or bulk purchase of lottery tickets. The Legislature abolished the Texas Lottery Commission, formally dissolved September 1, 2025, and former executive director Gary Grief was indicted in 2026 on a felony abuse-of-official-capacity charge, with the defunct Commission itself also indicted. This finding is held at Probable confidence: the money-laundering characterization derives from legislator statements reported in the press rather than a primary regulatory finding, even though the abolition and indictment themselves are independently corroborated. #### Cross-Monitor Connections The virtual-currency-kiosk licensing regime connects directly to the world-payments monitor's W1a (Licensing, Authorisation & Market Access) coverage of the same Chapter 161 development, and to the crypto monitor's crypto_licensing and consumer_protection modules, which read the identical statutory text for its digital-asset-market and consumer-disclosure implications rather than its AML-architecture implications. The lottery-abolition and indictment thread also intersects with advennt's gambling-regulatory coverage of the same Texas Lottery Commission events, though the money-laundering framing rendered here is specific to the financial-integrity lens on legislator statements about courier and bulk-purchase risk. #### Outlook The Finance Commission of Texas has not yet finalized implementing rules for Chapter 161's kiosk registration and blockchain-analytics standards; these are expected around 2026-Q4 and, once adopted, will convert the statute's framework-level analytics and antifraud requirements into concrete tooling and reporting-format obligations. The next cycle should also watch for any further primary-source documentation of the Lottery Commission successor-governance mechanics under TDLR, which remain under-documented at the T1 tier despite the significance of the abolition itself. 28 Aug 2026 · fim-2026-08-21 #### Lead Signal OFAC has designated two Mexican nationals and nine entities linked to Cartel Jalisco Nueva Generacion fuel-smuggling and tax-evasion schemes, an action paired with a FinCEN supplemental alert issued in coordination with the South Texas Homeland Security Task Force. Fiscal fuel theft, known regionally as huachicoleo, has become the largest non-narcotics illicit-revenue stream for Mexican cartels, laundered through falsified customs documentation and cross-border tanker and rail movement directly into South Texas. The joint OFAC-FinCEN posture, explicitly naming a South Texas task force as a partner, signals that border fuel-theft laundering is now treated as a standing cross-border architecture rather than a series of unconnected incidents, with direct relevance to banks, trade-finance desks and correspondent-banking relationships operating along the Texas-Mexico corridor. This finding is assessed as high confidence and grounded in a primary FinCEN release. It arrives alongside a second, independently significant development: a joint Texas Department of Banking and Colorado Division of Banking consent order against a licensed money transmitter for anti-money-laundering program deficiencies, including allegedly late currency-transaction and cross-border-currency reporting and inadequate agent monitoring, resolved with a 200,000 dollar penalty and an independent compliance monitor without admission of wrongdoing. The pairing of a federal sanctions action with a state-level AML consent order in the same reporting cycle illustrates the three-pillar balance this monitor tracks: the CJNG action is squarely a sanctions-evasion and CTF architecture matter, while the joint consent order is a domestic AML program-adequacy finding, and both bear on the same underlying exposure along a border state structurally positioned to intermediate illicit value movement. #### Other Developments A federal rollback of beneficial-ownership transparency arrived via a FinCEN final rule, effective August 14, 2026, permanently ending Corporate Transparency Act beneficial-ownership-information reporting for United States companies and United States persons, retaining reporting only for the foreign beneficial owners of foreign reporting companies, and providing for deletion of previously filed US-person beneficial-ownership data. No Texas-specific variance from this federal posture was identified this cycle, meaning Texas-registered entities are subject to the same national rollback affecting the rest of the country, without any offsetting state-level beneficial-ownership regime identified to fill the resulting transparency gap. A new state-level virtual-currency-kiosk regime took shape in Texas Finance Code Chapter 161, created by SB 1705 and effective September 1, 2025, requiring kiosk operators to register with the Texas Department of Banking, deploy blockchain-analytics and anti-fraud policies, cap daily transactions at 3,000 dollars, impose a 72-hour hold on first-time customers, and respond to law-enforcement information requests within 72 hours. The statute is explicitly aimed at elder-fraud and money-laundering typologies associated with kiosk-based cash-to-crypto conversion. Securities enforcement against a fraudulent crypto-mining investment scheme came from the Texas State Securities Board, which issued an emergency cease-and-desist order against TEXITcoin, MineTXC, Blockchain Mint and their founder for the fraudulent offer and sale of cryptocurrency-mining investment packages to Texas residents. Unlicensed and non-compliant money-transmission enforcement continued through Texas Department of Banking consent orders against Brotherhood Works, LLC, for conducting money transmission without a license, and against SeedTrust, LLC, for related Chapter 152 violations, each carrying an administrative penalty. #### Cross-Monitor Connections The Texas Department of Banking enforcement against a licensed money transmitter, together with the Brotherhood Works and SeedTrust consent orders, sits directly alongside the World Payments Monitor licensing and market-access tracking of the same statute and, in the first case, the same underlying entity; where the World Payments Monitor reads these actions as licensing-authorisation events, this monitor reads the identical facts as an AML/CTF program-adequacy finding. The Chapter 161 virtual-currency-kiosk regime is a shared substrate with the Crypto Monitor licensing and consumer-protection modules: the kiosk statute blockchain-analytics mandate, transaction cap and customer hold are, from this monitor vantage, AML/CTF and financial-innovation controls responding to elder-fraud and layering typologies, even as the Crypto Monitor treats the same statute primarily as a market-structure and consumer-protection development. Neither reading displaces the other; the same legislative and enforcement record supports both an illicit-finance lens and a market-structure lens without duplication of underlying fact-finding. #### Outlook The compensatory state-supervisory posture adopted by Texas is likely to remain the dominant AML/CTF signal for this jurisdiction while the federal beneficial-ownership architecture continues to unwind. FinCEN proposed reform of BSA AML/CFT program requirements toward a risk-based, outcomes-focused standard, expected around the first quarter of 2027, would touch Texas-licensed money-services businesses directly if finalised, and is a horizon item worth tracking alongside continuing Department of Banking examination activity, including the multistate coordination pattern evidenced by the joint Texas-Colorado order. Internationally, Cambodia exposure to a third FATF grey-listing amid scam-centre and casino money-laundering concerns remains an assessed-confidence watch item with no confirmed plenary action yet, illustrating the enforcement-versus-enablement divergence this monitor tracks across jurisdictions even where no direct Texas nexus is established this cycle. Continued monitoring will also track whether any state-level substitute for the CTA rollback emerges, given the absence of a comparable Texas beneficial-ownership disclosure regime identified to date. 11 Aug 2026 · fim-2026-08-05 #### Lead Signal The clearest signal this cycle is a bifurcated sanctions posture at OFAC: on 24 June 2026 the agency removed seven individuals and two Turkish intermediary entities from the Specially Designated Nationals list, following a similar mass removal on 28 May 2026, while the underlying Russia sanctions architecture under EO 14024 remains fully in force and OFAC simultaneously escalated designations against casino- and scam-linked laundering infrastructure. On 6 March 2026, OFAC designated the Bolai/Brilliancy Sihanoukville Investment and Development network under EO 14390 for laundering at least USD 73 million in victim funds through US-linked accounts, coordinated with the Department of Justice's Scam Center Strike Force. This calibrated posture, assessed at Assessed confidence, indicates a strategy of narrowing accumulation on lapsed-grounds individual designations while intensifying enforcement on high-severity laundering nodes, rather than a broad recalibration of the sanctions program itself. #### Other Developments The EU's AML Package reaches a structural inflection point. On 10 July 2026, the sixth Anti-Money Laundering Directive's core beneficial-ownership register provisions (Articles 11 to 13 and 15) and the Anti-Money Laundering Authority's package of 23 regulatory and implementing technical standards both fell due, a full year ahead of the AML Regulation's 10 July 2027 full direct-applicability date. Eleven member states remain in open infringement proceedings over the earlier 2025 register-access deadline, meaning