--- title: "United States — Washington State (US-WA) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/united-states-washington-state/ source_html: /jurisdictions/united-states-washington-state/index.html description: "Financial integrity intelligence for United States – Washington (US-WA): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T22:34:26Z content_sha256: 5ecc6db9d51f5df3a1b799d44bcca61cea63b2db61d82c77b9299ffca9a2e63b generator: "fe-fleet/md-twin@1.0" --- # United States — Washington State (US-WA) — 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 — Washington State US-WA Domains covered 6 of 8 Sources 160 Role actions 8 Horizon <90d 0 Jurisdiction profile FATF status: Compliant Tier: B Risk direction: Increasing Enablement vs enforcement: Mixed Washington operates within the federal BSA/FinCEN AML/CFT/CPF architecture (US is a FATF member, not grey-listed). More State-level oversight runs through the WA Department of Financial Institutions (DFI) under the Uniform Money Services Act (RCW 19.230), covering money transmitters and virtual-currency businesses. No WA-specific AML enforcement action or MER event was identified in the 18-month window; risk instead flows from federal-level deregulatory shifts (BOI/CTA narrowing, IRS crypto-examiner cuts, OCC preemption of state chartering authority) that dilute DFI's practical supervisory reach over the state's dense crypto-ATM/VASP and global tech-corporate population. Key deficiencies - No identified WA-specific AML/CFT enforcement action in the 18-month window despite the state hosting a significant VASP/crypto-ATM commercial base - Federal CTA/BOI interim final rule (March 2025) exempts domestic reporting companies from beneficial-ownership disclosure, removing the federal transparency backstop for WA-incorporated shell entities with no substitute state BO registry - OCC national trust charter preemption trend erodes WA DFI's practical supervisory authority over crypto firms that obtain federal charters - Federal IRS crypto-AML examiner staffing reductions (33% cut in 2025) shrink supervisory bandwidth over WA-domiciled money-services businesses Recent developments (18m) - FinCEN Section 311 designation of Huione Group as a primary money-laundering concern (Oct 2025), binding on WA-domiciled BSA-covered institutions and VASPs - OFAC/DOJ sanctions and record $15bn forfeiture action against Prince Group TCO (Oct 2025), applicable to WA-based crypto exchanges' sanctions-screening obligations - OFAC designation of DPRK-linked Cheil Credit Bank crypto addresses (Nov 2025), relevant to WA tech-sector and crypto-ATM exposure to DPRK laundering typologies - CTA/BOI interim final rule (March 2025) exempting domestic reporting companies from federal beneficial-ownership disclosure United States federal law that applies in United States – Washington is covered once, on the [United States](/jurisdictions/us/) page. This page covers United States – Washington’s own layer: its own law, regulators and enforcement. Brief ## Lead signal #### Lead Signal Washington State has placed itself inside a live federal dispute over corporate transparency. The states Attorney General, Nick Brown, joined a coalition of twenty states suing to block a federal administrative rollback of the Corporate Transparency Act beneficial-ownership reporting regime. The coalition, led by Oregon and Illinois, argues the rollback violates the Administrative Procedure Act, including through inadequate consultation before the rule change was made. This is not an enforcement action in the conventional sense; it is a state-level contest over whether the federal governments own beneficial-ownership transparency architecture, built under 31 U.S.C. Section 5336, will remain intact or be weakened by administrative action rather than legislative repeal. Read full brief #### Lead Signal Washington State has placed itself inside a live federal dispute over corporate transparency. The states Attorney General, Nick Brown, joined a coalition of twenty states suing to block a federal administrative rollback of the Corporate Transparency Act beneficial-ownership reporting regime. The coalition, led by Oregon and Illinois, argues the rollback violates the Administrative Procedure Act, including through inadequate consultation before the rule change was made. This is not an enforcement action in the conventional sense; it is a state-level contest over whether the federal governments own beneficial-ownership transparency architecture, built under 31 U.S.C. Section 5336, will remain intact or be weakened by administrative action rather than legislative repeal. The significance sits in what the suit reveals about where Washington locates risk. A reduction in federal beneficial-ownership reporting is, from the states perspective, not a settled policy preference but a live and contestable enabler-jurisdiction exposure: fewer records on who actually controls a US entity makes the country, and by extension any state operating within it, more permissive to the kind of opacity that enables illicit finance. Washingtons participation signals that view is being pressed through litigation rather than left to run its course administratively. #### Other Developments A parallel state enforcement action against an unlicensed money-transmission operator. The Washington State Department of Financial Institutions took action against an entity styled Digital Access LLC, dated 19 October 2026, under the states money-transmission framework (RCW 19.230). The substantive content of the action beyond its existence and date was not available to this dispatch, and no further detail is carried into this brief pending fuller sourcing. #### Cross-Monitor Connections A retreat in federal beneficial-ownership transparency, if realised, has structural implications beyond financial-crime monitoring narrowly defined: reduced visibility into who controls US legal entities is a standing input to tracking of sanctions evasion, conflict-finance layering, and state-capture typologies that other monitors in this fleet follow independently. The Washington suit is best read as a defensive state-level move to preserve the evidentiary base those adjacent trackers depend on, rather than as an isolated administrative dispute. #### Outlook The coalition suit is at an early procedural stage, and its outcome is not yet determined. The material question going forward is whether the federal rollback is stayed, narrowed, or allowed to proceed while litigation continues, and whether Washington or other coalition states take further action, such as seeking preliminary injunctive relief, if the rollback is not paused. As scheduled, no further procedural milestone has yet been confirmed in the material available to this dispatch. Earlier periodic briefs (4) 25 Oct 2026 · fim-2026-10-25 #### 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. 