--- title: "United States — Wyoming (US-WY) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/united-states-wyoming/ source_html: /jurisdictions/united-states-wyoming/index.html description: "Financial integrity intelligence for United States – Wyoming (US-WY): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: 126c4bf9971bac2cbcb3c90a5f8c642c2dbcacbe310f5c26d1918a5ee16a67d2 generator: "fe-fleet/md-twin@1.0" --- # United States — Wyoming (US-WY) — 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 — Wyoming US-WY Domains covered 8 of 8 Sources 162 Role actions 8 Horizon <90d 0 Jurisdiction profile FATF status: Largely Compliant Tier: A Risk direction: Increasing Enablement vs enforcement: Enabler Wyoming operates under standard US federal AML/CFT law (BSA, CTA, OFAC sanctions) but its state corporate/trust statutes impose no beneficial-ownership disclosure, ID verification, or registered-agent licensing for LLC/trust formation, driving the highest per-capita US incorporation rate. More Since 2019 Wyoming built parallel crypto-specific frameworks (SPDI bank charter, DAO-LLC statute, state-issued FRNT stablecoin) under its Division of Banking — a leading crypto regulatory sandbox that ICIJ also documents as a top domestic secrecy jurisdiction. Key deficiencies - No beneficial ownership disclosure required for Wyoming LLC, corporation, or trust formation - No certified ID verification required to form a company or trust — weaker than Cayman/Bermuda per academic comparative study - Registered-agent industry is unlicensed and unsupervised, enabling large-scale anonymous entity mills (e.g., 30 N. Gould St., Sheridan) - 2025 federal CTA rollback removes the principal backstop (federal BOI reporting) to Wyoming's state-level opacity for domestic entities Recent developments (18m) - FinCEN March 2025 interim final rule exempts all US domestic reporting companies (including Wyoming LLCs) from CTA beneficial ownership reporting - Wyoming bill signed Feb 24, 2025 streamlines state authority to dissolve shell companies linked to foreign adversaries - Wyoming Stable Token Commission launched FRNT, the first US state-issued stablecoin, August 2025 - OFAC designations (Jul 2025, Mar 2026) targeting DPRK IT-worker crypto-laundering networks, with ICIJ/FBI-documented nexus to Wyoming-registered shell entities - ICIJ Cyprus Confidential/Pandora Papers follow-up reporting (Dec 2024–Apr 2025) documents Wyoming overtaking Delaware as the top per-capita US incorporation secrecy hub - FinCEN flagged (Sept 2025) plans to delete previously collected domestic-company BOI data from the registry United States federal law that applies in United States – Wyoming is covered once, on the [United States](/jurisdictions/us/) page. This page covers United States – Wyoming’s own layer: its own law, regulators and enforcement. Brief ## Lead signal #### Lead Signal Wyoming has created its first standalone state felony money-laundering statute. House Bill 43 (26LSO-0146), codified at W.S. 6-3-1101 through 6-3-1103, took effect July 1, 2026, establishing a state-law money-laundering and illegal-investment offense independent of the federal Bank Secrecy Act and FinCEN regime that previously formed the sole basis for this exposure in the state. The statute's definition of a covered financial or business institution expressly includes casinos and money transmitters, and a violation is punishable by imprisonment of up to ten years and a fine. The structural significance here outweighs any single enforcement action: Wyoming's gambling and money-transmission sectors now face a dual federal-and-state criminal architecture where only a federal one existed before, and this is a durable legislative change rather than a shift in enforcement posture. Read full brief #### Lead Signal Wyoming has created its first standalone state felony money-laundering statute. House Bill 43 (26LSO-0146), codified at W.S. 6-3-1101 through 6-3-1103, took effect July 1, 2026, establishing a state-law money-laundering and illegal-investment offense independent of the federal Bank Secrecy Act and FinCEN regime that previously formed the sole basis for this exposure in the state. The statute's definition of a covered financial or business institution expressly includes casinos and money transmitters, and a violation is punishable by imprisonment of up to ten years and a fine. The structural significance here outweighs any single enforcement action: Wyoming's gambling and money-transmission sectors now face a dual federal-and-state criminal architecture where only a federal one existed before, and this is a durable legislative change rather than a shift in enforcement posture. #### Other Developments A persistent guidance gap sits beneath the new statute. Wyoming's Money Transmitters Act exempts virtual-currency-only activity from state money-transmitter licensure under W.S. 40-22-104(a)(vi), while W.S. 40-22-103(d) independently requires Bank Secrecy Act compliance regardless of that exemption. A single commentary source states that the Division of Banking has issued no public guidance, ruling, or interpretive letter addressing the mixed fiat-and-crypto case — where an entity conducts both exempt virtual-currency activity and non-exempt fiat money transmission. This is reported here at appropriately limited confidence: it rests on one Tier-3 vendor source and has not been independently confirmed against a Division of Banking primary instrument. If accurate, it means Wyoming's historically permissive crypto money-transmission posture now sits alongside an unresolved compliance boundary question, at the same moment the state has newly armed itself with an independent felony money-laundering charge that could reach exactly this kind of ambiguous conduct. The new felony statute's text extends by definition to money-transmitter conduct , which may include crypto-adjacent money-transmission activity given Wyoming's broad money-transmitter licensing population. This is not a crypto-specific enforcement signal so much as a structural layering: a state criminal backstop now covers a category of firm whose state licensure boundary (fiat versus virtual currency) remains, per the single available secondary source, unclarified by the primary regulator. #### Cross-Monitor Connections This development connects most directly to payments and crypto-infrastructure monitoring: any Wyoming-licensed or exempt money-transmission entity handling both fiat and virtual-currency flows now carries state felony exposure on top of federal BSA obligations, a consideration relevant to counterparty and vendor risk assessment for payment-rail and crypto-exchange relationships touching Wyoming. It also bears on enabler-jurisdiction analysis: a jurisdiction combining a historically permissive crypto money-transmission exemption with an unresolved guidance gap and a newly strengthened criminal backstop presents a mixed enablement/enforcement profile worth tracking alongside Wyoming's broader crypto-regulatory posture. #### Outlook The enrolled chapter text and final penalty schedule of HB0043 have not yet been independently re-verified against the enacted act; only the introduced-bill text was available this period, and confirming the final statutory language against the Wyoming Secretary of State's enrolled-bill record would close that gap. Separately, whether the Division of Banking issues any guidance clarifying the fiat/crypto money-transmission exemption boundary is the single most consequential open question for Wyoming's crypto-adjacent AML exposure; absent such guidance, firms operating in that boundary area face continued uncertainty layered onto new criminal-law stakes. Earlier periodic briefs (6) 25 Oct 2026 · fim-2026-10-25 #### Lead Signal Wyoming has created its first standalone state felony money-laundering statute. House Bill 43 (26LSO-0146), codified at W.S. 6-3-1101 through 6-3-1103, took effect July 1, 2026, establishing a state-law money-laundering and illegal-investment offense independent of the federal Bank Secrecy Act and FinCEN regime that previously formed the sole basis for this exposure in the state. The statute's definition of a covered financial or business institution expressly includes casinos and money transmitters, and a violation is punishable by imprisonment of up to ten years and a fine. The structural significance here outweighs any single enforcement action: Wyoming's gambling and money-transmission sectors now face a dual federal-and-state criminal architecture where only a federal one existed before, and this is a legislative change rather than a shift in enforcement posture. #### Other Developments A persistent guidance gap sits beneath the new statute. Wyoming's Money Transmitters Act exempts virtual-currency-only activity from state money-transmitter licensure under W.S. 40-22-104(a)(vi), while W.S. 40-22-103(d) independently requires Bank Secrecy Act compliance regardless of that exemption. A single commentary source states that the Division of Banking has issued no public guidance, ruling, or interpretive letter addressing the mixed fiat-and-crypto case — where an entity conducts both exempt virtual-currency activity and non-exempt fiat money transmission. This is reported here at appropriately limited confidence: it rests on one Tier-3 vendor source and has not been independently confirmed against a Division of Banking primary instrument. If accurate, it means Wyoming's historically permissive crypto money-transmission posture now sits alongside an unresolved compliance boundary question, at the same moment the state has newly armed itself with an independent felony money-laundering charge that could reach exactly this kind of ambiguous conduct. The new felony statute's text extends by definition to money-transmitter conduct , which may include crypto-adjacent money-transmission activity given Wyoming's broad money-transmitter licensing population. This is not a crypto-specific enforcement signal so much as a structural layering: a state criminal backstop now covers a category of firm whose state licensure boundary (fiat versus virtual currency) remains, per the single available secondary source, unclarified by the primary regulator. #### Cross-Monitor Connections This development connects most directly to payments and crypto-infrastructure monitoring: any Wyoming-licensed or exempt money-transmission entity handling both fiat and virtual-currency flows now carries state felony exposure on top of federal BSA obligations, a consideration relevant to counterparty and vendor risk assessment for payment-rail and crypto-exchange relationships touching Wyoming. It also bears on enabler-jurisdiction analysis: a jurisdiction combining a historically permissive crypto money-transmission exemption with an unresolved guidance gap and a newly strengthened criminal backstop presents a mixed enablement/enforcement profile worth tracking alongside Wyoming's broader crypto-regulatory posture. #### Outlook The enrolled chapter text and final penalty schedule of HB0043 have not yet been independently re-verified against the enacted act; only the introduced-bill text was available this period, and confirming the final statutory language against the Wyoming Secretary of State's enrolled-bill record would close that gap. Separately, whether the Division of Banking issues any guidance clarifying the fiat/crypto money-transmission exemption boundary is the single most consequential open question for Wyoming's crypto-adjacent AML exposure; absent such guidance, firms operating in that boundary area face continued uncertainty layered onto new criminal-law stakes. 