the beneficial-ownership supervisory perimeter will remain uneven even as the technical-standards architecture matures. Laos's Golden Triangle Special Economic Zone persists as an enabler-jurisdiction enclave. The Kings Romans-anchored zone continues to operate under a 99-year Lao concession to Zhao Wei's Magnitsky-sanctioned network, co-locating casino, crypto-exchange, and underground-banking activity outside effective state policing. The United Kingdom's failure-to-prevent-fraud offence is now operative. The Economic Crime and Corporate Transparency Act 2023's corporate offence took effect on 1 September 2025, with Home Office guidance built on six Bribery-Act-style principles; it is a distinct, non-replacing overlay on the Money Laundering Regulations 2017 for large UK and foreign organisations with a UK nexus. Colombia receives an unprecedented counternarcotics designation. The FY2026 Presidential Foreign Relations Authorization Act determination named Colombia as having failed demonstrably to meet its counternarcotics obligations, citing record coca cultivation, the first such finding in nearly thirty years, though sanctions were waived on national-interest grounds. FinCEN and OFAC widen enforcement against Mexico-based gambling establishments. Ten gambling establishments and their leadership were found to be of primary money-laundering concern in connection with Sinaloa Cartel laundering, coordinated with the Government of Mexico, identifying gambling as a trade-based money-laundering channel for narcotics proceeds. A related June 2026 FinCEN supplemental alert extended prior cross-border money-laundering-network typologies to fuel-smuggling and tax-evasion activity tied to the CJNG. Treasury advances stablecoin AML/CFT rulemaking. A proposed rule published 10 April 2026 sets AML/CFT and sanctions-compliance program requirements for GENIUS Act Permitted Payment Stablecoin Issuers, closing a structural gap between the Act's federal floor and existing Bank Secrecy Act obligations; the comment period closed 9 June 2026. Separately, Chainalysis reported USD 158 billion in illicit crypto flows in 2025, a 145 percent year-on-year increase. #### Cross-Monitor Connections The Cambodia and Laos enabler-jurisdiction findings sit squarely at the intersection of this monitor's sanctions and enabler-jurisdiction pillars and a state-capture reading: both jurisdictions illustrate weak or ceded state oversight converting casino and crypto infrastructure into laundering platforms rather than active state direction of the laundering itself. The Colombia and Mexico developments connect directly to conflict- and narco-finance monitoring of the Andean-Caribbean and Mexican corridors, where gambling and trade-finance channels are being used to launder narcotics proceeds. The GENIUS Act stablecoin rulemaking and the Chainalysis illicit-flows data point together toward a widening digital-asset risk-vector picture that intersects with sanctions-evasion monitoring wherever mixers, DeFi protocols, or self-hosted wallets are used to obscure counterparty exposure. #### Outlook Watch the AMLA technical-standards package's submission to the European Commission and the continuing infringement proceedings against the eleven-member-state cohort as the near-term test of whether the EU's beneficial-ownership supervisory perimeter closes the gap ahead of the AML Regulation's 2027 application date. On the US side, the GENIUS Act's state-certification review and the stablecoin AML/CFT final rule are the developments most likely to reshape the digital-asset compliance perimeter this year. Colombia's designation, though sanctions-waived on national-interest grounds, elevates counterparty-risk scrutiny for Colombia-exposed firms and is worth tracking for whether the waiver posture persists into the next review cycle. Southeast Asian casino-linked laundering enclaves in Cambodia and Laos remain the most acute enabler-jurisdiction risk surfaced this cycle and warrant continued monitoring for further designations or a possible additional FATF grey-list placement. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion The defining D1 development this cycle is OFAC Iran General License X, issued 22 June 2026 following a 17 June 2026 US-Iran memorandum of understanding establishing a 60-day de-escalation framework. GL X authorises production, delivery, sale and importation of Iranian-origin crude, petrochemical and petroleum products, plus USD-denominated payments to Iran and sanctioned Iranian entities and associated shipping, insurance and financing services, through 21 August 2026. Multiple T3 legal analyses independently characterise it as the broadest Iran sanctions relief in over a decade, materially broader than the narrow safety and environmental licenses it might otherwise be analogised to - though the significance judgment itself is held at Assessed confidence given reliance on secondary legal-analysis corroboration, while the licenses existence and scope are High-confidence, T1-sourced facts. Architecture over incident applies directly here: GL X is not a single transaction authorisation but a temporary reconfiguration of the entire Iran sanctions perimeter for Gulf Coast-facing energy trade, and its analytical significance lies in what it enables for the license window, not merely in the license as an administrative event. Continue reading Running parallel to the Iran relief is a persistent evasion architecture that GL X does not eliminate: Iran continues to use exchange houses, Gulf and Asia front companies, AIS-manipulated shipping and shadow-banking payment networks to move oil-sale proceeds. Texas Gulf Coast refining and import counterparties remain exposed to disguised Iranian-origin barrels and associated payment flows regardless of the temporary authorisation, since the underlying laundering infrastructure long precedes and will likely outlast the 60-day window. On the enforcement side, OFAC designated three Mexican nationals and two Mexico-based entities linked to a CJNG-affiliated fuel-theft network under Executive Order 14059, coordinated with FinCENs Cartel Oil Smuggling Alert of 1 May 2025 - a cross-pillar AML/CTF finding given CJNGs status as a designated Foreign Terrorist Organization. A structural friction point running through the domain is sanctions-regime divergence: OFACs Iran and Russia designations and general licenses, including GL X and Russia General License 134C (authorising delivery and sale of Russian-origin crude and petroleum products loaded on vessels as of 17 April 2026), are not fully mirrored by EU and UK sanctions lists. This characterisation is synthesised from multiple T1 OFAC primary records rather than independently confirmed against EU or UK primary sources, and is accordingly held at Assessed rather than High confidence. The practical consequence for Gulf Coast energy-trading and refining compliance teams is a widening multi-regime screening burden, where an activity authorised under one regimes general license may carry residual exposure under another regimes unmirrored list. #### Outlook The GL X window closes 21 August 2026, and its expiry, renewal or non-renewal will be the primary D1 signal to track into the following cycle, particularly given the 60-day de-escalation frameworks own uncertain durability. Separately, the practical trade-volume impact of GL X on Gulf Coast refiners and import terminals has not yet been quantified from primary trade-flow data, leaving a measurement gap between the licenses legal scope and its observed market effect. Continued OFAC/EU/UK list divergence should be watched for whether either bloc moves to harmonise treatment of Iran or Russia general-license carve-outs, or whether the gap widens further as the US pursues an increasingly bespoke licensing posture. Judgment: No Texas-specific sanctions-architecture or evasion signal this cycle; coverage gap, not a finding of stability. Uncertain #### Beneficial Ownership Globally, the structural direction of beneficial-ownership and corporate-transparency policy continues to run through the European Union's AML Package, built on three distinct instruments: the directly applicable AML Regulation (Regulation (EU) 2024/1624), the sixth AML Directive requiring Member State transposition, and the Anti-Money Laundering Authority Regulation (Regulation (EU) 2024/1620) establishing a supervisor that is progressively shifting oversight of cross-border obliged entities from purely national authorities toward a hybrid EU-level perimeter. Texas sits entirely outside that architecture; it has no AMLA exposure and no 6AMLD transposition obligation. The directly relevant development for Texas this cycle is domestic, not European: confirmation that FinCEN's March 2025 interim final rule exempts domestically formed companies, including Texas-formed LLCs and corporations, from Corporate Transparency Act beneficial-ownership reporting, leaving only foreign entities registered to do business in the United States within the reporting population. Continue reading This finding closes what had been an outstanding coverage gap for the jurisdiction: whether the domestic exemption persisted, and what venue any further challenge to it would run through. Both questions now have an answer. The exemption for domestically formed entities appears to be holding, and the Eastern District of Texas remains the forum of record, since the underlying litigation (Smith v. U.S. Department of the Treasury) was brought by plaintiffs who had formed Texas LLCs to hold real property and obtained a nationwide injunction that remains in force on the residual question the exemption did not resolve. For a