18 Oct 2026 · fim-2026-10-18 #### 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. 11 Oct 2026 · fim-2026-10-11 #### 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. 28 Sep 2026 · fim-2026-09-28 #### 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. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion This cycle's sanctions-relevant signal for Mexico-based financial-crime architecture is mixed in verification status. FinCEN's supplemental alert on huachicol fuel-smuggling and tax-evasion schemes, citing more than seven billion dollars in cumulative suspicious-activity reporting, expands the tracked enforcement architecture around Mexico-based transnational criminal organisations, even though the alert itself is an AML reporting instrument rather than a sanctions designation. The more directly sanctions-relevant item this cycle is a reported OFAC action against casinos linked to Cartel del Noreste, surfaced within reporting on Chinese money-laundering networks' professional-enabler role; this sub-claim rests on a single Tier-4 source and has not been corroborated by a Tier-1 or Tier-2 primary source this cycle. Consistent with the enablement-as-signal principle, the absence of a verified primary-source sanctions action is itself analytically notable: if confirmed, a Section 311-style special measure against Mexico-based casinos would represent a meaningful architectural escalation from advisory guidance to a structural sanctions tool targeting a specific sector; until verified, it should be treated as a reported development under active tracking rather than a confirmed architecture shift. The FinCEN advisory's associated reporting obligation references, including Bank Secrecy Act suspicious-activity reporting duties and FATF Recommendation 16 wire-transfer-transparency standards, underscore that the current architecture leans on AML reporting and correspondent due-diligence tools rather than direct sanctions designations for this specific casino-sector thread. No EU or UK autonomous-listing action parallel to the reported OFAC measure has been identified, consistent with continued divergence in how different jurisdictions structure casino-sector financial-crime sanctions exposure. Given the thinness of primary-source, sanctions-specific material this cycle relative to the AML-reporting and enabler-jurisdiction threads, this sub-brief is flagged for limited signal. Continue reading #### Outlook The item to watch is whether a Tier-1 OFAC press release or designation record emerges confirming the reported casino-sector sanctions action; its confirmation or non-confirmation next cycle will determine whether this escalates from a Tier-4-sourced report to a verified sanctions-architecture development. Baseline-Tracked Domains with No Current-Cycle Escalation (2 of 8) - D6 Compliance Technology & Active Defence: Standing coverage — no activity this cycle. - D7 AML/CTF Regime: Standing coverage — no activity this cycle. Regulatory horizon No dated horizon items this cycle. 1 item tracked without a confirmed date. 1 pending date · baseline fim-2026-07-06 Role action cards MLRO ### Washington joined a multistate suit to block a federal rollback of Corporate Transparency Act beneficial-ownership reporting. If the federal rollback proceeds notwithstanding the challenge, due-diligence files that currently rely on Corporate Transparency Act beneficial-ownership filings may lose a layer of federal corroboration, which has implications for source documentation used in suspicious-activity assessments. 1 evidence refs Compliance ### A twenty-state coalition, including Washington, is litigating to preserve the existing federal beneficial-ownership reporting regime. The underlying federal reporting obligation under the Corporate Transparency Act should be treated as contested rather than settled while the litigation is live, which affects how confidently a compliance programme can rely on continuity of that obligation when designing controls. 1 evidence refs Legal ### The coalition suit alleges the federal rollback violated the Administrative Procedure Act, including through inadequate consultation. The legal theory rests on procedural grounds, not a substantive defence of the beneficial-ownership policy itself, which affects how the litigations trajectory and likely remedies should be read. 1 evidence refs Board ### Washington has taken a public litigation position against a federal retrenchment of corporate beneficial-ownership transparency. This signals a state-level institutional view that reduced beneficial-ownership transparency is a material financial-crime risk, which is relevant to any board-level assessment of regulatory direction in jurisdictions where the institution operates. 1 evidence refs CTO ### No material change for this persona this cycle. No material change for this persona this cycle Risk ### A federal rollback of beneficial-ownership reporting, if it proceeds, reduces visibility relied upon across financial-crime risk typologies. Reduced beneficial-ownership transparency at the federal level is a cross-cutting exposure concentration point, since multiple downstream risk assessments depend on continuity of that reporting regime. 1 evidence refs Operations ### No material change for this persona this cycle. No material change for this persona this cycle Audit ### The reliability of beneficial-ownership documentation as an audit evidence source is now contested pending the outcome of state litigation. Control testing that assumes continuity of Corporate Transparency Act beneficial-ownership filings as a documentation source should note the pending litigation as a condition affecting that assumption. 1 evidence refs Scenario sketches ### Illustrative divergence between state litigation and federal beneficial-ownership retrenchment Illustrative orientation only, not a prediction or an observed fact. One possible structural path is that continued state-coalition litigation against a federal rollback of beneficial-ownership reporting produces a patchwork outcome: some states obtain injunctive protection of the existing reporting regime within their own enforcement reach, while federal administrative retrenchment proceeds elsewhere, producing a period in which the reliability of a beneficial-ownership filing depends on which court has ruled on which states challenge. Separately, and illustrating a different structural mechanism, the European Unions shift toward AMLA direct and indirect supervision of cross-border obliged entities under the AMLA Regulation, alongside the directly applicable AML Regulation and national transposition of the sixth AML Directive, could over time produce a visible gap between a consolidating EU-level beneficial-ownership supervisory perimeter and a contested, potentially narrowing, United States federal one, altering where illicit actors perceive relative opacity to be greatest. Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact. Standing trackers (T1–T6) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture no_change T2 · EU AML Package / AMLA no_change T3 · FATF Grey List no_change T4 · Beneficial-Ownership Register Status no_change T5 · Crypto & Digital-Asset Integrity watch T6 · Sanctions Regime Divergence no_change Registers ### Enforcement actions - 14 Oct 2025 - 14 Oct 2025 - 23 Jun 2026 - 4 Nov 2025 - 7 Mar 2025 - 14 Aug 2025 - 25 Nov 2025 - 9 Feb 2026 - 15 Jan 2025 - Consent order requiring payment of the remaining $50,000 of a Paid Fine, alongside licence surrender within 90 days. 9 Feb 2026 - Temporary cease-and-desist ordering full repayment of unredeemed Bitcoin-ATM voucher balances to customers. 1 Dec 2025 - 8 Oct 2026 - FinCEN issued a Section 311 finding designating Huione Group a foreign financial institution of primary money-laundering concern, severing its US correspondent/payable-through account access. The finding and subsequent final rule bind all US BSA-covered institutions and VASPs, including those domiciled in Washington, to cease processing transactions for the network. 14 Oct 2025 - OFAC designated the Prince Group TCO and 146 associated targets for cryptocurrency scam operations and forced-labor compounds; DOJ concurrently unsealed an indictment against chairman Chen Zhi and filed a record $15bn civil forfeiture against approximately 127,000 bitcoin. The designation applies sanctions-screening obligations to all US financial institutions and VASPs, including Washington-domiciled crypto exchanges. 14 Oct 2025 - OFAC listed over fifty crypto addresses belonging to sanctioned North Korean bank Cheil Credit Bank plus another DPRK financial institution and several bankers, for facilitating DPRK cybercrime and espionage financing. Washington-based crypto exchanges and MSBs are required to screen against the newly listed addresses. 4 Nov 2025 - DOJ, coordinating with German and Finnish authorities, disrupted Garantex, seizing domains/servers and freezing over $26 million in illicit funds, and unsealed criminal charges against its administrators for laundering hundreds of millions in cybercrime and sanctions-evasion proceeds. WA-domiciled VASPs and crypto-ATM operators are subject to ongoing screening obligations against Garantex-linked wallets and successor entities (e.g., Grinex). 7 Mar 2025 ### Sanctions changes - 14 Oct 2025 - 23 Jun 2026 - 4 Nov 2025 - 14 Aug 2025 - 1 Apr 2026 - 14 Sep 2026 - 25 Jun 2026 - 1 Oct 2026 - 29 Sep 2026 - OFAC designated the Prince Group TCO and 146 associated individuals/entities (including Cambodian Senator Kok An's business empire in a follow-on April 2026 action) for cryptocurrency scam operations, forced labor and money laundering, applicable to WA-domiciled financial institutions' sanctions-screening programs. 14 Oct 2025 - OFAC designated over fifty crypto addresses belonging to DPRK's Cheil Credit Bank plus another North Korean financial institution and several bankers involved in cybercrime and espionage financing. 4 Nov 2025 - FinCEN issued a notice implementing the FATF's February 2026 plenary outcome, informing US financial institutions that Kuwait and Papua New Guinea were added to the Jurisdictions Under Increased Monitoring list, while the High-Risk Jurisdictions Subject to a Call for Action list (Iran, DPRK, Burma) remained unchanged. 13 Feb 2026 - National Security Presidential Memorandum-2 (Feb 4, 2025) reimposed a 'maximum pressure' campaign on Iran; the Government of Iran and Iranian financial institutions remain blocked under E.O. 13599 and the ITSR, with US restrictions on correspondent accounts continuing to exceed baseline FATF recommendations. 4 Feb 2025 ### Regulatory horizon (register) - AMLR / 6AMLD full application and AMLD4/5 repeal - UK ECCTA 2023 failure-to-prevent-fraud offence - FinCEN NPRM: BSA special measure against A7 Network Sub-Agents - FATF October 2026 Plenary (first under UK Presidency) - GENIUS Act stablecoin implementing regulations deadline - FinCEN AML/CFT program reform rule finalization - FATF next plenary review of grey/high-risk lists ### Active schemes - Crypto-ATM/kiosk cash-out pipeline exploiting WA VASP base - DPRK IT-worker infiltration of WA tech-employment sector - Aerospace dual-use parts diversion to sanctioned Russian carriers Sources - [MSB Registrant Search | FinCEN.gov](https://www.fincen.gov/resources/msb-state-selector) - [Washington DFI](https://dfi.wa.gov/sites/default/files/consumer-services/enforcement-actions/C-25-3892-26-CO01-CoinZoom-Inc_web_Redacted.pdf) - [National Law Review](https://natlawreview.com/article/washington-dfi-enters-consent-order-digital-assets-focused-money-transmitter) - [mexc.com (news aggregator, citing BitcoinEthereumNews)](https://www.mexc.com/news/226151) - [FinCEN](https://www.fincen.gov/news/news-releases/fincen-issues-supplemental-alert-fuel-smuggling-and-tax-evasion-schemes-southern) - [FinCEN](https://www.fincen.gov/system/files/2025-08/FinCEN-Advisory-CMLN-508.pdf) - [Illicit Edge](https://illicitedge.com/chinese-money-laundering-networks-serving-mexico-based-drug-cartels/) - [Cambodianess](https://cambodianess.com/article/cambodia-removed-from-the-fatfs-grey-list) - [FATF](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [FATF](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) - [eucrim (Max Planck / OLAF-affiliated legal journal)](https://eucrim.eu/news/new-anti-money-laundering-directive-amld-6/) - [UK Home Office / gov.uk](https://assets.publishing.service.gov.uk/media/67f8ef1845705eb1a1513f35/Failure+to+Prevent+Fraud+Guidance+-+English+Language+v1.6.pdf) - [Federal Reserve Board](https://www.federalreserve.gov/newsevents/speech/files/barr20260331a.pdf) - [Holland & Knight](https://www.hklaw.com/en/insights/publications/2026/09/too-big-to-sanction-ofac-fincen-risks-foreign-financial-institutions) - [Financial Action Task Force](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-june-2026.html) - [Checklynx](https://checklynx.com/en/resources/knowledge-base/fatf-grey-list) - [Financial Crimes Enforcement Network](https://www.fincen.gov/boi) - [U.S. Department of