Financial Integrity Monitor
Sign in

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 — Indiana US-IN

Domains covered
7 of 8
Sources
160
Role actions
8
Horizon <90d
0
Jurisdiction profile
FATF status: Compliant Tier: A Risk direction: Increasing Enablement vs enforcement: Mixed

Indiana operates under the federal Bank Secrecy Act/AML framework administered by FinCEN and OFAC, supplemented by state money-transmitter licensing under the Indiana Uniform Money Services Act (Indiana Department of Financial Institutions).

MoreSince March 2025, domestically-formed Indiana entities are exempt from federal beneficial ownership reporting, and no Indiana-specific virtual-currency-kiosk consumer-protection statute has been confirmed, leaving state-level AML/CFT capacity thin relative to federal architecture.

Key deficiencies
  • Federal Corporate Transparency Act domestic-reporting-company exemption removes beneficial ownership visibility for Indiana-formed LLCs and corporations
  • No confirmed Indiana-specific crypto-ATM/kiosk consumer-protection statute despite Indiana being a documented Bitcoin Depot/Circle K scam-transmission site
  • Residential real estate and legal/title professional gatekeepers remain largely outside BSA compliance-program obligations nationally, a vulnerability that applies fully to Indiana's cash-purchase real estate market
Recent developments (18m)
  • FinCEN interim final rule (March 21/26, 2025) exempted all US-formed 'domestic reporting companies' -- including Indiana entities -- from Corporate Transparency Act beneficial ownership reporting
  • FinCEN issued FIN-2025-NTC1 Notice (August 4, 2025) on convertible virtual currency kiosk scam typologies, directly relevant given documented Indiana Circle K/Bitcoin Depot kiosk scam cases
  • ICIJ/CNN 'Coin Laundry' investigation (December 2025) named an Indiana Circle K location as a site where a scam victim deposited funds into a Bitcoin Depot kiosk
  • FinCEN issued AML/CFT Program NPRM (April 2026) and joint FinCEN/OFAC GENIUS Act stablecoin AML/CFT NPRM (April 2026), both applicable nationwide including to Indiana-chartered/licensed institutions
  • Bitcoin Depot -- operator of kiosks inside Indiana Circle K stores -- filed for bankruptcy (May 2026) amid multi-state AG lawsuits and a Connecticut banking-license suspension

United States federal law that applies in United States – Indiana is covered once, on the United States page. This page covers United States – Indiana’s own layer: its own law, regulators and enforcement.

Brief

Lead signal

Lead Signal

The defining development touching Indiana this cycle sits at the federal layer rather than the state one. FinCEN finalised a rule, effective 14 August 2026, that permanently exempts United States-formed entities and United States persons from Corporate Transparency Act beneficial-ownership reporting; only foreign reporting companies remain obligated going forward, and beneficial-ownership information previously filed by domestic persons is to be deleted. Indiana maintains no separate state-level beneficial-ownership registry, so the federal exemption is dispositive for the jurisdiction: there is no residual state reporting layer behind which domestic corporate-transparency obligations could otherwise persist. For a state whose corporate registry has never required beneficial-ownership disclosure independent of the federal regime, the practical effect of the Corporate Transparency Act in Indiana now narrows to foreign reporting companies only.

Read full brief

Lead Signal

The defining development touching Indiana this cycle sits at the federal layer rather than the state one. FinCEN finalised a rule, effective 14 August 2026, that permanently exempts United States-formed entities and United States persons from Corporate Transparency Act beneficial-ownership reporting; only foreign reporting companies remain obligated going forward, and beneficial-ownership information previously filed by domestic persons is to be deleted. Indiana maintains no separate state-level beneficial-ownership registry, so the federal exemption is dispositive for the jurisdiction: there is no residual state reporting layer behind which domestic corporate-transparency obligations could otherwise persist. For a state whose corporate registry has never required beneficial-ownership disclosure independent of the federal regime, the practical effect of the Corporate Transparency Act in Indiana now narrows to foreign reporting companies only.

A second, lower-confidence but structurally relevant signal concerns the scope of Indianas own money-transmission licensing regime. Indianas Money Transmission Modernization Act, codified at IC 28-8-4.1, excludes pure virtual-currency exchange, custody, or transmission from licensable money-transmission activity where no fiat money transmission is also present. The Indiana Department of Financial Institutions does not license or regulate the holding, transmittal, or exchange of cryptocurrency as such. This is a jurisdiction-level variance against the more common pattern among US states of licensing crypto exchanges as money transmitters, and it narrows the state-level AML perimeter for crypto activity in Indiana specifically, even though federal Bank Secrecy Act and FinCEN money-services-business registration continue to apply regardless of state licensing status.

Other Developments

Virtual-currency kiosk prohibition remains the standing state posture. Indiana enacted HB1116, signed 9 March 2026 and effective immediately, banning virtual-currency kiosks statewide, with enforcement framed under the states deceptive-sales-act authority and administered by the Attorney General. Approximately 900 kiosks were reported as affected. This predates the current collection window but continues to define Indianas state-level approach to consumer-facing crypto infrastructure, and it sits alongside the MTL exclusion as a second strand of the states crypto posture: Indiana declines to bring pure virtual-currency transmission within its money-transmitter licensing net, while simultaneously prohibiting a specific retail-facing crypto access channel it judges to carry elevated consumer-harm risk.

Securities enforcement against a crypto-interest platform continues active state engagement. The Indiana Secretary of States Securities Division reached a settlement with TradeStation Crypto, Inc. requiring cessation of an unregistered crypto interest-earning program that had been offered, sold, or renewed to Indiana investors, with a payment of $29,411.76. The exact settlement date could not be confirmed from available secondary reporting this cycle. The action is consistent with the states demonstrated pattern of pursuing unregistered crypto-investment products through securities law rather than through money-transmission or banking channels, reinforcing that Indianas crypto-integrity enforcement runs primarily through its Securities Division rather than its Department of Financial Institutions.

Cross-Monitor Connections

The narrowing of Indianas money-transmission perimeter for pure virtual-currency activity is a structural finding with relevance beyond financial-integrity reporting alone: it illustrates how a sub-national US jurisdiction can hold a materially different AML/CTF-relevant supervisory footprint from its peer states while remaining fully subject to the uniform federal Bank Secrecy Act layer. This divergence between state licensing scope and federal registration obligation is the kind of architecture-over-incident signal that other monitors tracking US state-level financial regulation would want visibility into, since a firm operating a pure virtual-currency business in Indiana faces a different state compliance posture than the same firm would face in a state that licenses crypto exchanges as money transmitters, even though both remain FinCEN money-services-business registrants. The Corporate Transparency Act domestic exemption is likewise a federal-level development whose consequences propagate uniformly to every US state including Indiana, and it is best read as removing a reporting layer rather than adding one, with no corresponding state-level backfill expected in Indiana given the absence of a state beneficial-ownership registry.

Outlook

The Corporate Transparency Act domestic-entity exemption, now in force since 14 August 2026, is likely to remain the governing beneficial-ownership position in Indiana absent a state-level registry initiative, which has not been signalled. Indianas money-transmission exclusion for pure virtual-currency activity similarly appears settled rather than transitional, resting on the existing statutory text of IC 28-8-4.1 rather than on any pending amendment identified this cycle. The states enforcement posture toward crypto-adjacent consumer harm, evidenced by the kiosk prohibition and the TradeStation Crypto settlement, is probable to continue operating through securities and consumer-protection channels rather than through an expansion of money-transmission licensing, as scheduled under the current statutory architecture. Coverage of sanctions, enabler-jurisdiction, conflict-finance, and compliance-technology domains was not actively pursued for this sub-national jurisdiction this cycle, and no inference should be drawn from that absence about the substantive state of those domains in Indiana.

Earlier periodic briefs (4)
25 Oct 2026 · fim-2026-10-25

Lead Signal

The defining development touching Indiana sits at the federal layer rather than the state one. FinCEN finalised a rule, effective 14 August 2026, that permanently exempts United States-formed entities and United States persons from Corporate Transparency Act beneficial-ownership reporting; only foreign reporting companies remain obligated going forward, and beneficial-ownership information previously filed by domestic persons is to be deleted. Indiana maintains no separate state-level beneficial-ownership registry, so the federal exemption is dispositive for the jurisdiction: there is no residual state reporting layer behind which domestic corporate-transparency obligations could otherwise persist. For a state whose corporate registry has never required beneficial-ownership disclosure independent of the federal regime, the practical effect of the Corporate Transparency Act in Indiana now narrows to foreign reporting companies only.

A second, lower-confidence but structurally relevant signal concerns the scope of Indianas own money-transmission licensing regime. Indianas Money Transmission Modernization Act, codified at IC 28-8-4.1, excludes pure virtual-currency exchange, custody, or transmission from licensable money-transmission activity where no fiat money transmission is also present. The Indiana Department of Financial Institutions does not license or regulate the holding, transmittal, or exchange of cryptocurrency as such. This is a jurisdiction-level variance against the more common pattern among US states of licensing crypto exchanges as money transmitters, and it narrows the state-level AML perimeter for crypto activity in Indiana specifically, even though federal Bank Secrecy Act and FinCEN money-services-business registration continue to apply regardless of state licensing status.

Other Developments

Virtual-currency kiosk prohibition remains the standing state posture. Indiana enacted HB1116, signed 9 March 2026 and effective immediately, banning virtual-currency kiosks statewide, with enforcement framed under the states deceptive-sales-act authority and administered by the Attorney General. Approximately 900 kiosks were reported as affected. This predates the current collection window but continues to define Indianas state-level approach to consumer-facing crypto infrastructure, and it sits alongside the MTL exclusion as a second strand of the states crypto posture: Indiana declines to bring pure virtual-currency transmission within its money-transmitter licensing net, while simultaneously prohibiting a specific retail-facing crypto access channel it judges to carry elevated consumer-harm risk.

Securities enforcement against a crypto-interest platform continues active state engagement. The Indiana Secretary of States Securities Division reached a settlement with TradeStation Crypto, Inc. requiring cessation of an unregistered crypto interest-earning program that had been offered, sold, or renewed to Indiana investors, with a payment of $29,411.76. The exact settlement date could not be confirmed from available secondary reporting. The action is consistent with the states demonstrated pattern of pursuing unregistered crypto-investment products through securities law rather than through money-transmission or banking channels, reinforcing that Indianas crypto-integrity enforcement runs primarily through its Securities Division rather than its Department of Financial Institutions.

Cross-Monitor Connections

The narrowing of Indianas money-transmission perimeter for pure virtual-currency activity is a structural finding with relevance beyond financial-integrity reporting alone: it illustrates how a sub-national US jurisdiction can hold a materially different AML/CTF-relevant supervisory footprint from its peer states while remaining fully subject to the uniform federal Bank Secrecy Act layer. This divergence between state licensing scope and federal registration obligation is the kind of architecture-over-incident signal that other monitors tracking US state-level financial regulation would want visibility into, since a firm operating a pure virtual-currency business in Indiana faces a different state compliance posture than the same firm would face in a state that licenses crypto exchanges as money transmitters, even though both remain FinCEN money-services-business registrants. The Corporate Transparency Act domestic exemption is likewise a federal-level development whose consequences propagate uniformly to every US state including Indiana, and it is best read as removing a reporting layer rather than adding one, with no corresponding state-level backfill expected in Indiana given the absence of a state beneficial-ownership registry.