reader tracking exposure rather than the litigation's procedural posture, the operative fact is that Texas entities able to form LLCs and corporations domestically currently face no federal beneficial-ownership filing obligation, a materially different position from where the Corporate Transparency Act's reporting regime initially stood before the exemption rule. The practical consequence for counterparties doing diligence on Texas-formed entities is that beneficial-ownership information is not centrally available through a federal registry for the great majority of domestic entities, since reporting applies only to the foreign-entity subset. This narrows, rather than closes, the avenues available to financial institutions and other obliged entities seeking ownership transparency on Texas counterparties for risk-based due diligence purposes; the gap is a structural one created by the exemption rule, not a gap in Texas's own corporate law, which continues to require standard formation documents through the Texas Secretary of State but does not itself mandate beneficial-ownership disclosure beyond that baseline. No additional Texas-specific transparency measure -- a state-level beneficial-ownership register, for instance -- was identified this cycle as having emerged to fill the space the federal exemption leaves. Absent such a measure, Texas's beneficial-ownership transparency posture for domestic entities currently rests entirely on whatever the Eastern District of Texas litigation eventually resolves regarding the exemption rule's validity, and on the continuing requirement that foreign entities registering to do business in Texas report under the Corporate Transparency Act's narrower surviving scope. #### Outlook The most likely near-term development remains judicial rather than legislative: any further ruling out of the Eastern District of Texas on the residual nationwide injunction could either reinforce the domestic exemption as currently understood or reopen reporting obligations for Texas-formed entities depending on how the court resolves the underlying challenge. Firms relying on the current exemption in their own compliance posture should treat it as the operative position as at this cycle rather than as a permanently settled one, given that the litigation generating it has not concluded. No change to this posture is expected imminently absent a ruling, and no competing state-level transparency initiative was identified as in development for Texas this cycle. Judgment: CTA domestic-entity exemption confirmed persisting for Texas-formed companies; E.D. Texas remains litigation venue for residual nationwide injunction. Fills a prior-cycle coverage gap. Probable #### Enabler Jurisdictions and Professional Facilitators Texas functions this cycle as FinCENs principal Southwest Border enforcement testbed, and the domains picture is genuinely mixed: expanded regulatory tooling sits alongside evidence that the underlying professional-laundering infrastructure remains only partially disrupted. FinCENs expanded Southwest Border Geographic Targeting Order, effective 7 March 2026 through 2 September 2026, lowers Currency Transaction Report thresholds across a $200 to $10,000 tiered structure for covered Texas border-area money services businesses, extending a standing enforcement architecture rather than introducing a novel tool. Continue reading The cycles most significant enforcement action - FinCENs first-ever penalty against an armored-car company - illustrates the limits of treating enforcement volume as a proxy for enforcement effectiveness. The $37,000,000 civil money penalty against Brinks Global Services USA, assessed 6 February 2025, addressed willful Bank Secrecy Act violations tied to hundreds of millions of dollars in bulk-currency shipments across the Southwest border on behalf of high-risk entities, including a Mexican currency exchanger. The underlying conduct dates to approximately October 2018 through October 2020, meaning the penalty was assessed roughly four and a half years after the violation period closed. That lag is material: it should temper any reading of the action as evidence of current enforcement intensity, since it reflects historical case-closure rather than a live deterrent against present-day bulk-cash smuggling activity. The sub-national supervisory picture compounds this caution. No independent, state-agency-originated enforcement action or public examination report specific to the recent window could be located for the Texas Department of Banking; the sub-national supervisory record instead relies entirely on the OFAC-Texas Department of Banking memorandum of understanding and on federal FinCEN and OFAC actions. This is a genuine sourcing-thinness gap rather than a finding of state-level inactivity, and it limits the ability to independently verify state-level supervisory intensity against Texas-chartered banks and state-licensed money services businesses. #### Outlook The Southwest Border Geographic Targeting Order reaches its next decision point on 2 September 2026, when FinCEN must decide whether to renew, expand, or allow the order to lapse; that decision will materially affect low-dollar cash reporting coverage across Texas border-area money services businesses and is the domains primary forward signal. Future cycles should directly search Texas Department of Banking disclosures to close the sub-national supervisory-intensity gap rather than continuing to infer state-level posture solely from federal action and the OFAC-TDB memorandum of understanding. Judgment: No Texas-specific enabler-jurisdiction signal this cycle. Uncertain #### Conflict Finance and Extractive-Industry Integrity This cycles priority D4 finding is a cartel-linked trade-based money-laundering architecture that constitutes a direct FinCEN alert primary-source description of an active, structural scheme rather than an isolated incident - an architecture-over-incident finding in the fullest sense. Cartel-affiliated huachicoleros steal fuel and crude oil from Pemex; Texas-based importers then purchase the stolen product at a steep discount and blend or resell it into US and global energy markets before repatriating the significant illicit profits back to Mexico via trade and financial channels. The scheme exploits the integrated US-Mexico energy trading relationship directly, using legitimate-looking trade documentation and blending processes to obscure the stolen origin of the underlying commodity. Continue reading This is a conflict/organised-violence-finance analogue distinct from FIMs traditional Sahel and DRC standing coverage, but methodologically identical to it: illicit extraction, discounted resale through ostensibly licit trade infrastructure, and profit repatriation to the originating conflict actor. The enforcement response has moved in step with the finding: OFAC designated three Mexican nationals and two Mexico-based entities linked to the network under Executive Order 14059, coordinated with FinCENs Cartel Oil Smuggling Alert of 1 May 2025. The significance of this designation is heightened by CJNGs status as a designated Foreign Terrorist Organization, which elevates the finding to a cross-pillar AML/CTF matter rather than a purely financial-integrity one - the fuel-theft revenue in question directly finances an organisation now formally treated as a terrorist entity by the United States government. A parallel Department of Justice prosecution in the Southern District of Texas, indicting a father and son for material support to the designated cartel, further evidences the cross-pillar treatment being applied to this architecture at the prosecutorial level. #### Outlook The key forward question for this domain is whether OFAC and FinCEN sustain and expand designations against the broader huachicolero-linked network beyond the initial five designated parties, or whether the architecture proves resilient to node-level removal in the way that comparable laundering-network typologies have shown elsewhere. The practical trade-volume and financial-flow impact of the underlying smuggling architecture on Gulf Coast and Permian Basin energy markets has not yet been quantified from primary trade-flow data, representing a measurement gap for future cycles to close. Judgment: No Texas-specific conflict-finance signal this cycle. Uncertain #### Crypto / Digital Assets / Financial Innovation Texas this cycle illustrates a jurisdiction actively enforcing its general money-transmission gateway against digital-asset activity in the same window that a federal statute is finalised to remove a meaningful slice of that gateway's future relevance. In September 2026 the Texas Banking Commissioner issued consent orders against two cryptocurrency and payment companies -- OKX and Triple A -- resolving allegations that each conducted money transmission involving stablecoin activity in Texas without holding the required licence under Chapter 152, the Money Services Modernization Act that took effect 1 September 2023 and replaced the former Chapter 151. No primary consent-order text was retrieved this cycle, so the specific penalty amounts and precise provisions cited against each firm remain unverified from primary sources; what is confirmed is that the actions occurred and rest on the general money-transmitter licensing gateway rather than any bespoke Texas crypto licence, since Texas, like most US states, regulates stablecoin and virtual-currency money transmission by applying its existing money-services framework rather than through purpose-built digital-asset legislation. Continue reading That state-level enforcement sits against a federal backdrop that shifted