--- title: "United States — Vermont (US-VT) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/united-states-vermont/ source_html: /jurisdictions/united-states-vermont/index.html description: "Financial integrity intelligence for United States – Vermont (US-VT): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: 04beb64a8f2da386c472e1f2b00d7457b02c0d901f19ca4c7d223a0ffd190f93 generator: "fe-fleet/md-twin@1.0" --- # United States — Vermont (US-VT) — 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 — Vermont US-VT Domains covered 8 of 8 Sources 141 Role actions 8 Horizon <90d 0 Jurisdiction profile FATF status: Largely Compliant Tier: B Risk direction: Increasing Enablement vs enforcement: Mixed Vermont operates under the federal U.S. More BSA/AML framework (FinCEN, OFAC) with no independent state AML statute; the Vermont Department of Financial Regulation (DFR) licenses and supervises the state's captive insurance sector and money-transmitter/MSB activity primarily for solvency and conduct, not dedicated AML typology. No state-level beneficial-ownership registry exists; federal CTA reporting now largely inapplicable to domestic entities. Key deficiencies - No state-level beneficial ownership registry; Vermont-formed LLCs and captive-insurance vehicles rely solely on the federal CTA framework, which as of March 2025 exempts domestic reporting companies from BOI reporting entirely - Captive insurance supervision by DFR is solvency/conduct-focused rather than AML/CFT-typology-focused, leaving a structural gap in illicit-finance risk assessment of a sector historically used to hold group liabilities - Vermont is not covered by any active FinCEN Residential Real Estate Geographic Targeting Order, leaving non-financed residential real estate purchases via legal entities in the state outside enhanced federal AML reporting until the national RRE Rule's national reporting requirement takes effect Recent developments (18m) - FinCEN's March 2025 interim final rule exempted all U.S.-formed ('domestic reporting company') entities and their beneficial owners from Corporate Transparency Act BOI reporting, narrowing beneficial-ownership transparency nationwide including for Vermont-formed LLCs and captive structures - District of Vermont federal prosecutors and FBI partners charged 25 Canadian nationals in a nationwide multimillion-dollar 'grandparent scam' elder-fraud and money-mule laundering network - FATF's March 2024 enhanced follow-up report upgraded the United States on Recommendation 24 (beneficial ownership) from Non-Compliant to Largely Compliant, while flagging continuing gaps in timely BO access - FinCEN renewed nationwide Residential Real Estate Geographic Targeting Orders (effective October 2025) ahead of the now-postponed national RRE beneficial-ownership reporting rule United States federal law that applies in United States – Vermont is covered once, on the [United States](/jurisdictions/us/) page. This page covers United States – Vermont’s own layer: its own law, regulators and enforcement. Brief ## Lead signal #### Lead Signal Vermont has enacted Act 142 (signed 16 June 2026), a single statute that reaches into two distinct corners of the states financial-integrity architecture at once. The Act continues and hardens the states existing prohibition on virtual-currency kiosks, stating that no person shall locate, operate, or otherwise make available for use a virtual currency kiosk in Vermont, while also expanding the statutory definition of money transmission to explicitly capture virtual-currency business activity. In the same instrument, Vermont creates an entirely new licensing and disclosure regime for sales-based financing and factoring providers under new 8 V.S.A. Section 2247, due to take effect 1 July 2027. Read together, these are not two unrelated provisions bundled into one bill: both halves narrow a channel that had previously operated with less direct state oversight, one in consumer-facing crypto-cash conversion and one in non-bank commercial credit. Read full brief #### Lead Signal Vermont has enacted Act 142 (signed 16 June 2026), a single statute that reaches into two distinct corners of the states financial-integrity architecture at once. The Act continues and hardens the states existing prohibition on virtual-currency kiosks, stating that no person shall locate, operate, or otherwise make available for use a virtual currency kiosk in Vermont, while also expanding the statutory definition of money transmission to explicitly capture virtual-currency business activity. In the same instrument, Vermont creates an entirely new licensing and disclosure regime for sales-based financing and factoring providers under new 8 V.S.A. Section 2247, due to take effect 1 July 2027. Read together, these are not two unrelated provisions bundled into one bill: both halves narrow a channel that had previously operated with less direct state oversight, one in consumer-facing crypto-cash conversion and one in non-bank commercial credit. The crypto-kiosk provision is the more immediately consequential of the two for financial-integrity purposes, since kiosks are a known vector for cash-to-crypto conversion schemes, including romance-scam and pig-butchering proceeds laundering. Enacted statutory text supports a continuing bar, though secondary commentary is not unanimous on whether this is now a permanent prohibition or an extended moratorium running to 2027, a distinction that matters for how durable the control should be treated going forward. #### Other Developments A new licensing perimeter for non-bank credit. Act 142 folds sales-based financing and factoring providers into Vermont lender or loan-solicitation licensure for the first time, paired with Truth in Lending Act-style disclosure obligations. This is a modest but structurally meaningful tightening: a segment of commercial credit that has operated outside state lender oversight will, from 1 July 2027, sit inside a licensing and disclosure perimeter, with Vermont's Department of Financial Regulation as the supervising authority. Expanded money-transmission scope. The same Act widens the statutory definition of money transmission to explicitly include virtual-currency business activity, reinforcing the existing licensure requirement under the state's money-services framework rather than creating a parallel regime. #### Cross-Monitor Connections The kiosk prohibition sits at the boundary between financial-integrity and payments-infrastructure concerns: a states choice to bar a cash-to-crypto on-ramp outright, rather than license and supervise it, is itself a form of enablement-by-exclusion that shapes where such activity migrates rather than eliminating it. The commercial-financing licensing regime connects to broader non-bank credit oversight questions playing out at state level across the United States, where sales-based financing (merchant cash advances, revenue-based financing) has grown largely outside the licensing frameworks built for traditional lending; Vermont's move is a data point in that wider architecture rather than an isolated local event. #### Outlook The commercial-financing licensing regime takes effect 1 July 2027, giving affected providers roughly a year's lead time from enactment to build out licensure and disclosure compliance; as scheduled, this falls just past the current compose cycle and should be tracked as a forward compliance deadline rather than a completed transition. Whether the virtual-currency-kiosk bar is treated by regulators as a permanent architectural feature of Vermont's money-transmission regime or revisited as a time-limited moratorium remains an open reconciliation point against the full enacted text. Earlier periodic briefs (6) 3 Nov 2026 · fim-2026-11-03 #### Lead Signal Vermont has enacted Act 142, a statute signed on 16 June 2026 that continues and hardens the state prior moratorium on virtual-currency kiosks while simultaneously creating a new licensing regime for sales-based commercial financing and factoring. The enacted text bars any person from locating, operating, or otherwise making available a virtual-currency kiosk in the state, and it expands the state money-transmission definition to capture virtual-currency business activity. The Vermont Department of Financial Regulation has previously flagged that cryptocurrency moving through unsupervised crypto-kiosks without sufficient controls creates an outsized risk, and Act 142 is the legislative answer to that concern. Secondary legal commentary has characterized the kiosk measure as a permanent ban, though the enacted statutory language and this characterization have not yet been fully reconciled, leaving some ambiguity over whether the prohibition is permanent or an extended continuation of an existing moratorium. The same statute separately brings sales-based financing and factoring providers under a new Vermont lender or loan-solicitation licensing regime, with Truth in Lending Act-style annual percentage rate disclosure obligations, effective from 1 July 2027. Together the two strands of Act 142 close two previously unlicensed channels: cash-to-crypto conversion through physical kiosks, and non-bank commercial credit extended outside existing lender licensure. Neither change creates a Vermont-specific anti-money-laundering statute distinct from the federal Bank Secrecy Act and FinCEN money-services-business baseline that already governs the state money-transmission chapter; both are better read as architecture-narrowing moves against known enabler gaps than as a new compliance regime in their own right. #### Other Developments Commercial-financing licensure closes an unlicensed credit channel. Act 142 adds a new provision to Vermont statute requiring providers of sales-based financing and factoring, such as merchant cash advance and revenue-based financing arrangements, to hold a Vermont lender or loan-solicitation license before continuing to operate in the state. Industry in this space has generally not operated under state lender licensure, so the one-year lead time before the 1 July 2027 effective date is itself the compliance-gap window regulators and providers now have to close. Law-firm secondary sources are the primary corroboration available for the detail of this provision and are broadly consistent with each other, though the particular statutory text for this specific provision has not been independently re-pulled. Kiosk prohibition formalizes an existing enforcement posture. The ban on virtual-currency kiosks is a continuation and hardening of a position Vermont regulators had already signaled through the Department of Financial Regulation prior reporting on crypto-kiosk risk. The expansion of the money-transmission definition to explicitly include virtual-currency business activity gives the state a clearer statutory hook for supervising or acting against unlicensed kiosk operators going forward, rather than relying solely on an interpretive extension of pre-existing transmission definitions. #### Cross-Monitor Connections The kiosk prohibition sits squarely inside the pattern tracked by digital-asset integrity work elsewhere in the firm: crypto-ATM and kiosk channels have been a recurring fraud and layering vector nationally, and a state-level permanent or near-permanent bar is the kind of structural hardening that reduces, rather than merely polices, that attack surface. The commercial-financing licensure change has a narrower but real connection to enabler-jurisdiction analysis generally, in that an unlicensed, undisclosed credit channel is precisely the kind of gap that enabler-jurisdiction typologies look for; Vermont closing it is a data point in the other direction from