the Treasury](https://home.treasury.gov/news/press-releases/sb0603) - [U.S. Department of State](https://www.state.gov/releases/office-of-the-spokesperson/2026/06/united-states-sanctions-networks-fueling-conflict-and-mineral-theft-in-eastern-drc) - [U.S. Department of the Treasury](https://home.treasury.gov/news/press-releases/sb0543) - [Chainalysis](https://www.chainalysis.com/blog/crypto-sanctions-2026/) - [CryptoSlate](https://cryptoslate.com/crypto-laws/uk-money-laundering-terrorist-financing-amendment-regulations-2026/) - [Washington State Department of Financial Institutions](https://dfi.wa.gov/newsletter/winter-2026-division-consumer-services/money-services-industry-update) - [FinCEN](https://www.fincen.gov/news/news-releases/operation-economic-outcast-takes-unprecedented-action-against-sanctions-evasion) - [FinCEN](https://www.fincen.gov/system/files/2026-10/FinCEN-Alert-A7-Network.pdf) - [OFAC / U.S. Treasury](https://ofac.treasury.gov/press-releases) - [ComplyAdvantage](https://complyadvantage.com/insights/fatf-plenary-june-2026-outcomes/) - [FinCEN](https://www.fincen.gov/system/files/2026-08/FinCEN-Alert-Scam-Centers.pdf) - [Washington State Department of Financial Institutions](https://dfi.wa.gov/sites/default/files/consumer-services/enforcement-actions/C-25-3892-26-CO01-CoinZoom-Inc_web_Redacted.pdf) - [Washington State Department of Financial Institutions](https://dfi.wa.gov/news/press/washington-state-dfi-takes-action-against-coinme-halt-all-money-transfers-washington-due) - [Washington State Department of Financial Institutions](https://dfi.wa.gov/news/press/washington-state-dfi-enters-multi-state-consent-order-coinme-inc) - [Georgia Department of Banking and Finance](https://dbf.georgia.gov/press-releases/2026-10-08/consent-order-entered-coinme-inc) - [Washington State Department of Financial Institutions](https://dfi.wa.gov/enforcement-actions) - [The Spokesman-Review](https://www.spokesman.com/stories/2026/oct/09/seattle-based-crypto-exchange-company-agrees-to-mu/) - [https://dfi.wa.gov/news/press/washington-state-dfi-enters-multi-state-consent-order-coinme-inc](https://dfi.wa.gov/news/press/washington-state-dfi-enters-multi-state-consent-order-coinme-inc) - [https://www.spokesman.com/stories/2026/oct/09/seattle-based-crypto-exchange-company-agrees-to-mu/](https://www.spokesman.com/stories/2026/oct/09/seattle-based-crypto-exchange-company-agrees-to-mu/) - [https://www.sheppard.com/insights/blogs/washington-dfi-reaches-2-5-million-settlement-with-crypto-kiosk-operator](https://www.sheppard.com/insights/blogs/washington-dfi-reaches-2-5-million-settlement-with-crypto-kiosk-operator) - [https://dfi.wa.gov/agency-enforcement-acts/uniform-money-services-act](https://dfi.wa.gov/agency-enforcement-acts/uniform-money-services-act) - [https://faisalkhan.com/solutions/licensing/money-transmitter-license/washington-money-transmitter-license](https://faisalkhan.com/solutions/licensing/money-transmitter-license/washington-money-transmitter-license) - [https://cryptoslate.com/crypto-laws/washington-uniform-money-services-act-virtual-currency-regime/](https://cryptoslate.com/crypto-laws/washington-uniform-money-services-act-virtual-currency-regime/) - [Washington State Office of Attorney General](https://www.einpresswire.com/article/952679546/ag-brown-sues-to-block-the-federal-administration-s-gutting-of-the-corporate-transparency-act) - [Washington State Department of Financial Institutions](https://dfi.wa.gov/) - [DEPARTMENT OF FINANCIAL INSTITUTIONS](https://www.fincen.gov/sites/default/files/shared/state_of_washington_dept_financial_services.pdf) - [Advisories | FinCEN.gov](https://www.fincen.gov/resources/advisoriesbulletinsfact-sheets/advisories) - [State Contact Information For MSBs](https://www.fincen.gov/sites/default/files/shared/msbstatecontactsfinal.pdf) - [Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2025-26) - [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) - [1 Financial Crimes Enforcement Network (FinCEN)](https://www.fincen.gov/system/files/2026-05/FinCEN-Year-in-Review-2025.pdf) - [TRM Labs | Agents and intelligence to fight crime](https://www.trmlabs.com/) - [FinCEN Exchange | FinCEN.gov](https://fincen.gov/resources/financial-crime-enforcement-network-exchange) - [DEPARTMENT OF THE TREASURY WASHINGTON, D.C. OFFICE OF FOREIGN ASSETS CONTROL](https://ofac.treasury.gov/media/935516/download?inline=) - [Alerts/Advisories/Notices/Bulletins/Fact Sheets | FinCEN.gov](https://www.fincen.gov/resources/advisoriesbulletinsfact-sheets) - [Press Releases | FinCEN.gov](https://www.fincen.gov/news/press-releases) - [News | FinCEN.gov](https://www.fincen.gov/news) - [United States Department of the Treasury Financial Crimes Enforcement Network - Home | FinCEN.gov](https://www.fincen.gov/) - [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) - [FinCEN Assesses $3.5 Million Penalty Against Paxful for Facilitating Suspicious Activity Involving Illicit Actors | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-assesses-35-million-penalty-against-paxful-facilitating-suspicious) - [FinCEN Exchange | FinCEN.gov](https://www.fincen.gov/resources/fincen-exchange) - [FinCEN Announces Data-Driven Border Operation to Address Potential Money Laundering | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-announces-data-driven-border-operation-address-potential-money-laundering) - [The Value of FinCEN Data - Law Enforcement ...](https://www.fincen.gov/resources/law-enforcement/case-examples) - [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) - [1 1. See 31 U.S.C. § 5312(a)(2); 31 C.F.R. § 1010.100(t). 2.](https://www.fincen.gov/system/files/2026-06/FinCEN-Alert-Fiscal-Fuel-Theft.pdf) - [1 The U.S. Department of the Treasury’s (Treasury)](https://www.fincen.gov/system/files/2025-08/FinCEN-Advisory-CMLN-508.pdf) - [1 The U.S. Department of the Treasury’s (Treasury) Financial](https://www.fincen.gov/system/files/2026-03/FinCEN-Advisory-Health-Care-Fraud.pdf) - [FinCEN Fines Western Union Financial Services, Inc. for Past Violations of Anti-Money Laundering Rules In Coordinated Action with DOJ and FTC | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-fines-western-union-financial-services-inc-past-violations-anti-money) - [PPSI-AMLCFT-NPRM.pdf](https://www.fincen.gov/system/files/2026-04/PPSI-AMLCFT-NPRM.pdf) - [International Action Dismantles Notorious Russian Crypto Exchange Garantex - Chainalysis](https://www.chainalysis.com/blog/russian-exchange-garantex-dismantled/) - [Blockchain Legal Library](https://www.trmlabs.com/blockchain-legal-library) - [2026 Crypto Crime Report: Scams](https://www.chainalysis.com/blog/crypto-scams-2026/) - [FinCEN