materially this cycle. On 23 October 2026 the Office of the Comptroller of the Currency published Federal Register implementing regulations for the GENIUS Act, confirming that Section 5(h) of the Act (12 U.S.C. 5904(h)) preempts any state requirement for a charter, licence or other authorisation to do business with respect to a federal qualified payment stablecoin issuer, effective from 18 January 2027. From that date, an issuer that qualifies as federally regulated under the Act moves out from under the Chapter 152 gateway entirely for licensing purposes, leaving Texas's own regime relevant mainly to non-qualifying issuers and to other categories of money transmission that do not meet the federal qualification criteria. The effect is a narrowing of the state's future jurisdiction over a specific category of stablecoin activity, not an elimination of Texas's role in supervising crypto-adjacent money transmission generally. The juxtaposition is analytically significant in its own right: a state regulator demonstrating active, recent enforcement capacity against unlicensed stablecoin money transmission just months before a federal statute narrows that regulator's jurisdictional reach for a subset of the same activity. This is not evidence of regulatory retreat in Texas; if anything the OKX and Triple A actions show the Texas Department of Banking applying its existing tools vigorously in the run-up to the federal transition, which may reflect an effort to establish enforcement precedent and compliance expectations for market participants before the jurisdictional map changes. Firms operating stablecoin or other digital-asset money-transmission activity touching Texas should read the current enforcement posture as the baseline reality now, with the federal preemption date functioning as a known future inflection rather than present relief from the state licensing requirement. #### Outlook The defining date for this domain is 18 January 2027, when the GENIUS Act's implementing regulations take effect and the state licensing preemption for federally qualified payment stablecoin issuers becomes operative. Between now and then, the Chapter 152 gateway remains fully in force for all stablecoin and virtual-currency money transmission touching Texas, and the OKX/Triple A actions signal continuing Texas Department of Banking appetite to enforce it. Whether the Texas Department of Banking will issue its own guidance reconciling the state framework with the incoming federal preemption was not identified this cycle and remains an open question worth monitoring, since the practical boundary between qualifying and non-qualifying issuers will determine how much of the state's current enforcement reach survives past the effective date. Judgment: TX DOB consent orders against OKX/Triple A for unlicensed stablecoin money transmission, plus the GENIUS Act's federal implementing regulations finalized this cycle, together represent material movement narrowing the state gateway's future scope while confirming active current enforcement. Probable Judgment: No RegTech/compliance-technology development for Texas this cycle; D6 exempt from substantive-finding floor. Uncertain #### AML/CTF Regime Texas AML/CTF supervision operates primarily through Finance Code Chapter 152, governing money transmission, and the newly enacted Chapter 161, governing virtual-currency kiosks, with the Texas Department of Banking as the designated supervisory authority. This cycle evidences an active examination and enforcement posture across both statutory tracks. Most significantly, a joint consent order between the Texas Department of Banking and the Colorado Division of Banking was entered against a licensed, multistate money transmitter for AML/CFT program deficiencies, including allegedly late currency-transaction and cross-border-currency reporting, inadequate agent monitoring, and Federal Trade Commission Safeguards Rule violations; the matter was resolved with a 200,000 dollar penalty and an independent compliance monitor, without admission of wrongdoing. This finding is sourced to two independent legal-press accounts rather than a located primary consent-order text, and confidence is accordingly assessed rather than high, though the multistate coordination between two state banking regulators is itself a notable supervisory-architecture signal: it indicates that Texas AML/CTF oversight of multistate-licensed money transmitters increasingly proceeds through coordinated, cross-state examination rather than purely unilateral state action. Continue reading Separately, and with high confidence grounded in a primary Texas Department of Banking supervisory publication, the Department issued consent orders against Brotherhood Works, LLC, for conducting money transmission without a license, and against SeedTrust, LLC, for related Chapter 152 violations, with administrative penalties applied in both matters. These are incident-level enforcement findings against unlicensed or non-compliant operators rather than architectural changes to the statutory framework, but they demonstrate that the Texas Department of Banking active-enforcement posture extends to unlicensed-activity detection as well as licensed-entity program-adequacy review. Taken together, this cycle evidence base supports a preliminary severity assessment of elevated for the joint multistate consent order, given its program-deficiency findings and monitor requirement, and monitored for the unlicensed-activity consent orders, which are more routine enforcement matters. The overall AML/CTF regime trajectory for Texas this cycle is best characterised as stable-but-active: no statutory change to Chapter 152 itself was identified, but supervisory and enforcement activity under the existing framework, plus the new Chapter 161 kiosk layer, remains continuous. #### Outlook Continuing multistate examination coordination, following the pattern evidenced by the joint Texas-Colorado consent order, is a reasonable expectation for other multistate-licensed money transmitters operating in Texas. FinCEN proposed reform of BSA AML/CFT program requirements toward a risk-based, outcomes-focused standard, expected around the first quarter of 2027, would, if finalised, apply to Texas-licensed money-services businesses and could shift examination emphasis from prescriptive checklist compliance toward risk-based program-effectiveness testing; this is a horizon item rather than a current obligation. This monitor will continue to track whether a located primary consent-order text becomes available for the joint Texas-Colorado matter, which would allow an upgrade from assessed to high confidence. Judgment: Standing Texas BSA/AML examination regime for MSBs unchanged this cycle; June 2026 TX-CO joint consent order illustrates active supervision of the standing framework. Probable Judgment: No financial-integrity-market commercial transaction identified for Texas this cycle. Uncertain Regulatory horizon Adopted 18 Jan 2027 · ±quarter ### GENIUS Act implementing regulations effective date Beginning 18 January 2027, federally qualified payment stablecoin issuers and approved insured-depository-institution subsidiaries are licensed, regulated and supervised exclusively by the OCC/primary federal regulator, preempting state charter/license requirements under 12 U.S.C. 5904(h). [Source](https://www.federalregister.gov/documents/2026/10/23/2026-21706) 1 dated · 1 pending date · baseline financial-integrity-2026-07-05 Role action cards MLRO ### Texas enforced its stablecoin money-transmission gateway against two named firms while a federal preemption of that same gateway was finalised for a future date. Suspicious-activity and licensing-compliance posture for stablecoin-related money transmission touching Texas should assume the current state licensing requirement remains fully live until 18 January 2027, regardless of the firm's eventual federal qualification status. 2 evidence refs Compliance ### A domestic beneficial-ownership reporting exemption for Texas-formed entities was confirmed as persisting, narrowing available ownership-transparency data sources. Due diligence programmes relying on Corporate Transparency Act filings for Texas-formed counterparties should recognise that domestic entities are currently out of scope, leaving only the foreign-entity subset reportable. 1 evidence refs Legal ### The Eastern District of Texas remains the active venue for residual litigation over the Corporate Transparency Act's domestic-entity exemption. The exemption currently in effect for Texas-formed entities is not a fully settled legal position; it rests on an interim final rule and an ongoing nationwide injunction that could still be revisited by the court. 1 evidence refs Board ### A federal statute finalised this cycle will, from January 2027, remove state licensing authority over a defined category of stablecoin issuer operating in Texas. Institutions with stablecoin issuance or distribution exposure touching Texas face a dated jurisdictional transition that should be factored into licensing-strategy and market-entry planning well ahead of the effective date. 1 evidence refs CTO ### Platform architecture for stablecoin products touching Texas must accommodate a dual-track licensing reality until January 2027. Systems and onboarding logic that determine licensing applicability should be built to distinguish federally qualified issuers from non-qualifying activity, since only the former benefits from the incoming state-licensing preemption. 