--- title: "United States — Wisconsin (US-WI) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/united-states-wisconsin/ source_html: /jurisdictions/united-states-wisconsin/index.html description: "Financial integrity intelligence for United States – Wisconsin (US-WI): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: fd9af43216030de2e4137f3b8ca5fc64a9e475367de6203b8f0480f41fe10e14 generator: "fe-fleet/md-twin@1.0" --- # United States — Wisconsin (US-WI) — 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 — Wisconsin US-WI Domains covered 6 of 8 Sources 150 Role actions 8 Horizon <90d 0 Jurisdiction profile FATF status: Largely Compliant Tier: B Risk direction: Increasing Enablement vs enforcement: Mixed Wisconsin operates under the federal BSA/AML framework administered by FinCEN and OFAC; the Wisconsin Department of Financial Institutions (Division of Banking) licenses money transmitters under state statute. More There is no state-level beneficial ownership registry — Wisconsin entities rely entirely on the federal Corporate Transparency Act regime, which was substantially rolled back in March 2025. Key deficiencies - No state beneficial ownership registry; Wisconsin-formed LLCs and corporations are now fully exempt from federal BOI reporting following the March 2025 CTA rule change - DOJ's April 2025 'Blanche Memo' deprioritizes unlicensed money-transmission and BSA prosecutions absent proof of willful intent, narrowing the practical enforcement net for Wisconsin-based crypto/MSB actors - No publicly identified state-level AML supervisory enforcement actions against Wisconsin-chartered financial institutions in the 18-month window (sourcing thinness) Recent developments (18m) - FinCEN interim final rule (March 26, 2025) exempted all domestic reporting companies — including Wisconsin-formed entities — from Corporate Transparency Act beneficial ownership reporting - DOJ/Chainalysis-assisted Eastern District of Wisconsin civil forfeiture seized over $5.5 million in cryptocurrency tied to a Mexican cartel-linked money-laundering network moving fentanyl/methamphetamine proceeds - DOJ's April 2025 Blanche Memo disbanded the National Cryptocurrency Enforcement Team and narrowed BSA/unlicensed-money-transmission prosecutions to cases with willful intent - FinCEN's nationwide Residential Real Estate reporting rule (effective March 1, 2026) replaces the metro-area Geographic Targeting Orders and now applies uniformly to non-financed real-estate transfers in Wisconsin - National DOJ Health Care Fraud Takedown (June 30, 2025) charged 324 defendants in over $14.6 billion in alleged fraud, amid a 330% rise in BSA health-care-fraud SAR filings 2020-2025 nationally United States federal law that applies in United States – Wisconsin is covered once, on the [United States](/jurisdictions/us/) page. This page covers United States – Wisconsin’s own layer: its own law, regulators and enforcement. Brief ## Lead signal #### Lead Signal The one development of note for Wisconsin this cycle sits at the junction of commodities-market preemption doctrine and a crypto-adjacent prediction-market product. Wisconsin's Attorney General sued Kalshi, Polymarket and Crypto.com on April 24, 2026, alleging these platforms were operating unlicensed sports-wagering-style products under state gambling law. The federal Commodity Futures Trading Commission separately sued the state, arguing that the Commodity Exchange Act preempts Wisconsin's enforcement against exchanges offering federally designated contract markets. Both matters remain consolidated on appeal before the Seventh Circuit (Nos. 26-2636, 26-2675), and on October 1, 2026, Kalshi filed an amicus brief arguing that the district court erred by declining to enjoin Wisconsin's enforcement action while the preemption question is litigated. Read full brief #### Lead Signal The one development of note for Wisconsin this cycle sits at the junction of commodities-market preemption doctrine and a crypto-adjacent prediction-market product. Wisconsin's Attorney General sued Kalshi, Polymarket and Crypto.com on April 24, 2026, alleging these platforms were operating unlicensed sports-wagering-style products under state gambling law. The federal Commodity Futures Trading Commission separately sued the state, arguing that the Commodity Exchange Act preempts Wisconsin's enforcement against exchanges offering federally designated contract markets. Both matters remain consolidated on appeal before the Seventh Circuit (Nos. 26-2636, 26-2675), and on October 1, 2026, Kalshi filed an amicus brief arguing that the district court erred by declining to enjoin Wisconsin's enforcement action while the preemption question is litigated. The structural question the appeal poses is whether a state retains any enforcement reach over a product that a federal regulator has already classified and licensed as a commodities-market instrument, merely because the product's payout structure resembles wagering. A ruling against preemption would leave states free to layer gambling-law enforcement onto federally regulated prediction markets wherever those markets touch politically or socially sensitive events; a ruling for preemption would harden a federal shield around exchange-listed products regardless of how a state chooses to characterize them. For crypto-adjacent platforms, which increasingly sit inside this federally regulated commodities wrapper, the outcome will shape how much insulation that wrapper actually provides against state-level consumer-protection and gambling theories. #### Other Developments No other material developments were identified for Wisconsin this cycle. Coverage of sanctions exposure, beneficial-ownership and corporate-transparency architecture, enabler-jurisdiction conduct, conflict-finance nexus, compliance-technology posture and the broader AML/CTF regime returned no sourced findings this cycle and is not addressed further here; those positions stand as previously published. #### Cross-Monitor Connections The preemption litigation sits squarely at the junction this monitor shares with the oversight of digital-asset market structure: the underlying dispute is not about money laundering typology but about which level of government gets to supervise a crypto-adjacent trading venue at all, and the answer will condition how effectively any AML/CTF or consumer-protection rule a state might wish to impose on such venues can actually be enforced. A Seventh Circuit ruling that narrows state authority over federally regulated exchange products would, by extension, narrow the set of levers available to state financial-integrity regulators generally, not just gambling regulators, wherever a product can be plausibly routed through a federal commodities license. #### Outlook The Seventh Circuit's disposition of the consolidated appeal is the development to watch. As scheduled, briefing continues following Kalshi's October 2026 amicus filing, and a ruling would resolve, at least for the Seventh Circuit's jurisdiction, how much room states retain to apply their own gambling and consumer-protection frameworks to platforms that hold federal commodities-market status. Until that ruling issues, Wisconsin's enforcement posture against these platforms remains legally contested and operationally unresolved. Earlier periodic briefs (5) 3 Nov 2026 · fim-2026-11-03 #### Lead Signal The one development of note for Wisconsin sits at the junction of commodities-market preemption doctrine and a crypto-adjacent prediction-market product. Wisconsin's Attorney General sued Kalshi, Polymarket and Crypto.com on April 24, 2026, alleging these platforms were operating unlicensed sports-wagering-style products under state gambling law. The federal Commodity Futures Trading Commission separately sued the state, arguing that the Commodity Exchange Act preempts Wisconsin's enforcement against exchanges offering federally designated contract markets. Both matters remain consolidated on appeal before the Seventh Circuit (Nos. 26-2636, 26-2675), and on October 1, 2026, Kalshi filed an amicus brief arguing that the district court erred by declining to enjoin Wisconsin's enforcement action while the preemption question is