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 — New Hampshire US-NH

Domains covered
8 of 8
Sources
121
Role actions
8
Horizon <90d
0
Jurisdiction profile
FATF status: Largely Compliant Tier: B Risk direction: Increasing Enablement vs enforcement: Mixed

NH regulates money transmission under RSA 399-G, supervised by the NH Banking Department, which operates an OFAC information-sharing MOU covering state-chartered banking organizations.

MoreFederal BSA/AML enforcement (FinCEN, USAO-NH) has been aggressive historically (Ian Freeman case) but NH's legislature has simultaneously embraced crypto via the first-in-nation Strategic Bitcoin Reserve (HB 302, 2025), creating tension between permissive digital-asset policy and AML supervisory capacity.

Key deficiencies
  • No NH-specific crypto-ATM consumer-protection/fraud-prevention statute, unlike Massachusetts, Iowa and 16+ other states that acted by late 2025
  • State's high-profile unlicensed-MSB precedent (Ian Freeman/Church of the Invisible Hand) illustrates continuing vulnerability of disguised religious/nonprofit fronts for bitcoin kiosk laundering
  • Reliance on federal AML examination capacity (IRS, FinCEN) that has been reduced nationally, thinning oversight of NH-domiciled MSBs and crypto kiosk operators
Recent developments (18m)
  • Governor Kelly Ayotte signed HB 302 in May 2025, making New Hampshire the first U.S. state to establish a Strategic Bitcoin Reserve authorizing the treasurer to invest up to 5% of state funds in bitcoin
  • FinCEN issued Notice FIN-2025-NTC1 (Aug 4, 2025) on CVC kiosk illicit-finance risk, explicitly citing prior USAO-District of New Hampshire prosecutions as typology evidence
  • New Hampshire Business Finance Authority's bitcoin-backed municipal bond plan received a Ba2 rating from Moody's in March 2026, an unprecedented sub-national bitcoin-linked debt instrument
  • National rollback of crypto AML oversight (IRS AML examiner headcount down 33% in FY2025; OCC-chartered crypto firms gaining exemption from state regulators) directly affects NH-domiciled money-transmission and crypto-kiosk populations

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

Brief

Lead signal

Lead Signal

New Hampshire enacted two statutes this cycle that, read together, describe a jurisdiction sharpening its posture at the retail edge of digital-asset activity while deliberately widening an exemption at the infrastructure-operation layer. Chapter 187 (SB 482), signed by the Governor on 19 June 2026 and taking effect 16 December 2026, imposes a $2,000-per-day per-customer transaction cap on digital asset transaction kiosks, a 48-hour hold with a refund right on a customer's first transaction, mandatory identity verification, fraud-risk warnings, and wallet screening against flagged addresses via blockchain analytics. The measure followed testimony from the Attorney General's office estimating roughly 250 such kiosks operating statewide and losses exceeding $2.6 million in a single municipality, Hampton, attributed to elder-fraud laundering through these machines. At the same time, HB 639 (the Blockchain Basic Laws), current law as of 18 August 2026, created a new statutory chapter exempting node operators, home and business digital-asset miners, and stakers from money-transmitter licensing under RSA 399-G, alongside a parallel exemption from securities treatment under RSA 421-B for mining and staking conducted with personal funds.

Read full brief

Lead Signal

New Hampshire enacted two statutes this cycle that, read together, describe a jurisdiction sharpening its posture at the retail edge of digital-asset activity while deliberately widening an exemption at the infrastructure-operation layer. Chapter 187 (SB 482), signed by the Governor on 19 June 2026 and taking effect 16 December 2026, imposes a $2,000-per-day per-customer transaction cap on digital asset transaction kiosks, a 48-hour hold with a refund right on a customer's first transaction, mandatory identity verification, fraud-risk warnings, and wallet screening against flagged addresses via blockchain analytics. The measure followed testimony from the Attorney General's office estimating roughly 250 such kiosks operating statewide and losses exceeding $2.6 million in a single municipality, Hampton, attributed to elder-fraud laundering through these machines. At the same time, HB 639 (the Blockchain Basic Laws), current law as of 18 August 2026, created a new statutory chapter exempting node operators, home and business digital-asset miners, and stakers from money-transmitter licensing under RSA 399-G, alongside a parallel exemption from securities treatment under RSA 421-B for mining and staking conducted with personal funds.

The pairing is the significant architecture here: New Hampshire is narrowing its anti-money-laundering perimeter precisely at the point where cash converts to and from digital assets through unattended kiosks, while simultaneously widening the exemption boundary for the upstream infrastructure that makes those assets exist and move. That is not a uniform liberalisation or a uniform tightening; it is a bifurcated enabler profile, and it is the kind of structural signal that a single enforcement action would not capture.

Other Developments

Examination powers strengthened. HB 1207, signed 10 July 2026, amended RSA 399-G to grant the New Hampshire Banking Department commissioner new powers effective 1 October 2026: the authority to require a licensee's books and records to be translated into English (at the licensee's expense, with an interpreter also chargeable to the licensee), and a new duty requiring delegate locations to post a certificate of authority. The Department's standing supervisory population, per its FY2026 annual report, comprised 202 active money-transmitter licensees and 1,638 authorised delegates — the base against which these expanded examination powers now apply.