2 evidence refs Risk ### Concentration risk in unlicensed stablecoin money transmission was demonstrated through two named-firm enforcement actions this cycle. Exposure-concentration models for counterparties engaged in Texas-touching stablecoin flows should weight the demonstrated enforcement risk alongside the separate, later-arriving federal preemption benefit. 1 evidence refs Operations ### No material change to transaction-monitoring thresholds or screening parameters was identified for Texas this cycle. No material change for this persona this cycle Audit ### A joint multistate consent order illustrated continuing active supervision of the standing Bank Secrecy Act examination framework for money transmitters. Audit testing scope for AML/CTF controls at multistate-licensed money transmitters operating in Texas should account for demonstrated regulator attention to currency-transaction-reporting timeliness and agent-monitoring adequacy. 1 evidence refs Scenario sketches ### Illustrative supervisory transition under AMLA direct/indirect oversight As an illustration only, consider how the move from purely national AML supervision toward the Anti-Money Laundering Authority's direct and indirect supervision of cross-border obliged entities, operating alongside the directly applicable AML Regulation and per-state transposition of the sixth AML Directive, could reshape where evasion typologies migrate. A hybrid EU-level supervisory perimeter could, in principle, push layering activity toward obliged entities and corridors that remain under purely national oversight for longer, or toward non-EEA jurisdictions such as Texas where no equivalent supranational supervisory layer exists at all. This is a structural illustration of a possible dynamic, not an observed migration and not a prediction of where activity will in fact move. 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 No US-TX-specific signal this cycle. T2 · EU AML Package / AMLA no_change Not applicable to US-TX as a US subnational jurisdiction. T3 · FATF Grey List no_change No US-TX-specific FATF signal this cycle. T4 · Beneficial-Ownership Register Status stable CTA domestic-entity exemption persists; E.D. Texas remains litigation venue. T5 · Crypto & Digital-Asset Integrity material_change TX DOB consent orders against OKX/Triple A; GENIUS Act implementing regulations finalized Oct 23, 2026. T6 · Sanctions Regime Divergence no_change No US-TX-specific sanctions-regime divergence signal this cycle. Registers ### Enforcement actions - 6 Feb 2025 - 1 May 2025 - 30 May 2025 - 7 Mar 2026 - 9 Oct 2025 - 2025 - 6 Mar 2026 - 2026 - 22 Jun 2026 - 11 May 2026 - 8 May 2026 - 11 Feb 2026 - 2026-04 - 11 Sep 2026 - 23 Sep 2026 - 18 Jun 2026 - 2026-09 - 2026-09 - 22 Jun 2026 - FinCEN assessed a civil money penalty against Brink's for willful BSA violations tied to hundreds of millions of dollars in bulk-currency shipments transmitted across the Southwest border, including for a Mexican currency exchanger that later pleaded guilty to BSA violations, without an effective AML program or SAR filings. 6 Feb 2025 - OFAC sanctioned three Mexican nationals and two Mexico-based entities linked to CJNG's fuel theft and oil smuggling operations exploiting the Texas-Mexico border energy trade, pursuant to E.O. 14059 and related cartel-designation authorities. 1 May 2025 - DOJ's Southern District of Texas indicted a father and son for providing material support to a Mexican cartel engaged in terrorism, part of the broader federal push under E.O. 14157 designating cartels as Foreign Terrorist Organizations. 30 May 2025 - FinCEN issued and progressively expanded Southwest Border Geographic Targeting Orders requiring covered Texas-area MSBs to file Currency Transaction Reports at lowered cash thresholds ($200-$10,000 tiers) to combat cartel money laundering and fentanyl trafficking proceeds. 7 Mar 2026 - FinCEN renewed Residential Real Estate GTOs requiring Texas title insurance companies to identify natural persons behind legal-entity purchasers in non-financed residential real estate transactions, ahead of transition to a nationwide reporting rule. 9 Oct 2025 ### Sanctions changes - 6 Feb 2026 - 22 Jun 2026 - 18 Dec 2025 - 1 May 2025 - 24 Jun 2026 - 1 Oct 2025 - 6 Mar 2026 - 30 Jun 2026 - OFAC designated multiple individuals, Turkey- and UAE-based trading/shipping entities, and vessels (including a Panama-flagged oil products tanker) as SDNs under the Iran shadow-fleet program for facilitating illicit Iranian oil trade, in a broader campaign under NSPM-2 that has repeatedly targeted intermediaries relevant to Gulf Coast-bound energy trade counterparties. 6 Feb 2026 - OFAC issued Iran General License X authorizing the production, delivery and sale of crude oil, petrochemical products and petroleum products of Iranian origin through August 21, 2026, alongside earlier general licenses (Q, T) authorizing limited safety/environmental transactions for specific blocked vessels. 22 Jun 2026 - OFAC removed the remaining name from the Foreign Sanctions Evaders (FSE) list under E.O. 13608 (Iran/Syria sanctions evasion authority), effective December 18, 2025. 18 Dec 2025 - OFAC designated Mexican nationals and Mexico-based entities linked to CJNG's fuel theft and oil smuggling network operating along the Texas-Mexico border, pursuant to E.O. 14059 targeting the global illicit drug trade's non-narcotics revenue streams. 1 May 2025 ### Regulatory horizon (register) - UK ECCTA failure-to-prevent-fraud offence implementation status - Texas virtual currency kiosk implementing rulemaking (Ch.161) - Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 - GENIUS Act state-certification framework for payment-stablecoin issuers (Texas) - GENIUS Act implementing regulations effective date - Nationwide Residential Real Estate reporting rule takes effect - GENIUS Act stablecoin implementing rules deadline - Southwest Border GTO expiration/renewal decision point - US FATF Recommendation 24 follow-up progress reporting ### Active schemes - [CRITICAL] Cartel-linked fuel/crude oil smuggling across Texas border - [HIGH] Southwest-border bulk cash smuggling via armored carriers/MSBs - [CRITICAL] Iranian oil shadow-banking network with Gulf trade nexus - [HIGH] Beneficial-ownership opacity post-CTA domestic exemption - Virtual-currency payment channel in Texas shell-company real estate Sources - [The 2022 and 2013 Methodologies for Assessing Technical Compliance with the FATF Recommendations and the Effectiveness of AML/CFT/CPF Systems](https://www.fatf-gafi.org/content/fatf-gafi/en/publications/Mutualevaluations/Fatf-methodology.html) - [Texas Department of Banking](https://www.dob.texas.gov) - [https://natlawreview.com/article/texas-and-colorado-enter-joint-aml-enforcement-action-against-money-transmitter](https://natlawreview.com/article/texas-and-colorado-enter-joint-aml-enforcement-action-against-money-transmitter) - [https://www.dob.texas.gov/sites/default/files/files/Applications-Forms-Publications/Publications/Suns/suns05-26.pdf](https://www.dob.texas.gov/sites/default/files/files/Applications-Forms-Publications/Publications/Suns/suns05-26.pdf) - [https://capitol.texas.gov/tlodocs/89R/analysis/pdf/SB01705H.pdf](https://capitol.texas.gov/tlodocs/89R/analysis/pdf/SB01705H.pdf) - [https://www.fincen.gov/news/news-releases/fincen-issues-supplemental-alert-fuel-smuggling-and-tax-evasion-schemes-southern](https://www.fincen.gov/news/news-releases/fincen-issues-supplemental-alert-fuel-smuggling-and-tax-evasion-schemes-southern) - [https://www.fincen.gov/news/news-releases/fincen-permanently-ends-beneficial-ownership-reporting-requirements-millions](https://www.fincen.gov/news/news-releases/fincen-permanently-ends-beneficial-ownership-reporting-requirements-millions) - [https://www.ssb.texas.gov/news-publications/texas-grounds-crypto-mining-investment-rocket-ship](https://www.ssb.texas.gov/news-publications/texas-grounds-crypto-mining-investment-rocket-ship) - [https://agbrief.com/news/cambodia/26/01/2026/cambodia-battles-to-avoid-third-fatf-grey-list-placement-amid-scam-crackdown/](https://agbrief.com/news/cambodia/26/01/2026/cambodia-battles-to-avoid-third-fatf-grey-list-placement-amid-scam-crackdown/) - [https://www.bloomberg.com/features/2024-golden-triangle-special-economic-zone/](https://www.bloomberg.com/features/2024-golden-triangle-special-economic-zone/) - [https://statutes.capitol.texas.gov/Docs/FI/htm/FI.152.htm](https://statutes.capitol.texas.gov/Docs/FI/htm/FI.152.htm) - [https://www.dob.texas.gov/sites/default/files/files/Applications-Forms-Publications/Applications-Forms/152memo.pdf](https://www.dob.texas.gov/sites/default/files/files/Applications-Forms-Publications/Applications-Forms/152memo.pdf) - [https://capitol.texas.gov/tlodocs/89R/analysis/html/HB03833H.htm](https://capitol.texas.gov/tlodocs/89R/analysis/html/HB03833H.htm) - [https://capitol.texas.gov/tlodocs/89R/billtext/html/SB01705S.htm](https://capitol.texas.gov/tlodocs/89R/billtext/html/SB01705S.htm) - [https://capitol.texas.gov/tlodocs/89R/billtext/html/HB04233S.htm](https://capitol.texas.gov/tlodocs/89R/billtext/html/HB04233S.htm) - [https://www.texastribune.org/2025/04/24/texas-lottery-courier-ban-lawsuit/](https://www.texastribune.org/2025/04/24/texas-lottery-courier-ban-lawsuit/) - [https://www.houstonpublicmedia.org/articles/news/texas/2026/08/20/559936/former-texas-lottery-chief-heads-to-court-heres-how-the-agencys-troubles-unfolded/](https://www.houstonpublicmedia.org/articles/news/texas/2026/08/20/559936/former-texas-lottery-chief-heads-to-court-heres-how-the-agencys-troubles-unfolded/) - [Texas Comptroller of Public Accounts](https://comptroller.texas.gov/purchasing/publications/divestment.php) - [Texas Secretary of State](https://www.sos.state.tx.us/corp/cta.shtml) - [Financial Crimes Enforcement