18 Oct 2026 · fim-2026-10-18 #### Lead Signal Wyoming's special purpose depository institution charter regime continues to incrementally diverge from the federal bank-charter and reserve baseline, and this cycle's signal is the continuation rather than the origination of that divergence. SF0095, effective July 1, 2025, amended W.S. 13-12-110 so that no special purpose depository institution may commence business until its full authorized capital is subscribed and paid in, and no SPDI may be chartered without a paid-up surplus fund of not less than 20 percent of its legally authorized capital stock. A further 2026 amendment package, SF0055 (Chapter 75, signed March 7, 2026, mostly effective July 1, 2026), continues this refinement. Read alongside Wyoming's long-standing virtual-currency money-transmitter exemption under W.S. 40-22-104(a)(vi), which exempts virtual-currency activity from the state's Money Transmitter Act licensing requirement while federal FinCEN BSA registration still formally applies, the structural picture is of a state charter and exemption architecture that sits adjacent to, rather than inside, the federal baseline most other states default to. #### Other Developments Sustained OFAC designation tempo marked the global sanctions picture this period: between October 1 and October 15, 2026, OFAC issued a sectoral determination and roughly 30 designations tied to Iran's automotive, rail and metals sectors, sanctioned 17 vessels and companies in Iran's petroleum shadow-fleet network, designated individuals tied to Cartel del Noreste's finance network, and imposed ICC-related sanctions that drew explicit public disagreement from the UK, Canada, Germany, France, Italy, Japan and the Netherlands. Cartel-linked financial flows through the US southwest border remain a live concern: FinCEN's supplemental alert, FIN-2026-Alert003, dated June 30, 2026, flagged over seven billion dollars in suspicious-activity reports tied to cartel fuel smuggling, including stablecoin-based payments, and FinCEN reissued a Geographic Targeting Order on September 2, 2026, requiring enhanced money-services-business reporting in designated New Mexico and Texas border counties. Cambodia's gaming regulator took enforcement action against licensed casinos linked to scam operations, revoking 20 of 195 licences and suspending 29 more, according to reporting from August and September 2026; Cambodia's next FATF mutual evaluation is scheduled for 2029. Wyoming's state-issued stablecoin continues to operate as a non-federal test case: the Frontier Stable Token, live since January 7, 2026 and managed by the Wyoming Stable Token Commission with Franklin Templeton as reserve manager, runs alongside the federal GENIUS Act's stablecoin framework, a juxtaposition made more salient by FinCEN's documentation of stablecoin use in the same period's cartel fuel-smuggling payment flows. #### Cross-Monitor Connections The Wyoming SPDI charter and money-transmitter exemption picture connects directly to the crypto monitor's tracking of Wyoming's digital-asset banking and stablecoin regime, where the same SF0095 and SF0055 amendments and the same Frontier Stable Token launch are tracked from a licensing and product-classification lens rather than an enabler-jurisdiction lens. The cartel fuel-theft and stablecoin-payment findings connect to the crypto monitor's interest in on-chain payment-rail usage and to the world-payments monitor's interest in cross-border settlement flows, though world-payments is not in scope this cycle. The OFAC designation tempo and the explicit allied disagreement over ICC-related sanctions is a signal relevant to the advennt monitor's extraterritorial-reach tracking for any jurisdiction with exposure to the designated networks, though no gambling-sector nexus was identified this cycle. #### Outlook Watch for the first public confirmation of mandatory secondary-sanctions designations under the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, whose delegation deadline for naming SDN-listing parties fell on October 18, 2026, with review required every 180 days thereafter; the full designation list was not yet public as of this cycle's cutoff. On the structural side, continued SPDI amendment activity in Wyoming through 2026 suggests the charter regime will keep evolving rather than settling, and the interaction between Wyoming's Frontier Stable Token and the federal GENIUS Act's dual federal-state licensing regime remains an open structural question worth tracking as both frameworks mature. 11 Oct 2026 · fim-2026-10-11 #### Lead Signal Wyoming has closed a statutory gap flagged by its own Legislative Service Office, which had noted the state was one of twenty in the nation without specific anti-money-laundering legislation. HB0043 (enacted as Chapter 89) creates Wyoming's first state-level criminal money laundering and illegal investment offenses, codified at W.S. 6-3-1101 through 6-3-1103, effective July 1, 2026. The statute defines "financial or business institution" to expressly include money transmitters and casinos, bringing both sectors within a state criminal predicate that previously did not exist. This sits alongside, rather than replaces, the existing federal Bank Secrecy Act and FinCEN reporting architecture that already applied to Wyoming-domiciled money transmitters and gaming operators; the state now has a dual federal-state AML predicate where it previously had only the federal layer. #### Other Developments Cross-state digital-asset supervisory coordination. The Wyoming Division of Banking and the New York Department of Financial Services announced, on October 1, 2026, a seven-page memorandum of understanding to share information and coordinate licensing, examinations and possible enforcement for virtual-currency and digital-asset businesses operating in either state. This is a process mechanism rather than a substantive change to either regulator's legal powers: no licensing requirement is added or removed by the MOU itself, and the finding rests on a single secondary report rather than a jointly published primary text. Custodia Bank's Federal Reserve access litigation effectively closes. The Tenth Circuit denied Custodia Bank's petition for rehearing of its suit against the Federal Reserve, a decision reported in mid-March 2026, narrowing the Wyoming special-purpose depository institution's path to direct Federal Reserve payment-system access. Custodia is reported to be pursuing correspondent-bank and so-called "skinny" master-account alternatives through relationships with other institutions, though the commercial detail of those alternatives rests on thin sourcing and is not independently confirmed. Wyoming's standing beneficial-ownership architecture is unchanged. The foreign-adversary administrative-dissolution authority created by HB0069, effective July 1, 2025, remains the operative Wyoming corporate-transparency mechanism; no new legislation in this area was identified. #### Cross-Monitor Connections The new money-laundering statute has a direct read-through to the payments and gaming perimeters this monitor shares with sister trackers: because the statute's "financial or business institution" definition expressly names money transmitters and casinos, any Wyoming-licensed payment company or gambling operator now sits inside a state criminal AML predicate in addition to the federal BSA/FinCEN framework. The Custodia Bank Federal Reserve litigation closure is a correspondent-banking and settlement-access development with direct bearing on how Wyoming special-purpose depository institutions reach the broader payment system, a matter of shared interest with payments-focused tracking of this jurisdiction. The WY-NY digital-asset MOU is similarly a cross-jurisdictional supervisory-architecture development relevant to any monitor tracking digital-asset licensing coordination between US states. #### Outlook The practical effect of HB0043 on enforcement volume will only become visible once the statute has been in force for a period; as at this cycle it is a newly effective instrument rather than one with an enforcement record. The WY-NY MOU's operational substance, including whether it produces joint examinations or enforcement referrals, likewise remains to be seen beyond its October 1, 2026 announcement. Separately, the Model Money Transmission Modernization Act (27LSO-0137), which would repeal and replace the Wyoming Money Transmitters Act with a multistate-recognition licensing framework, was carried to November 2026 for further committee revision and is a structural development to track into the 2027 session, given its direct bearing on which entities sit inside Wyoming's money-transmission perimeter, including money transmitters now newly captured by the HB0043 AML predicate. 4 Oct 2026 · fim-2026-10-04 #### Lead Signal Wyoming's digital-asset supervisory architecture moved on two fronts this cycle. On 1 October 2026, the New York State Department of Financial Services and the Wyoming Division of Banking signed a memorandum of understanding covering licensing and chartering coordination, joint examinations, and the sharing of supervisory reports, market trend data and notifications of potential enforcement actions for virtual-currency and digital-asset firms operating in both states. The arrangement narrows, without eliminating, a long-standing regulatory seam between New York's BitLicense regime and Wyoming's Special Purpose Depository Institution and money-transmitter-exemption regime. Separately, on 29 September 2026 the Wyoming Select Committee on Blockchain, Financial Technology and Digital Innovation Technology heard bill draft 27LSO-0138 v0.4, which would replace a capped civil-penalty ceiling with uncapped civil money penalties backing the Division of Banking's kiosk-enforcement toolkit established under 2026's HB0075. Both developments respond to the same underlying kiosk-facilitated fraud typology tied to FinCEN money-services-business and Bank Secrecy Act obligations, and together they represent the most concentrated movement in Wyoming's enabler-jurisdiction posture in recent cycles. The interstate MOU is a supervisory-coordination instrument, not a harmonisation of substantive law: Wyoming's SPDI charter and money-transmitter exemption for virtual currency remain in place, and New York's BitLicense regime remains separately administered. What changes is the information flow between the two regulators and, by extension, the practical cost of regulatory arbitrage for firms that previously could operate under one state's lighter perimeter while avoiding scrutiny from the other. #### Other Developments Sanctions cadence against Sinaloa Cartel finance infrastructure. On 29 September 2026, the Office of Foreign Assets Control added 21 individuals and 25 entities tied to the Los Mayos faction of the Sinaloa Cartel to the SDN List, including Alfonso Arzate Garcia, targeting fentanyl-trafficking revenue, money laundering, and an alleged protection network within regional Mexican authorities. The action continues a standing cartel-finance corridor already tracked across prior cycles and sustains, rather than newly opens, FIM's Mexico risk line. Kiosk-enforcement toolkit tightening. The same 29 September hearing that considered the civil-penalty draft sits atop an enforcement structure Wyoming built earlier in 2026 under HB0075, restricting kiosk operation to Money Transmitters Act licensees or Title 13 financial institutions. Draft 27LSO-0138 would remove the ceiling on civil penalties available against operators who run kiosks outside that licensed perimeter, a structural tightening of the deterrent rather than a new category of obligation. Interstate coordination mechanics. The NY DFS-Wyoming Division of Banking MOU establishes licensing and chartering coordination alongside joint examinations and enforcement-notification sharing. Full enforcement-coordination practice under the MOU remains untested, and the arrangement's effect on actual cross-border supervisory outcomes will only become observable in future cycles as examinations and notifications occur. #### Cross-Monitor Connections The NY-WY supervisory MOU and the kiosk-penalty draft both carry direct relevance to WPM's licensing and market-access tracking for the same jurisdiction, since the instruments at issue are the same underlying regulatory actions viewed through a payments-market-structure lens rather than an integrity lens. The OFAC Sinaloa Cartel designations connect to SCEM's conflict- and organised-crime-finance tracking given the cartel-finance and alleged official-corruption dimensions of the action, and to any monitor tracking correspondent-banking de-risking pressure arising from heightened Mexico-corridor sanctions exposure. #### Outlook The NY-WY MOU's practical effect depends on how examination coordination and enforcement notifications are actually used going forward; as scheduled, this is a structural enabler-jurisdiction narrowing whose enforcement-coordination practice has not yet been tested. The kiosk civil-penalty draft, if enacted, would complete a toolkit that began with HB0075's licensing restriction earlier in 2026, moving Wyoming's kiosk-fraud response from a capped-penalty regime to an uncapped one. The Sinaloa Cartel designation cadence is likely to continue absent a change in the underlying conflict-finance dynamics in Mexico, and the alleged official-corruption dimension of the September 2026 action may generate follow-on correspondent-banking scrutiny in future cycles. 