litigated. The structural question the appeal poses is whether a state retains any enforcement reach over a product that a federal regulator has already classified and licensed as a commodities-market instrument, merely because the product's payout structure resembles wagering. A ruling against preemption would leave states free to layer gambling-law enforcement onto federally regulated prediction markets wherever those markets touch politically or socially sensitive events; a ruling for preemption would harden a federal shield around exchange-listed products regardless of how a state chooses to characterize them. For crypto-adjacent platforms, which increasingly sit inside this federally regulated commodities wrapper, the outcome will shape how much insulation that wrapper actually provides against state-level consumer-protection and gambling theories. #### Other Developments No other material developments were identified for Wisconsin. Coverage of sanctions exposure, beneficial-ownership and corporate-transparency architecture, enabler-jurisdiction conduct, conflict-finance nexus, compliance-technology posture and the broader AML/CTF regime returned no sourced findings and is not addressed further here; those positions stand as previously published. #### Cross-Monitor Connections The preemption litigation sits squarely at the junction this monitor shares with the oversight of digital-asset market structure: the underlying dispute is not about money laundering typology but about which level of government gets to supervise a crypto-adjacent trading venue at all, and the answer will condition how effectively any AML/CTF or consumer-protection rule a state might wish to impose on such venues can actually be enforced. A Seventh Circuit ruling that narrows state authority over federally regulated exchange products would, by extension, narrow the set of levers available to state financial-integrity regulators generally, not just gambling regulators, wherever a product can be plausibly routed through a federal commodities license. #### Outlook The Seventh Circuit's disposition of the consolidated appeal is the development to watch. As scheduled, briefing continues following Kalshi's October 2026 amicus filing, and a ruling would resolve, at least for the Seventh Circuit's jurisdiction, how much room states retain to apply their own gambling and consumer-protection frameworks to platforms that hold federal commodities-market status. Until that ruling issues, Wisconsin's enforcement posture against these platforms remains legally contested and operationally unresolved. 11 Oct 2026 · fim-2026-10-11 #### Lead Signal Wisconsin closed a kiosk-specific anti-money-laundering gap this cycle through 2025 Wisconsin Act 226, codified at Wis. Stat. 217.12, which requires virtual currency kiosk operators to hold a Chapter 217 money-transmitter licence. The statute layers kiosk-specific customer-due-diligence timing onto that licensing requirement: operators must verify customer identity before an initial transaction and re-verify with a photograph on each subsequent transaction. Secondary reporting places the new daily transaction cap at $1,000 in fiat per customer, though this figure traces to law-firm commentary summarising the Act rather than independent confirmation against the statutory text this cycle. Taken together, these provisions narrow what had been a comparatively light-touch customer-identification regime for a cash-to-crypto conversion channel that has structurally been difficult to supervise. #### Other Developments The underlying AML architecture for Wisconsin is unchanged and remains federally-anchored. The state's AML/CTF regime continues to operate through the federal Bank Secrecy Act as applied via Chapter 217, the Money Transmission Modernization Act framework that took effect 1 January 2025; Wisconsin has no state-level financial intelligence unit or independent suspicious-activity-report regime of its own, and the Department of Financial Institutions functions as the non-depository financial-services licensing authority rather than as an investigative body. This baseline did not change this cycle; what changed is the addition of a product-specific layer onto an otherwise unchanged structure. A negative finding on enabler-jurisdiction exposure is itself worth recording. A Tier D corridor check against Cambodia, Laos, Mexico and Colombia returned no Wisconsin-linked nexus this cycle, which is a positive no-material-change finding rather than an unexamined gap. #### Cross-Monitor Connections The kiosk-specific customer-due-diligence and transaction-cap mechanics under Wis. Stat. 217.12 are the same control surface that a consumer-protection or payments-focused review would examine for fraud-prevention effect, since identity verification before each kiosk transaction and a capped daily transaction ceiling both reduce money-laundering opportunity and limit individual fraud exposure simultaneously. This is a case where a single statutory provision generates findings relevant to AML/CTF supervision and to consumer-facing fraud control at once, rather than two separate regulatory interventions. #### Outlook The principal item to watch is whether the Department of Financial Institutions issues supervisory guidance implementing the Act 226 kiosk provisions in operative detail; none had been located as of this cycle, and such guidance would move the AML picture from statutory text to a defined supervisory expectation for kiosk operators. The $1,000 daily transaction-cap figure also warrants independent confirmation against the statutory text, since it currently rests on secondary legal commentary rather than a verified primary citation. 28 Sep 2026 · fim-2026-09-28 #### Lead Signal Wisconsin enacted a state-level virtual-currency-kiosk licensing and consumer-protection statute this cycle, closing a narrow but concrete gap on a crypto cash on-ramp and off-ramp vector frequently implicated nationally in elder-fraud and pig-butchering typologies. 2025 Wisconsin Act 226 (AB 968), enacted 2026-04-08 and effective 2026-04-10, creates Wis. Stat. 217.12, requiring virtual currency kiosk operators to hold a Chapter 217 money transmitter license, with kiosk-specific customer identification, printed and on-screen fraud warnings, and a $1,000-per-customer-per-day transaction cap. Wisconsin is not acting alone: the enactment is part of an April 2026 wave of state-level virtual-currency-kiosk regulation alongside Virginia and Kentucky, suggesting a coordinated or at least parallel legislative response to a typology that state regulators nationally have identified as a retail-fraud vector. This sits atop an already mature architecture. Wisconsin's Chapter 217 money-transmission regime was substantially rewritten by 2023 Wisconsin Act 267 into the multistate Model Money Transmission Modernization Act, administered via the Nationwide Multistate Licensing System by the Department of Financial Institutions Division of Banking, with full licensee compliance required by January 1, 2025. Act 226's kiosk overlay is therefore layered onto a governing regime that was itself only recently modernised, and the kiosk-specific rule has no enforcement record yet given its five-month age. #### Other Developments Tribal sports-betting settlement as an emerging payments surface. Separate from the kiosk statute, Wisconsin's enacted (but not yet operational) tribal-exclusive online sports betting framework is expected to introduce a new regulated-payments surface once compacts are renegotiated and Bureau of Indian Affairs approval is secured: licensed tribal online sportsbooks would process statewide mobile wagers through tribal-land servers. General industry practice for hub-and-spoke tribal sportsbook AML controls is still forming nationally, with limited precedent beyond Florida, meaning this surface carries genuine architectural uncertainty rather than a settled control framework. #### Cross-Monitor Connections The tribal compact renegotiation and eventual sportsbook settlement channel intersects directly with payments-regulation questions being tracked separately for licensing and market-access purposes; the underlying legal and commercial mechanics of that renegotiation are payments-infrastructure questions as much as financial-integrity ones, and the AML control architecture for the resulting settlement flows will need to be assessed once a compact structure is finalised. The Act 226 kiosk overlay similarly connects to broader consumer-facing gambling and gaming policy developments in the state, given the shared crypto on-ramp exposure between kiosk-based cash conversion and gambling-adjacent payment flows. #### Outlook The near-term watch item is whether any enforcement action materialises under Act 226's new licensing and transaction-cap requirements; none has been identified as of this cycle. On the tribal sportsbook front, the compact renegotiation process begun by the Governor's Office in mid-2026 will determine both the timing and eventual AML control shape of the new settlement surface, with no Tier-1 source yet confirming the status of any individual tribe's renegotiation. 