A routine bank acquisition. Hometown Financial Group, a Massachusetts-based lender, agreed to acquire Primary Bank of Bedford, New Hampshire, for $160 million, adding roughly $743 million in assets and four New Hampshire branches. Nothing in the reporting identifies an anti-money-laundering or sanctions dimension to the transaction; it reads as ordinary community-bank consolidation rather than a supervisory or integrity event, though it is noted here as the only commercial-activity development material to New Hampshire this cycle.

Cross-Monitor Connections

The kiosk-specific transaction limits and hold periods in SB 482 sit squarely at the boundary between financial-integrity architecture and payments-consumer-protection framing: the same statute that this brief reads as an anti-money-laundering control at the cash-conversion point is, from a payments-conduct perspective, a fraud-prevention and consumer-safeguard measure for an identical population of kiosk users. Similarly, HB 639's exemption of node operators, miners and stakers from money-transmitter licensing is a financial-integrity perimeter question here, but the same statutory language also defines the boundary of crypto-specific licensing obligations tracked elsewhere. Readers following either the payments or the crypto-regulatory treatment of New Hampshire this cycle will recognise the same two instruments described from a different vantage point.

Outlook

The kiosk regime under SB 482 takes effect on 16 December 2026, and the practical test of its anti-money-laundering value will be whether the $2,000 daily cap, the 48-hour hold on first transactions, and the blockchain-analytics wallet screening actually reduce the elder-fraud laundering volume that motivated the bill, or whether operators and bad actors adapt around a per-kiosk, per-customer limit. The Banking Department's new translated-records and interpreter authority under HB 1207, effective 1 October 2026, will be worth watching for how actively it is used in examinations of the state's money-transmitter population, particularly where firms operate with multilingual customer bases or offshore documentation. New Hampshire's infrastructure-layer exemption under HB 639 remains current law with no indication of near-term revisitation, so the bifurcated posture described above should be read as a durable structural feature of the state's regime rather than a transitional arrangement awaiting correction.

Earlier periodic briefs (3)
25 Oct 2026 · fim-2026-10-25

Lead Signal

New Hampshire enacted two statutes that, read together, describe a jurisdiction sharpening its posture at the retail edge of digital-asset activity while deliberately widening an exemption at the infrastructure-operation layer. Chapter 187 (SB 482), signed by the Governor on 19 June 2026 and taking effect 16 December 2026, imposes a $2,000-per-day per-customer transaction cap on digital asset transaction kiosks, a 48-hour hold with a refund right on a customer's first transaction, mandatory identity verification, fraud-risk warnings, and wallet screening against flagged addresses via blockchain analytics. The measure followed testimony from the Attorney General's office estimating roughly 250 such kiosks operating statewide and losses exceeding $2.6 million in a single municipality, Hampton, attributed to elder-fraud laundering through these machines. At the same time, HB 639 (the Blockchain Basic Laws), current law as of 18 August 2026, created a new statutory chapter exempting node operators, home and business digital-asset miners, and stakers from money-transmitter licensing under RSA 399-G, alongside a parallel exemption from securities treatment under RSA 421-B for mining and staking conducted with personal funds.

The pairing is the significant architecture here: New Hampshire is narrowing its anti-money-laundering perimeter precisely at the point where cash converts to and from digital assets through unattended kiosks, while simultaneously widening the exemption boundary for the upstream infrastructure that makes those assets exist and move. That is not a uniform liberalisation or a uniform tightening; it is a bifurcated enabler profile, and it is the kind of structural signal that a single enforcement action would not capture.

Other Developments

Examination powers strengthened. HB 1207, signed 10 July 2026, amended RSA 399-G to grant the New Hampshire Banking Department commissioner new powers effective 1 October 2026: the authority to require a licensee's books and records to be translated into English (at the licensee's expense, with an interpreter also chargeable to the licensee), and a new duty requiring delegate locations to post a certificate of authority. The Department's standing supervisory population, per its FY2026 annual report, comprised 202 active money-transmitter licensees and 1,638 authorised delegates — the base against which these expanded examination powers now apply.

A routine bank acquisition. Hometown Financial Group, a Massachusetts-based lender, agreed to acquire Primary Bank of Bedford, New Hampshire, for $160 million, adding roughly $743 million in assets and four New Hampshire branches. Nothing in the reporting identifies an anti-money-laundering or sanctions dimension to the transaction; it reads as ordinary community-bank consolidation rather than a supervisory or integrity event, though it is noted here as the only commercial-activity development material to New Hampshire.

Cross-Monitor Connections

The kiosk-specific transaction limits and hold periods in SB 482 sit squarely at the boundary between financial-integrity architecture and payments-consumer-protection framing: the same statute that this brief reads as an anti-money-laundering control at the cash-conversion point is, from a payments-conduct perspective, a fraud-prevention and consumer-safeguard measure for an identical population of kiosk users. Similarly, HB 639's exemption of node operators, miners and stakers from money-transmitter licensing is a financial-integrity perimeter question here, but the same statutory language also defines the boundary of crypto-specific licensing obligations tracked elsewhere. Readers following either the payments or the crypto-regulatory treatment of New Hampshire will recognise the same two instruments described from a different vantage point.