Network](https://www.fincen.gov/boi) - [MercConsulting](https://merc.consulting/knowledge/llc-ownership-privacy-public-records) - [Texas Legislature](https://capitol.texas.gov/tlodocs/89R/billtext/html/SB00021H.htm) - [Texas Department of Banking](https://www.dob.texas.gov/sites/default/files/files/news/Testimony/2026/07-30-26t.pdf) - [Texas Legislature](https://capitol.texas.gov/tlodocs/89R/analysis/html/HB03833H.htm) - [https://capitol.texas.gov/tlodocs/89R/analysis/html/HB03833E.htm](https://capitol.texas.gov/tlodocs/89R/analysis/html/HB03833E.htm) - [https://dob.texas.gov/sites/default/files/files/Applications-Forms-Publications/Publications/Suns/suns07-26.pdf](https://dob.texas.gov/sites/default/files/files/Applications-Forms-Publications/Publications/Suns/suns07-26.pdf) - [https://www.dob.texas.gov/sites/default/files/files/Laws-Regulations/orders/2026-004.pdf](https://www.dob.texas.gov/sites/default/files/files/Laws-Regulations/orders/2026-004.pdf) - [https://ofac.treasury.gov/press-releases](https://ofac.treasury.gov/press-releases) - [https://www.squirepattonboggs.com/insights/publications/sanctions-brief-october-2026/](https://www.squirepattonboggs.com/insights/publications/sanctions-brief-october-2026/) - [https://checklynx.com/en/resources/knowledge-base/fatf-grey-list](https://checklynx.com/en/resources/knowledge-base/fatf-grey-list) - [https://www.dob.texas.gov/sites/default/files/files/news/press-releases/2026/06-22-26pr.pdf](https://www.dob.texas.gov/sites/default/files/files/news/press-releases/2026/06-22-26pr.pdf) - [https://natlawreview.com/article/texas-banking-commissioner-penalizes-2-crypto-firms-unlicensed-money-transmission](https://natlawreview.com/article/texas-banking-commissioner-penalizes-2-crypto-firms-unlicensed-money-transmission) - [https://www.dob.texas.gov/sites/default/files/files/news/Testimony/2026/06-24-26t.pdf](https://www.dob.texas.gov/sites/default/files/files/news/Testimony/2026/06-24-26t.pdf) - [https://home.treasury.gov/news/press-releases/sb0603](https://home.treasury.gov/news/press-releases/sb0603) - [https://www.sheppard.com/insights/blogs/texas-department-of-banking-resolves-unlicensed-money-transmission-allegations](https://www.sheppard.com/insights/blogs/texas-department-of-banking-resolves-unlicensed-money-transmission-allegations) - [National Law Review](https://natlawreview.com/article/texas-banking-commissioner-penalizes-2-crypto-firms-unlicensed-money-transmission) - [Sheppard Mullin (law firm blog)](https://www.sheppard.com/insights/blogs/texas-and-colorado-enter-into-a-joint-aml-enforcement-action-against-money-transmitter) - [Texas Department of Banking](https://www.dob.texas.gov/sites/default/files/files/Laws-Regulations/New-Actions/sm1023.pdf) - [Office of the Comptroller of the Currency / U.S. Federal Register](https://www.federalregister.gov/documents/2026/10/23/2026-21706) - [ACAMS](https://www.acams.org/en/news/texas-judge-lifts-remaining-beneficial-ownership-roadblock) - [HCH Lawyers (law firm blog)](https://www.hchlawyers.com/blog/2025/march/fincen-removes-beneficial-ownership-reporting-re/) - [Faisal Khan LLC](https://faisalkhan.com/solutions/licensing/money-transmitter-license/texas-money-transmitter-license) - [MoneyTransmitterLaw.com](https://moneytransmitterlaw.com/state-laws/texas/) - [FinCEN Penalizes Texas Bank for Violations of Anti-Money Laundering Laws Focusing on Section 312 Due Diligence Violations | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-penalizes-texas-bank-violations-anti-money-laundering-laws-focusing) - [United States Department of the Treasury Financial Crimes Enforcement Network | FinCEN.gov](https://www.fincen.gov/?mc_eid=UNIQID) - [FinCEN Year In Review | FinCEN.gov](https://www.fincen.gov/about-fincen/fincen-year-review) - [Statement by FinCEN Director Andrea M. Gacki before the House Committee on Financial Services, Subcommittee on National Security, Illicit Finance, and International Financial Institutions | FinCEN.gov](https://www.fincen.gov/news/testimony/statement-fincen-director-andrea-m-gacki-house-committee-financial-services) - [Enforcement Actions | FinCEN.gov](https://www.fincen.gov/news/enforcement-actions) - [MEMORANDUM OF UNDERSTANDING U.S. ...](https://ofac.treasury.gov/media/31331/download?inline=) - [United States Department of the Treasury Financial Crimes Enforcement Network - Home | FinCEN.gov](https://www.fincen.gov/) - [The FATF Recommendations](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html) - [Treasury Convenes Financial Institutions and Law Enforcement to Identify and Dismantle Money Laundering Networks | FinCEN.gov](https://www.fincen.gov/news/news-releases/treasury-convenes-financial-institutions-and-law-enforcement-identify-and) - [Guidance | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance) - [FinCEN Issues Expanded Southwest Border Geographic Targeting Order | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-expanded-southwest-border-geographic-targeting-order) - [FinCEN Issues Modified Southwest Border Geographic Targeting Order | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-modified-southwest-border-geographic-targeting-order) - [1 Financial Crimes Enforcement Network (FinCEN)](https://www.fincen.gov/system/files/2026-05/FinCEN-Year-in-Review-2025.pdf) - [FinCEN Southwest Border GTO FAQs, 3/19/2026](https://www.fincen.gov/system/files/2026-03/SWB-GTO-FAQs.pdf) - [FinCEN Alert, FIN-2025-Alert003, November 26, 2025](https://www.fincen.gov/system/files/FinCEN_Alert_Cross_Border_FINAL508.pdf) - [Frequently Asked Questions | FinCEN.gov](https://www.fincen.gov/boi-faqs) - [FinCEN Issues Southwest Border Geographic Targeting Order | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-southwest-border-geographic-targeting-order) - [Beneficial Ownership Information Reporting | FinCEN.gov](https://www.fincen.gov/boi) - [1 1. See 31 U.S.C. § 5312(a)(2); 31 C.F.R. § 1010.100(t). 2.](https://www.fincen.gov/system/files/2026-06/FinCEN-Alert-Fiscal-Fuel-Theft.pdf) - [The DOJ's NCET Disbanded: What This Means for Digital Assets - Chainalysis](https://www.chainalysis.com/blog/ncet-blanche-memo/) - [FinCEN-Advisory-CMLN-508.pdf](https://www.fincen.gov/sites/default/files/advisory/2025-08-28/FinCEN-Advisory-CMLN-508.pdf) - [1 The U.S. Department of the Treasury’s (Treasury)](https://www.fincen.gov/system/files/2025-08/FinCEN-Advisory-CMLN-508.pdf) - [1 1. See 31 U.S.C. § 5312(a)(2); 31 CFR § 1010.100(t). 2.](https://www.fincen.gov/system/files/shared/FinCEN-Alert-Oil-Smuggling-FINAL-508C.pdf) - [Oil Smuggling Schemes on the U.S. Southwest Border ...](https://www.fincen.gov/sites/default/files/shared/FinCEN-Alert-Oil-Smuggling-FINAL-508C.pdf) - [U.S. Treasury Targets Sinaloa Cartel Adding Crypto Address to Sanctions List | TRM Blog](https://www.trmlabs.com/resources/blog/u-s-treasury-targets-sinaloa-cartel-adding-crypto-address-to-sanctions-list) - [Blockchain Legal Library](https://www.trmlabs.com/blockchain-legal-library) - [FinCEN Consent Order Imposing Civil Money Penalty](https://www.fincen.gov/system/files/enforcement_action/2025-02-06/FinCEN-Brinks-FINALv508.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 Renews Real Estate Geographic Targeting Orders | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-renews-real-estate-geographic-targeting-orders-0) - [Geographic Targeting Order Covering TITLE INSURANCE COMPANY April 14, 2025](https://www.fincen.gov/system/files/shared/RRE-GTO-Order-April-14-2025-FINAL508.pdf) - [Geographic Targeting Order Covering TITLE INSURANCE COMPANY October 9, 2025](https://www.fincen.gov/system/files/2025-10/RRE-GTO-Order.pdf) - [FREQUENTLY ASKED QUESTIONS Issued: October 9, 2025](https://www.fincen.gov/system/files/2025-10/RRE-GTO-FAQs.pdf) - [FinCEN Renews and Expands Real Estate Geographic Targeting Orders | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-renews-and-expands-real-estate-geographic-targeting-orders-0) - [FinCEN GEOGRAPHIC TARGETING ORDER, April 14, 2025](https://www.fincen.gov/sites/default/files/shared/RRE-GTO-Order-April-14-2025-FINAL508.pdf) - [Geographic Targeting Order Covering TITLE INSURANCE ...](https://www.fincen.gov/sites/default/files/shared/Real%20Estate%20GTO%20GENERIC_111518_FINAL%20508.pdf) - [FREQUENTLY ASKED QUESTIONS Issued: April 14, 2025](https://www.fincen.gov/system/files/shared/RRE-GTO-FAQs-FINAL508.pdf) - [FinCEN Renews Real Estate “Geographic Targeting Orders” to Identify High-End Cash Buyers in Six Major Metropolitan Areas | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-renews-real-estate-geographic-targeting-orders-identify-high-end-cash) - [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) - [Money Services Business (MSB) Registration | FinCEN.gov](https://www.fincen.gov/resources/money-services-business-msb-registration) - [Money Services Businesses | FinCEN.gov](https://www.fincen.gov/resources/financial-institutions/money-services-businesses?type=All&page=7) - [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 TO MONEY SERVICES BUSINESSES ON OBTAINING AND MAINTAINING BANKING SERVICES | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/guidance-money-services-businesses-obtaining-and) - [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) - [Important Information for MSBs | FinCEN.gov](https://www.fincen.gov/resources/financial-institutions/money-services-businesses?field_date_release_value=&field_date_release_value_1=&type=All&page=2) - [Advisory on Illicit Activity Involving Convertible Virtual ...](https://www.fincen.gov/system/files/advisory/2019-05-10/FinCEN%20Advisory%20CVC%20FINAL%20508.pdf) - [State Contact Information For