28 Aug 2026 · fim-2026-08-21 #### Lead Signal Wisconsin's 2025 Wisconsin Act 226 (Wis. Stat. §217.12), in force since April 9, 2026, imposes a $1,000 daily transaction cap on virtual currency kiosk transactions, alongside mandatory fraud-warning disclosures, customer identification, live customer support, advance notice of kiosk locations to law enforcement, and a 30-day scam-victim refund obligation on kiosk operators. This is best read as architecture rather than incident: the state has built a targeted control regime around a specific, documented typology, cash-to-crypto kiosk conversion as a laundering and elder-fraud conduit, rather than issuing a single enforcement action against a specific operator. The statute's design, layering a transaction cap with disclosure, identification, and refund obligations, positions Wisconsin among the states building kiosk-specific AML and consumer-protection controls without adopting a comprehensive virtual-asset-service-provider licensing regime. It is also worth flagging what this development is not: no CTF- or CPF-specific finding accompanies it this cycle, consistent with the broader pattern in which AML-adjacent activity generates more visible legislative movement than CTF or CPF signals. #### Other Developments The legislative record around Act 226 also clarifies what did not change. A broader bill, Assembly Bill 471, which would have exempted node operation, crypto-to-crypto exchange, blockchain software development, and mining or staking activity from Chapter 217 money-transmitter licensing, failed to pass on March 23, 2026. A rival, narrower kiosk-licensing bill, Senate Bill 386, which would have required kiosk operators to hold a full Department of Financial Institutions money-transmitter license, also failed on the same date. The narrower measure that became law, Assembly Bill 968, enacted as Act 226, occupies a middle position between those two failed approaches: it neither broadens the money-transmitter exemption nor imposes a full licensing requirement on kiosk operators, instead creating a bespoke, kiosk-specific control layer. For a financial-integrity reading, the practical effect is that Wisconsin's general money-transmission licensing perimeter for crypto on- and off-ramp activity is unchanged this cycle; the new control sits alongside, rather than inside, the existing Chapter 217 licensing architecture. #### Cross-Monitor Connections The instrument at the center of this cycle's Wisconsin signal, the virtual-currency-kiosk control regime under Act 226, sits at a natural seam between financial-integrity typology and adjacent monitoring domains: the same kiosks are a payments-infrastructure question for a payments-focused monitor and, separately, a documented adjacent funding channel for unregulated or offshore gambling deposits for a gambling-regulatory monitor. This cycle's Wisconsin record does not itself contain a cross-border sanctions or beneficial-ownership dimension, so the connection here is one of shared subject matter, a single instrument regulated once but relevant to multiple monitoring lenses, rather than a substantive cross-monitor finding requiring further routing this cycle. #### Outlook Watch for two things next cycle: first, whether Wisconsin's Department of Financial Institutions issues implementing guidance or enforcement activity under the new §217.12 kiosk regime now that it is in force; second, whether neighboring states move toward the same kiosk-specific control model rather than the fuller VASP-licensing or broad-exemption approaches that Wisconsin's own legislature considered and rejected this cycle. Absent a new legislative session item, Wisconsin's D5 posture should be treated as newly settled architecture rather than an open policy question, pending any enforcement record building up under the new statute. 11 Aug 2026 · fim-2026-08-05 #### Lead Signal The most consequential development this cycle is the widening structural divergence between the United States and European Union on beneficial-ownership supervision. In the United States, FinCEN's March 2025 interim final rule continues to exempt domestic reporting companies and persons from Corporate Transparency Act beneficial-ownership-information reporting, a posture that remains in force through this cycle and that a Government Accountability Office review found exempts more than 99 percent of previously covered entities. In the European Union, the opposite trajectory is underway: the Anti-Money Laundering Authority formally absorbed all AML/CFT supervisory mandates from the European Banking Authority effective January 1, 2026, and closed a consultation on risk-assessment and entity-selection methodology on January 27, 2026, in preparation for direct supervision of approximately 40 high-risk cross-border institutions beginning in 2028. The result is a transatlantic beneficial-ownership regime moving in opposite directions at the same moment, one jurisdiction narrowing its domestic reporting perimeter, the other consolidating supervisory authority at a supranational level. This is a structural finding, not an episodic one, and it is assessed with high confidence given corroboration across independent Tier-1 AMLA primary sources and the FinCEN.gov reporting-status page. #### Other Developments Sanctions architecture around Russia's shadow fleet continued to escalate. The EU's 20th sanctions package, adopted April 23, 2026, added 46 vessels to its tanker listing, bringing the total to 632, while roughly 1,378 Russia-linked vessels are assessed to show rising AIS-signal manipulation. The United Kingdom's boarding of the tanker Smyrtos on June 14, 2026, under UNCLOS Article 110 statelessness authority, signals a more assertive at-sea enforcement posture than the listing regime alone would suggest, though this tracker's Houthi- and Yemen-linked channels were not independently searched this cycle and should be treated as a coverage gap rather than a confirmed null result. Southeast Asian enabler-jurisdiction risk remained structurally entrenched despite headline enforcement. Cambodia's National Bank Governor Chea Serey warned of renewed FATF grey-listing risk tied to persistent gaps in enforcement against illegal online gambling and scam compounds, even as the extradition of Chen Zhi and the liquidation of Prince Group's Cambodian banking and real-estate interests were held up as evidence of action. In Laos, the Golden Triangle Special Economic Zone continues to operate under a 99-year land concession that places it outside normal Lao jurisdictional reach, sustaining a scam-compound and money-laundering ecosystem alongside comparable sites in Myanmar and Cambodia. The FATF's June 17-19, 2026 Plenary added Iraq and Bosnia and Herzegovina to its grey list while removing Algeria and Namibia, leaving the list at 22 jurisdictions and underscoring that enabler-jurisdiction status remains a rotating rather than a resolved condition. Conflict and organized-crime finance drew sustained US Treasury attention. OFAC sanctioned two Mexican nationals and nine entities tied to a CJNG fuel-theft and tax-evasion trade-based money-laundering scheme, with FinCEN issuing a coordinated supplemental alert; more than $7 billion in related suspicious activity has been