29 Sep 2026 · fim-2026-09-28 #### Lead Signal Wyoming enacted HB0043 in its 2026 budget session, creating the state's first dedicated money-laundering and illegal-investment criminal offense under a new Article 11 of the criminal code, at W.S. 6-3-1101 through 6-3-1103. The statute expressly defines financial or business institution to include foreign or domestic money transmitters, casinos, and check cashers, bringing these sectors within the scope of the state's own currency-transaction and reporting duties for the first time under state law. This is a structural addition to Wyoming's AML architecture, supplementing rather than replacing the federal Bank Secrecy Act and FinCEN framework, which continues to be the primary supervisory regime; Wyoming has no independent state AML supervisory authority distinct from that federal framework. #### Other Developments SPDI Act amended for 2026. SF0055 modified capital adequacy, charter-application procedure, business-commencement timing, supervision-fee structure and resolution-fund provisions for Wyoming's Special Purpose Depository Institution charter, the state's bespoke digital-asset banking framework; most amendments are effective July 1, 2026, with rulemaking sections effective immediately. No Tier-1 anchor for the precise amendment text was retrieved this cycle. SPDI charter count confirmed. The Wyoming Banking Board has approved four SPDI charters to date, evidencing continued scale in the standing digital-asset banking regime. Digital Asset Authority proposed. The Wyoming Select Committee on Blockchain, Financial Technology and Digital Innovation Technology is drafting legislation to restructure the Wyoming Stable Token Commission into a broader Wyoming Digital Asset Authority, consolidating administration of all Wyoming government-issued digital assets under one statutory body; this is a consultation-stage item with no fixed introduction date confirmed. #### Cross-Monitor Connections The SPDI Act amendment and Digital Asset Authority proposal are read by the crypto monitor as crypto_licensing developments and by the world-payments monitor as W1a licensing and W12 correspondent-banking-adjacent developments; this financial-integrity reading foregrounds the AML/CTF and typology-relevant dimension of the same underlying facts, namely the absence of an independent state AML supervisor layered against an expanding digital-asset banking perimeter. HB0043's new money-laundering offense, by contrast, is a first-party AML/CTF development specific to this monitor's D7 domain. #### Outlook Watch whether the proposed Wyoming Digital Asset Authority is introduced in the 2027 general session, which would further consolidate Wyoming's digital-asset governance architecture. Separately, the practical enforcement application of HB0043's new money-laundering offense against the named covered institutions — money transmitters, casinos, and check cashers — has not yet been observed and remains a first-application item to watch as the statute's currency-transaction-reporting duties take practical effect. 22 Sep 2026 · fim-2026-08-05 #### Lead Signal Wyoming's 2026 record surfaces a state whose crypto-finance architecture is expanding faster than the federal access and compliance framework surrounding it. House Bill 75 brings virtual currency kiosk operators under the Wyoming Money Transmitters Act, requiring a state money-transmitter licence or a state-chartered financial-institution status, a response to documented fraud losses exceeding three million dollars in Campbell County. At the same time, the state's own stablecoin, the Frontier Stable Token, continues to scale as the first fiat-backed, fully-reserved stable token issued by a public entity in the United States — a structure in which Wyoming's state government is simultaneously issuer, reserve manager, and, by implication, a participant in its own regulatory perimeter. The GENIUS Act's permitted-payment-stablecoin-issuer framework arguably does not contemplate a state government as issuer, leaving the token's BSA and OFAC compliance posture ambiguous even as a joint FinCEN/OFAC notice of proposed rulemaking, issued 8 April 2026, moves to mandate AML and sanctions compliance programs for permitted payment stablecoin issuers generally — the first time such a program would be mandated by law for a payment-instrument class. Whether that mandate reaches a state-issued token is, on the evidence available this cycle, unresolved. Running alongside this is Custodia Bank's continuing federal court fight over Federal Reserve master-account access. The certiorari filing deadline for Custodia's Supreme Court petition was extended from 11 June to 11 July 2026 following the Tenth Circuit's denial of en banc rehearing — a procedural event, not a substantive ruling, but one that keeps open a structural question: whether a Wyoming special-purpose depository institution, chartered under Wyoming's own banking innovation regime, can obtain direct payment-rail access on the same footing as a federally chartered and FDIC-insured bank. Together, these three developments — kiosk licensing, stablecoin issuance, and Fed-access litigation — describe a single underlying architecture: Wyoming has built regulatory and chartering infrastructure for crypto-native financial activity that in several respects sits ahead of, rather than following, federal frameworks, and the compliance and access gaps that result are structural rather than incidental. #### Other Developments Crypto-kiosk licensing closes a documented harm gap. House Bill 75's new licensing chapter, W.S. 40-32-101 through 103, was enacted specifically in response to fraud losses in Campbell County, where at least three of six known kiosk operators had been operating without registration. The statute mirrors, at state level, the posture FinCEN itself took in a 2025 national advisory on convertible-virtual-currency kiosks, suggesting Wyoming's response is aligned with, rather than divergent from, federal typology guidance on this vector. The Frontier Stable Token's regulatory position remains structurally unresolved. Wyoming is simultaneously the token's issuer, its reserve manager, and a participant in the regulatory conversation about how permitted payment stablecoin issuers should be supervised. This is a cross-pillar structural question rather than a single enforcement fact, and it sits apart from the AML/CFT oversight questions that apply to privately issued stablecoins. A federal sanctions-compliance mandate for stablecoin issuers is now in process. The FinCEN/OFAC joint notice of proposed rulemaking, filed 8 April 2026, would require permitted payment stablecoin issuers to maintain effective sanctions compliance programs, described in the underlying notice as the first time such programs have been mandated by law. Final rules are not expected to take effect until roughly twelve months after issuance. #### Cross-Monitor Connections The Custodia Fed-access dispute and the Frontier Stable Token's regulatory ambiguity both connect to the enabler-jurisdiction architecture question that runs through Wyoming's broader crypto-banking regime: a state that has built a chartering and issuance framework substantially ahead of federal clarity on access and compliance. This is the kind of structural, architecture-level finding that this monitor's framing treats as more significant than a single enforcement action — the absence of federal payment-rail access for Wyoming's special-purpose depository institutions, and the absence of settled AML/sanctions treatment for a state-issued stablecoin, are themselves the signal, independent of whether any enforcement event follows. Analysts tracking correspondent-banking and payment-rail access questions in other permissive chartering jurisdictions should treat Wyoming's SPDI experience as a reference case for how federal-state friction in banking access can persist for years without resolution. #### Outlook Two threads carry into the next cycle. First, the Custodia certiorari question: if the Supreme Court denies review or Custodia does not file by 11 July 2026, the Fed master-account question returns to the lower-court record as settled against Custodia, at least for now, narrowing the near-term prospect of direct Fed access for Wyoming SPDIs. Second, the FinCEN/OFAC permitted-payment-stablecoin-issuer rulemaking: with final rules not expected to take effect until roughly twelve months after issuance, the applicability of the sanctions-compliance mandate to a state-government-issued token such as the Frontier Stable Token remains an open compliance question that this monitor will continue to track as the rulemaking progresses toward finalisation. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion The first-cycle baseline for United States - Wyoming surfaces a documented sanctions-architecture finding rather than an isolated enforcement episode. A DPRK IT-worker fraud and crypto-laundering network, which generated close to USD 800 million in 2024 for weapons programs, has been shown to route through US shell entities, including Wyoming-registered firms named in a 2024 FBI affidavit. Applying a three-level architecture reading: at the scheme level, DPRK operatives embedded as fraudulent remote IT workers collect wages in USDC and USDT; at the architecture level, proceeds consolidate through Wyoming and other US shell entities before moving through OTC traders, mixers, and cross-chain bridges across Russia, China, the UAE, Vietnam, and Laos; at the strategic-consequence level, the funds flow toward WMD and ballistic-missile program financing. This is state-directed sanctions evasion and proliferation financing, not opportunistic private crime, and the DPRK states direction of the laundering apparatus is the structural fact that elevates this above a routine designation. Continue reading OFAC has responded with two designation waves, in July 2025 naming Song Kum Hyok and four Russia-based entities, and in March 2026 naming six additional individuals and two entities, expanding the sanctioned-address set across multiple blockchain networks. What is analytically significant is the absence documented alongside this enforcement: no parallel UK OFSI or EU Council listing of the same named facilitators has been identified. This designation-tempo divergence is a regime-divergence signal in its own right - it creates a compliance gap for non-US institutions that rely on domestic sanctions lists when screening counterparties connected to Wyoming-linked entities, since a counterparty cleared against a UK or EU list may still carry OFAC-designated exposure. Wyomings own response sits at a different level entirely. In February 2025 the state enacted expedited dissolution authority permitting the Secretary of State to dissolve shell companies submitting false formation records or linked to foreign adversaries, following the 2024 dissolution of Sheridan-registered entities named in the FBI affidavit. This functions as a quasi-sanctions tool operating independently of federal OFAC listing tempo, but it is narrow - it addresses dissolution of already-identified bad actors rather than the upstream registered-agent vetting gap that allowed the entities to form in the first place. The sanctions-architecture reading of this cycle, therefore, is one of a documented and state-directed evasion network intersecting with a jurisdiction whose formation infrastructure remains structurally permissive even as its designation-adjacent enforcement (dissolution authority) and federal partner (OFAC) tighten around the edges. #### Outlook The sanctions-divergence gap between OFAC and its UK and EU counterparts is the single most actionable open question here: whether Wyomings shell-entity nexus draws matching international designations will determine whether non-US institutions face a persistent blind spot in screening Wyoming-linked counterparties, or whether the gap closes through diplomatic and enforcement coordination. Wyomings dissolution authority, while a genuine tool, does not resolve the underlying registered-agent oversight gap that the D3 tracker documents; further legislative reform is not expected before the February 2027 biennial session at the earliest. The trajectory for this domain is assessed as worsening, with the shell-entity nexus and the designation-tempo gap both moving in a direction that increases rather than reduces screening burden for financial institutions with Wyoming-linked exposure. Judgment: No US-WY-specific sanctions signal found this cycle. Uncertain #### Beneficial Ownership and Corporate Transparency The United States sits outside the EU AML Packages direct regulatory perimeter, so the primary subject matter for this jurisdiction is domestic: Wyomings state-level corporate and trust statutes, layered against a narrowing federal disclosure backstop. Wyoming requires no state-level beneficial-ownership disclosure and no certified identity verification for LLC, corporation, or trust formation, a finding corroborated by ICIJ investigative reporting, academic comparative study, and FinCENs own historical shell-company assessment. The states so-called cowboy-cocktail structure permits an anonymous LLC to serve as trustee or controller of a trust, with a second layered LLC beneath it stripping any named natural person from the public record, without requiring assets to be physically transferred into the state. This structure is actively marketed to foreign ultra-wealthy clients by offshore intermediaries, including the Cyprus-based ConnectedSky, which positions Wyoming structures as superior to