Finds Cambodia-Based Huione Group to be of Primary Money Laundering Concern, Proposes a Rule to Combat Cyber Scams and Heists | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-finds-cambodia-based-huione-group-be-primary-money-laundering-concern) - [FinCEN Issues Notice on the Use of Convertible Virtual Currency Kiosks for Scam Payments and Other Illicit Activity | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-notice-use-convertible-virtual-currency-kiosks-scam-payments-and) - [FinCEN Fines BTC-e Virtual Currency Exchange $110 Million for Facilitating Ransomware, Dark Net Drug Sales | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-fines-btc-e-virtual-currency-exchange-110-million-facilitating-ransomware) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [As crypto industry expands, US slashes office examining dirty money safeguards of cryptocurrency exchanges - ICIJ](https://www.icij.org/investigations/coin-laundry/as-crypto-industry-expands-u-s-slashes-office-examining-dirty-money-safeguards-of-cryptocurrency-exchanges/) - [TRM Labs Resources | Crypto Investigations, Compliance, and Policy Insights](https://www.trmlabs.com/resources) - [Trump administration curbs state oversight of crypto industry - ICIJ](https://www.icij.org/investigations/coin-laundry/trump-administration-curbs-state-oversight-of-crypto-industry/) - [OFAC lists 53 crypto addresses of sanctioned North Korean Cheil Credit Bank](https://www.elliptic.co/blog/ofac-lists-53-crypto-addresses-of-sanctioned-north-korean-cheil-credit-bank) - [2026 Crypto Crime Report – Illicit Crypto Trends & Typologies | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/2026-crypto-crime-report) - [Questions swirl around US plans for record $15B Prince Group crypto seizure - ICIJ](https://www.icij.org/investigations/coin-laundry/questions-swirl-around-us-plans-for-record-15b-prince-group-crypto-seizure/) - [U.S. Crackdown on Southeast Asian Crypto Scam Centers](https://www.chainalysis.com/blog/asian-scam-centers-crypto-fraud-april-2026/) - [DOJ Seizes $15 Billion in Bitcoin](https://www.chainalysis.com/blog/southeast-asia-crypto-scam-network-mining-pig-butchering-october-2025/) - [$15 billion seized by US originates from Iran/China bitcoin miner "theft"](https://www.elliptic.co/blog/15-billion-us-seizure-reveals-prince-groups-connection-to-iran-china-bitcoin-mining-theft) - [Prince Group targeted with $15B crypto seizure and sanctions for pig butchering operations](https://www.elliptic.co/blog/prince-group-targeted-with-crypto-sanctions-for-global-pig-butchering-operations) - [The Coin Laundry, a global cryptocurrency investigation](https://www.icij.org/investigations/coin-laundry/) - [UNITED STATES OF AMERICA FINANCIAL CRIMES ENFORCEMENT NETWORK](https://www.fincen.gov/system/files/2026-03/Canaccord-Consent-Order-No-2026-01.pdf) - [Memorandum of Understanding](https://ofac.treasury.gov/media/32091/download?inline=) - [FinCEN Proposes Rule to Fundamentally Reform Financial Institution Programs Designed to Fight Illicit Finance | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-proposes-rule-fundamentally-reform-financial-institution-programs) - [Enforcement Actions | FinCEN.gov](https://www.fincen.gov/news/enforcement-actions) - [1 FinCEN Advisory United States Department of the Treasury](https://www.fincen.gov/system/files/advisory/advissu7.pdf) - [Treasury Anti-Money Laundering Regulations | FinCEN.gov](https://www.fincen.gov/treasury-anti-money-laundering-regulations) - [Fact Sheet on MSB Registration Rule | FinCEN.gov](https://www.fincen.gov/fact-sheet-msb-registration-rule) - [Enforcement Actions for Failure to Register as a Money Services Business | FinCEN.gov](https://www.fincen.gov/enforcement-actions-failure-register-money-services-business) - [Definition of Money Transmitter (Merchant Payment Processor) | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/definition-money-transmitter-merchant-payment) - [Application of the Definition of Money Transmitter to Brokers and Dealers in Currency and Other Commodities | FinCEN.gov](https://fincen.gov/index.php/resources/statutes-regulations/guidance/application-definition-money-transmitter-brokers-and) - [FinCEN Notice, FIN-2025-NTC1, August 4, 2025](https://www.fincen.gov/system/files/2025-08/FinCEN-Notice-CVCKIOSK.pdf) - [Whether a Company that Provides Online Real-Time Deposit, Settlement, and Payment Services for Banks, Businesses and Consumers is a Money Transmitter rather | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/whether-company-provides-online-real-time) - [BSA Expectations Regarding Marijuana-Related Businesses | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/bsa-expectations-regarding-marijuana-related-businesses) - [FinCEN Issues Guidance to Financial Institutions on Marijuana Businesses | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-guidance-financial-institutions-marijuana-businesses) - [Guidance | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance?page=2) - [BSA Expectations Regarding Marijuana-Related Businesses](https://www.fincen.gov/system/files/shared/FIN-2014-G001.pdf) - [Pot Industry Banking Bill Still in Congressional Limbo (Correct) - Bloomberg](https://www.bloomberg.com/news/newsletters/2024-05-01/pot-industry-banking-bill-still-in-limbo-but-not-dead-yet) - [Draft: Study on Illicit Financial Flows resulting from Drug Trafficking and](https://www.unodc.org/documents/data-and-analysis/Studies/Illicit-financial-flows-15March.pdf) - [Marijuana Banking Update](https://www.fincen.gov/sites/default/files/shared/305326_MJ%20Banking%20Update%204th%20QTR%20FY2021_Public_Final.pdf) - [REQUEST ID SUMMARY OF REQUEST DATE RECEIVED REQUESTER GoFOIA # 19-001-F](https://www.fincen.gov/system/files/shared/FY19_FOIA_Log.pdf) - [FinCEN Guidance, FIN-2020-G001](https://www.fincen.gov/sites/default/files/2020-06/FinCEN_Hemp_Guidance_508_FINAL.pdf) - [Application of Money Services Business regulations to the rental of computer systems for mining virtual currency | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/application-money-services-business-0) - [Definition of Money Services Business (Money Transmitter/Currency Dealer or Exchanger) | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/definition-money-services-business-money-0) - [Application of FinCEN’s Regulations to Certain Business Models Involving Convertible Virtual Currencies | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/application-fincens-regulations-certain-business-models) - [FinCEN Issues Guidance on Virtual Currencies and Regulatory Responsibilities | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-guidance-virtual-currencies-and-regulatory-responsibilities) - [Application of Money Services Business Regulations to a Company Acting as an Independent Sales Organization and Payment Processor | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/application-money-services-business) - [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) - [Request for Administrative Ruling on the Application of FinCEN’s Regulations to a Virtual Currency Payment System | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/request-administrative-ruling-application) - [Request for Administrative Ruling on the Application of FinCEN’s Regulations to a Virtual Currency Trading Platform | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/request-administrative-ruling-application-0) - [Civil Penalties and Enforcement Information | Office of Foreign Assets Control](https://ofac.treasury.gov/civil-penalties-and-enforcement-information) - [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [Russia’s Airlines Skirt Sanctions to Keep Boeing, Airbus Jets Flying](https://www.bloomberg.com/graphics/2026-russian-airlines-sanctions/) - [Recent Actions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/enforcement-actions) - [News - European Commission](https://trade.ec.europa.eu/doclib/press/index.cfm?id=2207) - [DEPARTMENT OF THE TREASURY WASHINGTON, D.C. OFFICE OF FOREIGN ASSETS CONTROL](https://ofac.treasury.gov/media/934626/download?inline=) - [China Removes Ban on Boeing Deliveries After US Trade Truce - Bloomberg](https://www.bloomberg.com/news/articles/2025-05-13/china-removes-ban-on-boeing-deliveries-after-us-trade-truce) - [2010 Civil Penalties and Enforcement Information | Office of Foreign Assets Control](https://ofac.treasury.gov/civil-penalties-and-enforcement-information/2010-enforcement-information) - [U.S. DEPARTMENT OF THE TREASURY OFFICE OF FOREIGN ASSETS CONTROL](https://ofac.treasury.gov/media/933941/download?inline=) - [WT/DS353 - United States - Measures Affecting Trade in Large Civil Aircraft (second complaint)](https://policy.trade.ec.europa.eu/enforcement-and-protection/dispute-settlement/wto-dispute-settlement/wto-disputes-cases-involving-eu/wtds353-united-states-measures-affecting-trade-large-civil-aircraft-second-complaint_en) - [US DOJ Announces Largest Ever Seizure of Funds Related to Crypto Scams | TRM Labs](https://www.trmlabs.com/resources/blog/us-doj-announces-largest-ever-seizure-of-funds-related-to-crypto-scams) - [FinCEN Announces Recipients of Its 11th Law Enforcement Awards Program | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-announces-recipients-its-11th-law-enforcement-awards-program) - [Crypto Mixer Co-Founder Gets Four Years in Money-Laundering Case - Bloomberg](https://www.bloomberg.com/news/articles/2025-11-19/crypto-mixer-co-founder-gets-four-years-in-money-laundering-case) - [Crypto Sanctions: 2026 Crypto Crime Report](https://www.chainalysis.com/blog/crypto-sanctions-2026/) - [Crypto Mixer Co-Founder Gets Five Years in Money-Laundering Case - Bloomberg](https://www.bloomberg.com/news/articles/2025-11-06/crypto-mixer-co-founder-gets-five-years-in-money-laundering-case) - [The DOJ's NCET Disbanded: What This Means for Digital Assets - Chainalysis](https://www.chainalysis.com/blog/ncet-blanche-memo/) - [Organized Crime Shows High Level of Professionalization, Low Level of Crypto Sophistication - Chainalysis](https://www.chainalysis.com/blog/organized-crime-crypto/) - [Law enforcement, banks warn of money laundering gaps in major US crypto bill - ICIJ](https://www.icij.org/investigations/coin-laundry/law-enforcement-banks-warn-of-money-laundering-gaps-in-major-us-crypto-bill/) - [2025 Crypto Theft Reaches $3.4 Billion](https://www.chainalysis.com/blog/crypto-hacking-stolen-funds-2026/) - [North Korea Stole 76% of All Crypto Hack Value in 2026 — With Just Two Attacks | TRM Labs](https://www.trmlabs.com/resources/blog/north-korea-stole-76-of-all-crypto-hack-value-in-2026-with-just-two-attacks) - [OFAC Targets DPRK IT Workers Using Crypto](https://www.chainalysis.com/blog/ofac-targets-north-korean-it-workers-crypto-march-2026/) - [North Korea IT Workers: Inside the DPRK’s Crypto Laundering Network](https://www.chainalysis.com/blog/dprk-it-workers-north-korea-crypto-laundering-networks/) - [Chainalysis Links 2026 • March 31-April 1 • New York, NY](https://www.chainalysis.com/links-nyc/) - [Takeaways from MSMT’s Report on DPRK Cyber Operations](https://www.chainalysis.com/blog/msmt-report-north-korea-dprk-cyber-threats/) - [North Korea's crypto hackers have stolen over $2 billion in 2025](https://www.elliptic.co/blog/north-korea-linked-hackers-have-already-stolen-over-2-billion-in-2025) - [Report Describes Crypto’s $350 Billion Shadow War | OCCRP](https://www.occrp.org/en/news/report-describes-cryptos-350-billion-shadow-war) - [Drift Protocol Hack: How Privileged Access Led to a $285M Loss](https://www.chainalysis.com/blog/lessons-from-the-drift-hack/) - [Frequently Asked Questions | Office of Foreign Assets Control](https://ofac.treasury.gov/faqs/search?faq-search=&page=1) - [Memorandum of Understanding](https://ofac.treasury.gov/media/32091/download) - [What Is a VASP? Virtual Asset Service Provider - Chainalysis](https://www.chainalysis.com/glossary/virtual-asset-service-provider/) - [Money Services Business (MSB) Registration | FinCEN.gov](https://www.fincen.gov/resources/money-services-business-msb-registration) - [Questions on Virtual Currency](https://ofac.treasury.gov/faqs/topic/1626) - [Important Information for MSBs | FinCEN.gov](https://www.fincen.gov/resources/financial-institutions/money-services-businesses) - [Special Notice RMSB Posting](https://www.fincen.gov/system/files/shared/msbregformDRAFT.pdf) - [Enforcement Actions | FinCEN.gov](https://fincen.gov/news/enforcement-actions?fi=) - [Money Services Businesses | FinCEN.gov](https://www.fincen.gov/money-services-businesses) - [DEPARTMENT OF THE TREASURY WASHINGTON, D.C. OFFICE OF FOREIGN ASSETS CONTROL](https://ofac.treasury.gov/media/936396/download?inline=) - [Financial Crimes Enforcement Network Registration of Money Services Business](https://www.fincen.gov/system/files/shared/FinCENRMSB_ElectronicFilingInstructions.pdf) - [MSB Registrant Search | FinCEN.gov](https://www.fincen.gov/resources/msb-state-selector) - [Washington State Department of Financial Institutions](https://dfi.wa.gov/) - [FinCEN (US Department of the Treasury)](https://www.fincen.gov/news/news-releases/fincen-finds-cambodia-based-huione-group-be-primary-money-laundering-concern) - [FinCEN (US Department of the Treasury)](https://www.fincen.gov/news/news-releases/financial-action-task-force-identifies-jurisdictions-anti-money-laundering-5) - [International