reported since the original 2025 alert. Separately, a FY2026 US Presidential Determination named Colombia among five countries found to have failed demonstrably to meet counternarcotics obligations amid record coca cultivation, the first such finding for Colombia in nearly 30 years, though sanctions were waived on national-interest grounds. Stablecoin regulation entered its implementation phase with a visible structural gap. The GENIUS Act is moving toward final implementing rules targeted for July 18, 2026, with enforcement beginning January 2027, and two April 2026 Treasury notices of proposed rulemaking add FinCEN and OFAC illicit-finance secondary-market monitoring duties. Tether, operating from El Salvador with more than $140 billion in outstanding USDT, sits outside the Act's core US-domiciled-issuer audit and reserve framework, a contrast with Circle's USDC, which is already structured toward 1:1 reserve, monthly-attestation, and annual-audit compliance. #### Cross-Monitor Connections The Cambodia and Laos enabler-jurisdiction findings connect directly to conflict-finance and trafficking-adjacent monitoring: the same scam-compound ecosystem implicated in Cambodia's grey-listing risk is also a human-trafficking concern, and the Golden Triangle SEZ's jurisdictional exceptionalism is a recurring reference point for monitors tracking cross-border organized-crime infrastructure. The CJNG fuel-theft and Colombia counternarcotics findings both sit at the intersection of financial-integrity and conflict-finance monitoring, given that fuel-theft and drug-trafficking revenue streams are increasingly treated by US Treasury as parallel rather than separate enforcement priorities. The EU-US beneficial-ownership divergence has a bearing on any monitor tracking corporate-transparency or state-capture risk, since a widening gap in reporting-perimeter coverage on one side of the Atlantic changes the relative attractiveness of jurisdictions for opaque corporate structuring. The stablecoin findings, finally, are relevant to any monitor tracking payment-infrastructure or sanctions-evasion risk, given Tether's scale and its position outside the GENIUS Act's core audit perimeter. #### Outlook The coming cycle should be read against three converging timelines: the EU's AMLA build-out toward 2028 direct supervision, the GENIUS Act's move from final rulemaking to January 2027 enforcement, and Cambodia's effort to avoid a third FATF grey-listing episode. None of these are resolved, and the framing throughout this brief is assessed rather than confirmed except where Tier-1 primary sourcing exists, as it does for the AMLA supervisory transfer and the OFAC/FinCEN CJNG action. Watch for the AMLA's first published work programme in the second half of 2026, further Treasury guidance on state-federal stablecoin licensing interplay, and any confirmation of whether Cambodia's enforcement posture is judged sufficient to avert renewed grey-listing at a subsequent FATF Plenary. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion The sanctions architecture visible this cycle is bifurcated rather than uniformly tightening or loosening. OFAC designated over 13 individuals and 29 entities linked to cartel fuel and crude-oil smuggling across the southern border, complementing a South Texas High-Intensity Financial Crime Area task-force indictment, with FinCEN reporting over 7 billion dollars in related suspicious-activity filings nationally. This is a direct T1 regulatory action tracing a smuggling architecture through shell distributors and financial intermediaries into the broader United States financial system, and it sits alongside continued Counter Narcotics and Transnational Criminal Organization designation activity targeting Southeast Asian scam-center networks. Continue reading At the same time, OFAC's recent-actions log records repeated Russia-related Designations Removals entries through May to June 2026, alongside amended general licenses, a pattern unmirrored by European Union or United Kingdom authorities in the same window. OFAC has formally published an OFAC-OFSI Comparative Overview acknowledging divergence risk as this delisting track proceeds, which is itself an unusually explicit first-party acknowledgment of a structural regime-design gap rather than a mere list-update artifact. This divergence creates cross-jurisdiction compliance friction for any firm with correspondent or subsidiary relationships spanning the United States, United Kingdom, and European Union sanctions perimeters, since screening logic calibrated to one regime's list state will misalign with another's. A further status-level but structurally notable development is the complete emptying of the OFAC Foreign Sanctions Evaders List, whose remaining listed name was removed on 18 December 2025. The list is now empty, though subject to future additions; this is confirmed as a status fact rather than a policy reversal, and no United Kingdom or European Union equivalent list-emptying has been identified, reinforcing the broader theme of asymmetric list architecture across the three regimes. Read together, the cartel-designation expansion and the Russia-delisting track describe an enforcement posture that is intensifying against transnational organized-crime actors while simultaneously recalibrating, at the margin, its Russia-related perimeter. Architecture-over-incident framing suggests the more durable signal is not any single designation or delisting but the formalized acknowledgment of transatlantic divergence itself, since divergence of this kind tends to persist as a structural feature of the sanctions landscape long after any individual list action is superseded. #### Outlook The sanctions regime-divergence tracker is assessed as worsening, and the near-term signal to watch is whether further Russia-related delisting tranches proceed without a mirrored European Union or United Kingdom response, which would further entrench the divergence the OFAC-OFSI Comparative Overview has already acknowledged. No horizon item resolves this within the current cycle; it remains a structural condition rather than a scheduled event. Baseline-Tracked Domains with No Current-Cycle Escalation (2 of 8) - D7 AML/CTF Regime: Standing coverage — no activity this cycle. - D8 Commercial Activity: Standing coverage — no activity this cycle. Regulatory horizon In Force Pending 2027-Q1 · ±year ### Tribal gaming compact renegotiation for online sports betting (Act 247 implementation) Once compacts are amended and BIA-approved, licensed tribal online sportsbooks will begin processing statewide mobile wagers through servers on tribal land, a new regulated-payments channel. [Wisconsin Governor's Office / DOA Division of Gaming / 11 Tribal Nations Source](https://doa.wi.gov/Pages/AboutDOA/TribalCompactsAndAmendments.aspx) 1 dated · 2 pending date · baseline fim-2026-07-05 Role action cards Compliance ### A federal preemption appeal could redefine whether Wisconsin may apply state licensing or gambling law to crypto-adjacent prediction-market platforms. The outcome of the Seventh Circuit appeal will determine whether state-level compliance obligations can reach exchange-listed prediction-market products operating under a federal commodities license, directly affecting how such products should be assessed for state regulatory exposure. 1 evidence refs Legal ### Kalshi's amicus brief keeps the CFTC preemption theory against Wisconsin's gambling-law enforcement active before the Seventh Circuit. Litigation risk around state enforcement against federally licensed crypto-adjacent exchanges remains open pending the consolidated appeal, with implications for client-instruction exposure in similar multi-state enforcement contexts. 1 evidence refs Board ### An unresolved federal-state jurisdictional dispute over crypto-adjacent trading platforms is pending before a federal appeals court. Strategic exposure in this jurisdiction currently centers on a single unresolved preemption question rather than on any new enforcement incident or standing-regime change. 