Cayman, Singapore, or New Zealand alternatives for asset shielding. Continue reading This state-level opacity is now compounded by a federal development that requires precise framing. FinCENs March 26, 2025 interim final rule exempts all US-formed entities, including Wyoming LLCs and trusts, from Corporate Transparency Act beneficial-ownership reporting. The correction that matters here: this is an interim rule, not a final one. The public comment period closed May 27, 2025, and FinCEN has stated intent to issue a final rule in 2026 - the exemptions operative status remains provisional and subject to revision or legal challenge, not a settled statutory rollback. Treating it as settled would overstate the finding; treating it as genuinely open, with a documented risk of confirmation, is the more accurate register. Separately, FinCEN signalled in September 2025 an intention to delete beneficial-ownership data already collected on domestic reporting companies, which would further erode the federal transparency backstop if finalized. Globally, the EU AML Package sets the structural direction for beneficial-ownership transparency: it comprises three distinct instruments - the directly applicable AML Regulation (Reg (EU) 2024/1624), the sixth AML Directive requiring per-Member-State transposition, and the AMLA Regulation (Reg (EU) 2024/1620) establishing the Anti-Money Laundering Authority with a direct and indirect supervision perimeter that shifts obliged-entity oversight from purely national authorities toward a hybrid EU-level regime. For Wyoming, this architecture is not directly applicable - the United States falls outside the AMLR direct-applicability, 6AMLD transposition, and AMLA direct-supervision perimeters entirely. The only documented nexus is indirect: EU and Cyprus-based corporate-service intermediaries such as ConnectedSky actively market Wyoming structures to EU clients, meaning AMLA-era supervision of EU-based trust and company service providers is the operative control point for this cross-border risk, not any direct instrument reach into Wyoming itself. This durable structural backdrop is worth holding in view even though it is not this cycles primary story for a US sub-national jurisdiction. Wyomings own FATF standing frames the domestic picture: the United States is rated compliant on 9 of 40 Recommendations, largely compliant on 23, partially compliant on 5, and non-compliant on 3 as of March 2024, with beneficial-ownership access flagged as a persistent effectiveness gap. Wyoming is not separately assessed sub-nationally by FATF, meaning national-level ratings do not capture state-specific structural permissiveness. It is also worth registering a limiting counter-fact: Wyoming trust and LLC structures provide anonymity from the public record, but this is independent of federal IRS trust-reporting requirements and bank KYC obligations, both of which continue to apply. The opacity, in other words, is real but not absolute. #### Outlook The single most consequential open question for this domain is whether FinCENs 2026 final rule confirms, narrows, or reverses the March 2025 domestic-entity exemption; this will determine whether the federal transparency backstop to Wyomings state-level opacity is restored, further eroded, or left in its current diminished state. A secondary open question is whether Wyomings legislature, having rejected registered-agent and trust-transparency reform in 2016, 2022, and 2023, will revisit BO-adjacent reform at its February 2027 biennial session. Absent either federal or state movement, the trajectory here remains worsening. Judgment: No US-WY-specific beneficial-ownership development found this cycle. Uncertain #### Enabler Jurisdictions and Professional Facilitators The enabler-jurisdiction reading of this cycles Wyoming baseline turns on a distinction the FIM methodology treats as central: capacity deficit versus political choice. A single registered-agent address at 30 N. Gould St. in Sheridan accounted for over 40 percent of new Wyoming incorporations between 2019 and 2024, operating an unlicensed, address-only service that requires no client vetting. Wyomings registered-agent statute requires no training, background checks, or beneficial-owner collection from agents forming entities at this volume. This concentration attracted COVID-relief fraud exposure, foreign politically-exposed-person activity, and was named in an FBI affidavit describing a North Korean sanctions-evasion scheme - the same DPRK IT-worker network assessed under D1. Continue reading What elevates this from a capacity gap to a structural, choice-driven finding is the legislative record. Wyomings legislature rejected registered-agent oversight and trust-transparency reforms in 2016, 2022, and 2023, with the trust-formation and registered-agent services industry itself cited as the effective opposition to reform. Only a narrow foreign-adversary dissolution law passed in February 2025, addressing already-identified bad actors rather than the upstream vetting gap; broader registered-agent licensing reform remains pending despite the Wyoming Secretary of State and Treasurer publicly describing such reform as critical. This is legislative capture sustaining a gap that political will alone could close - a materially different and more serious finding than a jurisdiction lacking the administrative capacity to supervise its incorporation industry. A comparative academic study (Sharman) sharpens this further by finding that Wyoming and Nevada require no certified identity documents to form a company or open an associated bank account - a materially lower verification bar than classic offshore centres including Bermuda or the Cayman Islands. This finding undercuts the conventional onshore-versus-offshore risk framing that treats US states as inherently lower-risk than recognized secrecy jurisdictions; the evidence this cycle suggests the opposite ordering on this specific dimension. The cross-border professional-facilitator dimension is also documented this cycle: the Cyprus-based intermediary ConnectedSky markets Wyoming LLC-trust secrecy structures to European ultra-wealthy clients, positioning them as superior to Cayman, Singapore, and New Zealand structures for asset shielding. This is a professional-enabler nexus linking a non-EEA secrecy jurisdiction (Wyoming) to EU-domiciled facilitators, a pattern directly relevant to how AMLA will eventually assess cross-border obliged-entity risk from the EU side, even though Wyoming itself sits outside AMLAs reach. #### Outlook The enabler-jurisdiction classification for Wyoming is assessed as worsening precisely because the documented gap is legislative choice rather than administrative incapacity - a distinction that makes near-term resolution less, not more, likely absent a change in the underlying political economy of Wyomings registered-agent industry. The February 2027 biennial legislative session is the next probable vehicle for reform, following three prior rejections; whether the registered-agent industrys opposition holds a fourth time will be the key indicator to watch. In the interim, the Sheridan address concentration and the ConnectedSky cross-border marketing nexus both continue to operate without the oversight that would flag or interrupt them. Judgment: Wyoming's virtual-currency money-transmitter exemption remains an unresolved enabler-jurisdiction gap (Division of Banking guidance absent per single Tier-4 source), now paired with a new state AML felony backstop. Uncertain #### Conflict Finance and Extractive-Industry Integrity OFAC's 29 September 2026 SDN List additions targeting the Los Mayos faction of the Sinaloa Cartel sit squarely within FIM's standing conflict and organised-crime finance corridor tracking Mexico-linked illicit finance, alongside fuel-theft and cross-border cash and casino laundering vehicles tracked in prior cycles. The designations target 21 individuals and 25 entities tied to fentanyl-trafficking revenue and money laundering, and notably also name an alleged protection network within regional Mexican authorities — a corruption dimension that extends the conflict-finance reading beyond pure narcotics-proceeds laundering into the state-enablement layer that permits that laundering to continue with reduced local interdiction risk. Continue reading This Confirmed-tier development, evidenced directly against OFAC's own recent-actions page, continues rather than newly establishes the standing Sinaloa Cartel finance corridor. The architecture-over-incident framing that applies here is that a single designation action is less significant on its own than the sustained cadence of designations it forms part of: OFAC's continued willingness to designate new individuals and entities within the same organised-crime network over successive cycles indicates an active, ongoing enforcement posture against this specific conflict-finance architecture rather than a one-off response to a discrete triggering event. No Wyoming-specific nexus to this conflict-finance corridor was identified this cycle beyond the general federal sanctions-compliance obligations applicable to Wyoming-chartered financial institutions, including SPDIs, that must screen counterparties against the SDN List as updated by this action. #### Outlook The alleged official-corruption dimension of this designation action is the element most likely to generate follow-on developments: if the protection-network allegation leads to further designations of specific Mexican officials or state-adjacent entities, that would mark an escalation of OFAC's targeting logic from narcotics-and-laundering conduct into direct state-corruption designations. Whether that escalation occurs will only be observable in subsequent designation actions; at this stage, the development represents continuity of the existing cartel-finance enforcement cadence. Judgment: No US-WY-specific conflict-finance development found this cycle. Uncertain #### Crypto / Digital Assets / Financial Innovation Wyoming's new standalone state felony money-laundering statute, House Bill 43 (26LSO-0146), in force since July 1, 2026 and codified at W.S. 6-3-1101 through 6-3-1103, defines covered financial or business institutions to include money transmitters, a category that in Wyoming's broader regulatory landscape includes crypto-adjacent money-transmission activity. This layers a state criminal backstop onto a market structure where Wyoming has historically been permissive toward virtual-currency activity: W.S. 40-22-104(a)(vi) exempts virtual-currency-only activity from state money-transmitter licensure altogether. Continue reading That exemption, however, sits beside an unresolved compliance question. W.S. 40-22-103(d) independently requires Bank Secrecy Act compliance irrespective of the licensure exemption, and a single Tier-3 commentary source states that Wyoming's Division of Banking has issued no public guidance, ruling, or interpretive letter clarifying how this applies to an entity conducting mixed fiat-and-crypto money transmission. This claim is reported at Uncertain confidence: it has not been corroborated against a Division of Banking primary instrument, and no such instrument was located this period. Taken together, the picture for crypto-adjacent money-transmission activity in Wyoming is one of structural ambiguity — a historically light-touch licensing exemption, an unconfirmed guidance gap at the federal-compliance boundary, and now a new and more severe state-level criminal exposure layered on top of both. #### Outlook The single most consequential open question for this domain is whether the Division of Banking issues any clarifying guidance on the fiat/crypto money-transmission exemption boundary. Absent such guidance, firms operating in that boundary area continue to face an unresolved compliance question now compounded by meaningfully higher criminal-law stakes under HB0043. Independent confirmation of the guidance-gap claim against a Division of Banking primary source would materially change the confidence with which this picture can be stated. Judgment: Wyoming's new state money-laundering statute covers money-transmitter conduct, which may include crypto-adjacent activity, layering a state criminal backstop onto the existing virtual-currency exemption. Probable #### Compliance Technology and Active Defence Wyomings Division of Banking has partnered with Chainalysis for ongoing supervisory monitoring of money-laundering and illicit digital-asset activity across the states Special Purpose Depository Institution charter regime. This positions Wyomings crypto-bank supervisory architecture as RegTech-forward relative to peer US states, and it sits alongside this cycles other D6-relevant finding: two Wyoming state-government primary sources - the Secretary of States FinCEN-related page and the Wyoming Division of Bankings own site - were not incorporated into the baseline