Outlook

The Corporate Transparency Act domestic-entity exemption, now in force since 14 August 2026, is likely to remain the governing beneficial-ownership position in Indiana absent a state-level registry initiative, which has not been signalled. Indianas money-transmission exclusion for pure virtual-currency activity similarly appears settled rather than transitional, resting on the existing statutory text of IC 28-8-4.1 rather than on any pending amendment identified. The states enforcement posture toward crypto-adjacent consumer harm, evidenced by the kiosk prohibition and the TradeStation Crypto settlement, is probable to continue operating through securities and consumer-protection channels rather than through an expansion of money-transmission licensing, as scheduled under the current statutory architecture. Coverage of sanctions, enabler-jurisdiction, conflict-finance, and compliance-technology domains was not actively pursued for this sub-national jurisdiction, and no inference should be drawn from that absence about the substantive state of those domains in Indiana.

22 Sep 2026 · fim-2026-09-14

Lead Signal

Indiana has enacted a statewide ban on the operation of virtual-currency kiosks under House Enrolled Act 1116, enforced by the state Attorney General under Indiana's existing consumer-protection statutes (the Deceptive Consumer Sales Act) rather than through the Department of Financial Institutions' money-transmitter licensing regime. The final ban language supersedes an earlier draft that would have required money-transmitter licensure for kiosk operators rather than prohibiting the activity outright, a legislative shift from a licensing model toward outright prohibition. The measure targets kiosk-enabled fraud and scam typologies rather than money-laundering typologies directly, but its structural effect is to remove a cash-to-crypto off-ramp that was previously reachable in practice without money-transmitter-level know-your-customer procedures.

Other Developments

A broader 2026 state wave. Indiana's move sits within a wider pattern: at least twenty US states have adopted new virtual-currency kiosk laws in 2026, according to ABA Banking Journal reporting, with Indiana's outright ban assessed as the most restrictive approach currently observed among that cohort, moving away from the median state model of licensing kiosk operation with transaction limits.

Standing money-transmitter licensing layer unaffected. Indiana's Money Transmission Modernization Act (IC 28-8-4.1), administered by the Department of Financial Institutions, licenses fiat money transmission but explicitly did not adopt the virtual-currency transmission provisions of the model act. This structural fact is unchanged this cycle and continues to define the state's baseline AML/CTF exposure at the sub-national level, alongside the unchanged federal Bank Secrecy Act and FinCEN layer.

Cross-Monitor Connections

The kiosk ban is a shared factual predicate across the fleet's monitors this cycle: the crypto monitor addresses the licensing and on-chain-activity dimensions of Indiana's broader 2026 digital-asset legislative package, and world-payments addresses the product-channel-closure dimension of the same kiosk ban. This financial-integrity brief foregrounds the enabler-jurisdiction and typology dimensions specifically: the shift from a licensing-based draft to an outright ban is read here as a reduction in Indiana's enabler surface relative to the median state approach, since a licensing regime with limits still permits regulated activity to continue under supervision, whereas an outright ban removes the channel and its associated fraud-typology exposure entirely, at the cost of also removing the cash-to-crypto conversion pathway altogether for any legitimate use.

Outlook

The exact statutory effective date of HEA 1116's final kiosk-prohibition language has not been independently confirmed beyond bill text and secondary legal commentary. Watch for confirmation of that effective date, and for whether Indiana's approach becomes a reference point for other states currently weighing between the licensing-with-limits model and the outright-ban model within the ongoing 2026 wave of state-level crypto-kiosk legislation.

28 Aug 2026 · fim-2026-08-21

Lead Signal

On August 11, 2026, the U.S. Department of the Treasury's Financial Crimes Enforcement Network finalized a rule permanently exempting United States companies and United States persons from beneficial-ownership-information reporting obligations created by the Corporate Transparency Act. The rule adopts as permanent the interim final rule FinCEN issued in March 2025, and it narrows the regime so severely that only foreign reporting companies remain within its scope; beneficial-ownership data already filed by U.S. persons will be deleted from the registry entirely. Codified at 31 CFR 1010.380 as amended, this is a structural contraction of the federal beneficial-ownership transparency architecture, not an isolated enforcement or compliance event: a single enforcement action in a well-regulated centre is analytically less significant than a structural rollback of the underlying transparency architecture itself. Indiana inherits this rollback as a chain-parent jurisdiction with no supplementary state-level beneficial-ownership registry of its own, meaning the practical effect for entities operating in or through Indiana is a straightforward widening of domestic shell-company opacity risk, with no compensating state-level backstop. This finding is assessed at High confidence on Treasury's own primary-source publication.

Other Developments

Indiana enacts the first statewide ban on virtual-currency kiosks. Governor Mike Braun signed House Bill 1116 on March 9, 2026, prohibiting the operation of virtual-currency kiosks anywhere in the state, effective March 10, 2026, and sidelining an estimated 800 to 900 machines. The legislature acted following law-enforcement reporting of substantial elder-fraud losses tied to kiosk-based scams, including approximately $400,000 lost in Evansville alone during 2025. Enforcement sits with the Indiana Attorney General under deceptive-consumer-sales authority, carrying forfeiture and refund provisions for victims. This is best read as a discrete, enforcement-oriented legislative event rather than a structural regime change: it closes a specific retail access point associated with a well-documented fraud typology, and it is a distinct policy choice -- outright prohibition -- compared with the operating-standards models some peer states have pursued this cycle for the same kiosk-fraud problem. The three-pillar balance principle applies here: this is a consumer-fraud-driven AML-adjacent measure rather than a CTF or CPF-specific one, and the absence of a parallel CTF angle in the public record should not be read as an analytical omission.

FATF revises its list of jurisdictions under increased monitoring. At its June 19, 2026 Plenary, the Financial Action Task Force added Iraq and Bosnia and Herzegovina to the grey list and removed Algeria and Namibia, holding the total at 22 jurisdictions. There is no direct Indiana nexus to this revision, but it moves the global grey-list baseline that this monitor tracks structurally, and any correspondent-banking or enabler-jurisdiction exposure analysis touching Iraq or Bosnia and Herzegovina should now account for the heightened monitoring status.

Cross-Monitor Connections

Indiana's kiosk ban and the state's underlying money-transmission licensing posture toward virtual-currency activity connect directly to the World Payments Monitor's licensing and market-access coverage and to the Crypto monitor's licensing and consumer-protection modules, where the same underlying statutory facts are read through a payments-infrastructure lens and a digital-asset-rights lens respectively rather than the financial-crime lens applied here. Readers tracking all three monitors should expect to see the same HB 1116 fact rendered three ways: here as a fraud-typology enforcement measure, at World Payments as a licensing and market-access data point, and at Crypto as one half of a bifurcated 2026 Indiana digital-asset posture. The FinCEN beneficial-ownership rollback, while it has no Indiana-specific enforcement counterpart this cycle, is architecture-over-incident in character and bears on the broader pool of opaque corporate vehicles available to facilitate financial-crime typologies this monitor tracks under its enabler-jurisdiction and conflict-finance domains, even absent an Indiana-specific instance this cycle.

Outlook

The durability of the FinCEN rollback is not settled. National Small Business United v. Bessent and Texas Top Cop Shop v. Blanche remain pending before the U.S. Supreme Court on cert, with a coalition of twenty-five states filing amicus briefs urging review of the Corporate Transparency Act's constitutionality; a ruling is not expected before the first quarter of 2027 at the earliest, and general industry practice has already de-prioritized CTA compliance following the 2025 interim rule, meaning a Court ruling could either moot the current posture or reopen questions independent of FinCEN's own rule. Watch, too, for whether Indiana or peer states move to establish a supplementary beneficial-ownership registry to offset the federal narrowing, and for early Attorney General enforcement activity under the new kiosk ban that would test the practical reach of its forfeiture and refund provisions.

11 Aug 2026 · fim-2026-08-05

Lead Signal

The clearest structural signal this cycle is a widening divergence in beneficial-ownership transparency architecture between the two largest anti-money-laundering regulatory blocs. In the United States, FinCEN's March 2025 interim final rule removing beneficial-ownership-information reporting for domestic companies and persons remains in force, corroborated by a Tier-1 FinCEN source this cycle. In the European Union, the Anti-Money Laundering Authority formally assumed the full suite of AML/CFT mandates previously held by the European Banking Authority on January 1, 2026, and is advancing the selection methodology it will use for direct supervision of an initial cohort of institutions from 2028, corroborated by two independent Tier-1 AMLA primary sources. Read together, these developments describe not a single incident but a structural fork: one major bloc is narrowing its domestic corporate-transparency perimeter while the other is building a supranational supervisory layer atop a directly-applicable single rulebook. This is an architecture-level finding, assessed at High confidence given the Tier-1 corroboration on both sides of the comparison.

Other Developments

Sanctions architecture continued to expand its reach this cycle. OFAC's designation of Rosneft and Lukoil, together with their majority-owned subsidiaries, extends the sanctions perimeter deep into Russia's oil-major structure, with general licenses authorizing a wind-down and contingent divestment of non-Russian assets; this action is assessed at Assessed confidence, resting on a single Tier-4 secondary summary rather than a directly retrieved OFAC press release this cycle. Separately, a broad Houthi-network designation on January 16, 2026 named 21 individuals and entities plus one vessel connected to oil smuggling and financial facilitation, corroborated by two independent Tier-3 wire reports.

Stablecoin rulemaking entered an active, multi-agency phase. The OCC issued a notice of proposed rulemaking on February 25, 2026 implementing the GENIUS Act for national banks, federal savings associations, and qualified nonbank or state stablecoin issuers, with its comment period closing May 1, 2026. The FDIC board approved a parallel proposal on April 7, 2026 setting reserve-asset, capital, risk-management, and two-business-day redemption standards. A joint Treasury, FinCEN, and OFAC proposed rule followed on April 8, 2026, implementing GENIUS Act AML and sanctions-compliance program requirements for payment-stablecoin issuers. All three actions are corroborated by independent Tier-1 federal-regulator primary sources and are assessed at High confidence.

Enabler-jurisdiction signal was concentrated in three geographies. FinCEN's Section 311 finding against ten Mexico-based gambling establishments identifies them as of primary money-laundering concern for Sinaloa Cartel financing, and a supplemental FinCEN alert issued June 30, 2026 addresses CJNG fuel-smuggling, or huachicoleo, schemes exploiting the US-Mexico fuel trade. The UAE Central Bank issued six new AML/CFT supervisory documents on trade-based money-laundering typologies and continuous customer due diligence on April 16, 2026, though this rests on a single Tier-3 source this cycle. Cambodia's National Bank intensified its crackdown on illegal online gambling and scam centres, framed by the interpreter as driven by the risk of FATF re-listing rather than by a discrete new instrument.

FATF's June 2026 plenary updated the grey list, adding Bosnia and Herzegovina and Iraq while removing Algeria and Namibia, a Tier-1-corroborated, High-confidence development with no change to the black list.

Cross-Monitor Connections

The Mexico casino-sector and fuel-smuggling findings sit directly at the FIM/gambling-monitor boundary: FinCEN's Section 311 action against ten Mexico-based gambling establishments is a financial-integrity finding with a gambling-sector nexus that a gambling-focused monitor would read as a licensing and counterparty-risk signal rather than a pure AML finding. The GENIUS Act rulemaking track has a direct payments-monitor connection, since the OCC, FDIC, and joint Treasury/FinCEN/OFAC proposals collectively define the compliance perimeter that payment-stablecoin issuers and their bank and nonbank counterparties will need to operate within. The Rosneft/Lukoil and Houthi-network designations both carry conflict-finance and extractive-industry dimensions that a conflict-finance-focused reading would weight more heavily than the sanctions-architecture framing applied here.