1 evidence refs CTO ### The preemption dispute tests how much a federal commodities license insulates crypto-settled trading infrastructure from state-level legal challenge. Platform architecture decisions that rely on federal commodities designation to avoid state licensing regimes face a pending test case whose outcome could narrow or confirm that insulation. 1 evidence refs Risk ### A pending appellate ruling on federal preemption of state gambling-law enforcement against crypto-adjacent exchanges is the sole active exposure signal this cycle. Risk concentration in this jurisdiction is narrow and tied to a single litigation outcome whose resolution could either expand or contract the reach of state-level enforcement against similar products elsewhere. 1 evidence refs Standing trackers (T1–T6) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture stable T2 · EU AML Package / AMLA stable T3 · FATF Grey List stable T4 · Beneficial-Ownership Register Status stable T5 · Crypto & Digital-Asset Integrity watch Continuing CFTC v. Wisconsin / AG Kaul litigation is the only active WI-specific crypto-integrity architecture development this cycle. T6 · Sanctions Regime Divergence stable Registers ### Enforcement actions - 1 Jun 2025 - 30 Jun 2025 - 30 May 2025 - 4 Aug 2025 - 30 Jun 2026 - 12 May 2026 - Civil forfeiture action stemming from a money-laundering probe targeting a Mexican cartel-affiliated network; authorities identified centralized exchange accounts and crypto addresses moving fentanyl/methamphetamine proceeds, tracing transfers to Chinese fentanyl-precursor suppliers. 1 Jun 2025 - National Health Care Fraud Takedown charged 324 defendants in connection with over $14.6 billion in alleged fraud, amid FinCEN-observed 330% increase in BSA health-care-fraud reporting since the pandemic; part of Treasury's 2026 National Money Laundering Risk Assessment priorities. 30 Jun 2025 - OFAC designated over 13 individuals and 29 entities linked to cartel fuel and oil smuggling schemes on the southern border, complementing a South Texas HSTF indictment of a family for importing tens of millions of dollars in illicit Mexican crude oil from CJNG. 30 May 2025 - FinCEN issued a Notice urging financial institutions to be vigilant in identifying and reporting suspicious activity involving CVC kiosks, citing FBI IC3 data showing 10,956 complaints involving CVC kiosks in 2024 alone. 4 Aug 2025 ### Sanctions changes - 23 Apr 2026 - 18 Jun 2026 - 18 Dec 2025 - 30 Jun 2026 - 23 Apr 2026 - OFAC issued Counter Narcotics and Transnational Criminal Organizations designations (2025-2026 cycle) targeting cartel fuel/oil-smuggling and Southeast Asian scam-compound networks, including Cambodian Senator Kok An and 28 associated individuals/entities in April 2026. 23 Apr 2026 - OFAC recent-actions log for 2026 records multiple Russia-related Designations Removals alongside continued Counter Narcotics and Cuba designations, indicating an active US delisting track for select Russia-related parties even as other sanctions programs expand. 18 Jun 2026 - The OFAC Foreign Sanctions Evaders (FSE) List was emptied on December 18, 2025 when its remaining listed name was removed, leaving the list currently empty though subject to future additions. 18 Dec 2025 ### Regulatory horizon (register) - AMLA direct supervision of selected obliged entities - Tribal gaming compact renegotiation for online sports betting (Act 247 implementation) - Nationwide Residential Real Estate reporting rule takes effect - FATF follow-up review of US beneficial-ownership re-rating risk - AML/CFT Program modernization rule (AML Act 2020) finalization - CTA constitutionality litigation appeal outcome ### Active schemes - [HIGH] Cartel fentanyl-proceeds crypto laundering via Wisconsin exchange accounts - [HIGH] Domestic shell-entity opacity restored by Corporate Transparency Act rollback - [CRITICAL] Southeast Asian pig-butchering scam proceeds reaching United States victims - [HIGH] Cartel fiscal fuel-theft and oil-smuggling sanctions evasion network Sources - [Selected General Licenses Issued by OFAC | Office of Foreign Assets Control](https://ofac.treasury.gov/selected-general-licenses-issued-ofac) - [https://www.fincen.gov/boi](https://www.fincen.gov/boi) - [https://www.amla.europa.eu/amla-takes-major-step-toward-harmonised-eu-supervision_en](https://www.amla.europa.eu/amla-takes-major-step-toward-harmonised-eu-supervision_en) - [https://complyadvantage.com/insights/fatf-plenary-june-2026-outcomes/](https://complyadvantage.com/insights/fatf-plenary-june-2026-outcomes/) - [https://agbrief.com/news/cambodia/26/01/2026/cambodia-battles-to-avoid-third-fatf-grey-list-placement-amid-scam-crackdown/](https://agbrief.com/news/cambodia/26/01/2026/cambodia-battles-to-avoid-third-fatf-grey-list-placement-amid-scam-crackdown/) - [https://newlinesinstitute.org/global-security-mil-priorities/cybercrimes-human-trafficking-and-cryptocurrency-in-southeast-asias-special-economic-zones/](https://newlinesinstitute.org/global-security-mil-priorities/cybercrimes-human-trafficking-and-cryptocurrency-in-southeast-asias-special-economic-zones/) - [https://www.fincen.gov/news/news-releases/fincen-issues-supplemental-alert-fuel-smuggling-and-tax-evasion-schemes-southern](https://www.fincen.gov/news/news-releases/fincen-issues-supplemental-alert-fuel-smuggling-and-tax-evasion-schemes-southern) - [https://www.wttlonline.com/stories/colombia-designated-major-trafficker-in-fraa-review,14278](https://www.wttlonline.com/stories/colombia-designated-major-trafficker-in-fraa-review,14278) - [https://aotrading.io/blogs/stablecoin-regulation-2026-genius-act-clarity-act-tether-audit-gap](https://aotrading.io/blogs/stablecoin-regulation-2026-genius-act-clarity-act-tether-audit-gap) - [https://www.logisticsmiddleeast.com/analysis/how-far-can-europe-go-against-russias-shadow-fleet](https://www.logisticsmiddleeast.com/analysis/how-far-can-europe-go-against-russias-shadow-fleet) - [https://www.gci-ccm.org/insight/2025/12/corporate-transparency-act-2026-how-beneficial-ownership-reform-reshaping-us](https://www.gci-ccm.org/insight/2025/12/corporate-transparency-act-2026-how-beneficial-ownership-reform-reshaping-us) - [https://docs.legis.wisconsin.gov/document/acts/2025/226](https://docs.legis.wisconsin.gov/document/acts/2025/226) - [https://docs.legis.wisconsin.gov/2025/related/acts/226.pdf](https://docs.legis.wisconsin.gov/2025/related/acts/226.pdf) - [https://www.aarp.org/states/wisconsin/new-crypto-kiosk-law-stops-criminals-in-their-tracks/](https://www.aarp.org/states/wisconsin/new-crypto-kiosk-law-stops-criminals-in-their-tracks/) - [https://legiscan.com/WI/bill/AB471/2025](https://legiscan.com/WI/bill/AB471/2025) - [https://dfi.wi.gov/Documents/Securities/RegistrationOfProfessionals/EnforcementAdministrativeOrders/2026/20260512SDGFuturesRegenerative.pdf](https://dfi.wi.gov/Documents/Securities/RegistrationOfProfessionals/EnforcementAdministrativeOrders/2026/20260512SDGFuturesRegenerative.pdf) - [https://docs.legis.wisconsin.gov/statutes/statutes/217](https://docs.legis.wisconsin.gov/statutes/statutes/217) - [https://dfi.wi.gov/Pages/FinancialServices/LicensedFinancial/MoneyTransmitterModernizationAct.aspx](https://dfi.wi.gov/Pages/FinancialServices/LicensedFinancial/MoneyTransmitterModernizationAct.aspx) - [https://www.wsaw.com/2026/04/08/new-law-regulates-cryptocurrency-kiosks-wisconsin-protect-against-scams/](https://www.wsaw.com/2026/04/08/new-law-regulates-cryptocurrency-kiosks-wisconsin-protect-against-scams/) - [https://www.wispolitics.com/2026/banking-lobby-dfi-urge-wisconsin-lawmakers-not-to-deregulate-crypto-staking/](https://www.wispolitics.com/2026/banking-lobby-dfi-urge-wisconsin-lawmakers-not-to-deregulate-crypto-staking/) - [https://spectrumnews1.com/wi/milwaukee/news/2026/08/18/regulating-cryptocurrency-in-wisconsin](https://spectrumnews1.com/wi/milwaukee/news/2026/08/18/regulating-cryptocurrency-in-wisconsin) - [https://www.cftc.gov/PressRoom/PressReleases/9220-26](https://www.cftc.gov/PressRoom/PressReleases/9220-26) - [https://www.zigram.tech/article/fatf-grey-list-june-2026/](https://www.zigram.tech/article/fatf-grey-list-june-2026/) - [https://infobytes.orrick.com/2024-09-06/wisconsin-add-money-transmitter-license-nmls/](https://infobytes.orrick.com/2024-09-06/wisconsin-add-money-transmitter-license-nmls/) - [https://natlawreview.com/article/states-continue-targeting-virtual-currency-kiosks-new-licensing-and-consumer](https://natlawreview.com/article/states-continue-targeting-virtual-currency-kiosks-new-licensing-and-consumer) - [https://doa.wi.gov/Pages/AboutDOA/TribalCompactsAndAmendments.aspx](https://doa.wi.gov/Pages/AboutDOA/TribalCompactsAndAmendments.aspx) - [https://www.jdsupra.com/legalnews/wisconsin-enacts-regulatory-framework-3146847/](https://www.jdsupra.com/legalnews/wisconsin-enacts-regulatory-framework-3146847/) - [https://wisconsinwatch.org/2026/09/wisconsin-crypto-atm-scams-fraud-new-law-consumer-protection/](https://wisconsinwatch.org/2026/09/wisconsin-crypto-atm-scams-fraud-new-law-consumer-protection/) - [https://dfi.wi.gov/Pages/FinancialServices/LicensedFinancial/MoneyTransmitter.aspx](https://dfi.wi.gov/Pages/FinancialServices/LicensedFinancial/MoneyTransmitter.aspx) - [VitalLaw](https://www.vitallaw.com/news/federal-preemption-7th-cir-district-court-should-ve-blocked-wisconsin-from-enforcing-gambling-laws-argues-kalshi-as-amicus/sld01ea818877664a4bac8e0ffd75ad6eb004) - [Ticker