Outlook

The kiosk regime under SB 482 takes effect on 16 December 2026, and the practical test of its anti-money-laundering value will be whether the $2,000 daily cap, the 48-hour hold on first transactions, and the blockchain-analytics wallet screening actually reduce the elder-fraud laundering volume that motivated the bill, or whether operators and bad actors adapt around a per-kiosk, per-customer limit. The Banking Department's new translated-records and interpreter authority under HB 1207, effective 1 October 2026, will be worth watching for how actively it is used in examinations of the state's money-transmitter population, particularly where firms operate with multilingual customer bases or offshore documentation. New Hampshire's infrastructure-layer exemption under HB 639 remains current law with no indication of near-term revisitation, so the bifurcated posture described above should be read as a durable structural feature of the state's regime rather than a transitional arrangement awaiting correction.

4 Oct 2026 · fim-2026-10-04

Lead Signal

The principal development bearing on New Hampshire-licensed money transmitters this period is federal rather than state-originated: FinCEN, jointly with federal banking agencies, proposed on 10 April 2026 a fundamental reform of Bank Secrecy Act AML/CFT program-rule requirements, covering banks, casinos and card clubs, and money services businesses. The proposal would reset minimum standards for AML programs and would require every AML program to explicitly incorporate countering the financing of terrorism, a structural integration of the AML and CFT pillars rather than treating CFT as a secondary add-on. The proposal has not been finalised, and no primary Federal Register text was retrieved this period, so this development is recorded at Probable confidence on the strength of two independent trade-press sources.

Other Developments

New Hampshire's own AML/CFT architecture is unchanged. The state's standing regime rests on RSA 399-G, the money-transmitter licensing statute, with RSA 399-G:17 requiring licensees to create and implement plans to comply with the Bank Secrecy Act. This governance obligation was illustrated in practice by the New Hampshire Banking Department's 2025 order to show cause against BAM Trading Services Inc., a controlling-person BSA/AML compliance matter that demonstrates the Department's willingness to exercise its enforcement leverage under the existing statute.

Cross-Monitor Connections

The FinCEN NPRM, once finalised, would have direct bearing on how New Hampshire's money-transmitter licensees — including crypto-asset operators licensed under the state's RSA 399-G regime — structure their AML programs going forward, connecting this federal-level development to the state's digital-asset licensing perimeter tracked separately.

Outlook

The FinCEN NPRM is not yet in force; its expected impact date carries a year-level uncertainty band centred on early 2027. Primary-source retrieval of the Federal Register text, once available, would allow this development's confidence to move beyond Probable. New Hampshire's own RSA 399-G baseline, including the BSA-compliance-plan obligation at RSA 399-G:17, remains the governing framework for the state's money transmitters in the interim.

14 Jul 2026 · fim-2026-07-14

Lead Signal

New Hampshire enters this reporting cycle exhibiting a structural tension between two simultaneous trajectories: an accelerating embrace of bitcoin as a sovereign treasury instrument, and a contracting federal supervisory apparatus that the state depends on almost entirely for crypto-asset AML oversight. In May 2025 New Hampshire became the first US state to enact a legislated Strategic Bitcoin Reserve, with House Bill 302 authorizing the state treasury to hold up to five percent of state funds in bitcoin or digital assets exceeding a five-hundred-billion-dollar market capitalization threshold, of which bitcoin is currently the only qualifying instrument (fim-2026-W28-001). That legislative posture was reinforced in March 2026 when the New Hampshire Business Finance Authority received a provisional Ba2 rating from Moodys Ratings for a limited-recourse, pass-through bitcoin-backed conduit bond structure that places no state credit or public funds at risk (fim-2026-W28-002).

Assessed against this same window, the federal examination capacity New Hampshire relies on, in the absence of any dedicated state-level crypto-AML examination unit, contracted sharply: Internal Revenue Service Bank Secrecy Act and AML examiner headcount assigned to money-services-business and crypto-firm oversight fell thirty-three percent in fiscal year 2025, from two hundred eight agents to one hundred thirty nine (fim-2026-W28-004). Read together, these developments support an assessed key judgment that New Hampshire simultaneous embrace of bitcoin as a sovereign treasury asset alongside its absence of state-level crypto-AML provenance controls constitutes a structural, not episodic, enabler gap, compounded by a two-sided supervisory deficit in which federal examination capacity and independent state-level examination capability are both thinning at once.

Other Developments

The Ian Freeman precedent continues to anchor New Hampshire enabler-jurisdiction posture. The Ian Freeman and Church of the Invisible Hand scheme disabled know-your-customer features on bitcoin kiosks, laundered scam proceeds through bank accounts opened under ostensible religious-nonprofit fronts, and never registered as a money services business with FinCEN, and it remains the primary evidentiary basis for national FinCEN convertible-virtual-currency kiosk typology guidance (fim-2026-W28-006). An appellate court affirmed the underlying federal conviction and sentence in July 2025, representing continued enforcement follow-through within the current reporting window (fim-2026-W28-007).

FinCEN nationwide kiosk advisory formalized red-flag indicators for convertible virtual currency kiosk suspicious-activity-report filing in its August 2025 notice, citing prior prosecutions from the District of New Hampshire directly, and recording that the FBI Internet Crime Complaint Center logged more than ten thousand nine hundred fifty-six kiosk-related complaints in 2024, a ninety-nine percent year-on-year increase, with reported losses of approximately two hundred forty-six point seven million dollars (fim-2026-W28-003). The elder-fraud cash-to-bitcoin conversion pipeline that the advisory targets remains active nationally, including within outlets present in New Hampshire retail footprint, converting scam-victim cash instantly into bitcoin routed through cross-border laundering networks connected to Southeast Asian scam-compound operations (fim-2026-W28-012).

