United States — Washington State US-WA

Lead Signal

Washington's Department of Financial Institutions has entered a multistate consent order with crypto-kiosk and money-transmitter operator Coinme, Inc., alongside thirty-four other state regulators, resolving a 2025 Statement of Charges. The order requires Coinme to cease its cryptocurrency-kiosk operations in participating jurisdictions, pay $2.5 million in penalties and costs, and implement additional affirmative compliance measures. The action is structurally significant beyond its dollar figure: Washington has no bespoke crypto-money-transmission statute, so DFI is reaching this result entirely through the general money-transmitter licensing architecture built on the Uniform Money Services Act (RCW 19.230) and its implementing rules at WAC 208-690. That a multistate coalition of this scale converged on a kiosk operator through an ordinary money-services licensing framework, rather than through a crypto-specific statute, is itself the architectural finding: enforcement capacity against this business model does not depend on specialised legislation existing first.

Other Developments

Standing licensing perimeter for virtual-currency transmission. Washington's money-transmitter framework already extends to virtual-currency kiosks and ATMs, exchange platforms that settle transactions, hosted-wallet services with transfer control, and virtual-currency payment processors, according to guidance describing how these activities generally fall within the money transmitter framework. Crypto-specific add-ons layered onto that general perimeter, dating to a 2017 legislative amendment, require a $100,000 minimum tangible net worth for any licensee that stores virtual currency. This is a standing feature of the regime rather than a new development, and it did not change; it is the backdrop against which the Coinme order was reached.

Cross-Monitor Connections

The Coinme enforcement nexus sits at the intersection of state money-transmission law and the digital-asset space the crypto-focused monitor tracks separately: the same underlying facts — a kiosk operator required to cease operations, pay penalties and adopt new compliance measures — carry directly into that monitor's licensing-perimeter analysis, since Washington is using one regulatory architecture to cover both ordinary payment-services activity and virtual-currency activity. Washington's approach of folding crypto-kiosk activity into pre-existing money-services licensing, without a separate crypto statute, is also a datapoint for any observer comparing how permissively or restrictively different jurisdictions supervise this activity: a jurisdiction need not legislate specifically for crypto to bring enforcement action against it.

Outlook

The full text of the multistate consent order, including the Washington-specific allocation of the $2.5 million penalty, had not been independently retrieved at the time this material was compiled, which caps confidence in some of the operational detail at a probable rather than confirmed level. Primary statutory and rule text for RCW 19.230 and WAC 208-690-060(2) likewise had not been independently pulled, so the standing description of the net-worth and licensing-perimeter requirements rests on secondary legal commentary. What would most clear this picture is retrieval of the order's full text and of the underlying statutory and regulatory provisions themselves, which would allow the compliance-lift description to move from probable to confirmed.

Lead Signal

Washington State's Department of Financial Institutions has entered a multi-state consent order against Coinme, Inc., a Seattle-based money transmitter and crypto-kiosk operator, in coordination with 34 other state regulators. The order, entered 7-8 October 2026 under case reference C-25-4009-26-CO02, requires Coinme to pay a $2.5 million package of penalties and costs, to cease crypto-kiosk operations nationwide by 1 January 2027, and to engage an independent consultant to evaluate its BSA/AML program and implement corrective measures. Press reporting alongside the regulator's own release indicates the company allegedly claimed more than $8 million owed to customers as its own income, in violation of the Uniform Money Services Act (Chapter 19.230 RCW). This is a structural enforcement action against a licensee class, not an isolated incident: it establishes that Washington's crypto-kiosk supervisory programme is active, coordinated across jurisdictions, and willing to compel a full product-line shutdown rather than accept a lesser remediation.

The same enforcement register shows a parallel, still-pending Statement of Charges against Bitcoin Depot Operating LLC and its chief executive, entered 8 June 2026, also under the Uniform Money Services Act. The coexistence of a concluded consent order against one major kiosk brand and an unresolved charge against another signals that the Coinme settlement is part of a sustained supervisory programme targeting the crypto-kiosk segment as a whole, rather than a one-off resolution of a single firm's conduct.