research this cycle despite being independently retrievable, a gap that should be closed in subsequent cycles through direct citation of these state primary sources. Continue reading The RegTech partnership finding requires a specific and deliberate framing discipline. No documented enforcement action or illicit-flow finding attaches directly to the Chainalysis partnership itself at this stage. The correct register, per FIM methodology, is to treat the partnerships existence as a MONITORED-severity signal reflecting supervisory technology adoption, rather than to inflate it into a finding of either demonstrated effectiveness or theoretical vulnerability. The same crypto-bank architecture that the partnership monitors - SPDI charters, DAO-LLC, FRNT - is separately documented (under D5) as expanding the surface for crypto-native illicit-finance typologies even as federal AML and sanctions-screening rules are only now catching up; the Chainalysis partnership is best read as the states own acknowledgment of that expanding surface rather than evidence that the surface has been secured. #### Outlook The most immediate actionable item for this domain is procedural rather than substantive: prioritizing direct citation of the Wyoming Secretary of State and Wyoming Division of Banking primary sources in the next research cycle, since both are independently verified as retrievable and their absence from the current baseline is a research-completeness gap rather than a reflection of their non-existence. Substantively, this domains trajectory is assessed as watch rather than worsening or improving - the RegTech partnership is a genuine supervisory development, but its practical effectiveness against the specific illicit-finance nexus documented elsewhere in this cycle (D1, D5) has not yet been demonstrated one way or the other. Judgment: No RegTech/compliance-technology development specific to US-WY found this cycle. Uncertain #### AML/CTF Regime Wyoming's AML/CTF regime-of-record gained a structural addition this period: House Bill 43 (26LSO-0146) took effect July 1, 2026, creating W.S. 6-3-1101 through 6-3-1103, a standalone state felony offense for money laundering and illegal investment. This is architecturally significant because it is independent of the federal Bank Secrecy Act and FinCEN framework that had previously been the sole basis for AML exposure applicable to Wyoming's gambling and money-transmission sectors. The statute's definition of a covered financial or business institution expressly names casinos and money transmitters, and a violation carries imprisonment of up to ten years and a fine. Continue reading The structural read here is that Wyoming has moved from a single-layer (federal-only) AML enforcement architecture to a dual federal-and-state one for two sectors specifically named in the statute. This is the kind of regime change that matters more than any single enforcement action: it creates an independent state prosecutorial tool where none existed before, applicable regardless of whether federal authorities choose to act in a given case. The enrolled chapter text and final penalty schedule have not yet been independently re-verified against the enacted act — only the introduced-bill text was available this period — so the precise final statutory language remains to be confirmed against the Secretary of State's enrolled-bill record. #### Outlook Confirming the enrolled text and final penalty schedule against the primary enacted-act record is the immediate verification task. Beyond that, how Wyoming's Division of Banking and Attorney General choose to use this new tool in practice — whether as a backstop invoked alongside federal referrals or as an independent state prosecutorial avenue — will determine the statute's practical significance beyond its structural novelty. Judgment: Wyoming's AML/CTF regime-as-record now includes a state felony money-laundering statute expressly naming casinos and money transmitters, layered onto the federal BSA/FinCEN baseline administered through the Division of Banking. Probable #### Commercial Activity Custodia Bank, a Wyoming-chartered special-purpose depository institution, continues to pursue commercial arrangements involving tokenized-deposit payment automation and a deposit-stablecoin-switching token product, reported in connection with partners including Vantage Bank and Hazel Network, in the context of its narrowed direct Federal Reserve payment-access options following the Tenth Circuit's denial of its rehearing petition (reported mid-March 2026). These commercial developments are reported but rest mostly on a single aggregator-level source rather than a primary company announcement, so the detail of what these products actually involve and their commercial scale should be treated as uncertain rather than confirmed. The underlying litigation posture, by contrast, is better corroborated: the Tenth Circuit's denial of rehearing is reported by trade and legal press and represents a structural narrowing of Custodia's access to the federal payment system, which is the commercial driver behind its pursuit of alternative correspondent and "skinny" master-account arrangements referenced in connection with other institutions. Continue reading #### Outlook A primary company announcement or regulatory filing describing the actual terms of Custodia's tokenized-deposit and stablecoin-switching arrangements would materially improve confidence in this finding; until one is located, this commercial activity should be read as an uncertain but watch-worthy development rather than a confirmed commercial fact. Judgment: No US-WY-specific financial-integrity-vendor commercial activity found this cycle. Uncertain Regulatory horizon Consultation 2027-Q1 · ±half_year ### Proposed Wyoming Digital Asset Authority Consolidation of stable-token and digital-asset governance functions into a single statutory body, alongside review of open-banking frameworks and virtual-currency-kiosk rules under HB0075 (2026). [Wyoming Legislature — Select Committee on Blockchain, Financial Technology and Digital Innovation Technology Source](https://www.wyoleg.gov/Committees/2026/S19) Consultation 2027-Q1 · ±year ### Model Money Transmission Modernization Act (27LSO-0137) Repeal and replacement of the Wyoming Money Transmitters Act with a comprehensive multistate-recognition licensing framework. [Wyoming Legislature / Select Committee on Blockchain, Financial Technology and Digital Innovation Technology Source](https://wyoleg.gov/InterimCommittee/2026/S19-2026092827LSO-0137v0.4.pdf) Consultation 2027-Q2 · ±year ### FinCEN/OFAC Permitted Payment Stablecoin Issuer AML/CFT and Sanctions Compliance NPRM PPSIs treated as BSA financial institutions and required to maintain sanctions compliance programs; final rules effective 12 months after issuance. [Source](https://www.federalregister.gov/documents/2026/04/10/2026-06963/permitted-payment-stablecoin-issuer-anti-money-launderingcountering-the-financing-of-terrorism) 3 dated · 4 pending date · baseline financial-integrity-2026-07-05 Role action cards MLRO ### Wyoming created a standalone state felony money-laundering offense reaching casinos and money transmitters, effective July 1, 2026. MLROs for entities operating in Wyoming now face dual federal-and-state AML exposure rather than federal-only exposure. An unresolved guidance gap on the fiat/crypto money-transmitter exemption boundary, reported at limited confidence, adds uncertainty for firms whose activity spans both categories. 2 evidence refs Compliance ### A new Wyoming state felony AML statute and an unresolved crypto money-transmitter guidance gap both touch firms' compliance posture in the state. Compliance functions should note that Wyoming's AML compliance surface now includes an independent state criminal statute alongside the federal BSA baseline, and that the Division of Banking's position on the mixed fiat/crypto exemption boundary remains, per limited sourcing, unclarified. 2 evidence refs Legal ### Wyoming's HB0043 creates an independent state prosecutorial avenue for money laundering, distinct from federal BSA enforcement. Legal counsel advising Wyoming-licensed casinos or money transmitters should treat the new state felony statute as a standing exposure independent of any federal enforcement decision, and should track confirmation of the enrolled statutory text and penalty schedule against the enacted act. 1 evidence refs Board ### Wyoming's gambling and money-transmission sectors now carry dual federal-and-state criminal AML exposure. This is a structural, durable legislative change rather than an isolated enforcement event, and should be reflected in board-level risk assessment for any Wyoming-domiciled gambling or payments subsidiary. 1 evidence refs CTO ### Wyoming's money-laundering statute reaches money-transmitter conduct, a category that may include crypto-adjacent technical infrastructure. Technology functions supporting crypto-adjacent money-transmission activity in Wyoming should be aware the state's felony money-laundering statute applies to money transmitters generally, at the same time the licensing boundary for virtual-currency activity contains, per limited sourcing, an unresolved regulatory guidance gap. 2 evidence refs Risk ### A state-level AML felony backstop layered onto an unresolved crypto money-transmitter guidance gap raises Wyoming's structural risk profile for crypto-adjacent payment flows. Risk functions should treat Wyoming as a mixed enablement/enforcement jurisdiction: historically permissive crypto money-transmission licensing now sits alongside a materially strengthened state criminal AML backstop, with an unresolved compliance boundary question reported at limited confidence. 2 evidence refs Operations ### No material change for this persona this cycle. No material change for this persona this cycle Audit ### The enrolled text and final penalty schedule of Wyoming's new AML felony statute have not yet been independently verified against the enacted act. Internal audit should flag that current reporting on HB0043 relies on introduced-bill text rather than the enrolled, enacted statute, and should prioritize confirming the final language and penalty schedule against the Wyoming Secretary of State's record. 1 evidence refs Scenario sketches ### Dual-architecture enforcement escalation in state AML backstops Illustrative only: a state adopting a standalone felony money-laundering statute alongside an existing federal BSA/FinCEN regime could, over time, see state prosecutors use the new tool as a faster or lower-threshold avenue against gambling or money-transmission entities than a federal referral would permit, particularly where virtual-currency-adjacent conduct sits in a licensing exemption with an unresolved guidance boundary. This is an illustrative structural mechanism, not an observed prosecutorial pattern or a prediction of Wyoming's actual enforcement trajectory. Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact. ### EU AML Package / AMLA supervisory transition — illustrative structural orientation Illustrative only: the shift from purely national AML supervision toward AMLA direct and indirect supervision of cross-border obliged entities under the AMLA Regulation (Reg (EU) 2024/1620), alongside the directly-applicable AML Regulation (Reg (EU) 2024/1624) and per-member-state transposition of the sixth AML Directive, could reshape how supervisory gaps and evasion patterns are identified across the EU's internal market, shifting some detection capacity from national authorities toward a hybrid EU-level regime. This is architecture-over-incident framing for analytical orientation; it is not a prediction of any specific enforcement outcome and not a statement of observed fact for this cycle. 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 Not applicable at the US-WY subnational level. T3 · FATF Grey List no_change US is not grey-listed; no change at subnational level. T4 · Beneficial-Ownership Register Status no_change No Wyoming-specific BO registry development found this cycle. T5 · Crypto & Digital-Asset Integrity watch HB0043 money-laundering statute explicitly covers money-transmitter conduct, layering a state criminal backstop onto the virtual-currency money-transmitter exemption. T6 · Sanctions Regime Divergence no_change No US-WY-specific sanctions-divergence signal found this cycle. Registers ### Enforcement actions - 24 Feb 2025 - 26 Mar 2025 - 8 Jul 2025 - 12 Mar 2026 - 13 Oct 2026 - Wyoming signed into law (Feb 24, 2025) a bill streamlining the Secretary of State's authority to dissolve companies submitting false formation records or linked to foreign adversaries, following a 2024 dissolution of three shell entities at a Sheridan registered-agent address named in an FBI North Korea sanctions-evasion affidavit. 