Outlook

Watch three thresholds over the coming cycles. First, whether a primary OFAC source is retrieved to firm up the Rosneft/Lukoil designation beyond this cycle's Tier-4 secondary sourcing. Second, the pace of GENIUS Act rulemaking finalization ahead of the January 18, 2027 effective-date backstop, or the alternative 120-days-post-final-rule trigger, across all three rulemaking tracks. Third, whether AMLA's 2028 direct-supervision selection methodology and the AMLR/6AMLD single-rulebook transition, reaching full application July 10, 2027, proceed on the timeline reflected in this cycle's Tier-1 sourcing, or slip. Each of these would materially firm up or revise the architecture-level judgments rendered this cycle.

Domain intelligence (D1–D8)

D1 Sanctions

no_changestanding position

Sanctions Architecture and Evasion

Indiana sanctions exposure runs through the uniform federal OFAC architecture rather than any distinct state-level designation authority, and this cycle baseline documents a sanctions regime that remains structurally active on multiple fronts. OFAC removed the final remaining name from its Foreign Sanctions Evaders list on 18 December 2025, leaving the list empty, though new names may be added at any time; the mechanism has no direct European Union or United Kingdom equivalent, which is itself a structural divergence point in sanctions-list architecture with direct consequences for how US institutions, including Indiana-based BSA-covered entities, calibrate their screening protocols against a shrinking but still-live list. Designation activity did not slow during the same period: OFAC designated the Prince Group transnational criminal organization in October 2025, an action coordinated with UK sanctions and a simultaneous Department of Justice indictment, tied to Cambodia-based forced-labor scam compounds and accompanied by a fifteen billion dollar bitcoin forfeiture action, illustrating a close but imperfect alignment between the two allied sanctions regimes where the designation itself was coordinated but the forfeiture tool remains a purely domestic US mechanism. FinCEN separately designated the Cambodian Huione Group conglomerate as a foreign financial institution of primary money-laundering concern under Section 311 authority, severing its correspondent access to the US financial system after the network was found to have received over thirty-nine point six billion dollars in 2025 tied to scam and laundering networks with documented US victim exposure.

Continue reading

The most analytically significant finding in this domain this cycle, however, is not a designation but a divergence. OFAC designated two UK-registered digital asset exchanges, Zedcex Exchange and Zedxion Exchange, tied to an Iranian sanctions evader in January 2026, and no confirmed parallel UK Office of Financial Sanctions Implementation listing for the same corporate entities has been identified. Applying the architecture-over-incident principle, this is not read as an isolated gap in one listing round but as live evidence of a structural mismatch in listing scope between two closely coordinated sanctions regimes acting on the same underlying entities: US institutions with UK-domiciled virtual asset service provider counterparties, including any Indiana-based institution with such exposure, face compliance friction from a jurisdiction-by-jurisdiction rather than harmonized designation posture. This sits against a formal compliance backdrop that remains clean: the United States is absent from both the FATF Jurisdictions Under Increased Monitoring list and the Call for Action list as of the June 2026 plenary, and the jurisdiction profile for Indiana specifically records a compliant, tier-A status with no high-risk-third-country flag from either the EU or UK advisory notices. The domain trajectory is nonetheless assessed as deteriorating, reflecting the pattern of continued designation activity and an open regime-divergence question rather than any change in the formal FATF-adjacent status of the jurisdiction.

Three-pillar balance is worth stating explicitly here: the developments recorded this cycle sit predominantly within the AML and CTF pillars, with the Huione and Prince Group designations carrying clear anti-money-laundering and forced-labor-proceeds dimensions and the Zedcex and Zedxion action carrying a CTF classification tied to an Iranian sanctions evader. No CPF-specific development was identified in this jurisdiction-scoped baseline, a gap worth flagging rather than silently omitting, consistent with the standing correction for CTF and CPF under-weighting relative to AML enforcement volume. The jurisdiction risk tracker entry for Indiana records a mixed enforcement-versus-enablement balance precisely because the sanctions architecture itself is federal and uniformly applied, while the vulnerability documented elsewhere in this baseline concentrates in adjacent domains; no Indiana-specific sanctions-evasion nexus, such as dark-fleet, correspondent-banking, or commodity-rerouting activity, was identified this cycle.

Outlook

The next scheduled review point in the standing FATF process falls in October 2026, within an already-operative tri-annual list-update mechanism under which the United States is not currently grey- or black-listed; this is a periodic scrutiny point rather than an anticipated status change. Whether OFSI will issue a parallel listing for Zedcex and Zedxion remains an open question as of this baseline, and a direct check of the UK consolidated sanctions list in a subsequent cycle would confirm whether the listing-scope divergence has closed or persists. Continued OFAC designation activity against Cambodia-linked and Iran-linked networks should be expected to continue on the same cadence observed this cycle, consistent with the deteriorating trajectory rating of the domain, though this observation describes a pattern rather than a specific forecast of any named future designation.

Periodic updates (1)
11 Aug 2026 · fim-2026-08-05

Sanctions Architecture and Evasion

This cycle's most consequential sanctions-architecture development is OFAC's designation of Rosneft and Lukoil, Russia's two largest oil majors, together with all subsidiaries in which either holds a fifty-percent-or-greater ownership stake. General licenses accompanying the designations authorize a wind-down period and contingent divestment of non-Russian assets, a structure that in practice manages an orderly market exit rather than an abrupt freeze. The finding is assessed at Assessed confidence: it rests on a single Tier-4 secondary summary this cycle, and no direct OFAC press release for this specific action was retrieved, a gap worth closing before the finding is treated as fully verified.

Read architecturally rather than as an isolated incident, the Rosneft/Lukoil action extends a now-familiar pattern in the Russian sanctions-evasion architecture: designation of the parent entity, automatic capture of majority-owned subsidiaries under standard blocking rules, and general-license machinery to manage the resulting market disruption. This pattern matters more for its structural persistence than for any single designation, since it defines the compliance posture that banks, energy traders, and correspondent counterparties must maintain toward the entire Rosneft and Lukoil corporate family, not merely toward the two named parents.

Separately, a second sanctions-architecture development targeted the Yemen and Gulf corridor: on January 16, 2026, OFAC designated 21 individuals and entities and one vessel connected to Houthi oil-smuggling and financing networks, reportedly including Dubai-based facilitators and two Sana'a-based airlines. This is corroborated by two independent Tier-3 wire and news-agency sources, supporting an Assessed confidence rating even without a directly retrieved Tier-1 OFAC source this cycle.

Together, the two actions illustrate the three-pillar balance this analysis aims to maintain: the Rosneft/Lukoil action sits primarily in the AML/sanctions-evasion space, while the Houthi-network action carries a pronounced counter-terrorist-financing dimension, targeting the financial infrastructure sustaining an armed non-state actor's oil-smuggling revenue. Neither action, on the evidence available this cycle, has generated a documented enforcement or licensing response from a third-country jurisdiction, which is itself worth noting under the enablement-as-signal principle.

Outlook

The near-term test for the Rosneft/Lukoil architecture is whether a primary OFAC source and any general-license amendments surface in the coming cycles, and whether non-Russian counterparties visibly complete the divestments the general licenses contemplate. For the Houthi-network package, watch for follow-on designations against correspondent-banking or exchange-house nodes, and for any second-source corroboration that would move the current Tier-3-anchored finding toward Tier-1 confirmation.

D2 Beneficial Ownership

no_change

Beneficial Ownership and Corporate Transparency

Indiana sits outside the European Unions AML Package direct perimeter; the relevant architecture for this jurisdiction is federal United States beneficial-ownership law, not the European framework. Globally, the EU AML Package sets the structural direction for beneficial-ownership supervision through three distinct instruments operating together: the AML Regulation, known as the AMLR (Regulation (EU) 2024/1624), which applies directly across Member States without transposition; the sixth AML Directive, known as 6AMLD, which each Member State transposes into its own national law; and the AMLA Regulation (Regulation (EU) 2024/1620), which establishes the Anti-Money Laundering Authority and shifts supervision of certain cross-border obliged entities from purely national authorities toward a hybrid EU-level regime. None of this architecture reaches Indiana directly. In Indiana, the directly relevant development this cycle is the FinCEN final rule, effective 14 August 2026, permanently exempting United States-formed entities and United States persons from Corporate Transparency Act beneficial-ownership reporting, leaving only foreign reporting companies obligated to file.

Continue reading

The practical effect in Indiana is straightforward because the state has never operated a beneficial-ownership registry independent of the federal Corporate Transparency Act framework. Where some jurisdictions might see a federal reporting rollback create pressure for a state-level backfill, there is no indication of any such initiative in Indiana. The federal exemption therefore removes rather than relocates the domestic beneficial-ownership reporting obligation: a US-formed entity incorporated or operating in Indiana, and the US persons who control it, no longer file or update beneficial-ownership information with FinCEN at all, and previously filed data on such domestic persons and entities is to be deleted. Only a foreign reporting company with a nexus to Indiana would retain a live Corporate Transparency Act filing obligation going forward.

This is best read as a structural contraction of the federal corporate-transparency perimeter rather than as an Indiana-specific policy choice, and it leaves Indiana businesses and their beneficial owners outside any mandatory ownership-disclosure regime at either the state or federal level, except where a foreign reporting company structure is involved. For compliance functions at financial institutions operating in Indiana, this means counterparty due diligence on domestically-formed corporate customers can no longer rely on a Corporate Transparency Act filing as a verification source, since no such filing will exist for a purely domestic entity; existing customer due diligence obligations under the Bank Secrecy Act and applicable FinCEN customer-due-diligence rules continue independently of the Corporate Transparency Act change and are not altered by this exemption.

Outlook

The domestic-entity exemption is now in force and there is no pending litigation or legislative reversal identified in the material available this cycle that would suggest the exemption is provisional. Absent a new state-level beneficial-ownership initiative in Indiana, which has not been signalled by the Department of Financial Institutions, the Secretary of State, or any other state authority, the current position, that only foreign reporting companies file beneficial-ownership information with FinCEN, is probable to remain the governing standard in Indiana through the near term. Financial institutions and other obliged entities with Indiana operations should expect continued reliance on Bank Secrecy Act customer-due-diligence channels rather than Corporate Transparency Act filings as the operative beneficial-ownership verification pathway for domestically-formed customers.

Cumulative analysis

Beneficial Ownership and Corporate Transparency

The most consequential development in this domain, and in this baseline overall, is a structural reversal rather than a discrete incident. All US-formed entities, including Indiana-formed LLCs and corporations, and their beneficial owners are now exempt from Corporate Transparency Act beneficial ownership information reporting under the March 2025 interim final rule, which redefines reporting company to cover only foreign entities registered to do business in a US state. This removes the principal federal transparency mechanism as it applied to domestic entities, and the Indiana Secretary of State business registry captures only basic incorporation data with no beneficial-ownership layer, meaning Indiana-formed entities now carry effectively no beneficial-ownership disclosure obligation at either the federal or the state level. Applying the architecture-over-incident principle, this is assessed as the single most significant D2 finding in the baseline: a structural transparency-mechanism reversal outweighs any individual enforcement episode, and the finding is held at high confidence on Tier 1 sourcing. This gap is held at high confidence because it rests on Tier 1 federal rulemaking sourcing rather than inference, distinguishing it from the possible-confidence supervisory-visibility gap documented elsewhere in this baseline.

This sits alongside a long-standing and distinct blind spot in the same domain: a substantial share, on the order of twenty to thirty percent, of US residential property purchases, including in Indiana, close without mortgage financing and therefore fall outside lender anti-money-laundering checks, while title agents, real estate agents, and closing attorneys remain structurally outside Bank Secrecy Act compliance-program obligations. Read together with the domestic beneficial-ownership exemption, this describes a jurisdiction in which two of the principal channels through which opaque ownership is typically surfaced, corporate registries and real estate closing intermediaries, both carry no beneficial-ownership disclosure requirement, even though the overall formal compliance status of the jurisdiction remains clean, recorded as FATF-compliant, tier A, with no high-risk-third-country flag from either the EU or UK advisory notices.