Consortium of Investigative Journalists (ICIJ)](https://www.icij.org/investigations/coin-laundry/as-crypto-industry-expands-u-s-slashes-office-examining-dirty-money-safeguards-of-cryptocurrency-exchanges/) - [International Consortium of Investigative Journalists (ICIJ)](https://www.icij.org/investigations/coin-laundry/trump-administration-curbs-state-oversight-of-crypto-industry/) - [Bloomberg](https://www.bloomberg.com/graphics/2026-russian-airlines-sanctions/) - [Elliptic](https://www.elliptic.co/blog/ofac-lists-53-crypto-addresses-of-sanctioned-north-korean-cheil-credit-bank) - [Chainalysis](https://www.chainalysis.com/blog/russian-exchange-garantex-dismantled/) Coverage gaps fim-int-2026-07-07-G001: The full extent of Washington DFI's… fim-int-2026-07-07-G001: The full extent of Washington DFI's 18-month enforcement record remains unverified beyond the three actions the Challenge stage surfaced (Coinme, CoinZoom, multistate Block/Cash App); a direct review of the DFI enforcement-actions page is needed to confirm no further actions were missed. [resolved] fim-int-2026-07-07-G002: Whether Grinex's April 2026 suspens… fim-int-2026-07-07-G002: Whether Grinex's April 2026 suspension was a genuine cyberattack, a law-enforcement-linked disruption, or a false-flag exit scam remains unresolved; on-chain forensic follow-up would clarify the durability of the Garantex-successor evasion architecture. [resolved] fim-int-2026-07-07-G003: The post-extradition legal disposit… fim-int-2026-07-07-G003: The post-extradition legal disposition of Chen Zhi in China (charges, proceedings, any residual US extradition-treaty exposure) is not established in the current evidence base. [resolved] fim-int-2026-07-07-G004: No evidence was identified on wheth… fim-int-2026-07-07-G004: No evidence was identified on whether the Washington State legislature intends to respond to the federal CTA/BOI domestic-entity exemption with a state-level beneficial-ownership registry. [resolved] fim-int-2026-07-07-G005: Quantitative data on the number of … fim-int-2026-07-07-G005: Quantitative data on the number of Washington-domiciled crypto/VASP firms that have migrated to OCC national trust charters, and the resulting practical reduction in DFI supervisory reach, is absent from the current evidence base. [resolved] fim-int-2026-08-05-G001: No Tier-1/2 primary OFAC press rele… fim-int-2026-08-05-G001: No Tier-1/2 primary OFAC press release confirming the reported April 2026 Cartel del Noreste-linked casino sanctions action; only a single Tier-4 secondary source found this cycle. [resolved] fim-int-2026-08-05-G002: No AMLA/europa.eu or EUR-Lex primar… fim-int-2026-08-05-G002: No AMLA/europa.eu or EUR-Lex primary source retrieved this cycle for the AMLR/6AMLD transposition timeline; reliance on secondary legal-journal reporting caps confidence at Assessed. [resolved] fim-int-2026-08-05-G003: No fresh Colombia-specific national… fim-int-2026-08-05-G003: No fresh Colombia-specific national development found this cycle beyond the historical TD Bank BMPE corridor reference. [resolved] fim-int-2026-08-05-G004: D6 RegTech/AI-compliance vector ret… fim-int-2026-08-05-G004: D6 RegTech/AI-compliance vector returned no material finding this cycle. [resolved] fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): No new AMLR application milestone, 6AMLD transposition delta, or AMLA supervisory-perimeter change was independently verified this cycle; search allocation was concentrated on the bound US-WA jurisdiction and mandatory global items. [resolved] fim-int-2026-09-28-G002: Tier D corridor jurisdictions (KH, … fim-int-2026-09-28-G002: Tier D corridor jurisdictions (KH, LA, MX, CO) primary-source verification was not independently pulled this pass beyond Cambodia's standing non-grey-listed status. [resolved] fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', 'value': 'D6'}): D6 RegTech/enforcement-gap-log detail was not independently pulled this pass; recorded as coverage gap rather than confirmed no-material-change. [resolved] fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): No WSGC/D2 beneficial-ownership development was located for US-WA this cycle; coverage gap rather than confirmed no-change. [resolved] fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', 'value': 'D1'}): T1 tracker Houthi/Yemen UN Panel of Experts and OFSI channels were not independently re-verified this run due to pooled research budget. [resolved] fim-int-2026-10-04-G003: Tier D Laos (LA) and Colombia (CO) … fim-int-2026-10-04-G003: Tier D Laos (LA) and Colombia (CO) were not independently searched this cycle; treat as a coverage gap, not a confirmed absence of signal. [resolved] fim-int-2026-10-11-G001: Tier D jurisdiction checks (Cambodi… fim-int-2026-10-11-G001: Tier D jurisdiction checks (Cambodia, Laos, Mexico, Colombia) were not actively re-run this cycle given the pooled research budget was concentrated on the bound jurisdiction. [resolved] fim-int-2026-10-11-G002: No commercial-activity (D8) event m… fim-int-2026-10-11-G002: No commercial-activity (D8) event meeting the financial-integrity domain's scope was identified for Washington within the recency window; recorded as no_source pending further search. [resolved] fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): WSGC/DFI underlying BSA/AML examination report for the Coinme multi-state action was not independently retrieved this cycle; only the press release and secondary reporting were reviewed. [resolved] fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', 'value': 'D3'}): US-WA D3 (enabler jurisdictions) has no source this cycle; this subnational unit is structurally thin on primary enabler-jurisdiction material. [resolved] fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): Full Coinme consent order document (with WA-specific penalty allocation) was not independently retrieved this cycle; confidence capped at Probable pending primary document review. [resolved] fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): Primary WAC 208-690-060(2) and RCW 19.230 text was not independently pulled this cycle; standing AML/CFT record for crypto rests on secondary legal-commentary description only. [resolved] fim-int-2026-11-01-G001: FIM's global Tier D watch (Cambodia… fim-int-2026-11-01-G001: FIM's global Tier D watch (Cambodia, Laos, Mexico, Colombia) and six standing trackers were not independently re-verified this cycle because this union dispatch is scoped to the single bound jurisdiction US-WA rather than FIM's normal global sweep. [open] fim-int-2026-11-01-G002: Domains