Other Developments

Forced commercial wind-down as an AML remedy. The Coinme settlement is notable for converting an AML/BSA compliance failure directly into a commercial restructuring outcome: rather than a fine alone, the order compels the company to exit its crypto-kiosk product line nationwide within a fixed deadline. This blurs the usual separation between enforcement remedy and corporate strategy, and is the kind of outcome that merits tracking as a precedent for how kiosk-model AML deficiencies get resolved elsewhere.

Pending Bitcoin Depot matter unresolved. The Statement of Charges against Bitcoin Depot Operating LLC remains open in DFI's enforcement register as of this cycle. No settlement terms, penalty amount, or remediation requirements have yet been disclosed for that matter; it is carried forward as a standing watch item rather than a concluded finding.

Cross-Monitor Connections

The crypto-kiosk enforcement activity sits squarely at the intersection of Washington's AML/BSA supervisory posture and the commercial fortunes of digital-asset money-transmitter licensees, which is why this cycle's findings are filed under both the Crypto/Digital Assets domain and Commercial Activity. The same underlying consent order would be read by the World Payments Monitor as a licensing and market-access event for a non-bank payment-institution/EMI-type licensee, and by the crypto-focused monitor as a licensing and consumer-protection enforcement matter; FIM's own lens here is the AML/BSA programme deficiency that triggered the settlement and the forced exit from the product line it produced.

Outlook

The operative near-term date is 1 January 2027, the deadline by which Coinme must have ceased all crypto-kiosk operations in Washington under the terms of the consent order. Whether the firm meets that deadline, and whether the independent BSA/AML program review it was required to commission surfaces further findings, are the two concrete items to watch into the next cycle. The pending Bitcoin Depot Statement of Charges is the other open thread: its eventual disposition, whether by settlement, dismissal, or contested proceeding, will indicate whether Washington's kiosk-segment enforcement programme is moving toward a standard settlement template or toward more adversarial outcomes for firms that do not negotiate early.

Lead Signal

Washington State's Department of Financial Institutions led a coordinated, 34-regulator multi-state consent order against Coinme, Inc., entered 7-8 October 2026, over a deficient BSA/AML programme at the company's crypto kiosks. The order requires Coinme to cease all crypto-kiosk operations nationwide before 1 January 2027, undergo an independent BSA/AML compliance review, replace its compliance-responsible managers, and pay a $2.5 million penalty distributed across the settling agencies. Georgia's Department of Banking and Finance, acting alongside WA DFI as one of seven lead agencies among thirty-one other participating states, corroborates the same coordinated effort and terms. This is an architecture story as much as an incident: Washington regulates virtual-currency exchange, custody and kiosk operation as money transmission under the general Uniform Money Services Act (RCW 19.230), with no bespoke crypto AML statute, and the Coinme action demonstrates that this generic-statute architecture is being actively and materially enforced rather than left as a permissive gap.

Other Developments

Underlying consumer-protection findings. The October 2026 consent order resolves a 2025 Statement of Charges that had alleged Coinme failed to disclose voucher-redemption timeframes to consumers and failed to return unclaimed consumer property to the state as required by law. These findings sit alongside the BSA/AML deficiencies as part of the same resolved matter, illustrating how consumer-protection and AML findings can travel together within a single state enforcement action against a money-services business.

Lead-agency coordination as supervisory signal. Washington's role as one of seven lead agencies in a thirty-four-regulator examination is itself a notable structural fact: it shows active, originating supervisory capacity at the state level over crypto money transmission, rather than a jurisdiction that waits for federal action or depends on other states to identify risk.

Cross-Monitor Connections

The Coinme consent order sits at the intersection of state money-transmission licensing and AML/CFT supervision, a pairing the world-payments and crypto monitors are independently tracking for this jurisdiction under their own licensing and crypto-licensing lenses respectively. The underlying facts -- a 34-regulator consent order, a 1 January 2027 shutdown deadline, and a $2.5 million penalty -- are shared across all three monitors' treatments of this single matter, each foregrounding a different structural reading of the same underlying development.

Outlook

The compliance deadline of 1 January 2027 for Coinme's nationwide kiosk shutdown is the next concrete date to watch; whether the company meets that deadline, and whether the required independent BSA/AML review and management changes are completed on schedule, will indicate whether this generic-statute enforcement architecture achieves full remediation or generates further regulatory action. No other sanctions, beneficial-ownership, enabler-jurisdiction, conflict-finance, or compliance-technology signal specific to Washington arose this cycle.