Tracker](https://ticker-tracker.com/legal/wisconsin) - [1 FinCEN Advisory United States Department of the Treasury](https://www.fincen.gov/system/files/advisory/advissu7.pdf) - [The DOJ's NCET Disbanded: What This Means for Digital Assets - Chainalysis](https://www.chainalysis.com/blog/ncet-blanche-memo/) - [Enforcement Actions for Failure to Register as a Money Services Business | FinCEN.gov](https://www.fincen.gov/enforcement-actions-failure-register-money-services-business) - [Fact Sheet on MSB Registration Rule | FinCEN.gov](https://www.fincen.gov/fact-sheet-msb-registration-rule) - [DfI Driver, Vehicle, Operator & Enforcement Statistics 2025- ...](https://www.gov.uk/government/statistics/announcements/dfi-driver-vehicle-operator-enforcement-statistics-2025-26-q3) - [F I N C E N G U I D A N C E 1](https://www.fincen.gov/system/files/2019-05/FinCEN%20CVC%20Guidance%20FINAL.pdf) - [Alerts/Advisories/Notices/Bulletins/Fact Sheets | FinCEN.gov](https://www.fincen.gov/resources/advisoriesbulletinsfact-sheets) - [Administrative Ruling on the Application of FinCEN Regulations to Currency Transporters, Including Armored Car Services, and Exceptive Relief | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/administrative-ruling-application-fincen) - [News Releases on Unregistered Money Transmitter Enforcement Actions | FinCEN.gov](https://www.fincen.gov/news-releases-unregistered-money-transmitter-enforcement-actions) - [Advisories | FinCEN.gov](https://www.fincen.gov/resources/advisoriesbulletinsfact-sheets/advisories) - [FinCEN Notice, FIN-2025-NTC1, August 4, 2025](https://www.fincen.gov/system/files/2025-08/FinCEN-Notice-CVCKIOSK.pdf) - [Money laundering](https://www.trmlabs.com/glossary/money-laundering) - [The Complete Crypto Compliance Program Guide for Financial Institutions | TRM Labs](https://www.trmlabs.com/guides/crypto-compliance-program-guide-for-financial-institutions) - [What Is Money Laundering? Definition, Stages, and Crypto Laundering Methods - Chainalysis](https://www.chainalysis.com/glossary/money-laundering/) - [Crypto compliance](https://www.trmlabs.com/glossary/crypto-compliance) - [The Chinese-language Underground Crypto Money Laundering Ecosystem](https://www.chainalysis.com/blog/2026-crypto-money-laundering/) - [U.S. Crackdown on Southeast Asian Crypto Scam Centers](https://www.chainalysis.com/blog/asian-scam-centers-crypto-fraud-april-2026/) - [Organized Crime Shows High Level of Professionalization, Low Level of Crypto Sophistication - Chainalysis](https://www.chainalysis.com/blog/organized-crime-crypto/) - [United States Department of the Treasury Financial Crimes Enforcement Network - Home | FinCEN.gov](https://www.fincen.gov/) - [Important Information for MSBs | FinCEN.gov](https://www.fincen.gov/resources/financial-institutions/money-services-businesses) - [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) - [Money Services Business (MSB) Registration | FinCEN.gov](https://www.fincen.gov/resources/money-services-business-msb-registration) - [fincen logo MONEY SERVICES BUSINESS REGISTRATION FACT SHEET](https://www.fincen.gov/system/files/shared/FinCENfactsheet.pdf) - [Definition of Money Transmitter (Merchant Payment Processor) | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/definition-money-transmitter-merchant-payment) - [MSB Registrant Search | FinCEN.gov](https://www.fincen.gov/resources/msb-state-selector) - [Financial Crimes Enforcement Network Registration of Money Services Business](https://www.fincen.gov/system/files/shared/FinCENRMSB_ElectronicFilingInstructions.pdf) - [Money Services Businesses | FinCEN.gov](https://www.fincen.gov/money-services-businesses) - [Application of the Definition of Money Transmitter to Brokers and Dealers in Currency and Other Commodities | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/application-definition-money-transmitter-brokers-and) - [Attorney General’s Office Case Example (Mortgage Fraud) | FinCEN.gov](https://www.fincen.gov/resources/law-enforcement/case-examples/attorney-generals-office-case-example-mortgage-fraud) - [FinCEN Issues Analysis on Elder Financial Exploitation | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-analysis-elder-financial-exploitation) - [Financial Fraud Enforcement Task Force (FFETF) | FinCEN.gov](https://www.fincen.gov/financial-fraud-enforcement-task-force-ffetf) - [Elder Financial Exploitation: Threat Pattern & Trend ...](https://www.fincen.gov/system/files/shared/FTA_Elder_Financial_Exploitation_508Final.pdf) - [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) - [FinCEN Joins Agencies in Issuing A Statement on Elder Financial Exploitation | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-joins-agencies-issuing-statement-elder-financial-exploitation) - [FinCEN Reminds Financial Institutions to Remain Vigilant to Elder Financial Exploitation | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-reminds-financial-institutions-remain-vigilant-elder-financial) - [United States Department of the Treasury Financial Crimes Enforcement Network - Home | FinCEN.gov](https://fincen.gov/resources-victims) - [US Acts on Foreign Ownership of Farmland Amid China Tension - Bloomberg](https://www.bloomberg.com/news/articles/2025-07-08/us-acts-against-foreign-ownership-of-farmland-amid-china-tension) - [Senator Jon Tester Calls for Ban on Chinese Land Purchases After Report - Bloomberg](https://www.bloomberg.com/news/articles/2024-01-12/senator-calls-for-ban-on-chinese-land-purchases-following-report) - [US Laws Blocking Chinese Ownership of Farmland Are Unnecessary - Bloomberg](https://www.bloomberg.com/opinion/articles/2023-02-27/us-laws-blocking-chinese-ownership-of-farmland-are-unnecessary) - [Don’t Ban Chinese Investment in US Farmland - Bloomberg](https://www.bloomberg.com/opinion/articles/2022-08-12/don-t-ban-chinese-investment-in-us-farmland) - [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [Where is OFAC's Country List? What countries do I need to worry about in terms of U.S. sanctions? | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/where-is-ofacs-country-list-what-countries-do-i-need-to-worry-about-in-terms-of-us-sanctions) - [Additional Sanctions Lists | Office of Foreign Assets Control](https://ofac.treasury.gov/other-ofac-sanctions-lists) - [Recent Actions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions) - [| Office of Foreign Assets Control](https://ofac.treasury.gov/faqs/topic/1501) - [Canada Considers Easing Ban on Foreign Home Buyers Starting in 2027 - Bloomberg](https://www.bloomberg.com/news/articles/2025-12-22/canada-weighs-opening-its-housing-market-to-more-foreign-capital) - [Civil Penalties and Enforcement Information | Office of Foreign Assets Control](https://ofac.treasury.gov/civil-penalties-and-enforcement-information) - [Home | Office of Foreign Assets Control](https://ofac.treasury.gov/) - [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) - [OFAC Related Press Releases | Office of Foreign Assets Control](https://ofac.treasury.gov/press-releases) - [Sanctions List Service | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-list-service) - [Sanctions List