D1, D3, D4, D5, D6, D7, D8 … fim-int-2026-11-01-G002: Domains D1, D3, D4, D5, D6, D7, D8 had no WA-specific or WA-actor material located this cycle under the single-JID-bound dispatch; this is a coverage gap, not an asserted no-change across those domains globally. [open] FIM-GAP-001 (D3): Extensive search across FinCEN, OFAC, DOJ … FIM-GAP-001 (D3): Extensive search across FinCEN, OFAC, DOJ press archives, ICIJ, OCCRP, and quality-press financial-crime coverage identified no Washington State DFI-specific consent order or state-level AML enforcement action in the 18-month window, despite the state's significant regulated MSB/VASP population. FIM-GAP-002 (D5): IRS examiners assigned to review AML compl… FIM-GAP-002 (D5): IRS examiners assigned to review AML compliance of crypto firms and other MSBs fell 33% in 2025, from 208 to 139 agents nationally, reducing federal supervisory bandwidth over Washington-domiciled crypto-ATM operators and VASPs that rely on federal examination as a backstop to state DFI licensing supervision. FIM-GAP-003 (D2): A reinterpretation of OCC rules has allowe… FIM-GAP-003 (D2): A reinterpretation of OCC rules has allowed crypto firms to obtain national trust charters affording federal preemption from state AML/consumer-protection oversight, reducing Washington DFI's practical supervisory reach over crypto entities that migrate to federal charters (mirroring the Paxos/New York DFS precedent cited by ICIJ). FIM-GAP-004 (D2): FinCEN's March 2025 interim final rule exe… FIM-GAP-004 (D2): FinCEN's March 2025 interim final rule exempted all entities created in the United States (including Washington-incorporated LLCs/corporations) and their beneficial owners from Corporate Transparency Act BOI reporting; only foreign companies registered to do business in the US remain subject. ## Evidence #### Confidence-tiered claims WA's AML/CTF-adjacent regime is the general Uniform Money Services Act (UMSA, RCW 19.230; WAC 208-690) money-transmitter licensing overlay atop the federal BSA/FinCEN framework; no bespoke state AML statute exists. [[Source 1]](#sec-sources) Probable · 1 source Treasury/FinCEN designated the Russia-linked A7 Network (and its A7A5 ruble-pegged token) a significant transnational criminal organization under Operation Economic Outcast, Oct 1, 2026; FinCEN proposed a BSA special measure against its Sub-Agents. [[Source 1]](#sec-sources) Probable · 1 source FinCEN's Sept 3, 2026 alert (FIN-2026-Alert005) flags money laundering associated with digital-asset investment scam centers in Cambodia, concurrent with Treasury sanctions against Cambodian scam-center operators. [[Source 1]](#sec-sources) Probable · 1 source OFAC's Sept 29, 2026 action sanctioned Sinaloa Cartel leadership and associated corruption networks (Los Mayos faction, Baja California). [[Source 1]](#sec-sources) Probable · 1 source FATF grey list stands at 22 jurisdictions after the June 17-19, 2026 plenary (Bosnia and Herzegovina, Iraq added; Algeria, Namibia removed); October 2026 plenary (first under UK Presidency) pending. [[Source 1]](#sec-sources) Probable · 1 source 34-regulator multi-state consent order entered 2026-10-07/08 requiring nationwide crypto-kiosk shutdown by 2027-01-01 and a $2.5 million penalty [[Source 1]](#sec-sources) Probable · 1 source WA DFI acted as one of seven lead agencies in a 34-regulator coordinated multi-state examination of Coinme, Inc. [[Source 1]](#sec-sources) Probable · 1 source Virtual-currency exchange, custody and kiosk operation treated as money transmission under the general Uniform Money Services Act, with no bespoke crypto AML statute [[Source 1]](#sec-sources) Probable · 1 source Required to cease all crypto-kiosk operations nationwide before 2027-01-01, undergo independent BSA/AML compliance review, and replace compliance-responsible managers [[Source 1]](#sec-sources) Probable · 1 source 2025 Statement of Charges alleged failure to disclose voucher-redemption timeframes and failure to return unclaimed consumer property as required by law, resolved by the October 2026 consent order [[Source 1]](#sec-sources) Probable · 1 source Multi-state consent order (Order C-25-4009-26-CO02) entered Oct 7-8, 2026 by Washington DFI and 34 other regulators; requires $2.5m in penalties/costs, cessation of crypto-kiosk operations nationwide by Jan 1 2027, and an independent BSA/AML program review. [[Source 1]](#sec-sources) Probable · 1 source A Statement of Charges against Bitcoin Depot Operating LLC and its CEO (entered 06/08/2026) under the Uniform Money Services Act remains pending in DFI's enforcement register, alongside the Coinme action. [[Source 1]](#sec-sources) Probable · 1 source Coinme allegedly claimed more than $8 million owed to customers as its own income and violated the Uniform Money Services Act, including a deficient BSA/AML program. [[Source 1]](#sec-sources) Probable · 1 source Order requires Coinme to engage an independent consultant to evaluate its BSA/AML program and implement corrective measures. [[Source 1]](#sec-sources) Probable · 1 source Coinme, Inc. (Seattle-based) agreed to a $2.5m multi-state settlement requiring it to wind down its crypto-kiosk product line nationwide by Jan 1, 2027. [[Source 1]](#sec-sources) Probable · 1 source Multistate consent order (35 regulators incl. WA DFI) requiring cessation of crypto-kiosk operations, $2.5 million penalty/costs, and additional compliance measures, resolving a 2025 Statement of Charges. [[Source 1]](#sec-sources) Probable · 1 source Virtual-currency money transmission is regulated under the general money transmitter licensing framework; crypto-specific add-ons (SB 5031, 2017) require $100,000 minimum tangible net worth where virtual currency is stored, third-party security audit, and like-kind holding requirement. [[Source 1]](#sec-sources) Uncertain · 1 source coalition_suit_filed [[Source 1]](#sec-sources) Probable · 1 source Joined a 20-state coalition (led by Oregon and Illinois) suing to block a federal administrative rollback of Corporate Transparency Act beneficial-ownership reporting, alleging APA violations including inadequate consultation. [[Source 1]](#sec-sources) Probable · 1 source Virtual currency written directly into the WA money-transmitter statute since SB 5031 (2017); standing structural feature, unchanged this cycle. [[Source 1]](#sec-sources) Probable · 1 source Multistate consent order with crypto-kiosk operator Coinme, Inc., announced 2026-10-08, requiring cessation of kiosk operations and administrative penalties; this event predates the current cycle anchor (2026-11-01) and is not newly reported. [[Source 1]](#sec-sources) Probable · 1 source