It is useful to read this Indiana-specific deterioration against the durable structural backdrop of how beneficial-ownership and corporate-transparency architecture is evolving elsewhere, since the contrast is itself analytically informative. The EU AML Package is built from three distinct instruments rather than a single measure: a directly applicable AML Regulation, Regulation (EU) 2024/1624, which requires no domestic transposition; a sixth AML Directive, transposed individually by each Member State; and a separate AMLA Regulation, Regulation (EU) 2024/1620, which establishes the Anti-Money Laundering Authority and progressively shifts supervision of higher-risk obliged entities from purely national authorities toward a hybrid EU-level regime through a direct and indirect supervision perimeter. This is standing architectural context rather than a new development in this cycle; interpreter tracking of the EU AML Package and AMLA notes this framework is not a domestic supervisory matter for Indiana as a US state, with its relevance for this jurisdiction limited to Indiana-headquartered firms with EU counterparties that will face AMLA-supervised enhanced due diligence as the centralized EU supervisor becomes operational. The structural contrast is nonetheless notable: where the EU is actively constructing a centralized, hybrid supervisory layer for beneficial-ownership and obliged-entity oversight, the US this cycle moved in the opposite direction for its principal domestic transparency mechanism.

Outlook

No litigation or congressional action restoring domestic beneficial ownership reporting was identified this cycle, and the March 2025 exemption remains in effect as an interim final rule pending finalization, with no confirmed timeline for that final rule surfaced in this baseline. No Indiana state-level beneficial-ownership registry initiative was identified that would independently fill the resulting gap. The all-cash real estate blind spot likewise shows no confirmed regulatory change on the horizon within this baseline window. Absent a final CTA rule, litigation outcome, or state registry initiative, the structural gap in Indiana corporate and real estate beneficial-ownership visibility should be read as a durable rather than transitional feature of the current profile of the jurisdiction.

domain_sub_briefs · D2 · Cumulative analysis
Standing baseline position

US federal CTA BOI reporting narrowed permanently to foreign reporting companies only; U.S.-person data to be deleted from the registry

FinCEN's final rule (effective 2026-08-14) permanently exempts US-formed entities and persons from CTA beneficial-ownership reporting; only foreign reporting companies remain in scope.

Periodic updates (3)
25 Oct 2026 · fim-2026-10-25

Beneficial Ownership and Corporate Transparency

Indiana sits outside the European Unions AML Package direct perimeter; the relevant architecture for this jurisdiction is federal United States beneficial-ownership law, not the European framework. Globally, the EU AML Package sets the structural direction for beneficial-ownership supervision through three distinct instruments operating together: the AML Regulation, known as the AMLR (Regulation (EU) 2024/1624), which applies directly across Member States without transposition; the sixth AML Directive, known as 6AMLD, which each Member State transposes into its own national law; and the AMLA Regulation (Regulation (EU) 2024/1620), which establishes the Anti-Money Laundering Authority and shifts supervision of certain cross-border obliged entities from purely national authorities toward a hybrid EU-level regime. None of this architecture reaches Indiana directly. In Indiana, the directly relevant development is the FinCEN final rule, effective 14 August 2026, permanently exempting United States-formed entities and United States persons from Corporate Transparency Act beneficial-ownership reporting, leaving only foreign reporting companies obligated to file.

The practical effect in Indiana is straightforward because the state has never operated a beneficial-ownership registry independent of the federal Corporate Transparency Act framework. Where some jurisdictions might see a federal reporting rollback create pressure for a state-level backfill, there is no indication of any such initiative in Indiana. The federal exemption therefore removes rather than relocates the domestic beneficial-ownership reporting obligation: a US-formed entity incorporated or operating in Indiana, and the US persons who control it, no longer file or update beneficial-ownership information with FinCEN at all, and previously filed data on such domestic persons and entities is to be deleted. Only a foreign reporting company with a nexus to Indiana would retain a live Corporate Transparency Act filing obligation going forward.

This is best read as a structural contraction of the federal corporate-transparency perimeter rather than as an Indiana-specific policy choice, and it leaves Indiana businesses and their beneficial owners outside any mandatory ownership-disclosure regime at either the state or federal level, except where a foreign reporting company structure is involved. For compliance functions at financial institutions operating in Indiana, this means counterparty due diligence on domestically-formed corporate customers can no longer rely on a Corporate Transparency Act filing as a verification source, since no such filing will exist for a purely domestic entity; existing customer due diligence obligations under the Bank Secrecy Act and applicable FinCEN customer-due-diligence rules continue independently of the Corporate Transparency Act change and are not altered by this exemption.

Outlook

The domestic-entity exemption is now in force and there is no pending litigation or legislative reversal identified in the material available that would suggest the exemption is provisional. Absent a new state-level beneficial-ownership initiative in Indiana, which has not been signalled by the Department of Financial Institutions, the Secretary of State, or any other state authority, the current position, that only foreign reporting companies file beneficial-ownership information with FinCEN, is probable to remain the governing standard in Indiana through the near term. Financial institutions and other obliged entities with Indiana operations should expect continued reliance on Bank Secrecy Act customer-due-diligence channels rather than Corporate Transparency Act filings as the operative beneficial-ownership verification pathway for domestically-formed customers.

D3 Enabler Jurisdictions

no_changestanding position

Enabler Jurisdictions and Professional Facilitators

Indiana exposure in this domain centers on a capacity gap rather than a distinct legal choice to permit illicit finance. Unlike roughly eighteen other US states, Indiana has no confirmed transaction-limit, mandatory-KYC, or operator-liability statute governing crypto kiosks, despite documented scam-transmission cases at Circle K-sited Bitcoin Depot kiosks within the state; Indiana consumers are left reliant solely on federal FinCEN guidance and general fraud statutes rather than any state-specific consumer-protection backstop. This is best read as an enabler-jurisdiction capacity deficit distinct from, and additive to, the federal advisory framework: the absence of a state statute does not itself constitute enforcement failure, but it removes a layer of protection that a substantial number of peer states have already put in place.

Continue reading

Professional-facilitator infrastructure was also directly targeted at the federal level this cycle in a manner with binding consequences for Indiana. FinCEN issued a consent order against Brinks Global Services USA for moving bulk currency shipments across the US border without Bank Secrecy Act money-services-business registration, establishing a precedent binding on currency-transport MSBs operating in every state, including Indiana. This is a Tier 1 enforcement action against a professional-facilitator infrastructure provider rather than an end user, consistent with the standing focus of the domain on the intermediaries and jurisdictions that make illicit-finance channels function at scale rather than on the individual transactions that flow through them.

Indiana own supervisory visibility, however, is difficult to assess directly. No enforcement order, penalty, or license action specific to the Indiana Department of Financial Institutions was identified in open-source search despite the agency administering money-transmitter licensing under the state Uniform Money Services Act. This finding is held at only possible confidence because it is genuinely ambiguous between two distinct readings: either Indiana state-level enforcement volume against money-transmitter licensees is authentically low, or the state own regulatory reporting has a publication gap that open-source research could not penetrate. Enablement-as-signal reasoning would treat sustained non-enforcement in a state supervisory function as itself analytically significant, but the evidentiary basis here does not yet support choosing between a genuine enforcement gap and a transparency gap in the reporting of the state itself; this is flagged explicitly as a research gap rather than resolved in either direction.

Enabler-jurisdiction analysis in this baseline also intersects directly with the corporate-transparency finding recorded elsewhere in this brief: the Indiana Secretary of State registry captures only basic incorporation data with no beneficial-ownership layer, and title agents, real estate agents, and closing attorneys handling the twenty to thirty percent of US residential purchases completed without financing remain structurally outside Bank Secrecy Act compliance-program obligations. Both are professional-facilitator and registry-infrastructure gaps rather than the product of any single actor choice to enable illicit finance, and both meet the standard of the enabler-jurisdiction filter of assessing legal framework and enforcement capacity rather than actor intent.

Read through the F3 enabler-jurisdiction filter, the profile of Indiana requires assessing legal framework, enforcement history, and capacity against choice rather than treating any single gap as evidence of policy-level permissiveness. The crypto-kiosk gap, the unclear DFI enforcement record, and the non-differentiated real-estate professional-facilitator obligations of Indiana together produce a jurisdiction risk tracker classification of mixed enforcement-versus-enablement balance with a structural rather than episodic character. None of the three gaps identified this cycle reflects a discrete incident; each is a standing feature of the regulatory architecture of Indiana that predates this baseline and is likely to persist absent specific legislative or supervisory action.

Outlook

The legislative status of any Indiana General Assembly crypto-kiosk consumer-protection bill was not established in this baseline; direct tracking of state legislative records in a subsequent cycle would resolve whether Indiana is moving toward the statutory model already adopted by other states or remains without one. Direct verification against Indiana Department of Financial Institutions records would resolve whether the absence of a discoverable enforcement history reflects low enforcement volume or a publication gap, a distinction that materially changes the severity assessment of the domain. The Brinks consent-order precedent should be expected to inform supervisory expectations for currency-transport MSBs operating in Indiana going forward, independent of any state-specific legislative action.

Periodic updates (1)
11 Aug 2026 · fim-2026-08-05

Enabler Jurisdictions and Professional Facilitators

Three enabler-jurisdiction developments surfaced this cycle, spanning Mexico, the United Arab Emirates, and Cambodia, each illustrating a different facet of the enabler-jurisdiction typology: durable structural laundering channels, guidance-driven capacity building, and enforcement driven by reputational risk rather than by a discrete new instrument.

The most consequential is FinCEN's Section 311 finding that ten Mexico-based gambling establishments are of primary money-laundering concern for Sinaloa Cartel financing, a Tier-1, High-confidence finding this cycle. It arrives alongside a separate, also Tier-1, FinCEN supplemental alert issued June 30, 2026 addressing CJNG fuel-smuggling, or huachicoleo, schemes exploiting the US-Mexico fuel trade. Read together, these two findings support the judgment that Mexico's casino sector and its cross-border fuel trade are functioning as durable, structural laundering channels for two of Mexico's most significant cartel organizations, rather than episodic exposure. The casino-sector finding sits directly at the boundary between financial-integrity and gambling-regulatory analysis: a gambling-sector regulator would likely treat it as a licensing and counterparty-due-diligence signal, while this analysis treats it as evidence of a structural money-laundering channel. The concurrence of the two findings within the same reporting cycle illustrates a broader dynamic worth naming explicitly: Mexico's exposure spans both a licensed-but-vulnerable formal sector and an informal cross-border trade channel, and a correspondent bank or trade-finance provider assessing Mexico exposure should treat both channels as connected rather than independent risk vectors.

In the United Arab Emirates, the Central Bank issued six new AML/CFT supervisory documents on April 16, 2026, reinforcing trade-based money-laundering typology guidance and continuous customer-due-diligence obligations. This finding rests on a single Tier-3 source this cycle, with no primary CBUAE document URL retrieved, and is accordingly assessed at Assessed rather than High confidence. Guidance-driven capacity building of this kind is itself a meaningful enabler-jurisdiction signal under the enablement-as-signal principle: it indicates the UAE authorities are actively investing in TBML detection capacity ahead of, rather than only in response to, a specific enforcement failure. The CBUAE's continuous-CDD emphasis is also notable for what it implies about the UAE's own self-assessment of TBML exposure, consistent with the UAE's broader profile as a major trade and gold hub.