Updates](https://ofac.treasury.gov/recent-actions/sanctions-list-updates) - [International Criminal Court-Related Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/international-criminal-court-related-sanctions) - [DEPARTMENT OF THE TREASURY](https://www.fincen.gov/sites/default/files/shared/MSB_Final_Rule_Definition_and_OtherRegulations.pdf) - [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) - [MONEY TRANSMITTER REGULATORS ASSOCIATION](https://www.fincen.gov/system/files/shared/money_transmitters_regulators.pdf) - [Fact Sheet: Proposed Rule to Strengthen and Modernize ...](https://www.fincen.gov/system/files/shared/Program-NPRM-FactSheet-508.pdf) - [Administrative Ruling on Whether a Company that Offers a Payment Mechanism Based on Payable-Through Drafts to its Commercial Customers is a Money Transmitter | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/administrative-ruling-whether-company-offers) - [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) - [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) - [Beneficial Ownership Information Reporting | FinCEN.gov](https://www.fincen.gov/boi) - [Treasury Department won’t enforce beneficial ownership rule under the Corporate Transparency Act - ICIJ](https://www.icij.org/inside-icij/2025/03/treasury-department-wont-enforce-beneficial-ownership-rule-under-the-corporate-transparency-act/) - [Frequently Asked Questions | FinCEN.gov](https://www.fincen.gov/boi-faqs) - [Beneficial Ownership Information Report (BOIR) - BOI E-FILING](https://boiefiling.fincen.gov/fileboir) - [Small Entity Compliance Guide](https://www.fincen.gov/system/files/shared/BOI_Small_Compliance_Guide.v1.1-FINAL.pdf) - [Small Entity Compliance Guide | FinCEN.gov](https://www.fincen.gov/boi/small-entity-compliance-guide) - [Small Business Resources | FinCEN.gov](https://www.fincen.gov/boi/small-business-resources) - [Beneficial Ownership Reporting Outreach and Education Toolkit | FinCEN.gov](https://www.fincen.gov/boi/toolkit) - [U.S. Beneficial Ownership Information Registry Now Accepting Reports | FinCEN.gov](https://www.fincen.gov/news/news-releases/us-beneficial-ownership-information-registry-now-accepting-reports) - [FinCEN Issues Notice to Financial Institution Customers on Beneficial Ownership Information Requirements | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-notice-financial-institution-customers-beneficial-ownership) - [Assessments](https://www.fatf-gafi.org/en/calendars/assessments.html) - [Mutual Evaluations](https://www.fatf-gafi.org/en/publications/Mutualevaluations.html) - [Mutual Evaluation of the United States](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationoftheunitedstates.html) - [United States](https://www.fatf-gafi.org/en/countries/detail/United-States.html) - [Consolidated assessment ratings](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Assessment-ratings.html) - [2022 Procedures for the FATF AML/CFT/CPF Mutual Evaluations, Follow-Up and ICRG](https://www.fatf-gafi.org/en/publications/Mutualevaluations/5th-Round-Procedures.html) - [Calendars](https://www.fatf-gafi.org/en/calendars.html) - [Consolidated Processes and Procedures for Mutual Evaluations and Follow-Up Universal Procedures](https://www.fatf-gafi.org/en/publications/Fatfgeneral/Universal-procedures.html) - [Outcomes of meetings](https://www.fatf-gafi.org/en/the-fatf/outcomes-of-meetings.html) - [Events](https://www.fatf-gafi.org/en/calendars/events.html) - [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) - [Wisconsin](https://www.fincen.gov/sites/default/files/SARStats_files/SAR03/BSAR_SF_States/Wisconsin.xls) - [Blockchain Legal Library](https://www.trmlabs.com/blockchain-legal-library) - [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) - [The Value of FinCEN Data - Law Enforcement ...](https://www.fincen.gov/resources/law-enforcement/case-examples) - [Canaccord-Consent-Order-No-2026-01. ...](https://www.fincen.gov/system/files/2026-03/Canaccord-Consent-Order-No-2026-01.pdf) - [1 1. See 31 U.S.C. § 5312(a)(2); 31 C.F.R. § 1010.100(t). 2.](https://www.fincen.gov/system/files/2026-05/FinCEN-WCHT-Notice.pdf) - [Jeffrey Epstein Went to War Over Money Laundering Probe in 2007 Sex Case](https://www.bloomberg.com/features/2025-jeffrey-epstein-emails-money-laundering-charges/) - [1](https://www.fincen.gov/system/files/shared/FinCEN-Infographic-Public-2025-508.pdf) - [FinCEN Renews Residential Real Estate Geographic Targeting Orders | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-renews-residential-real-estate-geographic-targeting-orders-0) - [FinCEN GEOGRAPHIC TARGETING ORDER, April 14, 2025](https://www.fincen.gov/system/files/shared/RRE-GTO-Order-April-14-2025-FINAL508.pdf) - [FinCEN Renews Real Estate Geographic Targeting Orders | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-renews-real-estate-geographic-targeting-orders-0) - [Geographic Targeting Order Covering TITLE INSURANCE COMPANY October 9, 2025](https://www.fincen.gov/system/files/2025-10/RRE-GTO-Order.pdf) - [FinCEN Renews and Expands Real Estate Geographic Targeting Orders | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-renews-and-expands-real-estate-geographic-targeting-orders-2) - [FREQUENTLY ASKED QUESTIONS Issued: October 9, 2025](https://www.fincen.gov/system/files/2025-10/RRE-GTO-FAQs.pdf) - [FinCEN Renews Real Estate Geographic Targeting Orders for 12 Metropolitan Areas | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-renews-real-estate-geographic-targeting-orders-12-metropolitan-areas) - [Geographic Targeting Order Covering TITLE INSURANCE ...](https://www.fincen.gov/sites/default/files/shared/Real%20Estate%20GTO_Order_4.29.22_for%20Press%20Release.pdf) - [FinCEN Reissues Real Estate Geographic Targeting Orders for 12 Metropolitan Areas | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-reissues-real-estate-geographic-targeting-orders-12-metropolitan-areas) - [FinCEN Reissues Real Estate Geographic Targeting Orders and Expands Coverage to 12 Metropolitan Areas | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-reissues-real-estate-geographic-targeting-orders-and-expands-coverage-12) - [Enforcement Actions | FinCEN.gov](https://www.fincen.gov/news/enforcement-actions?field_tags_financial_institution_target_id=661) - [United States Department of the Treasury Financial Crimes Enforcement Network - Home | FinCEN.gov](https://www.fincen.gov/?trk=public_post-text) - [Requests by Law Enforcement for Financial Institutions to Maintain Accounts | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/requests-law-enforcement-financial-institutions-maintain) - [Guidance | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance?field_tags_financial_institution_target_id=All&page=5) - [Updated: March 2025 1 Financial Crimes Enforcement Network](https://www.fincen.gov/system/files/shared/BOI-FAQs-QA-508C.pdf) - [Section 314(a) | FinCEN.gov](https://www.fincen.gov/resources/section-314a) - [A Quick Reference Guide for Money Services Businesses](https://www.fincen.gov/system/files/shared/report_reference.pdf) - [Guidance On Interpreting “Frequently” Found In The ...](https://www.fincen.gov/resources/statutes-regulations/guidance/guidance-interpreting-frequently-found-criteria-exempting) - [United States Attorney's Office for the Western District of Wisconsin - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/1340804D:US) - [STATE CONTACT INFORMATION FOR MSBs](https://www.fincen.gov/system/files/shared/msbstatecontactsfinal.pdf) - [Virtual Asset Service Provider (VASP): Definition, Compliance & Examples](https://www.trmlabs.com/fr/glossary/virtual-asset-service-provider-vasp) - [Registration and De-Registration of Money Services Businesses | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/registration-and-de-registration-money-services-businesses) - [Selected General Licenses Issued by OFAC | Office of Foreign Assets Control](https://ofac.treasury.gov/selected-general-licenses-issued-ofac) - [FinCEN (U.S. Department of the Treasury)](https://www.fincen.gov/boi) - [Office of Foreign Assets Control, U.S. Department of the Treasury](https://ofac.treasury.gov/recent-actions/sanctions-list-updates) - [Chainalysis](https://www.chainalysis.com/blog/ncet-blanche-memo/) - [International