24 Feb 2025 - FinCEN issued an interim final rule (published March 26, 2025) redefining 'reporting company' to cover only foreign entities, formally exempting all US-formed entities and their beneficial owners — including Wyoming LLCs and trusts — from CTA beneficial ownership reporting to FinCEN. 26 Mar 2025 - OFAC designated a DPRK cyber actor and a Russia-based DPRK IT-worker network for orchestrating a fraudulent remote-employment scheme funneling wages into DPRK weapons programs; the parallel DOJ civil forfeiture action (June 5, 2025) targeted over $7.7 million in crypto/NFTs tied to the same laundering network, which US shell-entity investigations (including Wyoming) have documented. 8 Jul 2025 - OFAC designated a further six individuals and two entities for operating DPRK IT-worker fraud schemes generating close to $800 million in 2024 for DPRK's WMD and ballistic missile programs, converting proceeds through mainstream exchanges, DeFi services and cross-chain bridges across Vietnam, Laos and Spain. 12 Mar 2026 ### Sanctions changes - 8 Jul 2025 - 12 Mar 2026 - 29 Sep 2026 - 1 Oct 2026 - 8 Oct 2026 - 13 Oct 2026 - 15 Oct 2026 - OFAC added Song Kum Hyok and four Russia-based entities to the SDN List for facilitating DPRK IT-worker fraud and cryptocurrency laundering supporting DPRK weapons programs, building on a 2023 designation wave (Sim Hyon Sop, Wu Huihui, Cheng Hung Man) targeting the same laundering ecosystem. 8 Jul 2025 - OFAC designated six individuals and two entities on March 12, 2026 for DPRK IT-worker fraud schemes generating close to $800 million in 2024, expanding the sanctioned-address set across multiple blockchain networks reflecting DPRK's multi-chain laundering approach. 12 Mar 2026 ### Regulatory horizon (register) - US Treasury 2026 National ML/TF/PF Risk Assessments - UK ECCTA 2023 failure-to-prevent-fraud offence full first enforceable year - FinCEN/OFAC Permitted Payment Stablecoin Issuer AML/CFT and Sanctions Compliance NPRM - US Treasury 2026 National ML/TF/PF Risk Assessments - Proposed Wyoming Digital Asset Authority - Wyoming Digital Asset Authority (27LSO-0010 v0.9) - Model Money Transmission Modernization Act (27LSO-0137) - AMLA first selection round for direct supervision of up to 40 obliged entities - Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 -- mandatory SDN designation deadline - Wyoming money-laundering felony statute (HB0043) full implementation - GENIUS Act federal stablecoin framework full implementation - FinCEN/OFAC joint stablecoin illicit-finance risk rulemaking - Wyoming legislature: further registered-agent/corporate-registration reform bills - FinCEN third CTA rulemaking: customer due diligence rule revision ### Active schemes - The Cowboy Cocktail LLC-Trust Secrecy Layering - Wyoming Registered-Agent Mill Exploited for Fraud/Sanctions Evasion - DPRK IT-Worker Crypto Laundering via US Shell-Entity Nexus - Wyoming Crypto-Bank/Stablecoin Architecture (SPDI, DAO-LLC, FRNT) Sources - [Financial Institution Definition | FinCEN.gov](https://www.fincen.gov/financial-institution-definition) - [https://wyoleg.gov/2026/Introduced/HB0043.pdf](https://wyoleg.gov/2026/Introduced/HB0043.pdf) - [https://www.kioskmarketplace.com/news/wyoming-passes-crypto-kiosk-legislation/](https://www.kioskmarketplace.com/news/wyoming-passes-crypto-kiosk-legislation/) - [https://governor.wyo.gov/news-releases/wyoming-ushers-in-new-era-launches-first-of-its-kind-frontier-stable-token-for-public-purchase](https://governor.wyo.gov/news-releases/wyoming-ushers-in-new-era-launches-first-of-its-kind-frontier-stable-token-for-public-purchase) - [https://www.cryptotimes.io/2026/05/30/custodia-bank-takes-crypto-banking-fight-against-fed-to-supreme-court/](https://www.cryptotimes.io/2026/05/30/custodia-bank-takes-crypto-banking-fight-against-fed-to-supreme-court/) - [https://www.federalregister.gov/documents/2026/04/10/2026-06963/permitted-payment-stablecoin-issuer-anti-money-launderingcountering-the-financing-of-terrorism](https://www.federalregister.gov/documents/2026/04/10/2026-06963/permitted-payment-stablecoin-issuer-anti-money-launderingcountering-the-financing-of-terrorism) - [https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [Wyoming Legislature](https://wyoleg.gov/2026/Introduced/HB0043.pdf) - [LegiScan](https://legiscan.com/WY/rollcall/HB0043/id/1656021) - [Gillette News Record](https://www.gillettenewsrecord.com/news/local/article_4ea4be35-1b3a-4aca-af56-d52dfa32fa2b.html) - [Kiosk Marketplace](https://www.kioskmarketplace.com/news/wyoming-passes-crypto-kiosk-legislation/) - [FinCEN](https://www.fincen.gov/system/files/2025-08/FinCEN-Notice-CVCKIOSK.pdf) - [Office of the Governor of Wyoming](https://governor.wyo.gov/news-releases/wyoming-ushers-in-new-era-launches-first-of-its-kind-frontier-stable-token-for-public-purchase) - [CryptoTimes](https://www.cryptotimes.io/2026/05/30/custodia-bank-takes-crypto-banking-fight-against-fed-to-supreme-court/) - [CoinDesk](https://www.coindesk.com/policy/2026/03/13/court-closes-custodia-fight-with-federal-reserve-just-as-fed-opens-master-account-door) - [FATF](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [Federal Register / FinCEN / OFAC](https://www.federalregister.gov/documents/2026/04/10/2026-06963/permitted-payment-stablecoin-issuer-anti-money-launderingcountering-the-financing-of-terrorism) - [https://wyoleg.gov/2026/Enroll/HB0043.pdf](https://wyoleg.gov/2026/Enroll/HB0043.pdf) - [https://cryptoslate.com/crypto-laws/wyoming-special-purpose-depository-institutions-act/](https://cryptoslate.com/crypto-laws/wyoming-special-purpose-depository-institutions-act/) - [https://www.wyoleg.gov/Committees/2026/S19](https://www.wyoleg.gov/Committees/2026/S19) - [https://wyomingbankingdivision.wyo.gov/banks-and-trust-companies/special-purpose-depository-institutions](https://wyomingbankingdivision.wyo.gov/banks-and-trust-companies/special-purpose-depository-institutions) - [FF News](https://ffnews.com/news/new-york-state-department-of-financial-services-and-wyoming-division-of-banking--06be73fc) - [Wyoming Legislature](https://wyoleg.gov/Calendar/20260920/Meeting?type=committee&id=15164) - [OFAC](https://ofac.treasury.gov/recent-actions/20260929) - [Braumiller Law Group](https://www.braumillerlaw.com/wyoming-laws-more-crypto-friendly-with-issuance-of-state-stablecoin/) - [Wyoming Legislature (wyoleg.gov)](https://wyoleg.gov/2026/Enroll/HB0043.pdf) - [Wyoming Legislature (wyoleg.gov)](https://wyoleg.gov/2025/Enroll/HB0069.pdf) - [FingerLakes1 (staff report)](https://www.fingerlakes1.com/2026/10/01/new-york-wyoming-regulators-agree-to-coordinate-digital-asset-oversight/) - [Banking Dive](https://www.bankingdive.com/news/custodia-fed-master-account-rehearing-denied-petition-supreme-court-skinny-kraken/815086/) - [LeadIQ (aggregator)](https://leadiq.com/c/custodia-bank/5e6f5bb91d6f06b38205e9a0) - [https://wyoleg.gov/2025/Enroll/SF0095.pdf](https://wyoleg.gov/2025/Enroll/SF0095.pdf) - [https://www.billtrack50.com/billdetail/1767597](https://www.billtrack50.com/billdetail/1767597) - [https://citizenportal.ai/articles/5975309/Wyoming/Wyoming-committee-advances-amendments-to-specialpurpose-depository-and-state-bank-conversion-rules](https://citizenportal.ai/articles/5975309/Wyoming/Wyoming-committee-advances-amendments-to-specialpurpose-depository-and-state-bank-conversion-rules) - [https://ofac.treasury.gov/recent-actions/sanctions-list-updates](https://ofac.treasury.gov/recent-actions/sanctions-list-updates) - [https://ofac.treasury.gov/sanctions-programs-and-country-information](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [https://www.steptoe.com/en/news-publications/international-compliance-blog/weekly-sanctions-update-october-13-2026.html](https://www.steptoe.com/en/news-publications/international-compliance-blog/weekly-sanctions-update-october-13-2026.html) - [https://www.amla.europa.eu/news-media/news-articles_bg](https://www.amla.europa.eu/news-media/news-articles_bg) - [https://complyadvantage.com/insights/fatf-plenary-june-2026-outcomes/](https://complyadvantage.com/insights/fatf-plenary-june-2026-outcomes/) - [https://asgam.com/2026/09/07/cambodian-gaming-regulator-preparing-new-casino-license-renewal-framework-to-strengthen-sector/](https://asgam.com/2026/09/07/cambodian-gaming-regulator-preparing-new-casino-license-renewal-framework-to-strengthen-sector/) - [https://www.fincen.gov/system/files/2026-06/FinCEN-Alert-Fiscal-Fuel-Theft.pdf](https://www.fincen.gov/system/files/2026-06/FinCEN-Alert-Fiscal-Fuel-Theft.pdf) - [https://www.fincen.gov/news/news-releases/fincen-reissues-order-requiring-transparency-msbs-along-southwest-border](https://www.fincen.gov/news/news-releases/fincen-reissues-order-requiring-transparency-msbs-along-southwest-border) - [https://home.treasury.gov/news/press-releases/sb0367](https://home.treasury.gov/news/press-releases/sb0367) - [Faisal Khan LLC](https://faisalkhan.com/solutions/licensing/money-transmitter-license/wyoming-money-transmitter-license) - [Enforcement Actions | FinCEN.gov](https://www.fincen.gov/news/enforcement-actions) - [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) - [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) - [United States Department of the Treasury Financial Crimes Enforcement Network - Home | FinCEN.gov](https://www.fincen.gov/) - [News | FinCEN.gov](https://www.fincen.gov/news) - [Fincen](https://www.fincen.gov/news_room/rp/files/SAR01/Added_Value_Spreadsheets/BSAR-MSB/BSAR-MSB_County/WY_CountyResultsbyForm.xls) - [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) - [FinCEN Consent Order Imposing Civil Money Penalty](https://www.fincen.gov/sites/default/files/enforcement_action/2025-02-06/FinCEN-Brinks-FINALv508.pdf) - [Press Releases | FinCEN.gov](https://www.fincen.gov/news/press-releases) - [FinCEN Exchange | FinCEN.gov](https://www.fincen.gov/resources/fincen-exchange) - [Flash TRM Talks: The Wyoming DAO Law | TRM Blog](https://trmlabs.com/post/flash-trm-talk-the-wyoming-dao-law) - [Banking & Digital Assets: A Conversation with Wyoming Commissioner Albert Forkner](https://go.chainalysis.com/links-virtual-banking-and-digital-assets.html) - [Wyoming Partners with Chainalysis to Combat Money Laundering and Illicit Digital Asset Activity - Chainalysis](https://blog.chainalysis.com/reports/wyoming-division-of-banking-partnership-announcement) - [Cowboys and Crypto](https://www.trmlabs.com/trm-talks/cowboys-and-crypto) - [CRYPTO LEGAL LLC personal appointments - Find and update company information - GOV.UK](https://find-and-update.company-information.service.gov.uk/officers/NIfBjzJ0pudCdhKZkwAqJ8EOnUs/appointments) - [Wyoming Becomes the First to Launch a State-Issued Stablecoin - Bloomberg](https://www.bloomberg.com/news/articles/2025-08-19/wyoming-becomes-the-first-to-launch-a-state-issued-stablecoin) - [Wyoming Governor Expects State to Issue Own Stablecoin by July - Bloomberg](https://www.bloomberg.com/news/articles/2025-03-26/wyoming-governor-expects-state-to-issue-own-stablecoin-by-july) - [The Real Cowboys of Crypto: Wyoming Ropes a $1 Stablecoin](https://www.bloomberg.com/news/features/2026-06-16/wyoming-stablecoin-may-become-a-blueprint-or-cautionary-tale-for-other-states) - [Introduction to Decentralized Autonomous Organizations (DAOs) - Chainalysis](https://www.chainalysis.com/blog/introduction-to-decentralized-autonomous-organizations-daos/) - [SARStats Depository Institution](https://www.fincen.gov/fcn/SARStats_Maps/SARStats-Maps-DI.html) - [Millions in Covid relief funds went to shadowy companies registered at a Wyoming storefront that hundreds of thousands of firms used as an address - ICIJ](https://www.icij.org/investigations/pandora-papers/millions-in-covid-relief-funds-went-to-shadowy-companies-at-a-wyoming-storefront-that-hundreds-of-thousands-of-firms-used-as-an-address/) - [With sharp rise in incorporations, Wyoming cements reputation as US secrecy haven - ICIJ](https://www.icij.org/investigations/cyprus-confidential/with-sharp-rise-in-incorporations-wyoming-cements-reputation-as-us-secrecy-haven/) - [Trail of Drug-Linked Planes Leads Back to California Seller – and U.S. Aviation Regulatory ‘Blind Spot’ | OCCRP](https://www.occrp.org/en/project/narcofiles-the-new-criminal-order/trail-of-drug-linked-planes-leads-back-to-california-seller-and-us-aviation-regulatory-blind-spot) - [What Is a Company Formation Agent? | OCCRP](https://www.occrp.org/en/project/29leaks-inside-a-london-company-mill/what-is-a-company-formation-agent) - [The Role of Domestic Shell Companies in Financial Crime ...](https://www.fincen.gov/sites/default/files/shared/LLCAssessment_FINAL.pdf) - [Tax Havens Under Scrutiny | OCCRP](https://www.occrp.org/en/news/tax-havens-under-scrutiny) - [Financial Crimes Enforcement Network The Role of Domestic Shell Companies in](https://www.fincen.gov/system/files/shared/LLCAssessment_FINAL.pdf) - [Solutions to the Problem | OCCRP](https://www.occrp.org/en/project/offshore-crime-inc/solutions-to-the-problem) - [Pandora Papers Reveal Offshore Holdings of