Cambodia presents the clearest enforcement-versus-enablement contrast of the three. The National Bank of Cambodia's governor has intensified the country's crackdown on illegal online gambling and scam centres, and this cycle's reporting frames that intensification explicitly as a response to the risk of FATF re-listing rather than as the product of a specific new instrument. This is an Assessed-confidence finding resting on a single Tier-3 source, and it should be read as a capacity-and-posture signal rather than a structural finding: Cambodia's enforcement drive is real but reputationally motivated, and its durability beyond the immediate FATF-review cycle is not yet established.

Across all three jurisdictions, the pattern this cycle favors enforcement and guidance activity over documented enablement gaps, worth flagging under the three-pillar balance principle: the absence of a documented enablement failure this cycle should not be read as an absence of enabler-jurisdiction risk, only as an absence of corroborating evidence within this cycle's research window.

Outlook

Watch for follow-on FinCEN guidance or enforcement actions naming specific Mexican gambling establishments by name. For the UAE, watch for a primary CBUAE document retrieval that would firm up this cycle's Tier-3-anchored guidance finding. For Cambodia, the coming FATF review cycle is the key structural test of whether the current enforcement intensification is sustained or eases once re-listing risk recedes.

D4 Conflict Finance

no_changestanding position

Conflict Finance and Extractive-Industry Integrity

No Indiana-nexus or new material conflict-finance development was identified in this jurisdiction-specific baseline this cycle. The standing coverage areas of the domain, Russian war-economy financing, Sahel conflict-minerals flows, and Democratic Republic of Congo mining-sector governance, are unaddressed in this cycle Indiana-scoped research, and the domain tracker records the domain as quiet with a stable trajectory and a monitored severity-preliminary rating rather than any active or deteriorating signal. This absence should be read honestly as a gap in the evidentiary base of this cycle specific to Indiana rather than as an assessment that conflict-finance risk is genuinely absent from the jurisdiction; a sub-national baseline of this kind is unlikely to surface conflict-finance nexus points unless a specific Indiana-headquartered entity, financial institution, or extractive-industry supply-chain participant appears in reporting tied to one of the standing coverage areas, and no such appearance was identified this cycle.

Continue reading

The closest adjacent finding elsewhere in this baseline is the Prince Group transnational criminal organization designation recorded in the Sanctions Architecture and Evasion domain, which involves forced-labor scam compounds in Cambodia rather than conflict-mineral or armed-group financing in the strict sense of the standing coverage of this domain, and is treated there rather than folded into this domain to avoid overstating a conflict-finance nexus that the evidence does not establish. Consistent with the honesty-over-coverage principle, this sub-brief is being flagged as limited signal rather than padded with content not supported by the structured findings of this cycle.

Outlook

No forward-looking conflict-finance or extractive-industry development specific to Indiana was identified in this baseline. A subsequent cycle with broader research scope, or a specific Indiana-nexus finding tied to export-control compliance at Indiana-headquartered manufacturers with exposure to the standing Russian sanctions-evasion architecture, would be the most likely route by which this domain regains active signal for this jurisdiction.

D5 Crypto / Digital Assets / Financial Innovation

no_changestanding position

Crypto, Digital Assets, and Financial Innovation

Indiana is a documented physical node in the national crypto-ATM scam ecosystem. Bitcoin Depot kiosks installed inside Indiana Circle K convenience stores allow rapid cash-to-crypto conversion, and weak on-site know-your-customer procedures and limited operator screening allow remote scammers to direct victims to deposit cash that is instantly converted to bitcoin and routed to offshore or scammer-controlled wallets beyond the reach of domestic law enforcement; a specific Indiana victim case was documented in Tier 2 investigative reporting and corroborated by a Tier 1 FinCEN typology notice describing the same convertible-virtual-currency-kiosk pattern nationally.

Continue reading

The operator of that kiosk network is now itself under acute financial and regulatory pressure. The Connecticut Department of Banking issued an emergency suspension of the Bitcoin Depot money-transmitter license, citing anti-money-laundering control lapses and fee violations, with a corrected order date of 9 March 2026 that compresses the interval to the subsequent Chapter 11 bankruptcy filing in May 2026 to roughly two months, a substantially tighter causal sequence than an earlier baseline research figure had implied. Bitcoin Depot filed for Chapter 11 protection amid multi-state legal and regulatory pressure, a filing that directly touches the kiosk network operating inside Indiana retail locations and raises an unresolved question of ownership continuity for those kiosks going forward.

This acute, entity-specific pressure sits alongside a nationally advancing regulatory response for the broader digital-asset sector. FinCEN and OFAC have jointly proposed a rule under the GENIUS Act that would treat Permitted Payment Stablecoin Issuers as Bank Secrecy Act financial institutions with anti-money-laundering and counter-financing-of-terrorism program obligations, a forward-looking development that would directly affect any Indiana-touching stablecoin activity and the downstream compliance expectations of firms handling it. Read against the kiosk-network distress documented in this baseline, the domain presents a familiar pattern in digital-asset financial-integrity assessment: acute, node-specific enforcement pressure against a single operator coexists with a slower-moving but structurally more consequential regulatory build-out for the sector as a whole.

The underlying typology is documented at the federal level independent of the fate of any single operator: a FinCEN advisory notice addressing convertible virtual currency kiosks describes the same cash-deposit-to-instant-conversion pattern exploited in the Indiana case, and the associated obligation is classified as a partial control-gap signal, reflecting that screening obligations exist in guidance form but operator-level implementation and enforcement remain uneven across the kiosk-operator sector nationally. This distinguishes the Indiana finding as an instance of a documented, federally recognized typology rather than an isolated or novel scheme, which is itself relevant to how the finding should be weighted: the risk is structural to the crypto-kiosk business model as currently regulated, not specific to a single Indiana location or a single scammer network.

Three-pillar balance is worth stating directly in this domain: the crypto-ATM findings and the Bitcoin Depot enforcement cascade are predominantly AML-classified, consistent with the general pattern of the domain of AML developments outnumbering CTF and CPF findings; no CPF-specific digital-asset development was identified in this Indiana-scoped baseline, a gap that should be read as an absence of evidence rather than an assessment that no CPF-relevant digital-asset risk exists in the jurisdiction.

Outlook

The joint FinCEN-OFAC GENIUS Act stablecoin rule carries an estimated 2026 Q4 impact date on a year-scale uncertainty band, and its finalization would bring Permitted Payment Stablecoin Issuers within BSA program obligations nationally, including for any Indiana-touching activity. The Bitcoin Depot Chapter 11 process itself remains the most immediate open question for this jurisdiction: whether the kiosk network operating inside Indiana Circle K locations continues under new ownership, is wound down, or is acquired by another operator was not resolved in this baseline and would materially change the forward risk profile of the domain depending on the outcome. No confirmed change to the underlying vulnerability that allowed the documented scam pattern, cash deposited at a kiosk following remote telephone instruction and converted instantly to bitcoin routed outside domestic reach, was identified this cycle independent of the financial distress of the operator. Because the FinCEN advisory notice underlying this typology is guidance rather than a binding rule with kiosk-specific transaction limits, the practical effect of the GENIUS Act stablecoin rulemaking and the FinCEN AML and CFT program modernization on kiosk-level controls specifically will depend on how each final rule risk-based standard is applied to crypto-asset operators as a firm type, a question this baseline cannot resolve in advance of finalization.

D7 AML/CTF Regime

no_change

AML/CTF Regime

Indianas anti-money-laundering and counter-terrorist-financing posture is defined almost entirely by federal law. The states own regulatory architecture, principally the Money Transmission Modernization Act codified at IC 28-8-4.1 and administered by the Indiana Department of Financial Institutions, governs licensing of money transmitters operating in the state, but Bank Secrecy Act obligations and FinCEN money-services-business registration apply uniformly to covered firms regardless of whether a given activity requires Indiana state licensure. The notable state-level variance this cycle is that Indianas MTL regime excludes pure virtual-currency exchange, custody, or transmission from licensable money-transmission activity where no fiat money transmission is also present; the Department of Financial Institutions does not license or regulate the holding, transmittal, or exchange of cryptocurrency as such. This narrows the state-level AML perimeter for crypto-only businesses operating in Indiana relative to states that bring crypto exchanges within money-transmitter licensing, even though the federal Bank Secrecy Act and FinCEN money-services-business registration requirement continue to apply to such firms without regard to state licensing status.

Continue reading

This variance is a structural rather than episodic feature of Indianas regime: it is written into the statutory text of IC 28-8-4.1 itself, not the product of a discretionary enforcement choice that could shift cycle to cycle. The consequence for a firm offering pure virtual-currency services to Indiana customers is that it falls outside the states money-transmitter supervisory and examination framework while remaining fully subject to federal registration, suspicious-activity-reporting, and customer-identification obligations under the Bank Secrecy Act. The gap this creates is one of state-level supervisory touch rather than one of total regulatory absence: a crypto-only operator in Indiana answers to FinCEN at the federal layer but not to the Department of Financial Institutions at the state layer, a bifurcation that is itself a form of regulatory architecture worth noting independent of any single enforcement action.

Alongside this licensing-scope variance, Indiana continues to pursue AML/CTF-adjacent consumer-protection and securities enforcement through other channels. The states Attorney General enforces the virtual-currency kiosk prohibition enacted under HB1116 as a deceptive-sales-act matter, and the Secretary of States Securities Division has separately reached a settlement with TradeStation Crypto, Inc. over an unregistered crypto interest-earning program sold to Indiana investors. Neither of these actions runs through the Department of Financial Institutions or through a formal AML/CTF supervisory channel, which reinforces the pattern that Indianas engagement with crypto-adjacent financial-integrity risk is distributed across multiple state agencies rather than concentrated in a single AML regulator, with the federal Bank Secrecy Act layer providing the only consistent AML/CTF backbone across all of these activities.

Outlook

The MTL exclusion for pure virtual-currency activity rests on existing statutory text and no amendment to IC 28-8-4.1 has been identified this cycle, so the current narrowed state-level AML perimeter for crypto-only firms in Indiana is probable to persist absent legislative action. Federal Bank Secrecy Act and FinCEN money-services-business obligations will continue to apply to such firms regardless of any change in state licensing scope, providing a stable floor beneath the state-level variance. Continued state enforcement activity through the Attorney Generals deceptive-sales-act authority and the Securities Division is probable to remain the primary visible channel for Indianas engagement with crypto-adjacent financial-integrity risk, rather than any expansion of Department of Financial Institutions licensing jurisdiction over virtual-currency businesses.

Periodic updates (1)
25 Oct 2026 · fim-2026-10-25

AML/CTF Regime

Indianas anti-money-laundering and counter-terrorist-financing posture is defined almost entirely by federal law. The states own regulatory architecture, principally the Money Transmission Modernization Act codified at IC 28-8-4.1 and administered by the Indiana Department of Financial Institutions, governs licensing of money transmitters operating in the state, but Bank Secrecy Act obligations and FinCEN money-services-business registration apply uniformly to covered firms regardless of whether a given activity requires Indiana state licensure. The notable state-level variance is that Indianas MTL regime excludes pure virtual-currency exchange, custody, or transmission from licensable money-transmission activity where no fiat money transmission is also present; the Department of Financial Institutions does not license or regulate the holding, transmittal, or exchange of cryptocurrency as such. This narrows the state-level AML perimeter for crypto-only businesses operating in Indiana relative to states that bring crypto exchanges within money-transmitter licensing, even though the federal Bank Secrecy Act and FinCEN money-services-business registration requirement continue to apply to such firms without regard to state licensing status.