the permissive-jurisdiction pattern that enabler analysis more often surfaces. #### Outlook The virtual-currency kiosk prohibition took effect on 1 July 2026 and is now operative; the open question is whether its characterization as a permanent ban, as opposed to an extended moratorium, will be clarified by subsequent regulatory guidance or litigation. The commercial-financing licensing regime was adopted with the statute but its substantive obligations are not yet in effect: the lender or loan-solicitation licensure and Truth in Lending Act-style disclosure requirements for sales-based financing and factoring providers are due to take effect on 1 July 2027. Firms operating in either space should expect the intervening period to surface further guidance from the Vermont Department of Financial Regulation on scope and compliance expectations ahead of that date. 26 Oct 2026 · fim-2026-10-25 #### Lead Signal Vermont has enacted a structural tightening of its money-transmission and virtual-currency perimeter through Act 142 (H.648), signed into law on 16 June 2026. The statute does two distinct things at once: it folds virtual-currency business activity expressly into the definition of money transmission under 8 V.S.A. §2500, formalising a classification the Department of Financial Regulation had already been applying in enforcement practice, and it restricts the operation of virtual-currency kiosks, terminating existing kiosk registrations effective 1 July 2026 and barring new registrations for a period whose length is not settled in the record. The enacted text itself reads as an unconditional restriction with no visible sunset in the sections sampled, while secondary commentary is split between describing it as a permanent ban and describing it as a moratorium running to 1 July 2027. That gap matters for anyone tracking whether the kiosk channel reopens, and it is carried here as an open question rather than resolved either way. The formal inclusion of virtual-currency activity within the money-transmission definition is the more durable of the two changes. It removes any ambiguity about whether a crypto-asset business operating in Vermont needs a money-transmitter licence, aligning the statute book with what the Department of Financial Regulation had already been doing as a matter of enforcement posture. Read together, the two provisions describe a state regulator narrowing the informal, cash-adjacent, less-supervised edge of the virtual-currency ecosystem (kiosks) while simultaneously widening and hardening the licensing net around the formal, business-to-consumer edge of the same ecosystem. #### Other Developments A new commercial-financing licensing regime arrives alongside the virtual-currency provisions in the same omnibus act. New 8 V.S.A. §2247 requires providers of sales-based financing and factoring to Vermont recipients to hold a Department of Financial Regulation lender or loan-solicitation licence from 1 July 2027, with disclosure obligations styled on the federal Truth in Lending Act. Depository institutions, government entities, self-financing sellers, and transactions of $1,000,000 or more are exempt. This provision is corroborated by multiple independent secondary legal sources citing the same statutory section and commencement date, though no Department of Financial Regulation implementing guidance has yet been located to confirm the operative detail at primary-source level. It sits outside the virtual-currency core of the finding but shares its instrument and its date, and it signals the same institutional posture: a state regulator extending licensing coverage into financial-services activity that had previously sat outside direct state oversight. The standing AML supervisory architecture for Vermont remains the Vermont Money Services Act under 8 V.S.A. chapter 79, with the Department of Financial Regulation as the designated state supervisor for non-bank money transmitters, operating alongside the federal Bank Secrecy Act framework and FinCEN money-services-business registration. Vermont's 2025 participation in a 47-state coordinated enforcement action against Block, Inc. over its Cash App product's Bank Secrecy Act and anti-money-laundering compliance is standing context predating the window and is noted here only as backdrop to the supervisor's existing posture, not as new material. #### Cross-Monitor Connections The virtual-currency kiosk restriction and the expanded money-transmission definition both touch ground that a payments-focused reading would treat as licensing and market-access architecture, and a crypto-focused reading would treat as licensing and classification architecture: the same statutory text, read through different lenses, is the throughline of the Vermont material. The commercial-financing licensing regime, while adjacent to money-service-business supervision, points toward a broader non-bank-credit oversight question rather than a sanctions, beneficial-ownership, or conflict-finance one, and is flagged here for a reader tracking enabler-jurisdiction and professional-facilitator dynamics across the small-business lending space rather than for a reader tracking illicit-finance typologies directly. #### Outlook The open question carried is definitional: whether Vermont's virtual-currency-kiosk restriction is permanent or whether it lifts on 1 July 2027. Until the Department of Financial Regulation or a fuller read of the enacted statute resolves this, both possibilities should be treated as live, with the enacted text favouring an unconditional restriction. The commercial-financing licensing regime's 1 July 2027 commencement is a second date to track, as is the possibility that primary Department of Financial Regulation guidance will eventually displace the secondary-source corroboration relies on. No new sanctions, beneficial-ownership, conflict-finance, or compliance-technology signal was identified for Vermont; the state's regulatory energy this period was concentrated entirely on virtual-currency and non-bank-financing licensing architecture. 4 Oct 2026 · fim-2026-10-04 #### Lead Signal Vermont enacted Act 142 in 2026, a single legislative vehicle that reaches two distinct corners of the states financial-crime perimeter at once. The statute permanently bans the location, operation or offering of virtual-currency kiosks anywhere in Vermont, terminating every existing kiosk registration effective July 1, 2026 and imposing a six-year records-retention tail running to 2031. The same act expands the statutory definition of money transmission under 8 V.S.A. chapter 79 to expressly include virtual-currency business activity, a definitional move that brings virtual-asset service providers fully inside the Vermont Money Transmitter Acts BSA/AML licensing perimeter. The ban did not emerge from an abstract policy preference. The Vermont Department of Financial Regulations own report under 8 V.S.A. section 2577(g) documents virtual-currency kiosks as a vehicle for routing scam and fraud proceeds, giving the legislative response a traceable evidentiary basis rather than a generalized anti-crypto posture. Read together, the kiosk ban and the definitional expansion read as a structural tightening of the states crypto-adjacent AML perimeter: one closes an identified cash-in channel for illicit proceeds, the other widens the net of who must hold a license and run a compliance program in order to touch virtual-currency activity at all in the state. The architecture-over-incident reading matters here. This is not an isolated enforcement action against a single kiosk operator; it is a legislature permanently removing an entire channel-type from the regulated landscape while simultaneously widening the definitional gate that determines who needs a license to operate in virtual currency at all. That combination of elimination and expansion is the more analytically significant pattern, more durable than any single case outcome would have been. #### Other Developments A new commercial-financing licensing regime sits on the horizon. Act 142 also introduces a lender and loan-solicitation license for sales-based financing and factoring providers, carrying TILA-style disclosure and estimated-APR requirements, with an effective date of July 1, 2027. This is a cross-pillar compliance-technology and market-structure item rather than a typical AML finding: industry participants have not generally treated merchant-cash-advance-style and factoring products as licensed lending, so the run-up to the 2027 effective date opens a compliance gap worth tracking as firms determine whether their products fall inside the new perimeter. The enabler-jurisdiction angle traces back to the states own typology work. The Department of Financial Regulations section 2577(g) report is the documentary hinge connecting the kiosk channel to fraud-proceeds routing. That a state regulator produced and published its own typology finding, and then saw it translated directly into statute within the same cycle, is itself a notable data point about how enabler-channel identification can move quickly from regulatory report to binding prohibition when the evidentiary chain is clean. The standing AML/BSA licensing regime for money transmitters now has a wider aperture. Virtual-currency exchangers and custodial-wallet providers already fell within the Vermont Money Transmitter Acts NMLS-administered licensing, surety-bonding and BSA/AML compliance-program requirements; Act 142s definitional expansion simply confirms and hardens that virtual-currency business activity sits squarely inside that perimeter going forward, removing any residual argument that such activity sat outside money-transmission licensing. #### Cross-Monitor Connections The kiosk ban and money-transmission expansion both touch ground that the Crypto monitor and the World Payments monitor also cover from their own vantage points: licensing-perimeter changes of this kind are the kind of structural shift that typically appears as a tightening signal in a payments-licensing tracker and as a licensing-regime change in a digital-asset tracker, even though the underlying fact pattern is one and the same legislative act. The compliance-technology angle in the new commercial-financing license likewise intersects with how non-bank lenders and factoring platforms are treated across state licensing regimes more broadly, a theme that recurs wherever states extend licensing perimeters to previously under-regulated financial products. #### Outlook The near-term marker to watch is whether the Department of Financial Regulation issues implementing guidance interpreting the expanded money-transmission definition specifically as it applies to custodial-wallet or exchange activity; no such guidance had been located as of this cycle, leaving a documented gap between the statutory text and its operational application. A second marker is whether any enforcement action follows the July 1, 2026 termination of existing kiosk registrations; none had been identified as of this cycle. On the commercial-financing side, the run-up to the July 1, 2027 effective date for the new lender and loan-solicitation license is the item to track, particularly given the gap between how sales-based financing and factoring providers have operated to date and how the new licensing regime will treat them once in force. 