Bitcoin Depot exit from the crypto-ATM market removes one node from that same conversion architecture. The operator filed for Chapter 11 bankruptcy in May 2026, having operated more than nine thousand kiosk locations globally as of August 2025, and cited stringent state and municipal compliance obligations, transaction limits, and litigation including Massachusetts and Iowa attorney-general lawsuits as drivers of its exit (fim-2026-W28-005).

Beneficial-ownership visibility narrows at the federal level. A FinCEN interim final rule from March 2025 exempts all domestic reporting companies, including New Hampshire-formed limited liability companies and corporations, from Corporate Transparency Act beneficial-ownership reporting, leaving only foreign entities registered to do business in the state subject to filing obligations (fim-2026-W28-008).

OFAC sanctions cadence continued at the national level with direct application to New Hampshire regulated firms through standard US-person jurisdiction and the standing New Hampshire Banking Department information-sharing memorandum of understanding with OFAC. Exodus Movement, a self-custody wallet software provider, settled with OFAC in February 2026 over apparent sanctions violations (fim-2026-W28-009), and Gracetown, Inc. was assessed a civil monetary penalty in December 2025 (fim-2026-W28-010); New Hampshire, as a US state, retains no independent sanctions-designation authority of its own (fim-2026-W28-015).

Legislative horizon items bear directly on the state crypto-forward posture. Federal regulators must finalize GENIUS Act stablecoin implementing regulations ahead of a January 2027 deadline (fim-2026-W28-013), while law-enforcement and banking groups have warned that the pending Clarity Act market-structure bill could create AML oversight gaps through exemptions for decentralized and automated crypto services (fim-2026-W28-014).

Cross-Monitor Connections

The crypto-ATM elder-fraud conversion pipeline and the market exit of Bitcoin Depot carry consumer-fraud monitoring relevance beyond this monitor own AML, CTF and CPF scope, and have accordingly been flagged to FCW for its information-operations and financial-fraud coverage (fim-2026-W28-005, fim-2026-W28-012). The underlying architecture, in which cash deposited into nationally distributed kiosks converts instantly into bitcoin before moving through cross-border laundering networks linked to Southeast Asian scam-compound operations, sits at the intersection of consumer-protection failure and cross-border illicit finance that FCW is positioned to track from the demand side, even where this assessment is anchored to the New Hampshire-specific enabler and supervisory-capacity dimensions.

Outlook

Three regulatory horizon items will determine whether New Hampshire structural tension resolves toward tighter provenance control or further divergence. Finalization of GENIUS Act implementing regulations ahead of the January 2027 deadline is assessed as improving for custody and AML-provenance expectations applicable to state-level digital-asset programmes such as the Strategic Bitcoin Reserve and bitcoin-bond conduit (fim-reg-2026-101). Continued build-out of the Strategic Bitcoin Reserve allocation toward its statutory five percent cap during 2026 leaves custody, audit and AML-provenance controls for treasury-held bitcoin as an open supervisory question with an uncertain trajectory (fim-reg-2026-102). Passage or failure of the Clarity Act ahead of the 2026 midterm cycle is assessed as carrying a worsening risk direction for the federal crypto-AML perimeter within which New Hampshire crypto-forward money-services and kiosk population operates (fim-reg-2026-103). None of these developments has yet resolved the compounding two-sided supervisory gap identified this cycle.

Domain intelligence (D1–D8)

D1 Sanctions

no_changeno_changestanding position

Sanctions Architecture and Evasion

New Hampshire has no independent sanctions-designation authority of its own. As a US state, all sanctions designations and delistings applicable to New Hampshire-regulated financial and virtual-asset firms flow uniformly from the Office of Foreign Assets Control, transmitted through the standing New Hampshire Banking Department information-sharing memorandum of understanding with OFAC (fim-2026-W28-015). This is a structural provenance point rather than an enforcement gap: the absence of a distinct state sanctions regime reflects the constitutional allocation of foreign-affairs power to the federal government, and it applies identically to every US state, not to New Hampshire specifically.

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Within that uniform architecture, the national OFAC enforcement cadence continued this cycle in ways directly applicable to New Hampshire crypto-forward regulated environment. Exodus Movement, a self-custody crypto wallet software provider, reached a settlement with OFAC in February 2026 for apparent sanctions violations, establishing standard US-person jurisdiction over virtual-asset software firms operating within New Hampshire regulatory environment even where the firm itself has no state-specific nexus (fim-2026-W28-009). Separately, OFAC assessed a civil monetary penalty against Gracetown, Inc. in December 2025, part of the continuing national enforcement cadence that New Hampshire-chartered banking organizations monitor under the standing information-sharing arrangement with the state banking department (fim-2026-W28-010).

Applying an architecture-over-incident lens, neither the Exodus Movement settlement nor the Gracetown penalty constitutes a New Hampshire-specific sanctions-evasion architecture; both are data points generated by the uniform federal enforcement structure that New Hampshire, like every other US state, sits beneath. What is analytically significant is the absence of any documented New Hampshire-specific divergence from that national regime this cycle. New Hampshire-chartered banking organizations continue to apply the identical federal OFAC list that governs the rest of the US financial system, and no jurisdiction-level sanctions-evasion transit corridor, procurement route, or divergence point specific to New Hampshire has been identified. Given the state constitutional inability to operate an autonomous sanctions authority, this uniformity is the expected structural condition rather than a finding of enforcement adequacy or inadequacy in its own right.