This variance is a structural rather than episodic feature of Indianas regime: it is written into the statutory text of IC 28-8-4.1 itself, not the product of a discretionary enforcement choice that could shift cycle to cycle. The consequence for a firm offering pure virtual-currency services to Indiana customers is that it falls outside the states money-transmitter supervisory and examination framework while remaining fully subject to federal registration, suspicious-activity-reporting, and customer-identification obligations under the Bank Secrecy Act. The gap this creates is one of state-level supervisory touch rather than one of total regulatory absence: a crypto-only operator in Indiana answers to FinCEN at the federal layer but not to the Department of Financial Institutions at the state layer, a bifurcation that is itself a form of regulatory architecture worth noting independent of any single enforcement action.

Alongside this licensing-scope variance, Indiana continues to pursue AML/CTF-adjacent consumer-protection and securities enforcement through other channels. The states Attorney General enforces the virtual-currency kiosk prohibition enacted under HB1116 as a deceptive-sales-act matter, and the Secretary of States Securities Division has separately reached a settlement with TradeStation Crypto, Inc. over an unregistered crypto interest-earning program sold to Indiana investors. Neither of these actions runs through the Department of Financial Institutions or through a formal AML/CTF supervisory channel, which reinforces the pattern that Indianas engagement with crypto-adjacent financial-integrity risk is distributed across multiple state agencies rather than concentrated in a single AML regulator, with the federal Bank Secrecy Act layer providing the only consistent AML/CTF backbone across all of these activities.

Outlook

The MTL exclusion for pure virtual-currency activity rests on existing statutory text and no amendment to IC 28-8-4.1 has been identified, so the current narrowed state-level AML perimeter for crypto-only firms in Indiana is probable to persist absent legislative action. Federal Bank Secrecy Act and FinCEN money-services-business obligations will continue to apply to such firms regardless of any change in state licensing scope, providing a stable floor beneath the state-level variance. Continued state enforcement activity through the Attorney Generals deceptive-sales-act authority and the Securities Division is probable to remain the primary visible channel for Indianas engagement with crypto-adjacent financial-integrity risk, rather than any expansion of Department of Financial Institutions licensing jurisdiction over virtual-currency businesses.

Baseline-Tracked Domains with No Current-Cycle Escalation (1 of 8)
  • D8 Commercial Activity: Standing coverage — no activity this cycle.
Regulatory horizon
Proposed2027-Q1 · ±year

Indiana crypto-ATM/kiosk operator licensing bill

Kiosk operators would need DFI permission to install machines, obtain money-transmitter licensure, cap fees at 10 percent, and refund scam victims in full.
Source
1 dated · 3 pending date · baseline fim-2026-07-05
Role action cards
MLRO

Federal BOI exemption removes a domestic due-diligence input while Indianas MTL regime continues to exclude pure virtual-currency activity from state licensure.

The permanent domestic-entity exemption from Corporate Transparency Act reporting, effective 14 August 2026, means Corporate Transparency Act filings can no longer be relied on as a verification source for domestically-formed corporate customers in Indiana; existing Bank Secrecy Act customer-due-diligence obligations are unaffected and remain the operative standard. Separately, Indianas statutory exclusion of pure virtual-currency activity from money-transmission licensing under IC 28-8-4.1 does not relieve crypto-only counterparties of federal FinCEN money-services-business registration and reporting obligations.

2 evidence refs
Compliance

Indianas money-transmission licensing scope for virtual currency diverges from the common US state pattern.

Firms conducting pure virtual-currency exchange, custody, or transmission in Indiana fall outside the states Money Transmission Modernization Act licensing requirement absent accompanying fiat money transmission, per the Indiana Department of Financial Institutions position under IC 28-8-4.1. Compliance programs calibrated to a multi-state licensing assumption should confirm Indiana is correctly scoped as an exclusion state rather than a licensing state for crypto-only activity.

1 evidence refs
Legal

Corporate Transparency Act exposure for Indiana-domiciled entities is now confined to foreign reporting companies.

Following the FinCEN final rule effective 14 August 2026, US-formed entities and US persons, including those domiciled in Indiana, no longer carry a Corporate Transparency Act filing obligation; legal risk from non-filing or inaccurate beneficial-ownership disclosure is now confined to foreign reporting companies with a US nexus. Prior enforcement risk tied to domestic beneficial-ownership non-compliance is retired for US-formed entities going forward.

1 evidence refs
Board

A federal reporting rollback and a narrow state licensing perimeter together define Indianas current financial-integrity posture.

The permanent Corporate Transparency Act domestic exemption and Indianas statutory exclusion of pure virtual-currency activity from money-transmission licensing are both structural, durable features rather than transitional developments, and neither depends on discretionary enforcement choices that could reverse quickly. Continued state securities enforcement against unregistered crypto-investment products indicates financial-integrity risk in Indiana is being managed through securities and consumer-protection channels rather than through banking-style AML supervision.

2 evidence refs
CTO

Indianas crypto-infrastructure regulatory perimeter excludes pure virtual-currency transmission from state money-transmitter licensing.

Technical architecture serving Indiana customers for pure virtual-currency exchange, custody, or transmission does not require Indiana money-transmitter licensure under IC 28-8-4.1 unless fiat money transmission is also present in the product design, though federal FinCEN money-services-business registration requirements apply independently of this state-level exclusion. Platform design decisions that combine fiat and virtual-currency transmission functions would bring the Indiana licensing requirement back into scope.

1 evidence refs
Risk

State-level AML supervisory perimeter for crypto-only activity in Indiana is narrower than federal Bank Secrecy Act coverage.

The exclusion of pure virtual-currency activity from Indianas money-transmission licensing creates a bifurcation where federal Bank Secrecy Act and FinCEN obligations apply to crypto-only operators while state-level Department of Financial Institutions supervision does not, a structural gap in state-level supervisory touch that risk functions should account for when assessing concentration of oversight across jurisdictions. Continued securities enforcement activity against crypto-investment products signals persistent risk in the retail crypto-investment segment specifically.

2 evidence refs
Operations

Corporate Transparency Act filing workflows for domestic Indiana entities are discontinued; only foreign reporting company workflows remain active.

Operational screening and onboarding workflows that previously checked for or relied upon Corporate Transparency Act beneficial-ownership filings for domestically-formed Indiana entities should be updated to reflect that such filings no longer exist following the 14 August 2026 exemption; workflows for foreign reporting companies remain unchanged.

1 evidence refs
Audit

Documentation trails previously built on Corporate Transparency Act filings for domestic Indiana entities require revision.

Audit testing of customer-due-diligence files that referenced Corporate Transparency Act beneficial-ownership filings as supporting evidence for domestically-formed Indiana corporate customers should be updated to reflect that this evidentiary source is no longer generated as of 14 August 2026; audit scope for foreign reporting company files is unchanged.

1 evidence refs
Scenario sketches

AMLA direct-supervision transition and cross-border obliged-entity evasion pathways

Illustrative scenario for analytical orientation only. As the European Unions AML Package architecture matures, the move from purely national AML supervision toward AMLA direct and indirect supervision of designated cross-border obliged entities, operating alongside the directly-applicable AMLR and per-state 6AMLD transposition, could reshape where supervisory attention concentrates and where evasion pressure migrates. A plausible structural pattern, illustrative only, is that obliged entities reassess group structuring to fall inside or outside AMLA direct-supervision thresholds depending on which posture carries lower compliance friction, with downstream effects on beneficial-ownership transparency practices in non-EEA jurisdictions linked to EU corporate groups, including US entities such as those domiciled in Indiana that sit within multinational structures. This is architecture-over-incident illustration of a possible supervisory dynamic, not an observed fact or a prediction of how any specific entity will behave.

Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact.

Standing trackers (T1–T6)
TrackerStatusNote
T1 · Russian Sanctions-Evasion Architectureno_changeNo Indiana-specific nexus identified this cycle.
T2 · EU AML Package / AMLAno_changeNot applicable — US-IN is not an EEA member.
T3 · FATF Grey Listno_changeUnited States not on FATF grey list; no Indiana-specific action.
T4 · Beneficial-Ownership Register Statusno_changeNo state-level BO register distinct from federal CTA regime.
T5 · Crypto & Digital-Asset Integrityno_changeStanding position (kiosk ban, MTL exclusion) persists unchanged.
T6 · Sanctions Regime Divergenceno_changeNo Indiana-specific sanctions-divergence signal; federally administered.
Registers

Enforcement actions

  • 6 Feb 2025
  • 30 Jan 2026
  • 9 Mar 2026
  • 1 Aug 2025
  • 17 Jun 2026
  • 30 Jun 2026
  • 1 Jan 2026
  • FinCEN issued a consent order against Brink's for operating as an unregistered money transmitter, moving bulk currency shipments across the US border between unrelated parties without BSA registration or compliance program, following a January 2025 DOJ non-prosecution agreement. 6 Feb 2025
  • OFAC designated two UK-registered digital asset exchanges connected to an Iranian businessman and sanctions evader, cited by FinCEN as an example of DASP front companies exploited to move Iran-linked funds through crypto rails accessible to US-based virtual asset users. 30 Jan 2026
  • Connecticut suspended Bitcoin Depot's banking/money-transmitter license over anti-money-laundering control lapses; the same operator runs kiosks inside Indiana Circle K stores implicated in scam-transmission complaints, illustrating cross-state supervisory exposure for a single crypto-ATM network operating in Indiana. 1 Dec 2025
  • FinCEN designated Huione Group as a foreign financial institution of primary money laundering concern, severing its access to the US financial system after the network was found to have received over $39.6 billion in 2025 tied to scam and laundering networks with US victim exposure. 1 Aug 2025

Sanctions changes

  • 18 Dec 2025
  • 14 Oct 2025
  • 30 Jan 2026
  • 1 Jun 2026
  • 16 Jun 2026
  • 1 Oct 2025
  • 16 Jan 2026
  • 19 Jun 2026
  • OFAC removed the final remaining name from its Foreign Sanctions Evaders (FSE) List, emptying the list entirely, though new names may be added at any time; this affects compliance screening obligations for all US persons and institutions, including Indiana-based financial institutions and MSBs, that maintain FSE-screening protocols. 18 Dec 2025
  • OFAC designated the Prince Group Transnational Criminal Organization network (October 2025), coordinated with UK sanctions and a simultaneous DOJ indictment of founder Chen Zhi, tied to Cambodia-based forced-labor scam compounds and crypto laundering with US victims. 14 Oct 2025
  • OFAC designated Zedcex Exchange, Ltd. and Zedxion Exchange, Ltd., two UK-registered digital asset exchanges tied to an Iranian sanctions evader, as part of continued enforcement against Iran-linked crypto shadow-banking networks. 30 Jan 2026

Regulatory horizon (register)

  • U.S. Supreme Court review of CTA constitutionality
  • Indiana crypto-ATM/kiosk operator licensing bill
  • FinCEN Corporate Transparency Act final rule (domestic-entity BOI exemption)
  • FinCEN AML/CFT Program Rule modernization finalization
  • GENIUS Act stablecoin AML/CFT rule implementation
  • Next FATF plenary review of US MER follow-up / grey list