28 Sep 2026 · fim-2026-09-28 #### Lead Signal Vermont has converted a time-limited moratorium on virtual-currency kiosks into a permanent statutory ban. Act 142, enacted 16 June 2026 and effective 1 July 2026, amends 8 V.S.A. Chapter 79 to prohibit locating, operating, or otherwise making available a virtual-currency kiosk anywhere in the state. The move follows a Department of Financial Regulation finding that the prior moratorium had already driven a reduction of more than 94 percent in the number of cash-accepting kiosks operating in Vermont, and it reflects a recommendation from Attorney General Charity Clark that the protective measures already in place were insufficient to address ongoing consumer-fraud exposure at these access points. The architecture here is the significant fact, not any single enforcement episode: Vermont has permanently closed a recognised cash-to-crypto conversion channel that has featured prominently in romance-scam and impersonation-fraud typologies nationally, rather than layering additional disclosure or transaction-limit conditions onto continued kiosk operation. This is a structural foreclosure, and it sits alongside a customer-identification duty under 8 V.S.A. Section 2577(g) that required kiosk operators to verify identity before accepting payment and barred anonymous or third-party-identity transactions. That duty is now largely moot for new kiosk deployment given the permanent ban, though it remains binding on any kiosk that may retain legacy-exempt status. Act 142 also creates a new licensing and disclosure regime for commercial-financing providers under Title 8, with an effective date of 1 July 2027, a full year after the kiosk provisions take hold. This is a forward horizon item drawn from secondary legal-alert coverage rather than the enacted statutory text directly, and implementing guidance from the Department of Financial Regulation has not yet been published, so the compliance-readiness gap for affected non-bank providers cannot yet be assessed. #### Other Developments Vermont's virtual-currency business activity continues to be regulated as money transmission under 8 V.S.A. Chapter 79, with licensure required for exchanging, storing, administering, buying, selling, receiving, or transmitting virtual currency. There is no dedicated Vermont financial intelligence unit; federal Bank Secrecy Act and FinCEN requirements govern in parallel with the state licensing regime. This is a stable baseline finding rather than a new development, but it frames why the kiosk ban matters: the state licensing perimeter was already comprehensive on paper, and the specific gap being closed is the physical cash-acceptance point rather than the licensing architecture itself. The commercial-financing licensing regime represents a second, slower-moving strand of Act 142 distinct from the virtual-currency provisions, extending Title 8 licensing and disclosure obligations to a class of non-bank commercial-financing providers that previously operated outside dedicated state licensure. The one-year lag between the kiosk ban's effective date and the commercial-financing regime's effective date suggests a staged legislative rollout rather than a single unified reform, and readers should not conflate the two timelines. #### Cross-Monitor Connections The kiosk ban functions as a physical access-point closure with direct relevance to consumer-protection and payments-market-structure readings carried elsewhere in the fleet; the underlying instrument is the same Act 142 text examined here for its illicit-finance-vector implications. The commercial-financing licensing regime, once implementing guidance emerges, will generate AML/CTF regime-as-record findings for a newly captured category of non-bank lender that has not previously been subject to Vermont-specific governance obligations. #### Outlook The commercial-financing licensing regime is scheduled to take effect 1 July 2027, as adopted under Act 142; Department of Financial Regulation implementing guidance had not been published as of this cycle, and the compliance-readiness posture of affected non-bank providers remains unassessed pending that guidance. Whether any kiosks retain legacy-exempt status under a grandfather provision, and how the customer-identification duty under Section 2577(g) would apply to such a kiosk in practice, are open questions this cycle did not resolve. 22 Sep 2026 · fim-2026-09-21 #### Lead Signal Vermont has extended its virtual-currency-kiosk moratorium a further year, from 1 July 2026 to 1 July 2027, under Act 142 (H.648), signed 16 June 2026. This is the third consecutive annual amendment to 8 V.S.A. Chapter 79, Vermont's money-transmission and virtual-currency regime, following the 2024 rebuild under Act 110 and a further amendment under Act 23 in 2025. Read individually, each amendment is a modest legislative act. Read as a sequence, the pattern is architectural rather than episodic: Vermont's legislature has chosen, in three consecutive sessions, to tighten virtual-currency-specific money-transmission controls incrementally rather than settle on a fixed framework and leave it. This is the kind of structural signal that a purely incident-based reading of state gambling or fintech regulation would miss entirely. #### Other Developments Commercial-financing licensing regime introduced. Act 142 also introduces a wholly new licensing and disclosure regime for commercial-financing providers and brokers — specifically sales-based financing and factoring transactions — requiring covered providers and brokers to obtain a Vermont Department of Financial Regulation licence and provide standardized disclosures. This regime is not yet effective; it takes effect 1 July 2027, the same date the extended kiosk moratorium is currently set to expire. The new regime expands DFR's obliged-entity supervisory perimeter beyond money-transmission and virtual-currency businesses into a previously-unlicensed corner of commercial lending, ahead of any confirmed implementing-rules detail beyond the statutory text. Standing money-transmitter capital requirement unchanged. Money-transmitter licensees in Vermont continue to be subject to a minimum $100,000 surety bond requirement, a standing capital-adequacy control that has not moved this cycle and continues to apply to virtual-currency businesses operating under the money-transmission licence umbrella. #### Cross-Monitor Connections The kiosk-moratorium extension and the new commercial-financing licensing regime both sit inside Vermont's payments-and-money-transmission regulatory perimeter, which the world-payments monitor tracks from the licensing-and-market-access angle; a reader following the payments-structural side of this development should consult that monitor's treatment of Vermont this cycle. No sanctions-architecture, beneficial-ownership, or conflict-finance connection was identified for Vermont in the evidence available this cycle. #### Outlook Given the three-consecutive-year pattern of annual amendment to Chapter 79's virtual-currency provisions, a further extension of the kiosk moratorium in the 2027 legislative session is a plausible trajectory, though this is not confirmed by any evidence available this cycle and should be treated as an open question. The commercial-financing licensing regime's 1 July 2027 effective date is the nearer-term structural milestone to track, alongside whether DFR issues implementing rules or guidance beyond Act 142's statutory text — no such guidance was located this cycle. 3 Sep 2026 · fim-2026-08-05 #### Lead Signal The clearest signal this cycle is architectural rather than incident-specific: Russia-linked shadow-fleet vessels are showing rising AIS transponder blackout rates at the same time as sustained blocking sanctions from OFAC, OFSI, and the EU remain in place against Rosneft, Lukoil, Surgutneftegas, and Gazprom Neft. The co-occurrence of rising evasion signal and unchanged designation pressure is itself the finding: the evasion architecture underlying Russian crude exports appears to be adapting faster than the designation regime is closing it down, a structural read rather than a single-incident one. #### Other Developments AMLA completes its institutional handover. The EU's Anti-Money Laundering Authority formally absorbed the full AML/CFT supervisory mandate from the European Banking Authority effective January 1, 2026, and closed its consultation on the methodology for selecting the roughly forty highest-risk cross-border entities that will move to AMLA direct supervision from 2028. This is the definitive institutional handover point in the EU's supervisory build-out, ahead of the AML Regulation's direct-applicability date of July 2027. Cambodia's enabler-environment pattern persists. A politically-connected conglomerate, Lim Heng Group, is alleged to have leased premises at the Royal Hill Resort and Casino site to operators later running an industrial-scale cyber-scam and human-trafficking compound. Separately, OFAC designated the linked Bolai/K99 network for coercing trafficking victims into digital-asset fraud targeting Americans, with at least seventy-three million dollars laundered through US-based co-conspirators. Both findings surface despite Cambodia's 2023 exit from the FATF grey list, underscoring that grey-list removal did not resolve the casino-junket sector's function as an enabler channel. Vermont closes a crypto on-ramp. Act 142 converts what had been a temporary moratorium into a permanent, statewide ban on virtual-currency kiosks, effective July 1, 2026, terminating all existing kiosk registrations. The instrument sits in the state's general financial-services statute rather than a crime-specific one, but it is a genuine channel closure rather than a symbolic gesture. FinCEN moves on two fronts. A supplemental alert addressing southern-border fiscal fuel-theft and tax-evasion schemes tied to CJNG was coordinated with OFAC sanctions against two individuals and nine entities. Separately, FinCEN's proposed rule to operationalise a BSA and sanctions whistleblower programme, offering ten to thirty percent of collected penalties above one million dollars, signals an incentive-driven enforcement posture extending beyond BSA-covered institutions into any entity with sanctions exposure; this rulemaking is sourced here through secondary legal-analysis commentary and has not been independently re-verified against the FinCEN text this cycle. FATF grey list moves. The June 2026 Plenary added Iraq and Bosnia and Herzegovina to the grey list and removed Algeria and Namibia, leaving twenty-two jurisdictions under increased monitoring. UBS penalised for recidivist BSA violations. FinCEN imposed a 125 million dollar penalty on UBS Financial Services Inc. for recidivist Bank Secrecy Act violations. Mexican institutions excluded from the US financial system. FinCEN Section 311 special measures now prohibit covered US financial institutions from transmitting funds to or from CIBanco, Intercam, and a third Mexican financial institution, over opioid-trafficking-linked money-laundering exposure. #### Cross-Monitor Connections The Russian shadow-fleet finding routes directly to conflict-finance monitoring: continued crude-export evasion sustains war-economy financing, though this cycle's coverage is confined to the Russia-Ukraine corridor with no fresh sub-Saharan Africa or Latin America material located. The Cambodia findings connect enabler-jurisdiction and conflict-finance-adjacent monitoring lines, given the politically-connected nature of the implicated conglomerate and the scale of the underlying trafficking-and-fraud compound economy. The Vermont and Bolai/K99 findings both route to crypto-infrastructure monitoring: one is a regulatory channel closure, the other is continued illicit exploitation of a different digital-asset vector, and both surfaced in the same cycle. #### Outlook The AMLA handover and the FATF grey-list movement are the two developments most likely to generate follow-on obligations for obliged entities in coming cycles: AMLA's technical standards are largely due by July 2026 ahead of the 2027 AMLR enforcement date, and grey-list-driven enhanced due diligence obligations now extend to Iraq and Bosnia and Herzegovina. On the enforcement-incentive side, FinCEN's whistleblower rulemaking remains at the proposal stage with a comment period that closed June 1, 2026; its next material marker will be a final rule or further FinCEN commentary. The shadow-fleet evasion pattern remains the highest-severity unresolved thread of the cycle, given that rising AIS blackout rates alongside unchanged designation activity suggest the current sanctions posture is not closing the evasion gap. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion Vermont has no independent nexus to sanctions-evasion architecture; it inherits the federal Office of Foreign Assets Control perimeter in full, and this cycle's material developments apply nationally rather than through any state-specific channel. The most structurally significant development is the coordinated but non-identical action taken during the second half of 2025 by OFAC, the European Union Council, and HM Treasury's Office of Financial Sanctions Implementation against entities enabling ruble-backed stablecoin use to evade Russia sanctions. The three regimes moved against a shared target set without harmonising designation timing or scope, a structural divergence pattern that creates friction for any multi-jurisdictional financial institution, including a Vermont-chartered bank or fintech with digital-asset exposure or European counterparties. Continue reading Separately, the National Security Presidential Memorandum-2 maximum-pressure campaign against Iran, commenced February 2025, continues to block Iranian government and financial-institution property nationally. This posture is materially more restrictive than the parallel European Union and United Kingdom listings, another instance of the three-regime divergence pattern rather than convergence. The Huione Group Section 311 designation, addressed more fully under the digital-asset lens, is itself a sanctions-architecture point worth flagging here: Section 311 is a uniquely United States special-measures mechanism with no direct European Union or United Kingdom equivalent, meaning the same crypto-laundering network is targeted through structurally different legal tools across the three jurisdictions Vermont-serving institutions must navigate. For Vermont specifically, the analytical takeaway is architectural rather than incident-based: the state's exposure runs entirely through its captive-insurance sector's multinational parent groups, which must reconcile differing sanctions-screening obligations across regimes, and through any Vermont-chartered bank or payment company touching Russia-sanctions-adjacent digital-asset flows. No enforcement action against a Vermont-domiciled entity was identified this cycle, and that absence is itself worth noting under an enablement lens, though it may simply reflect the state's limited direct exposure rather than a permissive posture. #### Outlook The sanctions-regime divergence pattern identified across the ruble-stablecoin and Iran tracks is likely to persist rather than resolve, since it reflects differing statutory architectures (OFAC's broad jurisdiction-based blocking authority against OFSI's narrower breach-based model) rather than a temporary policy gap. For Vermont-linked institutions, the practical consequence is a continuing compliance burden of reconciling three non-identical sanctions perimeters, with the Section 311 mechanism serving as a reminder that the United States retains tools without direct transatlantic analogues. Judgment: No US-VT-specific sanctions development surfaced this cycle. Uncertain #### Beneficial Ownership and Corporate Transparency Vermont sits outside the European Union entirely, so the EU AML Package is not the primary subject matter for this jurisdiction's beneficial-ownership exposure; the directly relevant developments run through the federal Corporate Transparency Act framework and this cycle's judicial and regulatory corrections to it. The March 2025 FinCEN interim final rule exempting all United States-formed domestic reporting companies and their beneficial owners from Corporate Transparency Act reporting remains, as of this baseline, unfinalised, a status the original framing treated as a settled outcome rather than an interim, reversible one. Compounding this, a federal court in the Eastern District of Texas vacated the national Residential Real Estate reporting rule on March 19 2026, meaning reporting persons are not currently required to file Real Estate Reports with FinCEN while the order stands and FinCEN's appeal is pending. This removes, at least temporarily, the anticipated national beneficial-ownership backstop for non-financed residential real estate transfers that the earlier baseline had expected to take effect March 1 2026. Continue reading Vermont has no state-level beneficial-ownership registry of its own, so it depends entirely on this federal framework. With the domestic-company exemption unfinalised and the real-estate backstop currently inoperative, Vermont-formed entities, including the captive-insurance and holding-company structures addressed in more detail under the enabler-jurisdiction lens, currently sit without either a fully settled federal transparency floor or an independent state-level one. The narrower Residential Real Estate Geographic Targeting Orders, renewed effective October 2025 and requiring title insurance companies to identify natural persons behind non-financed shell-company purchases in designated metro areas, remain the only active federal real-estate transparency tool for the time being, and Vermont is not currently among the covered jurisdictions. The United States Financial Action Task Force compliance posture bears directly on this picture: the March 2024 enhanced follow-up report upgraded Recommendation 24 (beneficial ownership) to Largely Compliant, but the country remains Partially Compliant on five Recommendations and Non-Compliant on three of forty overall, a more mixed record than a simple good-standing characterisation suggests. The fifth-round mutual evaluation, which will re-assess beneficial-ownership effectiveness in light of the 2025 domestic-company exemption, has not yet been scheduled. Globally, the EU AML Package sets the structural direction for beneficial-ownership supervision even though it does not bind Vermont directly. That package now comprises three distinct instruments: the AML Regulation (Regulation (EU) 2024/1624), which is directly applicable across member states without national transposition; the sixth AML Directive, transposed individually by each member state; and the AMLA Regulation (Regulation (EU) 2024/1620), which establishes the Anti-Money Laundering Authority and a direct/indirect supervision perimeter that shifts oversight of high-risk cross-border obliged entities from purely national authorities toward a hybrid EU-level regime. Vermont sits entirely outside this perimeter, but the contrast is analytically instructive: where the European Union is building a centralised supervisory backstop precisely to close gaps created by fragmented national transparency regimes, the United States federal framework that Vermont depends upon has, this cycle, moved in the opposite direction on two fronts at once. #### Outlook The determining questions for Vermont's beneficial-ownership exposure are whether FinCEN issues a final Corporate Transparency Act rule that narrows, confirms, or reverses the domestic-company exemption, and whether FinCEN's appeal of the Residential Real Estate rule vacatur succeeds in reinstating the national reporting requirement. Either outcome would materially alter the transparency floor beneath a state whose captive-insurance and holding-company concentration gives this otherwise generic federal question outsized local significance. Judgment: No Vermont-specific beneficial-ownership development surfaced this cycle. Uncertain #### Enabler Jurisdictions and Professional Facilitators Vermont's Act 142, signed 16 June 2026, narrows a commercial-credit channel that had largely operated outside state lender oversight. New 8 V.S.A. Section 2247 requires sales-based financing and factoring providers, a category that includes merchant cash advance and revenue-based financing structures, to hold a Vermont lender license or a loan-solicitation license before offering such products to Vermont recipients, effective 1 July 2027. The same provision imposes Truth in Lending Act-style disclosure obligations: providers must disclose finance charges, an estimated annual percentage rate calculated under Regulation Z methodology, disbursement amounts, and total repayment figures before a transaction is consummated. Confessions of judgment taken in connection with these products are rendered void. Continue reading This is a facilitator-architecture story rather than an enforcement-incident story. Sales-based financing and factoring have historically sat in a regulatory grey zone in many US states, marketed as commercial transactions rather than consumer loans and therefore outside lender licensure and usury-style disclosure regimes. Vermont's choice to bring these providers inside a licensing and disclosure perimeter is a structural narrowing of an unlicensed facilitation channel, the kind of enabler-jurisdiction tightening that matters more for long-run exposure than any single enforcement action would. Corroboration for the operative provisions currently rests on multiple independent law-firm secondary sources describing the enacted Act; the underlying statutory text for this specific provision was not independently re-pulled this cycle, a gap that should be closed before the 2027 effective date approaches. The one-year lead time between enactment and the 1 July 2027 effective date constitutes the compliance gap window: providers that have not previously operated under state lender licensure now have a defined runway to come into the new perimeter, and the structural significance lies in Vermont having chosen to build that perimeter at all, not merely in any single provider's response to it. #### Outlook Watch for Vermont Department of Financial Regulation guidance or rulemaking narrowing ambiguity in scope (which sales-based financing arrangements fall inside Section 2247) ahead of the 1 July 2027 effective date. The structural question worth tracking is whether other states follow Vermont's model of folding commercial financing into existing lender-licensure frameworks rather than building a bespoke regime, since that choice shapes how portable the compliance burden is for multi-state providers. Judgment: Act 142 narrows a previously unlicensed commercial-finance channel by requiring state lender licensure for sales-based financing and factoring providers, a modest enabler-architecture tightening. Probable #### Conflict Finance and Extractive-Industry Integrity Continued Russian crude-export evasion via the shadow fleet directly sustains war-economy financing: rising AIS transponder blackout rates among shadow-fleet vessels this cycle coincide with sustained blocking sanctions from OFAC, OFSI, and the EU against Rosneft, Lukoil, Surgutneftegas, and Gazprom Neft, meaning the underlying export volumes these sanctions target continue moving through evasion channels rather than being fully interdicted. Coverage this cycle is limited to the Russia-Ukraine corridor; no fresh sub-Saharan Africa or Latin America conflict-finance material was located, and this brief does not assert developments in those geographies that were not