The Exodus Movement settlement carries a secondary significance for New Hampshire given the state crypto-forward posture more broadly. New Hampshire hosts a Moodys-rated bitcoin-backed conduit bond and a legislated Strategic Bitcoin Reserve, and the extension of standard OFAC self-custody-software jurisdiction to a wallet-software provider signals that the same federal sanctions architecture applicable to any US virtual-asset firm will apply equally to whatever custody, wallet, or software infrastructure New Hampshire state-level crypto programmes come to rely upon, without any distinct state-level sanctions carve-out or additional protection.

Outlook

No New Hampshire-specific sanctions-architecture development is currently on the near-term regulatory horizon beyond the continuing national OFAC cadence. The next material watch point is any OFAC Russia-programme or other designation action touching a New Hampshire-chartered or New Hampshire-domiciled financial institution directly, which would test for the first time whether the state uniform-application posture holds under a jurisdiction-specific designation rather than a generalized national action. Given New Hampshire complete dependence on the federal sanctions-designation apparatus, and the absence of any state-level mechanism to accelerate, delay, or diverge from federal listings, the sanctions-architecture posture for this jurisdiction is best read as a passthrough of the broader national trajectory rather than an independent variable, and its trajectory this cycle is assessed as stable.

Judgment: No NH-specific sanctions-evasion signal identified this cycle. Uncertain
Cumulative analysis

Sanctions Architecture and Evasion — Cumulative Analysis

This is the first cycle of structured tracking for New Hampshire under the sanctions-architecture domain, and the baseline it establishes is one of structural passthrough rather than independent posture. New Hampshire has no autonomous sanctions-designation authority; every designation and delisting applicable to New Hampshire-regulated financial and virtual-asset firms flows from the Office of Foreign Assets Control through the standing New Hampshire Banking Department information-sharing memorandum of understanding with OFAC (fim-2026-W28-015). That structural fact, an artifact of the constitutional allocation of foreign-affairs power to the federal government rather than any New Hampshire-specific choice, is the fixed backdrop against which every subsequent cycle enforcement data point should be read.

Within that backdrop, the national OFAC enforcement cadence recorded in this baseline cycle includes the February 2026 settlement with Exodus Movement, a self-custody wallet software provider, over apparent sanctions violations (fim-2026-W28-009), and the December 2025 civil monetary penalty assessed against Gracetown, Inc. (fim-2026-W28-010). Both actions apply to New Hampshire-regulated entities through standard US-person jurisdiction and the standing information-sharing arrangement, and neither reflects a New Hampshire-specific sanctions-evasion architecture, procurement network, or divergence point. No such state-specific architecture has been identified in this baseline research pass.

The analytically significant baseline finding is therefore one of absence: the absence, this cycle, of any documented New Hampshire-specific sanctions-evasion channel, transit corridor, or list-divergence point, set against a state that is simultaneously establishing itself as the most crypto-forward jurisdiction in the country through a legislated Strategic Bitcoin Reserve and a Moodys-rated bitcoin-backed conduit bond. The extension of standard OFAC jurisdiction to a self-custody wallet-software provider in the Exodus Movement action is a relevant marker for that broader posture, since it demonstrates that the same uniform federal sanctions architecture will reach whatever custody or software infrastructure New Hampshire own state-level crypto programmes eventually depend upon, without any distinct state-level carve-out.

Going forward, the tracking priority for this domain is narrow and specific: whether any future OFAC designation action names a New Hampshire-chartered or New Hampshire-domiciled institution directly, which would be the first genuine test of whether the uniform-application posture holds under jurisdiction-specific rather than generalized national pressure. Absent such an event, this domain trajectory for New Hampshire is properly read as a passthrough of the national sanctions-enforcement trend rather than an independent variable, and is assessed as stable at this baseline point.

domain_sub_briefs · D1 · Cumulative analysis

D2 Beneficial Ownership

no_changeno_changestanding position

Beneficial Ownership and Corporate Transparency

New Hampshire sits outside the European Union Anti-Money Laundering Package direct perimeter entirely; as a US state, its corporate-transparency exposure runs through the federal Corporate Transparency Act framework administered by FinCEN, not through any EU-level instrument. The directly relevant development for New Hampshire this cycle is a March 2025 interim final rule in which FinCEN exempted all domestic reporting companies, including New Hampshire-formed limited liability companies and corporations, from Corporate Transparency Act beneficial-ownership-information reporting; only foreign entities registered to do business in New Hampshire remain subject to the filing obligation (fim-2026-W28-008). Applying an architecture-over-incident lens, this is a durable structural narrowing of federal beneficial-ownership visibility into New Hampshire-domiciled corporate structures, not a single-instance regulatory event, and the standing beneficial-ownership tracker for this jurisdiction has moved to a deteriorating trajectory as a direct consequence.

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Globally, the European Union Anti-Money Laundering Package sets the structural direction toward which beneficial-ownership and corporate-transparency regulation elsewhere is converging, even though it does not apply to New Hampshire directly. That package now comprises three distinct instruments: the directly applicable Anti-Money Laundering Regulation, known as the AMLR (Regulation (EU) 2024/1624); the sixth Anti-Money Laundering Directive, or 6AMLD, which each EU member state transposes into national law individually; and the Anti-Money Laundering Authority Regulation (Regulation (EU) 2024/1620), which establishes the Anti-Money Laundering Authority itself and defines a supervisory perimeter under which the Authority will directly or indirectly supervise a defined population of cross-border obliged entities, shifting supervision away from a purely national-authority model toward a hybrid European Union-level regime. This architecture is durable structural backdrop against which any jurisdiction beneficial-ownership posture, including New Hampshire, can be read comparatively; it does not itself apply to New Hampshire-formed entities, and per-member-state transposition tracking of the sixth Anti-Money Laundering Directive is correspondingly not applicable to this jurisdiction, which sits outside the European Economic Area entirely.