Ukrainian President and his Inner Circle | OCCRP](https://www.occrp.org/en/project/the-pandora-papers/pandora-papers-reveal-offshore-holdings-of-ukrainian-president-and-his-inner-circle) - [WISE WYOMING LLC overview - Find and update company information - GOV.UK](https://find-and-update.company-information.service.gov.uk/company/OE028459) - [Watch Why Custodia Bank Is Suing the Federal Reserve - Bloomberg](https://www.bloomberg.com/news/videos/2023-05-24/why-custodia-bank-is-suing-the-federal-reserve-video) - [Custodia Bank Inc - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/1786708D:US) - [Bank Sue Federal Reserve Over Stress Tests, Citing Impact on Capital - Bloomberg](https://www.bloomberg.com/news/articles/2024-12-24/bank-groups-sue-fed-over-stress-tests-citing-impact-on-capital) - [Custodia Bank, Inc. - LEI: 254900GXUYDCZ0V0HH78](https://lei.bloomberg.com/leis/view/254900GXUYDCZ0V0HH78) - [Financial Crimes Enforcement Network](https://www.fincen.gov/system/files/guidance/guidance04262005.pdf) - [CERTIFICATION REGARDING CORRESPONDENT ACCOUNTS FOR FOREIGN BANKS](https://www.fincen.gov/system/files/shared/Certification+Regarding+Correspondent+Accounts+for+Foreign+Banks.pdf) - [FinCEN Announces $140 Million Civil Money Penalty against USAA Federal Savings Bank for Violations of the Bank Secrecy Act | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-announces-140-million-civil-money-penalty-against-usaa-federal-savings) - [1264211D: United States Bankruptcy Court for the District of Wyoming Stock Price Quote - - Bloomberg](https://www.bloomberg.com/quote/1264211D:US) - [Beneficial Ownership Information Reporting | FinCEN.gov](https://www.fincen.gov/boi) - [Frequently Asked Questions | FinCEN.gov](https://www.fincen.gov/boi-faqs) - [Beneficial Ownership Information Reporting Rule Fact Sheet | FinCEN.gov](https://www.fincen.gov/beneficial-ownership-information-reporting-rule-fact-sheet) - [FinCEN Removes Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Persons, Sets New Deadlines for Foreign Companies | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-removes-beneficial-ownership-reporting-requirements-us-companies-and-us) - [Fact Sheet: Beneficial Ownership Information Access and Safeguards Final Rule | FinCEN.gov](https://www.fincen.gov/news/news-releases/fact-sheet-beneficial-ownership-information-access-and-safeguards-final-rule) - [Small Entity Compliance Guide | FinCEN.gov](https://www.fincen.gov/boi/small-entity-compliance-guide) - [Reference Materials | FinCEN.gov](https://www.fincen.gov/boi/Reference-materials) - [Quick Reference | FinCEN.gov](https://www.fincen.gov/boi/quick-reference) - [1 Notice to Customers: Beneficial Ownership Information Reference Guide](https://www.fincen.gov/system/files/shared/BOI-Notice-to-Customers-508FINAL.pdf) - [Financial Crimes Enforcement Network U.S. Department of the Treasury](https://www.fincen.gov/system/files/shared/BOI_Small_Compliance_Guide.v1.1-FINAL.pdf) - [US Treasury Sanctions North Korean Cyber Facilitator Linked to IT Worker Scheme | TRM Labs](https://www.trmlabs.com/resources/blog/us-treasury-sanctions-north-korean-cyber-facilitator-linked-to-it-worker-scheme) - [North Korea Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/north-korea-sanctions) - [US Imposes Sanctions Over North Korean Fraud Targeting US Firms - Bloomberg](https://www.bloomberg.com/news/articles/2026-03-12/us-imposes-sanctions-over-north-korean-fraud-targeting-us-firms) - [OFAC Charged and Sanctioned DPRK Facilitators](https://www.chainalysis.com/blog/ofac-dprk-north-korea-sanctions-april-2023/) - [US Sanctions Target North Korean Fake-Tech-Worker Scheme - Bloomberg](https://www.bloomberg.com/news/articles/2025-07-08/us-sanctions-target-north-korean-fake-tech-worker-scheme) - [Guidance on the Democratic People's Republic of Korea ...](https://ofac.treasury.gov/media/923126/download?inline=) - [North Korea IT Workers: Inside the DPRK’s Crypto Laundering Network](https://www.chainalysis.com/blog/dprk-it-workers-north-korea-crypto-laundering-networks/) - [OFAC Targets DPRK IT Workers Using Crypto](https://www.chainalysis.com/blog/ofac-targets-north-korean-it-workers-crypto-march-2026/) - [Publication of North Korea Information Technology Workers Advisory | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20220516) - [UNCLASSIFIED UNCLASSIFIED May 16, 2022](https://ofac.treasury.gov/system/files/126/20220516_dprk_it_worker_advisory.pdf) - [Wyoming’s Crypto Journey with Wyoming Stable Token Commission Director Anthony Apollo](https://www.trmlabs.com/resources/trm-talks/wyomings-crypto-journey-with-wyoming-stable-token-commission-director-anthony-apollo) - [Wyoming’s Stablecoin Plan Is Latest Crypto Push by Cowboy State - Bloomberg](https://www.bloomberg.com/news/articles/2024-09-18/wyoming-s-stablecoin-plan-is-latest-crypto-push-by-cowboy-state) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [TRM Labs Resources | Crypto Investigations, Compliance, and Policy Insights](https://www.trmlabs.com/resources) - [White House Economists Say Stablecoin Rewards Won’t Harm Banks - Bloomberg](https://www.bloomberg.com/news/articles/2026-04-08/white-house-economists-says-stablecoin-rewards-won-t-harm-banks) - [Federal Register/Vol. 91, No. 69/Friday, April 10, 2026/ ...](https://ofac.treasury.gov/media/935481/download?inline=) - [WY: Weyerhaeuser Co Stock Price Quote - New York - Bloomberg](https://www.bloomberg.com/quote/WY:US) - [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) - [Assessments](https://www.fatf-gafi.org/en/calendars/assessments.html) - [Consolidated assessment ratings](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Assessment-ratings.html) - [The FATF Recommendations](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html) - [United States](https://www.fatf-gafi.org/en/countries/detail/United-States.html) - [Publications](https://www.fatf-gafi.org/en/publications.html) - [Outcomes FATF Plenary, 11-13 February 2026](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-FATF-plenary-february-2026.html) - [The 2022 and 2013 Methodologies for Assessing Technical Compliance with the FATF Recommendations and the Effectiveness of AML/CFT/CPF Systems](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Fatf-methodology.html) - [Outcomes of meetings](https://www.fatf-gafi.org/en/the-fatf/outcomes-of-meetings.html) - [The gatekeepers who help open America to oligarchs and scammers - ICIJ](https://www.icij.org/investigations/pandora-papers/the-gatekeepers-who-help-open-america-to-oligarchs-and-scammers/) - [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/) - [The ‘cowboy cocktail’: How Wyoming became one of the world’s top tax havens - ICIJ](https://www.icij.org/investigations/pandora-papers/the-cowboy-cocktail-how-wyoming-became-one-of-the-worlds-top-tax-havens/) - [US Treasury Department removes ‘escape hatch’ for criminals from beneficial ownership reporting form - ICIJ](https://www.icij.org/investigations/fincen-files/us-treasury-department-removes-escape-hatch-for-criminals-from-beneficial-ownership-reporting-form/) - [FinCEN plans to delete data on U.S. companies from beneficial ownership database - ICIJ](https://www.icij.org/news/2025/09/fincen-plans-to-delete-data-on-u-s-companies-from-beneficial-ownership-database/) - [BOI E-FILING - FinCEN](https://boiefiling.fincen.gov/) - [Resources Search](https://www.trmlabs.com/resources/resources-search) - [Crypto Firm Kraken Acquires Backed Finance in Tokenization Push - Bloomberg](https://www.bloomberg.com/news/articles/2025-12-02/crypto-firm-kraken-acquires-backed-finance-in-tokenization-push) - [Chainalysis Grows Revenue 100% Year Over Year; Prepares for Surge in Private Sector Business - Chainalysis](https://www.chainalysis.com/blog/chainalysis-october-2020-company-update/) - [KRAKEN INVESTMENTS LTD overview - Find and update company information - GOV.UK](https://find-and-update.company-information.service.gov.uk/company/12199459) - [Crypto Exchange Kraken Said to Prepare for IPO in 2026 - Bloomberg](https://www.bloomberg.com/news/articles/2025-03-07/crypto-exchange-kraken-said-to-prepare-for-ipo-in-2026) - [KRAKEN CAPITAL LIMITED overview - Find and update company information - GOV.UK](https://find-and-update.company-information.service.gov.uk/company/11197855) - [KRAKEN FINANCIAL SERVICES LTD overview - Find and update company information - GOV.UK](https://find-and-update.company-information.service.gov.uk/company/12405708) - [Settlement Agreement between the U.S. Department of the Treasury’s Office of Foreign Assets Control and Payward, Inc. ('Kraken') | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20221128) - [KRAKEN ASSOCIATES LTD overview - Find and update company information - GOV.UK](https://find-and-update.company-information.service.gov.uk/company/12104779) - [INTERNATIONAL CORPORATE SECRETARIES LLC personal appointments - Find and update company information - GOV.UK](https://find-and-update.company-information.service.gov.uk/officers/WPOFR41_q0rDH5ZCWBlQHCi3PGU/appointments) - [WYOMING LIMITED overview - Find and update company information - GOV.UK](https://find-and-update.company-information.service.gov.uk/company/03662942) - [20JAMA25, LLC - LEI: 254900K1JQ4RLHBWNG72](https://lei.bloomberg.com/leis/view/254900K1JQ4RLHBWNG72) - [SERVICES WY LIMITED overview - Find and update company information - GOV.UK](https://find-and-update.company-information.service.gov.uk/company/07810595) - [Aveva Capital, LLC - LEI: 254900AUX2TJFA6BAS61](https://lei.bloomberg.com/leis/view/254900AUX2TJFA6BAS61) - [Sunlight Ranch Company - LEI: 549300ELCJO7E3MQLL30](https://lei.bloomberg.com/leis/view/549300ELCJO7E3MQLL30) - [Appendix 3](https://democracy.kirklees.gov.uk/documents/s20285/13c.%20Appendix%203%20-%20TD%20letter%20to%20WY%20authorities.pdf) - [Wyoming Partners with Chainalysis to Combat Money Laundering and Illicit Digital Asset Activity - Chainalysis](https://www.chainalysis.com/blog/wyoming-division-of-banking-partnership-announcement/) - [MEMORANDUM OF UNDERSTANDING](https://ofac.treasury.gov/media/31351/download?inline=) - [STATE CONTACT INFORMATION FOR MSBs](https://www.fincen.gov/system/files/shared/msbstatecontactsfinal.pdf) - [Wyoming National Bank/Riverton WY - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/412872Z:US) - [First National Bank of Wyoming/DE - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/445504Z:US) - [Wyoming Community Development Authority - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/55826MF:US) - [OFAC Consolidated Frequently Asked Questions | Office of Foreign Assets Control](https://ofac.treasury.gov/faqs/all-faqs) - [WyHy Federal Credit Union - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/0428780D:US) - [Important Information for Depository Institutions | FinCEN.gov](https://www.fincen.gov/resources/financial-institutions/depository-institutions) - [Wyoming Office of State Lands & Investments - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/0999913D:US) - [Financial Crimes Enforcement Network 37 U.S. Department of the Treasury](https://www.fincen.gov/system/files/shared/Appendix_A.pdf) - [Financial Institution Definition | FinCEN.gov](https://www.fincen.gov/financial-institution-definition) - [FinCEN (US Treasury)](https://www.fincen.gov/news/news-releases/fincen-removes-beneficial-ownership-reporting-requirements-us-companies-and-us) - [Office of Foreign Assets Control (US Treasury)](https://ofac.treasury.gov/sanctions-programs-and-country-information/north-korea-sanctions) - [Financial Action Task Force](https://www.fatf-gafi.org/en/countries/detail/United-States.html) - [International Consortium of Investigative Journalists (ICIJ)](https://www.icij.org/investigations/cyprus-confidential/with-sharp-rise-in-incorporations-wyoming-cements-reputation-as-us-secrecy-haven/) - [International Consortium of Investigative Journalists (ICIJ)](https://www.icij.org/investigations/pandora-papers/millions-in-covid-relief-funds-went-to-shadowy-companies-at-a-wyoming-storefront-that-hundreds-of-thousands-of-firms-used-as-an-address/) - [Bloomberg](https://www.bloomberg.com/news/articles/2025-08-19/wyoming-becomes-the-first-to-launch-a-state-issued-stablecoin) - [TRM Labs](https://www.trmlabs.com/resources/blog/us-treasury-sanctions-north-korean-cyber-facilitator-linked-to-it-worker-scheme) - [Office of Foreign Assets Control (US Treasury) / Wyoming Division of Banking](https://ofac.treasury.gov/media/31351/download?inline=) - [Chainalysis](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [OCCRP](https://www.occrp.org/en/news/tax-havens-under-scrutiny) Coverage gaps fim-int-2026-07-05-G001: CTA interim final rule's finalizati… fim-int-2026-07-05-G001: CTA interim final rule's finalization status (expected 2026) requires verification; the final rule could reverse, narrow, or confirm the domestic-entity BOI exemption, and current confidence should not be treated as settled law until the final rule