Consortium of Investigative Journalists (ICIJ)](https://www.icij.org/inside-icij/2025/03/treasury-department-wont-enforce-beneficial-ownership-rule-under-the-corporate-transparency-act/) - [Financial Action Task Force (FATF)](https://www.fatf-gafi.org/en/countries/detail/United-States.html) - [FinCEN (U.S. Department of the Treasury)](https://www.fincen.gov/news/news-releases/fincen-renews-residential-real-estate-geographic-targeting-orders-0) - [FinCEN (U.S. Department of the Treasury)](https://www.fincen.gov/system/files/2026-03/FinCEN-Advisory-Health-Care-Fraud.pdf) Coverage gaps fim-int-2026-07-05-G001: No public Wisconsin Department of F… fim-int-2026-07-05-G001: No public Wisconsin Department of Financial Institutions Division of Banking enforcement bulletin or consent-order archive was located; targeted retrieval of state-level bulletins would resolve whether the enforcement absence is genuine or a publication gap. [resolved] fim-int-2026-07-05-G002: The FATF next Plenary or follow-up … fim-int-2026-07-05-G002: The FATF next Plenary or follow-up review outcome on the United States beneficial-ownership re-rating has not yet occurred; the actual re-rating decision would firm up the Possible/Assessed confidence currently assigned to this risk. [resolved] fim-int-2026-07-05-G003: The National Small Business United … fim-int-2026-07-05-G003: The National Small Business United v. Yellen appeal outcome remains undecided; a ruling would resolve the current uncertainty on the Corporate Transparency Act domestic-exemption trajectory. [resolved] fim-int-2026-07-05-G004: The FinCEN appeal of the vacated Re… fim-int-2026-07-05-G004: The FinCEN appeal of the vacated Residential Real Estate reporting rule has not yet been resolved; the appellate outcome would determine whether the nationwide reporting obligation is reinstated, narrowed, or abandoned. [resolved] fim-int-2026-08-05-G001: Houthi/Yemen-linked UN Panel of Exp… fim-int-2026-08-05-G001: Houthi/Yemen-linked UN Panel of Experts, OFAC and OFSI designation channels were not independently searched this cycle; T1 tracker status carried forward without fresh verification. [resolved] fim-int-2026-08-05-G002: ECCTA 2023 failure-to-prevent-fraud… fim-int-2026-08-05-G002: ECCTA 2023 failure-to-prevent-fraud implementation stage (SFO/FCA reasonable-prevention-procedures guidance) was not independently verified this cycle. [resolved] fim-int-2026-08-05-G003: PEP-classification FCA thematic-rev… fim-int-2026-08-05-G003: PEP-classification FCA thematic-review findings were not sourced this cycle. [resolved] fim-int-2026-08-05-G004: No primary regulator citation was r… fim-int-2026-08-05-G004: No primary regulator citation was retrieved for the D6 enforcement-gap log this cycle; the perpetual-KYC/BOI-verification trend rests on a single Tier-4 industry-commentary source. [resolved] fim-int-2026-08-21-G001: No T1 federal Bureau of Indian Affa… fim-int-2026-08-21-G001: No T1 federal Bureau of Indian Affairs compact-approval timeline located for tribal mobile sports betting rails, which may generate adjacent payments/AML findings once established. [resolved] fim-int-2026-08-21-G002: Tier D jurisdictions (KH, LA, MX, C… fim-int-2026-08-21-G002: Tier D jurisdictions (KH, LA, MX, CO) not searched this cycle; pooled union budget was allocated to the bound jurisdiction US-WI. [resolved] fim-int-2026-08-21-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-08-21-G003 ({'scheme': 'financial_integrity', 'value': 'D2'}): Full findings and monetary amount of the SDG Futures Regenerative Impact Ventures LLC cease-and-desist order were not extracted this cycle. [resolved] fim-int-2026-09-05-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): FATF grey-list June 2026 Plenary change sourced only via T4 aggregator; no fatf-gafi.org primary confirmation retrieved this cycle. [resolved] fim-int-2026-09-05-G002: Tier D jurisdictions (KH, LA, MX, C… fim-int-2026-09-05-G002: Tier D jurisdictions (KH, LA, MX, CO) not actively re-swept this run given JID-bound search-budget allocation. [resolved] fim-int-2026-09-05-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G003 ({'scheme': 'financial_integrity', 'value': 'D5'}): No primary DFI press release located corroborating the $46M elder crypto-scam loss figure or the 330-site takedown count; sourced only via T3 press. [resolved] fim-int-2026-09-28-G001: Tier-D watch jurisdictions (Cambodi… fim-int-2026-09-28-G001: Tier-D watch jurisdictions (Cambodia, Laos, Mexico, Colombia) and the mandatory Houthi/Yemen check were not independently re-searched this cycle because pooled web-search budget was concentrated on US-WI. [resolved] fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): No Tier-1 source confirms the status of any individual Wisconsin tribe's compact renegotiation as of the dispatch date. [resolved] fim-int-2026-10-11-G001: DFI supervisory guidance implementi… fim-int-2026-10-11-G001: DFI supervisory guidance implementing the Act 226 kiosk provisions has not yet been located; watch for publication next cycle. [open] fim-int-2026-10-11-G002: D1 (sanctions), D2 (beneficial owne… fim-int-2026-10-11-G002: D1 (sanctions), D2 (beneficial ownership), D3 (enabler jurisdictions beyond the Tier D negative check) and D4 (conflict finance) produced no jurisdiction-specific material this cycle for this subnational jurisdiction; this reflects thin coverage of a US state against federal-level architecture rather than a confirmed absence of risk. [open] fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): No source found for domains D1 (Sanctions), D2 (Beneficial Ownership) this cycle. [open] fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', 'value': 'D4'}): D4 (Conflict Finance) not applicable in this subnational regime this cycle. [open] fim-int-2026-11-01-G003: D3, D6, D7 carried thin/no coverage… fim-int-2026-11-01-G003: D3, D6, D7 carried thin/no coverage this cycle per research coverage report. [open] FIM-GAP-001 (D2): The March 2025 interim final rule exemptin… FIM-GAP-001 (D2): The March 2025 interim final rule exempting all US-formed 'domestic reporting companies' from beneficial ownership reporting removes the principal mechanism by which Wisconsin-formed LLCs/corporations' true owners could be identified by FinCEN, reversing the basis for the FATF 'largely compliant' BO rating. FIM-GAP-002 (D5): DOJ's April 2025 Blanche Memo directs pros… FIM-GAP-002 (D5): DOJ's April 2025 Blanche Memo directs prosecutors not to pursue unlicensed-money-transmission or BSA charges absent proof of willful intent, disbanding the National Cryptocurrency Enforcement Team and narrowing the practical enforcement net for crypto/MSB actors operating in or through Wisconsin. FIM-GAP-003 (D3): No Wisconsin Department of Financial Insti… FIM-GAP-003 (D3): No Wisconsin Department of Financial Institutions (Division of Banking) public consent order, license revocation, or state-level AML enforcement action against a Wisconsin-chartered MSB, money transmitter, or depository institution was identified in the 18-month window despite exhaustive search. ## Evidence #### Confidence-tiered claims Virtual currency kiosk operators must hold a Chapter 217 money-transmitter licence [[Source 1]](#sec-sources) Probable · 1 source Kiosk operators must verify customer identity before an initial transaction and re-verify with a photograph on each subsequent transaction [[Source 1]](#sec-sources) Probable · 1 source Daily kiosk transactions capped at $1,000 fiat per customer [[Source 1]](#sec-sources) Probable · 1 source Federal Bank Secrecy Act applied through Chapter 217 (Money Transmission Modernization Act, 2023 Wisconsin Act 267, in force 1 Jan 2025); DFI is the non-depository financial services licensing authority; no state-level FIU or independent SAR regime [[Source 1]](#sec-sources) Probable · 1 source No Wisconsin-linked nexus found this cycle to Cambodia, Laos, Mexico, or Colombia corridors Probable Kalshi filed an amicus brief on 2026-10-01 in the consolidated Seventh Circuit appeal arguing the district court erred in not enjoining Wisconsin's enforcement against Kalshi, Polymarket and Crypto.com. [[Source 1]](#sec-sources) Probable · 1 source