Read against that backdrop, the New Hampshire domestic exemption moves in the opposite direction from the European Union trajectory: where the European Union architecture is consolidating beneficial-ownership visibility upward toward a hybrid supervisory authority, the federal exemption of domestic reporting companies narrows visibility into New Hampshire-formed entities specifically, leaving only foreign entities registered to do business in the state subject to beneficial-ownership filing. The practical effect is that beneficial-ownership information for the substantial majority of New Hampshire corporate structures, including any entities interposed within the state Strategic Bitcoin Reserve custody or bond-conduit arrangements, is no longer collected at the federal beneficial-ownership registry level, absent some other applicable disclosure requirement.

The federal exemption also interacts with the enabler-jurisdiction dimension addressed elsewhere in this cycle: the Ian Freeman scheme relied in part on ostensible religious and nonprofit fronts to obscure beneficial control of accounts receiving money-transmission proceeds, a technique that beneficial-ownership disclosure exists specifically to counter (fim-2026-W28-006). A narrower federal domestic reporting-company disclosure regime does not resolve that class of front-entity risk, and its removal for domestic filers arguably widens the pool of undisclosed New Hampshire-formed vehicles that could in principle be used for equivalent front-entity structuring going forward. Separately, no New Hampshire Treasurer disclosure documentation describing beneficial-ownership or provenance-screening procedures for state-acquired bitcoin holdings has been located, leaving the beneficial-ownership dimension of the Strategic Bitcoin Reserve itself an open question this cycle.

Outlook

The near-term watch point for New Hampshire beneficial-ownership posture is any further FinCEN final-rule action either restoring or additionally narrowing the domestic beneficial-ownership-information reporting scope established by the March 2025 interim final rule. No New Hampshire state-level legislative response addressing the resulting visibility gap has been identified this cycle. Given the deteriorating trajectory already recorded on the standing beneficial-ownership tracker, and the structural nature of the federal exemption, the analytically significant question going forward is whether any other disclosure mechanism, state-level or federal, will substitute for the visibility lost at the Corporate Transparency Act registry level, particularly with respect to entities associated with the state crypto-forward treasury and bond-conduit programmes.

Judgment: No NH-specific beneficial-ownership development found this cycle. Uncertain
Cumulative analysis

Beneficial Ownership and Corporate Transparency — Cumulative Analysis

This is the first cycle of structured tracking for New Hampshire under the beneficial-ownership domain, and the baseline finding is a structural narrowing of federal visibility rather than a strengthening. New Hampshire is a non-EEA jurisdiction whose corporate-transparency exposure runs entirely through the federal Corporate Transparency Act framework, not through any European instrument. In March 2025, FinCEN exempted all domestic reporting companies, including New Hampshire-formed limited liability companies and corporations, from beneficial-ownership-information reporting, leaving only foreign entities registered to do business in the state subject to the filing obligation (fim-2026-W28-008). This baseline development has already moved the standing beneficial-ownership tracker for New Hampshire to a deteriorating trajectory.

The durable structural backdrop against which this and future cycles should be read is the European Union Anti-Money Laundering Package, which does not apply to New Hampshire directly but sets the comparative global direction of travel. That package comprises three distinct instruments: the directly applicable Anti-Money Laundering Regulation (Regulation (EU) 2024/1624), the sixth Anti-Money Laundering Directive transposed individually by each member state, and the Anti-Money Laundering Authority Regulation (Regulation (EU) 2024/1620), which establishes a supervisory perimeter shifting oversight from purely national authorities toward a hybrid European Union-level regime. New Hampshire, as a non-EEA jurisdiction, sits outside this perimeter, and per-member-state transposition tracking is not applicable here; the European architecture is recorded as comparative backdrop, not as a New Hampshire development.

Against that backdrop, New Hampshire own trajectory over this baseline cycle runs counter to the direction of the European consolidation: visibility into New Hampshire-formed entities is narrowing at the federal level precisely as the European Union model is centralizing beneficial-ownership supervision upward. This baseline cycle also establishes a connective finding worth carrying forward: the Ian Freeman enabler-jurisdiction scheme relied on ostensible religious and nonprofit fronts to obscure beneficial control of laundering-proceeds accounts (fim-2026-W28-006), a technique that beneficial-ownership disclosure exists to counter, and the newly narrowed domestic reporting-company regime does not resolve that class of risk going forward. A further baseline gap identified this cycle is the absence of any New Hampshire Treasurer documentation on beneficial-ownership or provenance screening for state-acquired bitcoin held within the Strategic Bitcoin Reserve, leaving that specific transparency question unresolved as tracking continues.