publishes. [resolved] fim-int-2026-07-05-G002: Wyoming Secretary of State (sos.wyo… fim-int-2026-07-05-G002: Wyoming Secretary of State (sos.wyo.gov/FinCEN/) and Wyoming Division of Banking (wyomingbankingdivision.wyo.gov) primary sources exist and were not incorporated into the baseline source register; direct citation of these state-government primary sources should be prioritized next cycle. [resolved] fim-int-2026-07-05-G003: FRNT stablecoin launch chronology n… fim-int-2026-07-05-G003: FRNT stablecoin launch chronology needs confirmation via a direct Wyoming Stable Token Commission primary source distinguishing test-issuance dates (August-October 2025) from the public launch date (January 7, 2026). [resolved] fim-int-2026-07-05-G004: No confirmed EU Council or UK OFSI … fim-int-2026-07-05-G004: No confirmed EU Council or UK OFSI parallel designation of the OFAC-listed DPRK IT-worker facilitators has been established; direct verification against EU Council and OFSI consolidated lists would sharpen the T6 sanctions-divergence assessment. [resolved] fim-int-2026-07-05-G005: A precise FinCEN CFR citation for t… fim-int-2026-07-05-G005: A precise FinCEN CFR citation for the March 2025 interim final rule's exemption scope was not captured in the research bundle, limiting precise obligation_refs classification for D2 claims. [resolved] fim-int-2026-07-05-G006: No evidence of documented illicit-f… fim-int-2026-07-05-G006: No evidence of documented illicit-flow activity specific to the SPDI/DAO-LLC/FRNT crypto-bank architecture itself (as distinct from the separate DPRK IT-worker scheme) was established, limiting confidence in the MONITORED severity assignment for that scheme. [resolved] fim-int-2026-08-05-G001: No independent Tier-1 sweep of OFAC… fim-int-2026-08-05-G001: No independent Tier-1 sweep of OFAC/OFSI/UN Panel of Experts conducted this cycle beyond incidental global search. [resolved] fim-int-2026-08-05-G002: No conflict-finance/extractive-indu… fim-int-2026-08-05-G002: No conflict-finance/extractive-industry material surfaced or searched for this cycle. [resolved] fim-int-2026-08-05-G003: No RegTech/compliance-technology-sp… fim-int-2026-08-05-G003: No RegTech/compliance-technology-specific development identified this cycle. [resolved] fim-int-2026-08-05-G004: Tier D jurisdictions (KH, LA, MX, C… fim-int-2026-08-05-G004: Tier D jurisdictions (KH, LA, MX, CO) received only incidental coverage via the global FATF Plenary search; a dedicated corridor sweep is needed next cycle. [resolved] fim-int-2026-08-05-G005: FinCEN/OFAC PPSI NPRM applicability… fim-int-2026-08-05-G005: FinCEN/OFAC PPSI NPRM applicability to state-government-issued stablecoins (e.g., FRNT) remains unresolved; no primary-source clarification located this cycle. [resolved] fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): No Wyoming-specific corporate-transparency or beneficial-ownership registry development was located this cycle (D2); the state's LLC-anonymity profile is a known structural condition not independently re-verified. [resolved] fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): No Tier-1 anchor for the specific SF0055 2026 SPDI amendment text was retrieved this cycle; the Division of Banking's SPDI page did not surface the amendment text directly. [resolved] fim-int-2026-09-28-G003: Tier D jurisdiction watch (KH, LA, … fim-int-2026-09-28-G003: Tier D jurisdiction watch (KH, LA, MX, CO) was not run this cycle because this dispatch is bound to the single jurisdiction US-WY. [resolved] fim-int-2026-10-04-G001: No positive signal was found this c… fim-int-2026-10-04-G001: No positive signal was found this cycle for Cambodia, Laos or Colombia under the Tier D mandatory sweep; pooled web_search budget did not extend to active searches for these jurisdictions. [resolved] fim-int-2026-10-04-G002: Exact content and resolution of 6AM… fim-int-2026-10-04-G002: Exact content and resolution of 6AMLD transposition status is not applicable to US-WY; D2/D6 coverage remained thin this cycle. [resolved] fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): No official WY Division of Banking/NY DFS joint press release or MOU text independently retrieved this cycle; the digital-asset supervisory cooperation agreement rests on a single T3 secondary report. [resolved] fim-int-2026-10-11-G002: Tier D (KH/LA/MX/CO) search was not… fim-int-2026-10-11-G002: Tier D (KH/LA/MX/CO) search was not run this cycle; search budget was allocated to the bound jurisdiction US-WY. [resolved] fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', 'value': 'D8'}): Custodia Bank/Vantage Bank/Hazel Network commercial collaboration detail rests on a single T4 aggregator snippet without a primary company announcement. [resolved] fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): No material global beneficial-ownership (D2) development was surfaced this cycle; coverage was thin. [open] fim-int-2026-10-18-G002: Tier-D watch jurisdictions Laos and… fim-int-2026-10-18-G002: Tier-D watch jurisdictions Laos and Colombia yielded no material from the queries run this cycle. [open] fim-int-2026-10-18-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G003 ({'scheme': 'financial_integrity', 'value': 'D6'}): No compliance-technology/active-defence (D6) development was independently surfaced this cycle. [open] fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): The enrolled chapter text and final penalty schedule of HB0043 were not independently re-verified against the enacted act; only the introduced-bill text was retrieved. [open] fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', 'value': 'D3'}): No Division of Banking primary instrument was located confirming or denying the stated guidance gap on the fiat/crypto money-transmission exemption boundary. [open] fim-int-2026-10-25-G003: D1, D2, D4, D6, D8 carried no US-WY… fim-int-2026-10-25-G003: D1, D2, D4, D6, D8 carried no US-WY-specific material this cycle; Tier-D jurisdiction watch (KH, LA, MX, CO) and global sweeps were not performed given the single-jurisdiction scope of this dispatch. [open] FIM-GAP-001 (D2): FinCEN's March 2025 interim final rule exe… FIM-GAP-001 (D2): FinCEN's March 2025 interim final rule exempts all US domestic entities — including Wyoming LLCs and trusts — from federal beneficial ownership reporting, removing the principal federal backstop against Wyoming's state-level absence of BO disclosure requirements. FinCEN has additionally signaled plans to delete already-collected domestic-company BOI data. FIM-GAP-002 (D3): Wyoming's legislature has repeatedly rejec… FIM-GAP-002 (D3): Wyoming's legislature has repeatedly rejected registered-agent oversight and trust-transparency reforms (2016, 2022, 2023), with the trust-formation lawyer industry and free-speech arguments cited as effective opposition; only a narrow foreign-adversary dissolution-authority bill passed in February 2025, leaving the broader registered-agent licensing gap unaddressed. FIM-GAP-003 (D2): An academic comparative study (Sharman) fo… FIM-GAP-003 (D2): An academic comparative study (Sharman) found Wyoming and Nevada require no certified ID documents to form a company or open an associated bank account — weaker verification than notorious offshore centers such as Bermuda and the Cayman Islands, which impose stricter certified-ID requirements on beneficial owners. FIM-GAP-004 (D6): No direct Wyoming state-government (.gov) … FIM-GAP-004 (D6): No direct Wyoming state-government (.gov) primary URL (e.g., Wyoming Secretary of State business-filings portal or Division of Banking regulatory page) could be independently retrieved via search at baseline; state-specific supervisory detail is sourced via a federal OFAC–Wyoming supervisory MOU and investigative journalism rather than a Wyoming-issued primary document. ## Evidence #### Confidence-tiered claims MOU covering licensing/chartering coordination, joint examinations, and supervisory-report and enforcement-notification sharing for virtual-currency and digital-asset firms operating in both states, signed 2026-10-01. [[Source 1]](#sec-sources) Probable · 1 source Bill draft 27LSO-0138 v0.4 would replace a capped civil-penalty ceiling with uncapped civil money penalties backing the Division of Banking's kiosk-enforcement toolkit established under 2026's HB0075, heard 2026-09-29. [[Source 1]](#sec-sources) Probable · 1 source 21 individuals and 25 entities tied to the Los Mayos faction of the Sinaloa Cartel, including Alfonso Arzate Garcia, targeting fentanyl trafficking, money laundering and an alleged protection network within regional Mexican authorities. [[Source 1]](#sec-sources) Probable · 1 source SDN List update dated 2026-09-29 adding Sinaloa-Cartel-linked individuals, part of a broader cartel-finance/corruption designation action. [[Source 1]](#sec-sources) Probable · 1 source Wyoming's money-transmission AML perimeter continues to run through the federal BSA/FinCEN framework plus the state Money Transmitter Act, which exempts virtual-currency activity from licensure while leaving SPDIs under direct Division of Banking prudential supervision. [[Source 1]](#sec-sources) Probable · 1 source Wyoming creates statutory money laundering and illegal investment offenses at W.S. 6-3-1101 through 6-3-1103, effective July 1, 2026 [[Source 1]](#sec-sources) Probable · 1 source Seven-page MOU (announced Oct 1, 2026) to share information and coordinate licensing, examinations and possible enforcement for virtual-currency/digital-asset businesses operating in either state [[Source 1]](#sec-sources) Probable · 1 source 10th Circuit denied Custodia Bank's petition for rehearing of its suit against the Federal Reserve (decision reported March 16, 2026), narrowing direct Fed payment-system access [[Source 1]](#sec-sources) Probable · 1 source Standing foreign-adversary administrative-dissolution authority (HB0069, effective July 1, 2025) remains unchanged; carried forward [[Source 1]](#sec-sources) Probable · 1 source No special purpose depository institution may commence business until its full authorized capital is subscribed and paid in, and no SPDI may be chartered without a paid-up surplus fund of not less than 20% of its legally authorized capital stock (W.S. 13-12-110, as amended by SF0095). [[Source 1]](#sec-sources) Probable · 1 source W.S. 40-22-104(a)(vi) exempts virtual-currency activity from the Wyoming Money Transmitter Act's licensing requirement, while federal FinCEN BSA registration still formally applies. [[Source 1]](#sec-sources) Probable · 1 source Sectoral determination and approximately 30 designations against Iran's automotive/rail/metals sectors, 17 vessels/companies in Iran's petroleum shadow-fleet network, Cartel del Noreste finance-network designations, and ICC-related sanctions drawing allied public disagreement (Oct 1-15 2026). [[Source 1]](#sec-sources) Probable · 1 source Supplemental alert (FIN-2026-Alert003, June 30, 2026) flagged over $7 billion in suspicious-activity reports tied to cartel fuel smuggling including stablecoin-based payments; GTO reissued Sept 2, 2026 requiring enhanced MSB reporting in designated NM/TX border counties. [[Source 1]](#sec-sources) Probable · 1 source Revoked 20 of 195 licensed casinos and suspended 29 more after investigating links to scam operations (Aug-Sep 2026 reporting); next FATF mutual evaluation scheduled for 2029. [[Source 1]](#sec-sources) Probable · 1 source Wyoming's state-issued stablecoin continues as a non-federal test case running alongside the GENIUS Act's federal stablecoin framework; live since Jan 7, 2026, managed by the Wyoming Stable Token Commission with Franklin Templeton as reserve manager. [[Source 1]](#sec-sources) Probable · 1 source Standalone state money-laundering and illegal-investment felony (W.S. 6-3-1101 - 6-3-1103), in force since 2026-07-01, naming casinos and money transmitters as covered financial or business institutions. [[Source 1]](#sec-sources) Probable · 1 source W.S. 40-22-104(a)(vi) exempts virtual-currency-only activity from state money-transmitter licensure, but W.S. 40-22-103(d) independently requires BSA compliance; a secondary source states the Division of Banking has issued no public guidance on the mixed fiat-and-crypto case. [[Source 1]](#sec-sources) Uncertain · 1 source Wyoming House Bill 43 created standalone state felony offenses for money laundering and illegal investment (W.S. 6-3-1101 through 1103), effective 2026-07-01. [[Source 1]](#sec-sources) Probable · 1 source On Oct 1, 2026 NYDFS and Wyoming's Division of Banking signed a MOU coordinating licensing, examination and information-sharing for virtual-currency/digital-asset entities operating in both states; no common authorization created. [[Source 1]](#sec-sources) Probable · 1 source House Bill 75 brought virtual-currency kiosk operators within the Wyoming Money Transmitters Act licensing perimeter. [[Source 1]](#sec-sources) Probable · 1 source