Lead Signal

The defining development this cycle is structural rather than punitive: FinCEN finalized a rule, effective August 14, 2026, permanently exempting U.S. companies and U.S.-person beneficial owners from Corporate Transparency Act beneficial-ownership-information reporting, leaving only foreign registrants in scope. Treasury's own materials frame this as relief for small businesses, but the architecture consequence is that the domestic beneficial-ownership registry FinCEN built under the CTA is now effectively hollowed out for the U.S. entities that make up the overwhelming majority of the register. Previously submitted U.S.-person BOI is to be deleted. This is the most consequential domestic beneficial-ownership transparency reversal since the CTA's 2022 implementing rule, and it lands at a moment when FATF's own Recommendation 24 on beneficial ownership remains a live international benchmark against which the U.S. registry will now be measured with a materially narrower domestic scope.

Other Developments

Sanctions architecture continues to route through already-sanctioned and third-country nodes. OFAC re-designated VTB Bank Public Joint Stock Company on September 14, 2026, this time for facilitating Iranian sanctions evasion under Operation Economic Outcast, layered atop VTB's existing Russia-related SDN listing dating to February 2022. The same period saw FinCEN issue a notice of proposed rulemaking finding five UAE-based branches of Egypt's Banque Misr to be a primary money-laundering concern for facilitating sanctions evasion, consistent with the UAE's recurring role as a secondary-sanctions transit point. Conflict-finance enforcement reached the DRC gold trade. On June 25, 2026, OFAC designated Gasabo Gold Refinery Ltd, its chairman and managing director, and three affiliated Rwandan mining companies for refining and exporting an estimated sixty kilograms or more of gold smuggled from mines in eastern DRC controlled by M23 and supervised by the Rwanda Defence Force, implementing the December 2025 Washington Accords. FATF's grey list moved at the June Plenary. At the June 19, 2026 Plenary, FATF removed Algeria and Namibia from increased monitoring following successful on-site visits; secondary reporting indicates Bosnia and Herzegovina and Iraq were added, which would bring the list to twenty-two jurisdictions ahead of the October 2026 Plenary. The UK narrowed its enhanced-due-diligence trigger. From June 30, 2026, S.I. 2026/621 amended MLR 2017 regulation 33(1)(b) and (3)(a) so that mandatory enhanced due diligence applies only to a FATF call-for-action country; the UK no longer maintains a separate high-risk third-countries list, and FATF grey-list status is now a risk factor rather than a UK EDD trigger, a divergence from the EU's own twenty-six-country high-risk list. Digital-asset laundering of sanctioned oil proceeds was documented. Chainalysis's 2026 Crypto Crime Report traces more than one hundred million dollars tied to Iranian oil sales, brokered by an OFAC-designated individual, laundered through stablecoin purchases and decentralized-finance protocols and bridges between 2023 and 2025.

Cross-Monitor Connections

The Gasabo Gold Refinery designation connects directly to conflict-finance and commodity-flow monitoring: a documented mine-to-refinery-to-market chain running from M23-controlled extraction through Rwanda Defence Force-supervised transit to refining and onward sale is the kind of extractive-industry integrity finding that a commodity-flow monitor would track alongside this sanctions action. The Banque Misr NPRM and VTB re-designation both bear on state-capture and enablement questions relevant to a monitor tracking how sanctioned or adjacent state and quasi-state actors route financial activity through permissive third-country banking nodes. The Chainalysis finding on Iranian oil-proceeds laundering through stablecoins and DeFi is directly relevant to any monitor tracking illicit-finance use of digital-asset infrastructure to obscure sanctioned-actor flows.

Outlook

Watch the October 2026 FATF Plenary, the first under UK Presidency, for confirmation of the Bosnia and Herzegovina and Iraq grey-list additions reported after the June Plenary; a T1 FATF confirmation would resolve the current Probable-confidence secondary-reporting gap. Watch also whether FinCEN's Banque Misr NPRM proceeds to a final special-measures rule, which would be the first concrete enforcement outcome of the UAE-facilitation theory documented this cycle. On the beneficial-ownership front, the practical downstream effect of the CTA exemption on U.S. law-enforcement and international-cooperation access to ownership data is one of the more consequential open questions raised, though not resolved, by this cycle's developments.