MSBs](https://www.fincen.gov/sites/default/files/shared/msbstatecontactsfinal.pdf) - [Iran Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/iran-sanctions) - [Iran-related Designations; Publication of Updated Iran Shipping Advisory | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20250416) - [FinCEN Advisory on the Iranian Regime's Illicit Oil ...](https://www.fincen.gov/system/files/FinCEN-Advisory-Illicit-Oil-Smuggling-508.pdf) - [DEPARTMENT OF THE TREASURY WASHINGTON, D.C. OFFICE OF FOREIGN ASSETS CONTROL](https://ofac.treasury.gov/media/935376/download?inline=) - [Iran-related Designations | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20260206) - [PPSI-AMLCFT-NPRM.pdf](https://www.fincen.gov/system/files/2026-04/PPSI-AMLCFT-NPRM.pdf) - [OFAC ALERT](https://ofac.treasury.gov/media/935546/download) - [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [Issuance of Iran-related General License | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20260622_33) - [Sanctions List Updates](https://ofac.treasury.gov/recent-actions/sanctions-list-updates) - [Beneficial Ownership Information Frequently Asked Questions | FinCEN.gov](https://www.fincen.gov/boi/beneficial-ownership-information-frequently-asked-questions) - [FinCEN Alert, FIN-2024-Alert005, December 18, 2024](https://www.fincen.gov/system/files/2024-12/Alert-FinCEN-Scams-FINAL508.pdf) - [Quick Reference | FinCEN.gov](https://www.fincen.gov/boi/quick-reference) - [Texas Social-Media Law on Web Censorship Upheld by Federal Appeals Court - Bloomberg](https://www.bloomberg.com/news/articles/2022-09-16/texas-social-media-law-upheld-by-federal-appeals-court) - [Guidance | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance?page=6) - [Tech Groups Ask US Supreme Court to Review Texas Social Media Law - Bloomberg](https://www.bloomberg.com/news/articles/2022-12-15/us-supreme-court-asked-to-review-texas-social-media-law-by-tech-groups) - [UNITED STATES OF AMERICA FINANCIAL CRIMES ENFORCEMENT NETWORK](https://www.fincen.gov/system/files/2026-03/Canaccord-Consent-Order-No-2026-01.pdf) - [Independent Review of Disclosure and Fraud Offences](https://assets.publishing.service.gov.uk/media/67e279cb4fed20c7f559f559/2025.03.13.Independent.Review.Part.One.Report.Disclosure.Print.20pt.LF_0.1.pdf) - [US Supreme Court Halts Texas Law Targeting Social Media Platforms - Bloomberg](https://www.bloomberg.com/news/articles/2022-05-31/supreme-court-halts-texas-law-on-social-media-content-moderation) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [2025 Crypto Adoption and Stablecoin Usage Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/2025-crypto-adoption-and-stablecoin-usage-report) - [Elliptic's 2026 regulatory and policy outlook: US sets the pace](https://www.elliptic.co/blog/elliptics-2026-regulatory-and-policy-outlook-us-sets-the-pace) - [스테이블코인이란 무엇입니까? 유형, 위험 및 사례(USDT, ...](https://www.trmlabs.com/ko/glossary/stablecoins) - [What are the different types of stablecoins?](https://www.elliptic.co/blockchain-basics/different-types-of-stablecoins) - [Bitcoin Strategic Reserves - Chainalysis](https://www.chainalysis.com/blog/bitcoin-strategic-reserves/) - [Road to Crypto Regulation Part 2: Stablecoins](https://www.chainalysis.com/blog/the-road-to-crypto-regulation-part-2-stablecoins/) - [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/) - [How crypto regulation changed in 2025: a global review](https://www.elliptic.co/blog/how-crypto-regulation-changed-in-2025) - [FSB thematic review 2025: Global crypto regulation remains fragmented despite market growth](https://www.elliptic.co/blog/fsb-thematic-review-2025) - [FinCEN Alert on Bulk Cash Smuggling and Repatriation by ...](https://www.fincen.gov/system/files/shared/BCS-Alert-FINAL-508C.pdf) - [FinCEN Announces $37,000,000 Civil Money Penalty Against Brink’s Global Services USA, Inc. for Violations of the Bank Secrecy Act | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-announces-37000000-civil-money-penalty-against-brinks-global-services-usa) - [FinCEN Issues Alert on Bulk Cash Smuggling and Repatriation by Mexico-based Transnational Criminal Organizations | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-alert-bulk-cash-smuggling-and-repatriation-mexico-based) - [BRINKS CO - Form 8-K - FY2025](https://www.sec.gov/Archives/edgar/data/0000078890/000007889025000039/exhibit991pressrelease2025.htm) - [United States' progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/united-states-fur-2024.html) - [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) - [United States](https://www.fatf-gafi.org/en/countries/detail/United-States.html) - [Assessments](https://www.fatf-gafi.org/en/calendars/assessments.html) - [Consolidated assessment ratings](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Assessment-ratings.html) - [Outcomes of meetings](https://www.fatf-gafi.org/en/the-fatf/outcomes-of-meetings.html) - [Publications](https://www.fatf-gafi.org/en/publications.html) - [The 2022 and 2013 Methodologies for Assessing Technical Compliance with the FATF Recommendations and the Effectiveness of AML/CFT/CPF Systems](https://www.fatf-gafi.org/content/fatf-gafi/en/publications/Mutualevaluations/Fatf-methodology.html) - [FinCEN (U.S. Department of the Treasury)](https://www.fincen.gov/news/news-releases/fincen-announces-37000000-civil-money-penalty-against-brinks-global-services-usa) - [FinCEN (U.S. Department of the Treasury)](https://www.fincen.gov/system/files/shared/FinCEN-Alert-Oil-Smuggling-FINAL-508C.pdf) - [Office of Foreign Assets Control (U.S. Department of the Treasury)](https://ofac.treasury.gov/recent-actions/20260206) - [FinCEN (U.S. Department of the Treasury)](https://www.fincen.gov/news/news-releases/fincen-renews-residential-real-estate-geographic-targeting-orders-0) - [FinCEN (U.S. Department of the Treasury)](https://www.fincen.gov/news/news-releases/fincen-issues-expanded-southwest-border-geographic-targeting-order) - [Office of Foreign Assets Control / Texas Department of Banking (MOU)](https://ofac.treasury.gov/media/31331/download?inline=) - [Financial Action Task Force (FATF)](https://www.fatf-gafi.org/en/publications/Mutualevaluations/united-states-fur-2024.html) - [FinCEN (U.S. Department of the Treasury)](https://www.fincen.gov/boi) - [Chainalysis](https://www.chainalysis.com/blog/ncet-blanche-memo/) - [Elliptic](https://www.elliptic.co/blog/elliptics-2026-regulatory-and-policy-outlook-us-sets-the-pace) Coverage gaps fim-int-2026-07-07-G001: No Texas Department of Banking-orig… fim-int-2026-07-07-G001: No Texas Department of Banking-originated enforcement action or public examination report specific to this window was located; future cycles should directly search state-agency disclosures to verify sub-national supervisory intensity. [resolved] fim-int-2026-07-07-G002: The operative status of overlapping… fim-int-2026-07-07-G002: The operative status of overlapping CTA-related litigation (Smith v. U.S. Department of Treasury versus the stayed Texas Top Cop Shop injunction) requires continuous docket monitoring given a history of rapid appellate reversals. [resolved] fim-int-2026-07-07-G003: The practical trade-volume impact o… fim-int-2026-07-07-G003: The practical trade-volume impact of OFAC Iran General License X on Gulf Coast refiners and import terminals has not yet been quantified from primary trade-flow data. [resolved] fim-int-2026-07-07-G004: The measurable effect of the DOJ Bl… fim-int-2026-07-07-G004: The measurable effect of the DOJ Blanche Memo on Texas VASP SAR-filing volume or examination frequency is not yet observable in available enforcement data. [resolved] fim-int-2026-07-07-G005: No RegTech, AI/ML transaction-monit… fim-int-2026-07-07-G005: No RegTech, AI/ML transaction-monitoring, or federal banking-agency model-risk guidance specific to Texas or the broader US jurisdiction was collected this cycle, leaving the D6 domain assessment thinly evidenced. [resolved] fim-int-2026-07-07-G006: The scheduling and scope of FATF's … fim-int-2026-07-07-G006: The scheduling and scope of FATF's next follow-up report addressing US Recommendation 24 re-rating risk has not yet been published. [resolved] fim-int-2026-08-05-G001: No T1 UN Panel of Experts, OFAC, or… fim-int-2026-08-05-G001: No T1 UN Panel of Experts, OFAC, or OFSI Yemen/Houthi-specific designation check was performed this cycle, leaving the T1 sanctions-evasion tracker incomplete for that channel. [resolved] fim-int-2026-08-05-G002: D4 conflict-finance coverage beyond… fim-int-2026-08-05-G002: D4 conflict-finance coverage beyond the Colombia/Venezuela corridor (e.g. Sahel conflict-mineral trade, DRC mining-sector governance) was not searched this cycle. [resolved] fim-int-2026-08-05-G003: Precise estimated-impact-date detai… fim-int-2026-08-05-G003: Precise estimated-impact-date detail for UK ECCTA next-phase Home Office/SFO guidance could not be established from available T2/T4 sources this cycle. [resolved] fim-int-2026-08-05-G004: Sub-Saharan Africa, Central Asia, a… fim-int-2026-08-05-G004: Sub-Saharan Africa, Central Asia, and Pacific Tier-D jurisdictions were not surfaced this cycle, leaving a regional-balance coverage gap pending a future monthly pass. [resolved] fim-int-2026-08-20-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-08-20-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): No T1 primary consent-order text located for the TX-CO joint AML enforcement action; sourced only from T3 legal-press summaries. [resolved] fim-int-2026-08-20-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-08-20-G002 ({'scheme': 'financial_integrity', 'value': 'D3'}): No US-TX-specific D3 enabler-jurisdiction finding was located this cycle. [resolved] fim-int-2026-08-20-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-08-20-G003 ({'scheme': 'financial_integrity', 'value': 'D1'}): No T1 FATF plenary outcome located for Cambodia's 2026 grey-list risk assessment; sourced from T3/T4 press only. [resolved] fim-int-2026-09-14-G001: Tier D jurisdictions (KH, LA, MX, C… fim-int-2026-09-14-G001: Tier D jurisdictions (KH, LA, MX, CO) not independently searched this cycle; pooled union search budget was allocated to US-TX obligations across all five consumers. [resolved] fim-int-2026-09-14-G002: D1-D4 domains have thin coverage fo… fim-int-2026-09-14-G002: D1-D4 domains have thin coverage for US-TX this cycle; no US-TX-specific sanctions, beneficial-ownership, enabler-jurisdiction or conflict-finance nexus was searched beyond confirming no change. [resolved] fim-int-2026-09-14-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-09-14-G003 ({'scheme': 'financial_integrity', 'value': 'D5'}): Finance Commission of Texas implementing rules for Chapter 161 (kiosk registration/analytics standards) were not located as finalized administrative rules this cycle; statute is in force but rule-level detail is pending. [resolved] fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', 'value': 'D4'}): D4 conflict finance has no Texas-specific finding distinct from federal oil-and-gas/energy-sanctions policy this cycle; coverage is thin. [resolved] fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', 'value': 'D6'}): D6 compliance-technology guidance for US-TX was not researched this cycle; coverage is thin. [resolved] fim-int-2026-09-28-G003: Tier D (KH/LA/MX/CO) sweep was defe… fim-int-2026-09-28-G003: Tier D (KH/LA/MX/CO) sweep was deferred this cycle in favour of the bound jurisdiction's pooled search budget. [resolved] fim-int-2026-10-04-G001: No material signal was reached for … fim-int-2026-10-04-G001: No material signal was reached for D2 (Beneficial Ownership) within the search budget allotted to this US-TX-bound dispatch; Texas has no state-level BO registry and the EU AML Package was not independently re-derived this cycle. [resolved] fim-int-2026-10-04-G002: No material signal was reached for … fim-int-2026-10-04-G002: No material signal was reached for D3 (Enabler Jurisdictions) or D4 (Conflict Finance) within this cycle's search budget beyond the OFAC Sinaloa designation already carried under D1. [resolved] fim-int-2026-10-04-G003: No RegTech/compliance-technology (D… fim-int-2026-10-04-G003: No RegTech/compliance-technology (D6) development was identified for Texas or globally within this cycle's research budget. [resolved] fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): No Texas state-level beneficial-ownership registry was located to fill the gap left by the federal CTA exemption of all US-formed entities. [open] fim-int-2026-10-11-G002: Tier D jurisdictions (KH, LA, MX, C… fim-int-2026-10-11-G002: Tier D jurisdictions (KH, LA, MX, CO) and global standing trackers T1-T3 and T6 were not substantively re-swept this cycle because the research budget was allocated to the bound jurisdiction US-TX. [open] fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', 'value': 'D5'}): The underlying DOB consent-order PDFs for OKX and Triple A specifically were not directly retrieved; findings rest on secondary T3 legal commentary. [open] fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): No primary consent order text was retrieved for the OKX/Triple A Texas DOB actions; penalty amounts and specific provisions not independently verified. [open] fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', 'value': 'D1'}): D1 (sanctions), D3 (enabler jurisdiction) and D4 (conflict finance) carry no Texas-specific signal this cycle; this is a coverage gap, not a finding of stability. [open] fim-int-2026-10-25-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G003 ({'scheme': 'financial_integrity', 'value': 'D6'}): D6 (Compliance Technology and Active Defence) was not researched this cycle for Texas. [open] FIM-GAP-001 (D2): Following E.D. Texas litigation and FinCEN… FIM-GAP-001 (D2): Following E.D. Texas litigation and FinCEN's March 2025 interim rule, domestically-formed reporting companies (including the large volume of Texas-registered LLCs/corporations) are exempt from CTA beneficial-ownership reporting, reversing progress FATF had credited toward closing the US's long-flagged BO transparency gap. FIM-GAP-002 (D3): Despite repeated Southwest Border GTOs, Fi… FIM-GAP-002 (D3): Despite repeated Southwest Border GTOs, FinCEN Exchange events in McAllen/El Paso, and the Brink's penalty, Chinese money laundering networks alone generated an estimated $7.1 billion in suspected suspicious transactions from December 2018 to November 2025, indicating the underlying bulk-cash and professional money-laundering infrastructure along the Texas border remains only partially disrupted. FIM-GAP-003 (D3): No independent, Texas Department of Bankin… FIM-GAP-003 (D3): No independent, Texas Department of Banking-originated enforcement action or public examination report specific to the 18-month window could be located; the sub-national supervisory record for this baseline relies on the OFAC-Texas Department of Banking MOU and federal FinCEN/OFAC actions rather than direct state-agency enforcement publications. FIM-GAP-004 (D5): DOJ's April 2025 'Blanche Memo' directs pr… FIM-GAP-004 (D5): DOJ's April 2025 'Blanche Memo' directs prosecutors to deprioritize digital-asset regulatory violations (including BSA/AML charges) absent clear willful misconduct, favoring traditional fraud/money-laundering charges; this shifts the practical enforcement posture nationally, including against Texas-based virtual-asset service providers and MSBs handling convertible virtual currency. ## Evidence #### Confidence-tiered claims Finance Code Chapter 152 (Money Services Modernization Act), AML/CFT program duties flowing from federal BSA/FinCEN MSB registration [[Source 1]](#sec-sources) Probable · 1 source INX Digital, Inc. (consent order March 31, 2026, change-of-control violation under §152.151) [[Source 1]](#sec-sources) Probable · 1 source Sinaloa Cartel leadership and Baja California corruption networks, Sept 29, 2026 [[Source 1]](#sec-sources) Probable · 1 source Mandatory SDN designations under the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, beginning Oct 18, 2026, with 180-day recurring review [[Source 1]](#sec-sources) Probable · 1 source Ramad Pay, Inc. consent order, June 18, 2026, penalty plus mandated independent-party verification and quarterly reporting for up to two years [[Source 1]](#sec-sources) Probable · 1 source 22 jurisdictions on the grey list as of the 19 June 2026 Plenary (Bosnia & Herzegovina and Iraq added; Algeria and Namibia removed) [[Source 1]](#sec-sources) Probable · 1 source $95,000 administrative penalty, consent order effective 2026-09-11, for unlicensed stablecoin money transmission and custody services to Texas customers 2018-2024. [[Source 1]](#sec-sources) Probable · 1 source $20,000 administrative penalty, consent order effective 2026-09-23, for unlicensed stablecoin/non-convertible cryptocurrency payment processing for merchants. [[Source 1]](#sec-sources) Probable · 1 source Texas DOB and Colorado Division of Banking entered a joint consent order effective 2026-06-18, $200,000 penalty, for AML/CFT program deficiencies including BSA implementing-regulation and FTC Safeguards Rule violations. [[Source 1]](#sec-sources) Probable · 1 source Final rule effective 2026-08-14 permanently removes the requirement for US companies and US persons to report beneficial-ownership information, narrowing the federal register to foreign reporting companies. [[Source 1]](#sec-sources) Probable · 1 source Texas Finance Code Ch. 152 (Money Services Modernization Act), supervised by the Texas Department of Banking, is the standing designated reporting/supervisory architecture for MSBs; Supervisory Memorandum 1037 treats sovereign-backed, redeemable stablecoins as 'money or monetary value' triggering licensure. [[Source 1]](#sec-sources) Probable · 1 source Issued Sept 2026 consent orders against OKX and Triple A resolving allegations of unlicensed Texas money transmission involving stablecoin activity. [[Source 1]](#sec-sources) Probable · 1 source Texas money transmitters/MSBs (incl. crypto/stablecoin businesses meeting the Ch.152 money test) must maintain a BSA/AML program per 31 CFR §1022.210, with risk-rated examination cycles (12/18/24 months); no state-specific SAR/CTR threshold distinct from federal BSA. [[Source 1]](#sec-sources) Probable · 1 source FinCEN's March 2025 interim final rule exempts domestically formed companies (including Texas LLCs/corporations) from CTA beneficial-ownership reporting; only foreign entities registered to do business remain in scope. E.D. Texas (Smith v. U.S. Dept. of Treasury) remains the litigation venue for a residual nationwide injunction. [[Source 1]](#sec-sources) Probable · 1 source Treasury/OCC finalized GENIUS Act implementing regulations, published Federal Register Oct 23, 2026, effective Jan 18, 2027, preempting state charter/licence requirements for federally qualified payment stablecoin issuers. [[Source 1]](#sec-sources) Probable · 1 source Joint consent order (June 22, 2026) with a licensed money transmitter over alleged AML/CFT program deficiencies including late CTR filings, agent-monitoring weaknesses, and unremediated independent-review findings. [[Source 1]](#sec-sources) Probable · 1 source Chapter 152 money-transmission licensing applies to crypto/stablecoin intermediaries; two consent orders (OKX, Triple A) resolved September 2026, reported October 6, 2026 [[Source 1]](#sec-sources) Probable · 1 source