Future cycles should watch for any further FinCEN rulemaking narrowing or restoring domestic reporting-company scope, any New Hampshire state-level legislative response to the resulting visibility gap, and any Treasurer-level disclosure addressing beneficial-ownership or provenance screening for state-held digital assets. Absent such developments, the deteriorating trajectory recorded at this baseline stands as the operative assessment.

domain_sub_briefs · D2 · Cumulative analysis

D3 Enabler Jurisdictions

watchmaterial_change

Enabler Jurisdictions and Professional Facilitators

New Hampshire's status as an enabler jurisdiction this cycle is defined by simultaneity rather than direction. HB 639, current law as of 18 August 2026, created a new statutory chapter exempting node operators, home and business digital-asset miners, and stakers from money-transmitter licensing under RSA 399-G, and extended a parallel exemption from securities treatment under RSA 421-B where mining or staking is conducted with personal funds. This deepens a posture the state had already established: New Hampshire is one of a small number of jurisdictions that does not require a licence for standalone virtual-currency transmission, and HB 639 extends that permissiveness explicitly to the infrastructure-operation layer of the crypto ecosystem — the entities that run the nodes, mine the assets, and validate the chains, rather than the entities that convert those assets to and from dollars for customers.

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Against that widening at the infrastructure layer, the same legislative session narrowed the state's posture at the retail cash-conversion point. SB 482 (Chapter 187), signed 19 June 2026 and effective 16 December 2026, imposes a $2,000-per-day per-customer transaction cap, a 48-hour hold with refund right on first transactions, mandatory identity verification, fraud-risk warnings, and blockchain-analytics wallet screening specifically on digital asset transaction kiosks. The bill followed Attorney General testimony estimating roughly 250 such kiosks statewide and losses exceeding $2.6 million in Hampton alone, attributed to a documented elder-fraud laundering channel.

The analytical significance of reading these two instruments together is that New Hampshire cannot be filed as simply "permissive" or simply "tightening" this cycle. It is doing both, at two different points in the same value chain, and the exemption from licensing for infrastructure operators remains current law with no indication the kiosk tightening will be extended upstream to reach it. A jurisdiction that exempts the production and validation layer from licensing while regulating the retail conversion layer is making a considered choice about where its enforcement resources and consumer-protection concerns are best deployed — and the absence of any move to licence miners, stakers, or node operators is itself a signal about where New Hampshire does not intend to extend its perimeter, at least for now.

Outlook

The durability of this bifurcated posture will be tested by whether other states follow New Hampshire's lead on either half of the pairing. If the kiosk-specific consumer protections under SB 482 prove effective at reducing elder-fraud losses once they take effect on 16 December 2026, other enabler jurisdictions with similarly permissive infrastructure-exemption regimes may adopt comparable retail-layer controls without disturbing their underlying licensing exemptions for miners and node operators. Conversely, if losses persist after the kiosk rules take effect, pressure may build to extend scrutiny upstream, though nothing in the current legislative record suggests that is imminent. For now, New Hampshire's structural choice — exempt the infrastructure, regulate the retail conversion point — stands as enacted and should be read as a considered design rather than an unresolved gap.

Judgment: HB 639's statutory exemption of node operators/miners/stakers from MTL licensing deepens NH's documented posture as a deliberately permissive jurisdiction for crypto infrastructure, while SB 482 simultaneously tightens the retail cash-conversion point -- a bifurcated enabler profile. Probable
Cumulative analysis

Enabler Jurisdictions and Professional Facilitators — Cumulative Analysis

This is the first cycle of structured tracking for New Hampshire under the enabler-jurisdiction domain, and it establishes New Hampshire as a national reference case rather than a peripheral one. The Ian Freeman and Church of the Invisible Hand scheme, which disabled know-your-customer controls on bitcoin kiosks and laundered scam proceeds through bank accounts opened under ostensible religious-nonprofit fronts including the Shire Free Church, the Church of the Invisible Hand, and the Crypto Church of New Hampshire, without ever registering as a money services business with FinCEN, is the primary evidentiary basis for FinCEN own national convertible-virtual-currency kiosk typology guidance (fim-2026-W28-006). New Hampshire is therefore the origin jurisdiction of a laundering typology that now operates as national doctrine rather than local precedent.

Enforcement follow-through on that specific scheme has continued within this baseline window: an appellate court affirmed the underlying federal conviction and sentence in July 2025 (fim-2026-W28-007), correcting what had been an understated picture of New Hampshire-specific enforcement continuity. That follow-through is a genuine and durable enforcement data point, but it addresses only the disrupted scheme itself, not the underlying structural design gap that made front-entity money-transmission laundering possible in New Hampshire in the first place: the ease with which a nonprofit or religious front can open bank accounts and conduct unlicensed money transmission before registration requirements are triggered.

That structural design gap is independently confirmed by a second baseline finding: unlike at least eighteen other US states, including Massachusetts, that had enacted crypto-ATM-specific consumer-protection statutes by September 2025, New Hampshire continues to rely only on general fraud and money-services-business law and federal advisories to address the cash-to-crypto elder-fraud vector (fim-2026-W28-011). Read through the enabler-jurisdiction capacity-versus-choice distinction, this reflects legislative choice or inertia rather than incapacity, since New Hampshire possesses the same general legislative capacity as its peer states that have already closed this gap. The same nationally distributed kiosk footprint that channels the broader elder-fraud conversion pipeline documented this cycle runs through New Hampshire retail environment as well (fim-2026-W28-012), meaning the enabler dimension is not confined to the disrupted Freeman precedent alone but extends to an ongoing, unaddressed statutory design question.