Active schemes

  • [HIGH] Domestic BOI exemption enabling shell-layering in Indiana entities
  • [HIGH] Crypto-ATM cash-to-crypto scam conduit at Indiana retail sites
  • All-cash real estate purchases as AML blind spot
Sources
  1. Administrative Rulings | FinCEN.gov
  2. https://www.hklaw.com/en/insights/publications/2026/01/ofac-sanctions-top-5-trends-for-2026
  3. https://www.aa.com.tr/en/americas/us-targets-alleged-houthi-oil-smuggling-weapons-networks-with-new-sanctions/3801653
  4. https://www.fincen.gov/news/news-releases/fincen-removes-beneficial-ownership-reporting-requirements-us-companies-and-us
  5. https://www.amla.europa.eu/amla-takes-major-step-toward-harmonised-eu-supervision_en
  6. https://www.fincen.gov/news/news-releases/fincen-combats-financial-support-sinaloa-cartel-finding-transactions-involving
  7. https://www.fincen.gov/news/news-releases/fincen-issues-supplemental-alert-fuel-smuggling-and-tax-evasion-schemes-southern
  8. https://www.khaleejtimes.com/business/uae-central-bank-tightens-anti-money-laundering-rules
  9. https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-june-2026.html
  10. https://home.treasury.gov/news/press-releases/sb0435
  11. https://www.casinoguardian.co.uk/2026/01/27/cambodia-intensifies-crackdown-on-illegal-online-gambling-amid-fatf-scrutiny/
  12. https://home.treasury.gov/news/press-releases/sb0603
  13. https://www.federalregister.gov/documents/2026/08/14/2026-16576/beneficial-ownership-information-reporting-requirement-revision
  14. https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html
  15. https://www.hklaw.com/en/insights/publications/2026/06/what-happened-to-fincens-corporate-transparency-act
  16. https://www.in.gov/dfi/files/MTMA-Licensing-Guidance-Updated.pdf
  17. https://www.aarp.org/money/scams-fraud/indiana-crypto-kiosk-ban/
  18. https://www.ipm.org/news/2026-03-16/emergency-declaration-law-ends-cryptocurrency-atm-use-in-indiana-sidelining-about-800-units
  19. https://iga.in.gov/pdf-documents/124/2026/house/bills/HB1116/HB1116.02.COMH.pdf
  20. https://natlawreview.com/article/indiana-prohibits-virtual-currency-kiosks
  21. https://bankingjournal.aba.com/2026/04/states-tighten-reins-on-crypto-atms/
  22. https://statecapitallobbyist.com/cryptocurrency/state-by-state-how-crypto-kiosk-regulation-is-reshaping-the-virtual-currency-industry/
  23. https://law.justia.com/codes/indiana/title-28/article-8/chapter-4-1/
  24. https://indianacapitalchronicle.com/2026/02/05/indiana-lawmakers-consider-crypto-pension-investments-atm-scam-crackdown/
  25. https://www.in.gov/dfi/files/SEA-458-Guidance.pdf
  26. https://www.fincen.gov/system/files/2026-10/FinCEN-Alert-A7-Network.pdf
  27. https://ofac.treasury.gov/press-releases
  28. https://www.latintimes.com/300-million-frozen-86-compounds-closed-real-scorecard-cambodias-scam-crackdown-599446
  29. https://finance.yahoo.com/markets/crypto/articles/treasury-first-genius-act-rule-073833593.html
  30. https://www.mayerbrown.com/en/insights/publications/2026/04/out-with-the-old-in-with-the-risk-based-fincen-proposes-fundamental-reform-of-aml-cft-program-requirements
  31. U.S. Department of the Treasury
  32. FinCEN
  33. Indiana Code (via Justia)
  34. Indiana Dept. of Financial Institutions (via NMLS)
  35. Dubois County Herald
  36. National Law Review
  37. OFAC
  38. https://iga.in.gov/pdf-documents/124/2026/house/bills/HB1116/HB1116.05.ENRS.pdf
  39. https://www.recordinglaw.com/us-laws/scams-and-fraud/indiana-scam-and-fraud-laws/
  40. https://faisalkhan.com/solutions/licensing/money-transmitter-license/indiana-money-transmitter-license
  41. 1 FinCEN Advisory United States Department of the Treasury
  42. Enforcement Actions for Failure to Register as a Money Services Business | FinCEN.gov
  43. Important Information for MSBs | FinCEN.gov
  44. UNITED STATES OF AMERICA FINANCIAL CRIMES ENFORCEMENT NETWORK
  45. Fincen
  46. Application of the Definition of Money Transmitter to Brokers and Dealers in Currency and Other Commodities | FinCEN.gov
  47. MSB Registrant Search | FinCEN.gov
  48. News Releases on Unregistered Money Transmitter Enforcement Actions | FinCEN.gov
  49. 1st Review of the Suspicious Activity Reporting System (SARS) | FinCEN.gov
  50. Alerts/Advisories/Notices/Bulletins/Fact Sheets | FinCEN.gov
  51. 1 The U.S. Department of the Treasury’s (Treasury) Financial
  52. PPSI-AMLCFT-NPRM.pdf
  53. Fact Sheet: Proposed Rule to Fundamentally Reform Financial
  54. FinCEN WCHT Notice
  55. Treasury Department Publishes National Money Laundering Risk Assessment and National Terrorist Financing Risk Assessment | FinCEN.gov
  56. FinCEN Supplemental Alert on Fuel Smuggling and Tax ...
  57. FinCEN Alert on the Use of Front Companies...
  58. Fact Sheet: Proposed Rule to Strengthen and Modernize ...
  59. Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
  60. Fact Sheet: Proposed Rule to Implement the GENIUS Act’s Anti-
  61. Recent Actions | Office of Foreign Assets Control
  62. Press Releases | FinCEN.gov
  63. Inotiv, Inc. - Form 8-K - FY2025
  64. 26North BDC, Inc. - Form 40-17G - FY2025
  65. TCW ETF Trust - Form 40-17G - FY2025
  66. Outdoor Holding Co - Form 8-K - FY2025
  67. News | FinCEN.gov
  68. TCW STRATEGIC INCOME FUND INC - Form 40-17G - FY2025
  69. Papp Investment Trust - Form 40-17G - FY2025
  70. Money Services Business (MSB) Registration | FinCEN.gov
  71. Fact Sheet on MSB Registration Rule | FinCEN.gov
  72. Memorandum of Understanding
  73. Financial Crimes Enforcement Network Registration of Money Services Business
  74. Definition of Money Transmitter (Merchant Payment Processor) | FinCEN.gov
  75. Retailers keep cashing in on crypto ATMs as scams surge - ICIJ
  76. FinCEN Notice, FIN-2025-NTC1, August 4, 2025
  77. Massachusetts sues Bitcoin Depot, alleging the crypto ATM operator knowingly facilitated crypto scams - ICIJ
  78. Law enforcement, banks warn of money laundering gaps in major US crypto bill - ICIJ
  79. Amid a scam crackdown, crypto giants keep fueling bitcoin ATMs - ICIJ
  80. Crypto ATM operator Bitcoin Depot files for bankruptcy - ICIJ
  81. How Crypto ATMs in the U.S. Became A Favorite Tool for Scammers | OCCRP
  82. FinCEN Issues Notice on the Use of Convertible Virtual Currency Kiosks for Scam Payments and Other Illicit Activity | FinCEN.gov
  83. Flip Book: Investigating Crypto Scams | TRM Labs
  84. 2026 Crypto Crime Report: Scams
  85. 2026 Crypto Crime Report – Illicit Crypto Trends & Typologies | TRM Labs
  86. $15 billion seized by US originates from Iran/China bitcoin miner "theft"
  87. Questions swirl around US plans for record $15B Prince Group crypto seizure - ICIJ
  88. Blockchain Legal Library
  89. FinCEN-Advisory-CMLN-508.pdf
  90. Maduro Accused of 25 Years of Narco-Terrorism Crimes by DOJ - Bloomberg
  91. Questions on Virtual Currency
  92. Application of FinCEN’s Regulations to Persons Administering, Exchanging, or Using Virtual Currencies | FinCEN.gov
  93. FinCEN Notice, FIN-2025-NTC1, August 4, 2025
  94. Requirements for Certain Transactions Involving Convertible Virtual Currency or Digital Assets (reopening of comment period) | FinCEN.gov
  95. Virtual Asset Service Provider (VASP): Definition, Compliance & Examples
  96. Requirements for Certain Transactions Involving Convertible Virtual Currency or Digital Assets | FinCEN.gov
  97. Application of FinCEN’s Regulations to Virtual Currency Mining Operations | FinCEN.gov
  98. Application of Money Services Business regulations to the rental of computer systems for mining virtual currency | FinCEN.gov
  99. FinCEN Issues Guidance on Virtual Currencies and Regulatory Responsibilities | FinCEN.gov
  100. Request for Administrative Ruling on the Application of FinCEN’s Regulations to a Virtual Currency Payment System | FinCEN.gov
  101. FinCEN Removes Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Persons, Sets New Deadlines for Foreign Companies | FinCEN.gov
  102. Beneficial Ownership Information Reporting | FinCEN.gov
  103. Frequently Asked Questions | FinCEN.gov
  104. Interim Final Rule: Questions and Answers | FinCEN.gov
  105. Small Entity Compliance Guide | FinCEN.gov
  106. Beneficial Ownership Information Reporting Rule Fact Sheet | FinCEN.gov
  107. Fact Sheet: Beneficial Ownership Information Access and Safeguards Final Rule | FinCEN.gov
  108. Reference Materials | FinCEN.gov
  109. Small Business Resources | FinCEN.gov
  110. Financial Crimes Enforcement Network U.S. Department of the Treasury
  111. Sanctions Programs and Country Information | Office of Foreign Assets Control
  112. Civil Penalties and Enforcement Information | Office of Foreign Assets Control
  113. Sanctions List Service | Office of Foreign Assets Control
  114. 2024 Civil Penalties and Enforcement Information | Office of Foreign Assets Control
  115. 2023 Civil Penalties and Enforcement Information | Office of Foreign Assets Control
  116. Sanctions List Search Tool | Office of Foreign Assets Control
  117. Home | Office of Foreign Assets Control
  118. U.S. DEPARTMENT OF THE TREASURY OFFICE OF FOREIGN ASSETS CONTROL
  119. Additional Sanctions Lists | Office of Foreign Assets Control
  120. Jurisdictions under Increased Monitoring - 13 February 2026
  121. Jurisdictions under Increased Monitoring - 19 June 2026
  122. "Black and grey" lists
  123. Outcomes FATF Plenary, 17-19 June 2026
  124. High-Risk Jurisdictions subject to a Call for Action - 13 February 2026
  125. High-risk and other monitored jurisdictions
  126. News
  127. Money Laundering Advisory Notice: June 2026 - GOV.UK
  128. High-Risk Jurisdictions subject to a Call for Action - 19 June 2026
  129. US takes aim at real estate money laundering - ICIJ
  130. Advisory on Kleptocracy and Foreign Public Corruption
  131. 1 The U.S. Department of the Treasury’s (Treasury)
  132. 1 FIN-2022-A002 June 15, 2022 Advisory on Elder Financial Exploitation
  133. Elder Financial Exploitation: Threat Pattern & Trend ...
  134. Advisories | FinCEN.gov
  135. Financial Fraud Enforcement Task Force (FFETF) | FinCEN.gov
  136. 1 Financial Crimes Enforcement Network (FinCEN)
  137. Fraud Warning
  138. SAR Advisory Key Terms | FinCEN.gov
  139. The Opportunity Before Congress on Crypto Legislation - Chainalysis
  140. GENIUS Act Passes Senate, Paving the Way for Landmark US Crypto Legislation | TRM Labs
  141. From trading bans to total embrace, a global guide to crypto regulation
  142. Crypto regulatory affairs: CLARITY Act Senate delay creates uncertainty
  143. Crypto Regulatory Affairs: US Senators introduce framework for crypto regulation
  144. Landmark cryptocurrency legislation passes US House, to be signed into law by President Trump - ICIJ
  145. Stablecoin Bill Advances in Senate in Big Win for Crypto - Bloomberg
  146. INSTRUCTIONS
  147. United States Department of the Treasury Financial Crimes Enforcement Network - Home | FinCEN.gov
  148. Special Measures | FinCEN.gov
  149. Enforcement Actions | FinCEN.gov
  150. UNITED STATES OF AMERICA FINANCIAL CRIMES ENFORCEMENT NETWORK
  151. Regulatory Releases | FinCEN.gov
  152. Administrative Rulings | FinCEN.gov
  153. FinCEN (U.S. Department of the Treasury)
  154. U.S. Department of the Treasury
  155. Financial Action Task Force
  156. International Consortium of Investigative Journalists (ICIJ)
  157. FinCEN (U.S. Department of the Treasury)
  158. Office of Foreign Assets Control (U.S. Department of the Treasury)
  159. TRM Labs
  160. International Consortium of Investigative Journalists (ICIJ)
Coverage gaps
fim-int-2026-07-05-G001: No direct Indiana Department of Fin…
fim-int-2026-07-05-G001: No direct Indiana Department of Financial Institutions enforcement record was located in open-source search; downstream verification via in.gov/dfi records would resolve whether this reflects low enforcement volume or a state publication gap. [resolved]
fim-int-2026-07-05-G002: No confirmed parallel UK OFSI listi…
fim-int-2026-07-05-G002: No confirmed parallel UK OFSI listing status for the Zedcex and Zedxion exchanges was established; a direct check of the OFSI consolidated list would confirm whether the US-UK divergence persists or has since closed. [resolved]
fim-int-2026-07-05-G003: The finalized text and effective da…
fim-int-2026-07-05-G003: The finalized text and effective date of the FinCEN AML and CFT Program Rule are not yet available; Federal Register publication of the final rule would firm up the D6 horizon assessment. [resolved]
fim-int-2026-07-05-G004: The legislative status of any India…
fim-int-2026-07-05-G004: The legislative status of any Indiana General Assembly crypto-kiosk consumer-protection bill was not established this cycle; direct tracking of state legislative records would close this gap. [resolved]
fim-int-2026-07-05-G005: The precise order text and stated r…
fim-int-2026-07-05-G005: The precise order text and stated rationale for the Connecticut Department of Banking Bitcoin Depot suspension were not directly retrieved; primary-source confirmation of the corrected 2026-03-09 date would resolve the date discrepancy flagged in the verification challenge. [resolved]
fim-int-2026-07-14-G001: No fresh EU AML Package/AMLA transp…
fim-int-2026-07-14-G001: No fresh EU AML Package/AMLA transposition or supervisory-perimeter development located this cycle across T1/T2 sources. [resolved]
fim-int-2026-07-14-G002: Cambodia grey-listing-avoidance cla…
fim-int-2026-07-14-G002: Cambodia grey-listing-avoidance claim rests on a single Tier-4 trade-press source with no independent corroboration. [resolved]
fim-int-2026-07-14-G003: Colombia FRAA major-trafficker desi…
fim-int-2026-07-14-G003: Colombia FRAA major-trafficker designation not yet cross-checked against a primary Federal Register notice. [resolved]
fim-int-2026-07-14-G004: EU 21st sanctions package crypto-ev…
fim-int-2026-07-14-G004: EU 21st sanctions package crypto-evasion provisions sourced only via Tier-3/4 secondary coverage; no direct EU Council legal text reviewed this cycle. [resolved]
fim-int-2026-08-05-G001: No direct OFAC press release was re…
fim-int-2026-08-05-G001: No direct OFAC press release was retrieved this cycle for the Rosneft/Lukoil designation itself; reliance rests on a Tier-4 secondary summary. [resolved]
fim-int-2026-08-05-G002: No primary Treasury report URL for …
fim-int-2026-08-05-G002: No primary Treasury report URL for the March 2026 digital-asset illicit-finance-countering technologies report was retrieved this cycle. [resolved]
fim-int-2026-08-05-G003: No Sub-Saharan Africa, Central Asia…
fim-int-2026-08-05-G003: No Sub-Saharan Africa, Central Asia, or Pacific-specific findings surfaced this cycle, a documented regional-coverage gap. [resolved]
fim-int-2026-08-21-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-08-21-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): No Indiana-nexus finding was located this cycle for D1 (sanctions), D3 (enabler jurisdictions), or D4 (conflict finance); logged as a coverage gap rather than an asserted no-material-change finding. [resolved]
fim-int-2026-08-21-G002 ({'scheme': 'financial_integrity', '…
fim-int-2026-08-21-G002 ({'scheme': 'financial_integrity', 'value': 'D3'}): Tier D watch jurisdictions (KH, LA, MX, CO) were checked against the current FATF list but no Indiana-specific corridor findings were located this cycle. [resolved]
fim-int-2026-09-14-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-09-14-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): Exact statutory effective date of HEA 1116's final kiosk-prohibition language not independently confirmed beyond bill text and secondary legal commentary. [resolved]
fim-int-2026-09-14-G002 ({'scheme': 'financial_integrity', '…
fim-int-2026-09-14-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): No IGC/DFI administrative-rule-level implementing guidance for HEA 1042's non-custodial-software carve-out was retrieved this cycle. [resolved]
fim-int-2026-09-14-G003: Tier D multi-jurisdiction sweep (KH…
fim-int-2026-09-14-G003: Tier D multi-jurisdiction sweep (KH, LA, MX, CO) was not run this cycle; the union dispatch is scoped to the single bound jurisdiction US-IN per the operator's per-JID union lock. [resolved]
fim-int-2026-09-28-G001: D1-D4 and D6 domain evidence was no…
fim-int-2026-09-28-G001: D1-D4 and D6 domain evidence was not actively re-searched this cycle due to pooled search budget across a five-consumer union dispatch scoped to a single US subnational JID. [resolved]
fim-int-2026-09-28-G002: Tier D mandatory jurisdiction watch…
fim-int-2026-09-28-G002: Tier D mandatory jurisdiction watch (Cambodia, Laos, Mexico, Colombia) was not actively re-swept this cycle. [resolved]
fim-int-2026-09-28-G003: Indiana Code Title 28-8-4.1 statute…
fim-int-2026-09-28-G003: Indiana Code Title 28-8-4.1 statute text was corroborated only via a secondary code-hosting site (Justia) rather than the primary iga.in.gov statutory page this cycle. [resolved]
fim-int-2026-10-04-G001: No US-IN-specific beneficial-owners…
fim-int-2026-10-04-G001: No US-IN-specific beneficial-ownership finding was located this cycle; D2 coverage for US-IN remains thin. [resolved]
fim-int-2026-10-04-G002: The Federal Register text of the GE…
fim-int-2026-10-04-G002: The Federal Register text of the GENIUS Act interim final rule (2026-19966) was not directly retrieved this cycle; the SCRC/$10bn mechanics rest on T3 secondary coverage. [resolved]
fim-int-2026-10-04-G003: No substantive D4 conflict-finance …
fim-int-2026-10-04-G003: No substantive D4 conflict-finance finding for this cycle; no dedicated Houthi/Yemen designation beyond a negative confirmation. [resolved]
fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): Tier-D jurisdiction (KH/LA/MX/CO) watch was not independently re-researched this cycle; search budget was directed at the bound US-IN jurisdiction per the union operator lock. [open]
fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', 'value': 'D3'}): No Indiana-specific enabler-jurisdiction (D3) or conflict-finance (D4) signal was located this cycle, consistent with Indiana's profile as a sub-national US jurisdiction without independent AML supervisory architecture. [open]
fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', 'value': 'D5'}): Exact settlement date for the TradeStation Crypto, Inc. / Indiana Securities Division settlement could not be confirmed this cycle. [open]
fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', 'value': 'D3'}): No AG enforcement actions under the virtual-currency-kiosk or sweepstakes statutes located for this window. [open]
fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', 'value': 'D1'}): D1, D2, D4, D6 and D8 domains returned no Indiana-specific findings; full federal/state AML enforcement-docket and FinCEN advisory channels were not exhaustively searched this cycle given budget for a single-jurisdiction pass. [open]
FIM-GAP-001 (D2): The March 2025 CTA interim final rule exem…
FIM-GAP-001 (D2): The March 2025 CTA interim final rule exempts all US-formed entities, including Indiana LLCs and corporations, from beneficial ownership reporting, eliminating the primary federal transparency mechanism intended to unmask shell-company structures nationwide.
FIM-GAP-002 (D3): No Indiana-specific crypto-ATM/kiosk consu…
FIM-GAP-002 (D3): No Indiana-specific crypto-ATM/kiosk consumer-protection statute has been confirmed, unlike the roughly 18 US states that have passed such laws following the surge in scam-related crypto kiosk complaints; Indiana is a documented site of Bitcoin Depot/Circle K kiosk scam transmission.
FIM-GAP-003 (D2): No Indiana Department of Financial Institu…
FIM-GAP-003 (D2): No Indiana Department of Financial Institutions-specific supervisory enforcement order, penalty, or license action was identified in open-source search for the 18-month baseline window, despite the state administering money-transmitter licensing under the Uniform Money Services Act.