evidenced. Continue reading #### Outlook The conflict-finance read on the shadow-fleet trend is a continuity finding, not a new-development one: the same evasion architecture flagged under sanctions-architecture monitoring this cycle is the mechanism sustaining conflict-adjacent revenue, and no independent conflict-finance-specific escalation, such as a new interdiction or a fresh revenue estimate, was evidenced this cycle. Judgment: No Vermont-specific conflict-finance development surfaced this cycle. Uncertain #### Crypto, Digital Assets, and Financial Innovation Vermont's Act 142 continues the state's prohibition on virtual-currency kiosks, stating plainly that no person shall locate, operate, or otherwise make available for use a virtual currency kiosk in Vermont. This is a continuation and hardening of a position Vermont's Department of Financial Regulation had already signalled in its own reporting under the states money-services statute, which had found that cryptocurrency conversion through crypto-kiosks without sufficient controls creates an outsized risk. The Act also expands the statutory definition of money transmission to explicitly capture virtual-currency business activity, reinforcing rather than replacing the existing money-transmitter licensure requirement under the state's money-services chapter. Continue reading Crypto kiosks (crypto ATMs) are a well-documented vector for scam-proceeds laundering, particularly romance-scam and so-called pig-butchering schemes in which victims are induced to convert cash into virtual currency at a physical kiosk for onward transfer. Vermont's response, an outright statutory bar rather than a licensing-and-supervision model, represents one end of a policy spectrum that other US states are approaching differently, some opting to license and monitor kiosk operators rather than prohibit the channel altogether. Enacted statutory text, independently confirmed against the primary legislative document, supports a continuing prohibition; what remains unresolved is whether secondary commentary describing this as a permanent ban is correct, or whether the provision is better read as an extended moratorium running to 2027. That reconciliation has not been completed against the full enacted-bill text this cycle, and the distinction carries real weight: a permanent statutory bar and a time-limited moratorium with a 2027 sunset are different durability postures for the same underlying control, even though the operative prohibition is identical for the present. The expanded money-transmission definition is the quieter but structurally durable half of this development. By writing virtual-currency business activity explicitly into the money-transmission definition, Vermont removes any ambiguity about whether such activity already fell inside its money-services licensure perimeter, aligning statutory text with examination practice that Vermont's regulator had likely already been applying. #### Outlook The open question for the next review is definitional: does the kiosk prohibition read as permanent architecture or as a moratorium approaching a 2027 boundary, and that distinction should be resolved by re-checking the full enacted-bill text rather than relying on secondary commentary that currently diverges. Separately, Vermont's continued no-kiosk stance is worth tracking against neighbouring state approaches, since a hard prohibition in one state while others license and supervise the same channel shapes where kiosk-based conversion activity concentrates regionally. Judgment: Act 142 continues Vermont's virtual-currency-kiosk prohibition and expands the statutory money-transmission definition to explicitly capture virtual-currency business activity; secondary sources disagree on whether the kiosk bar is now permanent or an extended moratorium. Probable #### Compliance Technology and Active Defence No Vermont-specific regulatory-technology or supervisory-technology development was identified this cycle; the sole material finding is national in scope. FinCEN's proposed rule to fundamentally reform financial-institution anti-money-laundering and counter-terrorist-financing program requirements continues moving toward possible finalisation in 2026, signalling a shift toward risk-based, effectiveness-oriented, technology-enabled compliance expectations. This would directly affect Vermont-chartered banks, money services businesses, and captive-insurance-adjacent financial entities, should the reform be finalised as proposed, by revising program-design expectations toward greater use of technology-driven detection rather than the current rules-based baseline. Continue reading This reform bears directly on the supervisory gap identified in the enabler-jurisdiction domain: a risk-based, effectiveness-oriented compliance standard applied to Vermont-chartered banks and money services businesses does not, on its own, extend to state-supervised captive insurers, which fall outside FinCEN's direct anti-money-laundering examination authority and remain under Vermont Department of Financial Regulation's solvency-and-conduct-focused oversight. The reform's technology-enabled detection expectations therefore apply unevenly across Vermont's financial-services landscape, reaching federally chartered and BSA-obligated entities while leaving the captive-insurance sector's supervisory gap unaddressed by this particular mechanism. #### Outlook Whether the FinCEN reform is finalised as proposed in 2026 will determine the pace at which Vermont-chartered banks and money services businesses are expected to adopt technology-enabled, risk-based compliance architectures. Separately, and independent of this reform's outcome, the captive-insurance sector's anti-money-laundering supervisory gap will persist unless a distinct state-level or federal mechanism specifically addressing that sector is introduced. Judgment: No RegTech or compliance-technology development identified for Vermont this cycle. Uncertain #### AML/CTF Regime Vermont's AML/CTF architecture for virtual-currency business activity continues to rest on the state's money-transmission licensing framework under 8 V.S.A. Chapter 79, which requires licensure for exchanging, storing, administering, buying, selling, receiving, or transmitting virtual currency. There is no dedicated Vermont financial intelligence unit; federal Bank Secrecy Act and FinCEN reporting and program requirements apply in parallel with, rather than in place of, the state licensing regime. This dual-layer structure — state licensure plus federal BSA obligations — is the stable baseline against which this cycle's kiosk-related development should be read, and it has not itself changed this cycle. Continue reading What has changed is the removal, via Act 142, of a specific retail access point that sat within this regime: the virtual-currency kiosk. Prior to the permanent ban taking effect on 1 July 2026, kiosk operators licensed under Chapter 79 were subject to an additional state-specific customer-identification duty under 8 V.S.A. Section 2577(g), requiring identity verification prior to accepting payment and barring anonymous or third-party-identity transactions. This provision functioned as a targeted know-your-customer overlay addressing the particular laundering and fraud risk profile of cash-accepting kiosks, distinct from the general customer-due-diligence expectations applicable to licensed money transmitters more broadly. With the permanent ban now in force for new kiosk activity, this overlay is largely superseded in practical effect, though it remains the applicable legal standard for any kiosk that may continue operating under a legacy exemption — a status this cycle's evidence did not resolve either way. The architectural significance for the AML/CTF regime as a whole is that Vermont has chosen elimination of a higher-risk retail channel over continued supervision of it. This is consistent with the broader three-pillar analytical principle that the absence of continued enforcement activity in a channel is not itself evidence of adequate control; here, the state legislature and Department of Financial Regulation appear to have reached the opposite conclusion — that the channel's risk profile, evidenced by a documented reduction of more than 94 percent in kiosk numbers under the interim moratorium and by Attorney General Charity Clark's assessment of insufficient consumer protection, warranted permanent closure rather than enhanced conditions. Separately, Act 142 also creates a new Title 8 licensing and disclosure regime for commercial-financing providers, effective 1 July 2027. This extension of state licensure to a previously less-supervised category of non-bank financial activity is, in AML/CTF regime terms, a capacity-building development: it brings a new population of entities within a state licensing and disclosure perimeter for the first time. Department of Financial Regulation implementing guidance for this new regime has not yet been published, so the specific due-diligence, recordkeeping, or reporting content of the regime cannot yet be characterized. #### Outlook The Chapter 79 money-transmission licensing baseline, together with parallel federal BSA/FinCEN obligations, remains the stable core of Vermont's AML/CTF regime for virtual-currency activity. The near-term item to monitor is whether Department of Financial Regulation implementing guidance for the new commercial-financing licensing regime, due to take effect 1 July 2027, specifies AML-relevant due-diligence or reporting obligations for the newly captured provider population; none has been published as of this cycle. Whether any legacy-exempt kiosks remain subject to the Section 2577(g) identification duty in practice is a secondary open item. Judgment: Vermont's AML architecture continues to rest on the federal Bank Secrecy Act/FinCEN framework for money-services businesses, layered under state money-transmitter licensure (8 V.S.A. Chapter 79) supervised by DFR; no VT-specific AML statute or threshold distinct from the federal baseline was identified this cycle. Uncertain Judgment: No commercial transaction among financial-integrity-infrastructure firms identified this cycle for Vermont. Uncertain Regulatory horizon Adopted 1 Jul 2027 · ±quarter ### Commercial financing licensing regime (8 V.S.A. Section 2247) effective Sales-based financing and factoring providers must hold a Vermont lender or loan-solicitation license and give Truth in Lending Act-style disclosures from 1 July 2027. [Source](https://legislature.vermont.gov/Documents/2026/Docs/ACTS/ACT142/ACT142%20As%20Enacted.pdf) Adopted 1 Jul 2027 · ±quarter ### VT commercial-financing/factoring licensing regime in force Providers and brokers funding or soliciting commercial financing/factoring transactions in Vermont will require DFR licensure and must give standardized disclosures, effective 1 July 2027. [Vermont Department of Financial Regulation Source](https://legislature.vermont.gov/Documents/2026/Docs/ACTS/ACT142/ACT142%20As%20Enacted.pdf) In Force 1 Jul 2027 · ±quarter ### VT virtual-currency-kiosk moratorium expires The current moratorium on new virtual-currency kiosks operating in Vermont is due to expire on this date absent further legislative extension. [Vermont Department of Financial Regulation Source](https://legislature.vermont.gov/statutes/section/08/079/02577) Adopted 2027-Q3 · ±quarter ### Vermont Act 142 commercial-financing licensing regime Non-bank commercial-financing providers operating in Vermont will face a new state licensing and disclosure regime from 1 July 2027. [Vermont Department of Financial Regulation Source](https://legislature.vermont.gov/Documents/2026/Docs/ACTS/ACT142/ACT142%20As%20Enacted.pdf) Adopted 2027-Q3 · ±quarter ### Commercial financing (sales-based financing & factoring) licensing regime under Act 142 Providers of sales-based financing and factoring to Vermont recipients will need a lender or loan-solicitation licence, with TILA-style disclosures and an estimated-APR requirement, from July 1, 2027. [Source](https://legislature.vermont.gov/Documents/2026/Docs/ACTS/ACT142/ACT142%20As%20Enacted.pdf) 5 dated · 2 pending date · baseline financial-integrity-2026-07-05 Role action cards MLRO ### Vermont bars virtual-currency kiosks and widens money-transmission scope, while licensing a new non-bank commercial-credit channel. SAR-relevant cash-to-crypto conversion via kiosks remains categorically barred in Vermont, and virtual-currency business activity is now unambiguously within the money-transmission licensure perimeter, which should sharpen monitoring rationale for any Vermont-touching flows. 2 evidence refs Compliance ### A new 8 V.S.A. Section 2247 licensing and disclosure regime reaches sales-based financing and factoring providers from 1 July 2027. Obliged-entity exposure now extends to commercial-financing providers that previously operated outside Vermont lender licensure, with Truth in Lending Act-style disclosure obligations attached. 1 evidence refs Legal ### Confessions of judgment tied to covered commercial-financing products are void under Act 142. Enforcement and contractual-remedy exposure shifts for commercial-financing arrangements touching Vermont once the licensing regime takes effect. 1 evidence refs Board ### Vermont has structurally tightened two enabler channels: crypto-kiosk conversion and unlicensed commercial credit. This is an architecture-level development rather than an isolated enforcement incident, relevant to institutional exposure in both digital-asset and commercial-lending lines touching Vermont. 2 evidence refs CTO ### Virtual-currency kiosks remain categorically prohibited in Vermont and virtual-currency activity is explicitly within money-transmission scope. Any kiosk-based or virtual-currency-business infrastructure with Vermont touchpoints sits inside a hardened statutory bar and an expanded licensure definition. 2 evidence refs Risk ### Act 142 narrows two previously less-supervised channels: crypto-cash kiosks and non-bank commercial credit. Exposure concentration in either channel within Vermont should be reassessed against the new licensing perimeter and the continuing kiosk bar. 2 evidence refs Operations ### No material change for this persona this cycle No material change for this persona this cycle Audit ### No material change for this persona this cycle No material change for this persona this cycle Standing trackers (T1–T6) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture no_change No material change surfaced in this US-VT-bound research pass. T2 · EU AML Package / AMLA no_change Not applicable; US-VT is outside the EEA/AMLR/6AMLD/AMLA perimeter. T3 · FATF Grey List no_change No US-VT-specific FATF grey-list implication identified this cycle. T4 · Beneficial-Ownership Register Status no_change No Vermont-specific beneficial-ownership registry development surfaced this cycle. T5 · Crypto & Digital-Asset Integrity stable Vermont's Act 142 continuation of the virtual-currency-kiosk prohibition and expanded money-transmission scope is an incremental state-level hardening of a known crypto-ATM fraud vector. T6 · Sanctions Regime Divergence no_change No US-VT-specific sanctions-divergence development surfaced this cycle. Registers ### Enforcement actions - 1 Jun 2025 - 26 Mar 2025 - 9 Oct 2025 - 6 Mar 2026 - 3 Aug 2026 - 30 Jun 2026 - 23 Apr 2026 - Federal prosecutors in the District of Vermont charged 25 Canadian nationals in connection with a nationwide multimillion-dollar 'grandparent scam' targeting elderly victims, involving cash-courier money-mule collection and cross-border layering of fraud proceeds. 1 Jun 2025 - FinCEN issued an interim final rule revising the definition of 'reporting company' under the Corporate Transparency Act to exempt all U.S.-formed ('domestic reporting company') entities and their beneficial owners from BOI reporting, retaining only foreign entities registered to do business in a U.S. state. 26 Mar 2025 - FinCEN renewed nationwide Geographic Targeting Orders requiring title insurance companies to identify natural persons behind shell-company non-financed residential real estate purchases, effective October 2025, pending the postponed national Residential Real Estate AML reporting rule. 9 Oct 2025 ### Sanctions changes - 1 Sep 2025 - 4 Feb 2025 - 22 Oct 2025 - During the second half of 2025, the U.S. (with the EU and UK) took coordinated steps to target entities and individuals enabling Russia's use of ruble-backed stablecoins to evade sanctions, applying federally to all U.S. persons and entities including those in Vermont. 1 Sep 2025 - FinCEN issued a proposed rule amending its October 2025 identification of Huione Group as a financial institution of primary money laundering concern under Section 311, a nationally applicable special-measures designation binding on all U.S. financial institutions, including those chartered or operating in Vermont. 1 Jan 2026 - Continuation and enforcement of the 'maximum pressure' Iran sanctions campaign under National Security Presidential Memorandum-2 (Feb. 2025), maintaining blocking of Iranian government and financial-institution property nationally, applicable within Vermont as elsewhere in the U.S. 4 Feb 2025 ### Regulatory horizon (register) - FinCEN 2026 National Money Laundering Risk Assessment refresh - VT commercial-financing/factoring licensing regime in force - VT virtual-currency-kiosk moratorium expires - Vermont Act 142 commercial-financing licensing regime - Commercial financing (sales-based financing & factoring) licensing regime under Act 142 - Vermont commercial-financing licensing regime (8 V.S.A. §2247, via Act 142/H.648) - Virtual-currency kiosk restriction under 8 V.S.A. §2577(f) - Commercial financing licensing regime (8 V.S.A. § 2247) - Commercial financing licensing regime (8 V.S.A. § 2247) effective - GENIUS Act stablecoin implementing rules deadline - National Residential Real Estate AML reporting rule effective date - FinCEN NPRM to reform AML/CFT program requirements - US 5th-round FATF mutual evaluation scheduling ### Active schemes - Post-Corporate-Transparency-Act-rollback opacity of Vermont-formed LLCs and captives - [HIGH] Transnational grandparent scam elder-fraud money-mule network - National pig-butchering crypto-fraud pipeline reaching Vermont victims Sources - [When Wall Street’s Insurance Playbook Goes Wrong](https://www.bloomberg.com/features/2025-america-insurance-part-2/) - [FATF](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-june-2026.html) - [AMLA](https://www.amla.europa.eu/amla-takes-major-step-toward-harmonised-eu-supervision_en) - [FinCEN](https://www.fincen.gov/) - [The Vibes (Reuters investigation)](https://www.thevibes.com/articles/world/125062/cambodian-casino-tycoons-empire-allegedly-links-to-major-cyber-scam-compound) - [Orrick InfoBytes](https://infobytes.orrick.com/2026-06-26/new-vermont-law-bans-virtual-currency-kiosks-and-creates-commercial-financing-licensing-regime/) - [U.S. Department of the Treasury](https://home.treasury.gov/news/press-releases/sb0179) - [Mayer Brown](https://www.mayerbrown.com/en/insights/publications/2026/04/fincens-proposed-whistleblower-program-a-sea-change-in-aml-and-sanctions-enforcement) - [TRM Labs](https://www.trmlabs.com/resources/blog/ofac-sanctions-cambodian-senator-and-scam-center-network-targeting-americans-with-digital-asset-fraud) - [FATF](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-june-2026.html) - [U.S. Department of the Treasury](https://home.treasury.gov/news/press-releases/sb0547) - [AMLA](https://www.amla.europa.eu/amla-takes-major-step-toward-harmonised-eu-supervision_en) - [FinCEN](https://www.fincen.gov/news/news-releases/fincen-issues-supplemental-alert-fuel-smuggling-and-tax-evasion-schemes-southern) - [U.S. Department of the Treasury](https://home.treasury.gov/news/press-releases/sb0179) - [The Vibes (Reuters investigation)](https://www.thevibes.com/articles/world/125062/cambodian-casino-tycoons-empire-allegedly-links-to-major-cyber-scam-compound) - [TRM Labs](https://www.trmlabs.com/resources/blog/ofac-sanctions-cambodian-senator-and-scam-center-network-targeting-americans-with-digital-asset-fraud) - [Follow the Money](https://www.ftm.eu/articles/switching-ais-off-shadow-fleet-going-even-darker) - [Mayer Brown](https://www.mayerbrown.com/en/insights/publications/2026/04/fincens-proposed-whistleblower-program-a-sea-change-in-aml-and-sanctions-enforcement) - [FinCEN](https://www.fincen.gov/) - [Orrick InfoBytes](https://infobytes.orrick.com/2026-06-26/new-vermont-law-bans-virtual-currency-kiosks-and-creates-commercial-financing-licensing-regime/) - [Vermont Legislature (statute)](https://legislature.vermont.gov/statutes/section/08/079/02577) - [https://legislature.vermont.gov/statutes/section/08/079/02577](https://legislature.vermont.gov/statutes/section/08/079/02577) - [https://legislature.vermont.gov/Documents/2026/Docs/ACTS/ACT142/ACT142%20As%20Enacted.pdf](https://legislature.vermont.gov/Documents/2026/Docs/ACTS/ACT142/ACT142%20As%20Enacted.pdf) - [https://dfr.vermont.gov/industry/banking/financial-services/money-services](https://dfr.vermont.gov/industry/banking/financial-services/money-services) - [https://faisalkhan.com/solutions/licensing/money-transmitter-license/vermont-money-transmitter-license](https://faisalkhan.com/solutions/licensing/money-transmitter-license/vermont-money-transmitter-license) - [https://www.consumerprotectioninsights.com/2026/07/vermont-imposes-licensing-and-disclosure-requirements-for-sales-based-financing-and-factoring-transactions/](https://www.consumerprotectioninsights.com/2026/07/vermont-imposes-licensing-and-disclosure-requirements-for-sales-based-financing-and-factoring-transactions/) - [Vermont General Assembly](https://legislature.vermont.gov/statutes/section/08/079/02577) - [Vermont General Assembly](https://legislature.vermont.gov/Documents/2026/Docs/ACTS/ACT142/ACT142%20As%20Enacted.pdf) - [Orrick, Herrington & Sutcliffe LLP](https://infobytes.orrick.com/2026-06-26/new-vermont-law-bans-virtual-currency-kiosks-and-creates-commercial-financing-licensing-regime/) - [Vermont Statutes Online](https://legislature.vermont.gov/statutes/section/08/079/02577) - [Orrick](https://infobytes.orrick.com/2026-06-26/new-vermont-law-bans-virtual-currency-kiosks-and-creates-commercial-financing-licensing-regime/) - [Vermont DFR](https://dfr.vermont.gov/sites/finreg/files/documents/Virtual%20Currency%20Kiosk%20Report%20Pursuant%20to%208%20V.S.A.%20%C2%A7%202577(g).pdf) - [FaisalKhan.com](https://faisalkhan.com/solutions/licensing/money-transmitter-license/vermont-money-transmitter-license) - [https://infobytes.orrick.com/2026-06-26/new-vermont-law-bans-virtual-currency-kiosks-and-creates-commercial-financing-licensing-regime/](https://infobytes.orrick.com/2026-06-26/new-vermont-law-bans-virtual-currency-kiosks-and-creates-commercial-financing-licensing-regime/) - [https://www.huschblackwell.com/newsandinsights/vermont-folds-sales-based-financing-and-factoring-into-its-licensing-regime](https://www.huschblackwell.com/newsandinsights/vermont-folds-sales-based-financing-and-factoring-into-its-licensing-regime) - [https://dfr.vermont.gov/press-release/vermont-joins-80-million-enforcement-action-against-block-inc-cash-app-bsaaml](https://dfr.vermont.gov/press-release/vermont-joins-80-million-enforcement-action-against-block-inc-cash-app-bsaaml) - [https://ago.vermont.gov/blog/2026/04/30/vermont-urges-cftc-recognize-state-authority-over-sports-related-prediction-markets](https://ago.vermont.gov/blog/2026/04/30/vermont-urges-cftc-recognize-state-authority-over-sports-related-prediction-markets) - [Vermont Department of Financial Regulation](https://dfr.vermont.gov/sites/finreg/files/documents/Virtual%20Currency%20Kiosk%20Report%20Pursuant%20to%208%20V.S.A.