Evidence

Confidence-tiered claims

Virtual currency and payroll processing excluded from Indiana's Money Transmission Modernization Act (SEA 458 / IC 28-8-4.1), leaving crypto activity outside state MTL/AML supervision. [Source 1]
Probable · 1 source
Designated Sinaloa Cartel leadership figures and associated corruption networks (2026-09-29). [Source 1]
Probable · 1 source
$300M frozen, 86 scam compounds closed, 27 casinos sanctioned, 18 licenses pulled (July 2025-Aug 2026); Amnesty International disputes completeness, citing new casino approvals near known scam-compound sites. [Source 1]
Probable · 1 source
Stablecoin Certification Review Committee and $10bn consolidated-issuance threshold distinguishing state-certifiable from federally-supervised payment stablecoin issuers (Federal Register 2026-19966, effective 2026-09-30). [Source 1]
Probable · 1 source
Codify mandatory, documented risk-assessment process incorporating FinCEN's AML/CFT National Priorities as part of the internal-controls requirement. [Source 1]
Probable · 1 source
Russia-based transnational-criminal-organization network used for crypto-enabled sanctions evasion, drawing on TRM Labs on-chain analysis. [Source 1]
Probable · 1 source
Indiana's MTL regime (IC 28-8-4.1) excludes pure virtual-currency exchange, custody or transmission from licensable money transmission activity absent fiat money transmission. [Source 1]
Probable · 1 source
FinCEN's final rule, effective 2026-08-14, permanently exempts US-formed entities and US persons from Corporate Transparency Act beneficial-ownership reporting; only foreign reporting companies remain obligated; previously filed US-person data will be deleted. [Source 1]
Probable · 1 source
Indiana enacted HB1116 (signed 2026-03-09, effective immediately) banning virtual-currency kiosks statewide, enforced by the Attorney General as a deceptive-sales-act matter; roughly 900 kiosks affected. [Source 1]
Probable · 1 source
Settlement with TradeStation Crypto, Inc. requiring cessation of an unregistered crypto interest-earning program offered/sold/renewed to Indiana investors; $29,411.76 payment. [Source 1]
Probable · 1 source
Virtual-currency kiosks, effective on passage 2026-03-09, enforced by Attorney General as deceptive consumer sales act [Source 1]
Probable · 1 source
State money-transmitter licensure under the Model Money Transmission Modernization Act (effective 2024) [Source 1]
Probable · 1 source
money transmission, including entities whose fiat leg touches virtual-currency activity, administered by the Indiana Department of Financial Institutions [Source 1]
Probable · 1 source
31 U.S.C. 5318(h) BSA AML/CFT program requirement, emphasising programme effectiveness over technical compliance [Source 1]
Probable · 1 source
Indiana adopted the Model Money Transmission Modernization Act effective 2024-01-01 but excluded the virtual-currency transmission provisions from its adoption. [Source 1]
Probable · 1 source
Indiana bans the operation of virtual-currency kiosks outright, effective immediately on signature 2026-03-09, enforced via the Indiana Deceptive Consumer Sales Act rather than DFI licensing. [Source 1]
Probable · 1 source