%20%C2%A7%202577(g).pdf) - [Orrick Infobytes](https://infobytes.orrick.com/2026-06-26/new-vermont-law-bans-virtual-currency-kiosks-and-creates-commercial-financing-licensing-regime/) - [Husch Blackwell](https://www.huschblackwell.com/newsandinsights/vermont-folds-sales-based-financing-and-factoring-into-its-licensing-regime) - [Enforcement Actions | FinCEN.gov](https://www.fincen.gov/news/enforcement-actions) - [1 Financial Crimes Enforcement Network (FinCEN)](https://www.fincen.gov/system/files/2026-05/FinCEN-Year-in-Review-2025.pdf) - [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) - [News | FinCEN.gov](https://www.fincen.gov/news) - [Press Releases | FinCEN.gov](https://www.fincen.gov/news/press-releases) - [United States Department of the Treasury Financial Crimes Enforcement Network - Home | FinCEN.gov](https://www.fincen.gov/?var=v100002) - [Advisories | FinCEN.gov](https://www.fincen.gov/resources/advisoriesbulletinsfact-sheets/advisories) - [Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov](https://www.fincen.gov/news/news-releases/financial-action-task-force-identifies-jurisdictions-anti-money-laundering-5) - [Alerts/Advisories/Notices/Bulletins/Fact Sheets | FinCEN.gov](https://www.fincen.gov/resources/advisoriesbulletinsfact-sheets) - [FinCEN Year In Review | FinCEN.gov](https://www.fincen.gov/about-fincen/fincen-year-review) - [A Money Services Business Guide Financial Crimes Enforcement Network](https://www.fincen.gov/system/files/guidance/msb_prevention_guide.pdf) - [Memorandum of Understanding](https://ofac.treasury.gov/media/31341/download) - [Important Information for MSBs | FinCEN.gov](https://www.fincen.gov/resources/financial-institutions/money-services-businesses) - [Financial Crimes Enforcement Network Registration of Money Services Business](https://www.fincen.gov/system/files/shared/FinCENRMSB_ElectronicFilingInstructions.pdf) - [Enforcement Actions for Failure to Register as a Money Services Business | FinCEN.gov](https://www.fincen.gov/enforcement-actions-failure-register-money-services-business) - [Financial Crimes Enforcement Network](https://www.fincen.gov/system/files/guidance/guidance04262005.pdf) - [Money Services Business (MSB) Registration | FinCEN.gov](https://www.fincen.gov/resources/money-services-business-msb-registration) - [1 Financial Crimes Enforcement Network U.S. Department of the Treasury](https://www.fincen.gov/system/files/shared/FinCEN%20Enforcement%20Statement_FINAL%20508.pdf) - [Statement from the Financial Crimes Enforcement Network | FinCEN.gov](https://www.fincen.gov/news/news-releases/statement-financial-crimes-enforcement-network-0) - [Guidance | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance?field_tags_financial_institution_target_id=All&page=9) - [Guidance on Obtaining and Retaining Beneficial Ownership Information | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/guidance-obtaining-and-retaining-beneficial-ownership) - [GIM11020 - Captive insurers: tax havens and local organisation - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/general-insurance-manual/gim11020) - [Frequently Asked Questions | FinCEN.gov](https://www.fincen.gov/boi-faqs) - [November 2024 Captive insurance Consultation](https://assets.publishing.service.gov.uk/media/6735d32a2469c5b71dbc7b00/Captive_insurance_consultation1.pdf) - [Concealment of Beneficial Ownership July 2018 of Financial Intelligence Units](https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/FATF-Egmont-Concealment-beneficial-ownership.pdf) - [Beneficial Ownership](https://www.fatf-gafi.org/en/topics/beneficial-ownership.html) - [Fact Sheet: Beneficial Ownership Information Reporting Notice of Proposed Rulemaking (NPRM) | FinCEN.gov](https://www.fincen.gov/news/news-releases/fact-sheet-beneficial-ownership-information-reporting-notice-proposed-rulemaking) - [Beneficial Ownership Information Reporting | FinCEN.gov](https://www.fincen.gov/boi) - [U.S. Department of the Treasury Financial Crimes Enforcement Network](https://www.fincen.gov/system/files/shared/BOI_FinCEN_Brochure_508C.pdf) - [Beneficial Ownership Information Report (BOIR) - BOI E-FILING](https://boiefiling.fincen.gov/fileboir) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2025-26) - [Blockchain Legal Library](https://www.trmlabs.com/blockchain-legal-library) - [Elliptic's 2026 regulatory and policy outlook: 5 crypto trends to expect in 2026](https://www.elliptic.co/blog/regulatory-and-policy-crypto-trends-to-except-in-2026) - [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) - [From trading bans to total embrace, a global guide to crypto regulation](https://www.icij.org/investigations/coin-laundry/cryptocurrency-regulations-global-explainer/) - [FSB thematic review 2025: Global crypto regulation remains fragmented despite market growth](https://www.elliptic.co/blog/fsb-thematic-review-2025) - [Elliptic's 2026 regulatory and policy outlook: a global pivot toward innovation](https://www.elliptic.co/blog/elliptics-2026-regulatory-and-policy-outlook-global-pivot-to-innovation) - [PWG Report on Digital Assets: Building Crypto’s Future Together](https://www.chainalysis.com/blog/pwg-report-digital-assets-building-the-future-of-crypto-july-2025/) - [2025 Regulatory outlook: US regulators will pave the way for banks to use digital assets](https://www.elliptic.co/blog/2025-regulatory-outlook-us-regulators-will-pave-the-way-for-banks-to-use-digital-assets) - [Controlled Risk Insurance Co of Vermont Inc - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/1293517D:US) - [Sterling College in Vermont to Stop Teaching Amid Enrollment Strains - Bloomberg](https://www.bloomberg.com/news/articles/2025-12-01/sterling-college-in-vermont-to-stop-teaching-amid-enrollment-strains) - [Oil Trading 'God' Andrew Hall Makes a Home in Vermont - Bloomberg](https://www.bloomberg.com/news/articles/2013-03-14/oil-trading-god-andrew-hall-makes-a-home-in-vermont) - [Captive insurance - GOV.UK](https://www.gov.uk/government/consultations/captive-insurance) - [July 2025 Captive insurance Consultation response](https://assets.publishing.service.gov.uk/media/686fc3f910d550c668de3e04/Captive_insurance_Consultation_Response.pdf) - [IPT08750 - IPT audit assurance: captive insurers - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/insurance-premium-tax/ipt08750) - [Vermont Mutual Insurance Co - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/12768Z:US) - [GIM11010 - Captive insurers: background - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/general-insurance-manual/gim11010) - [GIM11040 - Captive insurers: commercial reasons for establishing a captive - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/general-insurance-manual/gim11040) - [GIM11060 - Captive insurers: taxation issues: possible approaches - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/general-insurance-manual/gim11060) - [Captive Insurance Management Services - Find a Tender](https://www.find-tender.service.gov.uk/Notice/076527-2025) - [DOJ Uses Organized Crime Statute in $263 Million Cryptocurrency Theft, Money Laundering and Home Invasion Conspiracy | TRM Labs](https://www.trmlabs.com/resources/blog/doj-uses-organized-crime-statute-in-263-million-cryptocurrency-theft-money-laundering-and-home-invasion-conspiracy) - [Trudeau Broke the Law in SNC-Lavalin Case, Says Ethics Commissioner | OCCRP](https://www.occrp.org/en/news/trudeau-broke-the-law-in-snc-lavalin-case-says-ethics-commissioner) - [1 Department of Commerce, Department of the Treasury, and](https://ofac.treasury.gov/media/931471/download?inline=) - [Settlement Agreement between the U.S. Department of the Treasury's Office of Foreign Assets Control and Adani Enterprises Limited | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20260518) - [OFAC Related Press Releases | Office of Foreign Assets Control](https://ofac.treasury.gov/press-releases) - [New powers to root out fake ‘lawyers’ giving rogue asylum advice - GOV.UK](https://www.gov.uk/government/news/new-powers-to-root-out-fake-lawyers-giving-rogue-asylum-advice) - [Facebook group immigration adviser impersonator prosecuted - GOV.UK](https://www.gov.uk/government/news/facebook-group-immigration-adviser-impersonator-prosecuted) - [Accusations Fly in Canadian Money Laundering Inquiry | OCCRP](https://www.occrp.org/en/news/accusations-fly-in-canadian-money-laundering-inquiry) - [Counter Terrorism Designations | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20250722) - [Review of Financial Regulation in the Caribbean Overseas ...](https://assets.publishing.service.gov.uk/media/5a74a7d340f0b61df4777658/4855.pdf) - [Vermont Mutual Group Inc - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/7616979Z:US) - [Vermont Inc - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/1779410D:US) - [Anti-money laundering and counter-terrorist financing measures Cayman Islands](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/CFATF-Cayman-Islands-Mutual-Evaluation.pdf) - [Death in Service Captive Insurance Consultation](https://democracy.bathnes.gov.uk/documents/s79732/Death%20In%20Service%20Captive%20Insurance.pdf) - [Christina E Nolan, United States Attorney's Office for the District of Vermont: Profile and Biography - Bloomberg Markets](https://www.bloomberg.com/profile/person/20293254) - [1 FIN-2022-A002 June 15, 2022 Advisory on Elder Financial Exploitation](https://www.fincen.gov/system/files/advisory/2022-06-15/FinCEN%20Advisory%20Elder%20Financial%20Exploitation%20FINAL%20508.pdf) - [BSA Requirements for MSBs | FinCEN.gov](https://www.fincen.gov/bsa-requirements-msbs) - [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) - [FREQUENTLY ASKED QUESTIONS Issued: October 9, 2025](https://www.fincen.gov/system/files/2025-10/RRE-GTO-FAQs.pdf) - [Fact Sheet on MSB Registration Rule | FinCEN.gov](https://www.fincen.gov/fact-sheet-msb-registration-rule) - [About the BSA E-Filing System - FinCEN](https://bsaefiling.fincen.gov/about) - [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) - [Geographic Targeting Orders Involving Certain Real Estate ...](https://www.fincen.gov/system/files/shared/508_FAQ_April2023REGTO.pdf) - [BSA E-Filing System - Login](https://bsaefiling.fincen.gov/file-now) - [Real Estate Geographic Targeting Order](https://www.fincen.gov/system/files/shared/508_Real%20Estate%20GTO%20Order%20FINAL%20GENERIC%2011.4.2020.pdf) - [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) - [Assessments](https://www.fatf-gafi.org/en/calendars/assessments.html) - [Mutual Evaluation of the United States](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationoftheunitedstates.html) - [Consolidated assessment ratings](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Assessment-ratings.html) - [United States](https://www.fatf-gafi.org/en/countries/detail/United-States.html) - [Outcomes FATF Plenary, 22-24 October 2025](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-FATF-plenary-october-2025.html) - [FATF Annual Report 2024-2025](https://www.fatf-gafi.org/en/publications/Fatfgeneral/FATF-Annual-report-2024-2025.html) - [Publications](https://www.fatf-gafi.org/en/publications.html) - [Report on the State of Effectiveness and Compliance with the FATF Standards](https://www.fatf-gafi.org/en/publications/Fatfgeneral/Effectiveness-compliance-standards.html) - [Dear (personalize):](https://www.fincen.gov/sites/default/files/shared/climo2.pdf) - [When Wall Street’s Insurance Playbook Goes Wrong](https://www.bloomberg.com/features/2025-america-insurance-part-2/) - [GIM11180 - Captive insurers: mortgage indemnity business - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/general-insurance-manual/gim11180) - [Blockchain Legal Library](https://www.trmlabs.com/blockchain-legal-library?f612fd81_page=2) - [VERMONT LTD overview - Find and update company information - GOV.UK](https://find-and-update.company-information.service.gov.uk/company/16818195) - [LLM11000 - Lloyd's Manual: Glossary - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/lloyds-manual/llm11000) - [GIM9140 - Mutual insurance: particular types: captive mutual insurers - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/general-insurance-manual/gim9140) - [FinCEN (U.S. Department of the Treasury)](https://www.fincen.gov/boi-faqs) - [FATF](https://www.fatf-gafi.org/en/publications/Mutualevaluations/united-states-fur-2024.html) - [Vermont Department of Financial Regulation](https://dfr.vermont.gov/) - [TRM Labs](https://www.trmlabs.com/blockchain-legal-library) - [Elliptic](https://www.elliptic.co/blog/regulatory-and-policy-crypto-trends-to-except-in-2026) - [Chainalysis](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [FinCEN (U.S. Department of the Treasury)](https://www.fincen.gov/news/news-releases/fincen-renews-residential-real-estate-geographic-targeting-orders-0) - [Elliptic](https://www.elliptic.co/blog/elliptics-2026-regulatory-and-policy-outlook-us-sets-the-pace) Coverage gaps fim-int-2026-07-07-G001: Vermont Department of Financial Reg… fim-int-2026-07-07-G001: Vermont Department of Financial Regulation own-site primary statistical and examination-policy documentation on captive-insurance anti-money-laundering practice was not directly retrieved; sizing relies on secondary and aggregator references. [resolved] fim-int-2026-07-07-G002: The appellate outcome of FinCEN app… fim-int-2026-07-07-G002: The appellate outcome of FinCEN appeal of the Residential Real Estate reporting rule vacatur is not yet known and should be tracked to determine whether the national reporting requirement will be reinstated. [resolved] fim-int-2026-07-07-G003: Final GENIUS Act implementing regul… fim-int-2026-07-07-G003: Final GENIUS Act implementing regulations from OCC, FDIC, Treasury, FinCEN, OFAC, and NCUA have not been published; the outcome relative to the July 18 2026 statutory deadline is unresolved. [resolved] fim-int-2026-07-07-G004: Scheduling of the United States fif… fim-int-2026-07-07-G004: Scheduling of the United States fifth-round Financial Action Task Force mutual evaluation has not been announced, limiting forward assessment of beneficial-ownership effectiveness re-rating timing. [resolved] fim-int-2026-07-07-G005: Whether FinCEN will issue a final C… fim-int-2026-07-07-G005: Whether FinCEN will issue a final Corporate Transparency Act rule that narrows, confirms, or reverses the March 2025 interim domestic-reporting-company exemption remains undetermined. [resolved] fim-int-2026-08-05-G001: No fresh sub-Saharan Africa or Lati… fim-int-2026-08-05-G001: No fresh sub-Saharan Africa or Latin America conflict-finance material located this cycle beyond Russia-Ukraine oil-export evasion. [resolved] fim-int-2026-08-05-G002: No material located for Laos (LA) o… fim-int-2026-08-05-G002: No material located for Laos (LA) or Colombia (CO) Tier-D watch jurisdictions this cycle. [resolved] fim-int-2026-08-05-G003: 6AMLD per-Member-State transpositio… fim-int-2026-08-05-G003: 6AMLD per-Member-State transposition status was not separately updated this cycle. [resolved] fim-int-2026-09-21-G001: D1-D4 and D6 global standing tracke… fim-int-2026-09-21-G001: D1-D4 and D6 global standing trackers and Tier D jurisdiction watch (KH, LA, MX, CO) could not be substantively re-verified this cycle; pooled research budget was prioritised toward the bound jurisdiction US-VT. [resolved] fim-int-2026-09-21-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-21-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): No DFR implementing rules/guidance beyond the statutory text was located for Act 142's 2026 amendments this cycle. [resolved] fim-int-2026-09-28-G001: Tier-D watch (Cambodia, Laos, Mexic… fim-int-2026-09-28-G001: Tier-D watch (Cambodia, Laos, Mexico, Colombia) was not evaluated this cycle owing to the single-jurisdiction (US-VT) binding of this dispatch; a properly-scoped global FIM cycle should re-run that coverage. [resolved] fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): DFR implementing guidance for the new Act 142 commercial-financing licensing regime has not yet been published; compliance-readiness gap for affected non-bank providers not yet assessable. [resolved] fim-int-2026-09-28-G003: Standing trackers T1-T4 and T6 carr… fim-int-2026-09-28-G003: Standing trackers T1-T4 and T6 carry no US-VT-specific nexus this cycle; global-layer coverage for these trackers is deferred to a jurisdiction-unbound FIM cycle. [resolved] fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): DFR implementing guidance interpreting Act 142's expanded 'money transmission' definition specifically for custodial-wallet or exchange activity was not located this cycle. [resolved] fim-int-2026-10-04-G002: Standing Tier D jurisdiction watch … fim-int-2026-10-04-G002: Standing Tier D jurisdiction watch (Cambodia, Laos, Mexico, Colombia) and the monthly regional-balance pass were not performed this cycle due to the US-VT jurisdiction-binding override. [resolved] fim-int-2026-10-04-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G003 ({'scheme': 'financial_integrity', 'value': 'D5'}): No enforcement action arising from the July 1, 2026 kiosk-registration termination was located this cycle. [resolved] fim-int-2026-10-25-G001: Full text of Act 142 Sec. on §2577(… fim-int-2026-10-25-G001: Full text of Act 142 Sec. on §2577(f) was not completely read this cycle; whether the kiosk restriction is a permanent ban or a moratorium ending 1 July 2027 could not be resolved from the excerpts retrieved. [resolved] fim-int-2026-10-25-G002: No Vermont-specific D1 (sanctions),… fim-int-2026-10-25-G002: No Vermont-specific D1 (sanctions), D4 (conflict finance) or D6 (compliance technology) finding was located this cycle. [resolved] fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): Whether the Act 142 virtual-currency-kiosk provision is a permanent prohibition or an extended moratorium to 2027-07-01 was not reconciled against the full enacted-bill text this cycle; secondary sources disagree. [open] fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): Tier-D watch jurisdictions (KH, LA, MX, CO) were not actively researched this cycle because the dispatch was bound to US-VT only. [open] fim-int-2026-11-01-G003: Tier D jurisdiction watch (KH, LA, … fim-int-2026-11-01-G003: Tier D jurisdiction watch (KH, LA, MX, CO) not actively researched this cycle because dispatch was single-jurisdiction-bound to US-VT. [open] FIM-GAP-001 (D2): Vermont has no independent state-level ben… FIM-GAP-001 (D2): Vermont has no independent state-level beneficial-ownership registry; following FinCEN's March 2025 exemption of domestic reporting companies from CTA BOI reporting, Vermont-formed LLCs and captive-insurance vehicles are now largely outside any beneficial-ownership disclosure regime, federal or state. FIM-GAP-002 (D3): Vermont's Department of Financial Regulati… FIM-GAP-002 (D3): Vermont's Department of Financial Regulation supervises captive insurers primarily for solvency and market conduct; there is no dedicated AML/CFT typology-based examination program specific to the captive-insurance sector at the state level. FIM-GAP-003 (D3): This baseline was unable to directly retri… FIM-GAP-003 (D3): This baseline was unable to directly retrieve current statistics, AML-supervisory guidance, or examination policy documents published on the Vermont Department of Financial Regulation's own site (dfr.vermont.gov) specific to captive-insurance beneficial-ownership or AML practice; captive-industry scale claims rely on secondary/aggregator references (a 2019 industry economic-contributions study cited by a UK government consultation) rather than a current Vermont-issued primary statistical publication. FIM-GAP-004 (D2): Vermont is not currently among the metropo… FIM-GAP-004 (D2): Vermont is not currently among the metropolitan areas covered by FinCEN's Residential Real Estate Geographic Targeting Orders, leaving non-financed residential real-estate purchases by legal entities in the state outside enhanced federal beneficial-ownership reporting until the national RRE Rule's reporting requirement takes effect in March 2026. ## Evidence #### Confidence-tiered claims Act 142 permanently bans the location, operation or offering of virtual-currency kiosks in Vermont and terminates all existing kiosk registrations effective July 1, 2026, with a six-year records-retention tail to 2031. [[Source 1]](#sec-sources) Probable · 1 source Act 142 expands the statutory definition of 'money transmission' under 8 V.S.A. chapter 79 to expressly include virtual-currency business activity. [[Source 1]](#sec-sources) Probable · 1 source Money transmitters, including virtual-currency exchangers and custodial-wallet providers, must hold NMLS-administered DFR licensure, surety bonding, and maintain a BSA/AML compliance program. [[Source 1]](#sec-sources) Probable · 1 source DFR's §2577(g) report documents virtual-currency kiosks as a vehicle for routing scam/fraud proceeds, forming the policy basis for Act 142's permanent kiosk ban. [[Source 1]](#sec-sources) Probable · 1 source Act 142 introduces a new lender/loan-solicitation licence for sales-based financing and factoring providers, with TILA-style disclosures and estimated-APR requirements, effective July 1, 2027. [[Source 1]](#sec-sources) Probable · 1 source Existing virtual-currency-kiosk registrations terminate 1 July 2026; new kiosk registration restricted thereafter (duration disputed: permanent per one T3 source, moratorium to 1 July 2027 per a T4 source). [[Source 1]](#sec-sources) Disputed · 1 source Virtual-currency business activity is expressly included within the statutory definition of money transmission requiring a Vermont money-transmitter licence. [[Source 1]](#sec-sources) Probable · 1 source Providers of sales-based financing and factoring to Vermont recipients must hold a DFR lender or loan-solicitation licence from 1 July 2027; depository institutions, government entities, self-financing sellers, and transactions of $1,000,000+ are exempt; TILA-style disclosures mandated. [[Source 1]](#sec-sources) Probable · 1 source Vermont Department of Financial Regulation is the designated state AML supervisor for non-bank money transmitters, coordinating with other states (e.g. the 2025 47-state Block Inc./Cash App BSA/AML settlement, which Vermont joined but which predates this cycle's window). [[Source 1]](#sec-sources) Probable · 1 source in_force [[Source 1]](#sec-sources) Probable · 1 source enacted_not_yet_effective [[Source 1]](#sec-sources) Probable · 1 source No person shall locate, operate, or otherwise make available for use a virtual currency kiosk in Vermont. [[Source 1]](#sec-sources) Probable · 1 source Money-transmission definition expanded to explicitly include virtual-currency business activity. [[Source 1]](#sec-sources) Probable · 1 source New 8 V.S.A. § 2247 requires Vermont lender/loan-solicitation licensure for sales-based financing and factoring providers and TILA-style APR disclosure, effective 2027-07-01. [[Source 1]](#sec-sources) Probable · 1 source