This baseline assessment also establishes a durable cross-domain linkage worth carrying into future cycles: the federal examination-capacity contraction recorded elsewhere this cycle is the primary detection mechanism for any future comparable front-entity scheme in New Hampshire, and its thinning bears directly on how reliably this enabler-jurisdiction posture can be monitored going forward (fim-2026-W28-004). Taken as a whole, this baseline cycle establishes New Hampshire enabler-jurisdiction trajectory as deteriorating: a nationally significant laundering typology originated and was prosecuted here, yet the state-level statutory gap that enabled it remains open, and the federal detection apparatus relied upon to catch its recurrence is contracting rather than strengthening. The principal item to track going forward is whether any New Hampshire General Court bill addressing crypto-ATM consumer protection is introduced to close this gap.

domain_sub_briefs · D3 · Cumulative analysis
Periodic updates (2)
25 Oct 2026 · fim-2026-10-25

Enabler Jurisdictions and Professional Facilitators

New Hampshire's status as an enabler jurisdiction is defined by simultaneity rather than direction. HB 639, current law as of 18 August 2026, created a new statutory chapter exempting node operators, home and business digital-asset miners, and stakers from money-transmitter licensing under RSA 399-G, and extended a parallel exemption from securities treatment under RSA 421-B where mining or staking is conducted with personal funds. This deepens a posture the state had already established: New Hampshire is one of a small number of jurisdictions that does not require a licence for standalone virtual-currency transmission, and HB 639 extends that permissiveness explicitly to the infrastructure-operation layer of the crypto ecosystem — the entities that run the nodes, mine the assets, and validate the chains, rather than the entities that convert those assets to and from dollars for customers.

Against that widening at the infrastructure layer, the same legislative session narrowed the state's posture at the retail cash-conversion point. SB 482 (Chapter 187), signed 19 June 2026 and effective 16 December 2026, imposes a $2,000-per-day per-customer transaction cap, a 48-hour hold with refund right on first transactions, mandatory identity verification, fraud-risk warnings, and blockchain-analytics wallet screening specifically on digital asset transaction kiosks. The bill followed Attorney General testimony estimating roughly 250 such kiosks statewide and losses exceeding $2.6 million in Hampton alone, attributed to a documented elder-fraud laundering channel.

The analytical significance of reading these two instruments together is that New Hampshire cannot be filed as simply "permissive" or simply "tightening". It is doing both, at two different points in the same value chain, and the exemption from licensing for infrastructure operators remains current law with no indication the kiosk tightening will be extended upstream to reach it. A jurisdiction that exempts the production and validation layer from licensing while regulating the retail conversion layer is making a considered choice about where its enforcement resources and consumer-protection concerns are best deployed — and the absence of any move to licence miners, stakers, or node operators is itself a signal about where New Hampshire does not intend to extend its perimeter, at least for now.

Outlook

The durability of this bifurcated posture will be tested by whether other states follow New Hampshire's lead on either half of the pairing. If the kiosk-specific consumer protections under SB 482 prove effective at reducing elder-fraud losses once they take effect on 16 December 2026, other enabler jurisdictions with similarly permissive infrastructure-exemption regimes may adopt comparable retail-layer controls without disturbing their underlying licensing exemptions for miners and node operators. Conversely, if losses persist after the kiosk rules take effect, pressure may build to extend scrutiny upstream, though nothing in the current legislative record suggests that is imminent. For now, New Hampshire's structural choice — exempt the infrastructure, regulate the retail conversion point — stands as enacted and should be read as a considered design rather than an unresolved gap.

14 Jul 2026 · fim-2026-07-14

Enabler Jurisdictions and Professional Facilitators

New Hampshire remains the national reference point for a specific and durable enabler-jurisdiction typology: the use of ostensible religious or nonprofit front entities to disguise unlicensed money-transmission and bitcoin-kiosk laundering activity. The Ian Freeman and Church of the Invisible Hand scheme disabled know-your-customer features on bitcoin kiosks, laundered scam-victim proceeds through bank accounts opened in the name of ostensible religious organizations including the Shire Free Church, the Church of the Invisible Hand, and the Crypto Church of New Hampshire, and never registered the underlying operation as a money services business with FinCEN despite operating at money-transmission scale (fim-2026-W28-006). This architecture, hosted, prosecuted, and originated within New Hampshire, is now the primary evidentiary basis for FinCEN own national convertible-virtual-currency kiosk typology guidance, meaning the state occupies the origin point of a typology now applied nationally rather than a purely local incident.

Applying the enabler-jurisdiction filter, the relevant question is not whether the underlying scheme has been disrupted, which it has, but whether the architecture it demonstrated remains available elsewhere. An appellate court affirmed the underlying federal conviction and sentence in July 2025, representing continued enforcement follow-through within the current eighteen-month reporting window and correcting a baseline assessment that had understated the degree of New Hampshire-specific enforcement continuity (fim-2026-W28-007). That follow-through demonstrates enforcement capacity against the specific disrupted scheme, but it does not, on its own, address the structural design gap that made the scheme possible in the first instance, namely the ease with which a nonprofit or religious-front entity can open bank accounts and conduct unlicensed money transmission without triggering registration requirements until well after victim losses accumulate.

That structural design gap persists in a second and distinct form. Unlike at least eighteen other US states, including Massachusetts, that had enacted crypto-ATM-specific consumer-protection statutes by September 2025, New Hampshire continues to address the cash-to-crypto elder-fraud vector only through general fraud and money-services-business law and federal advisories, without any dedicated state-level statutory backstop (fim-2026-W28-011). Assessed against the enabler-jurisdiction filter capacity-versus-choice distinction, this is a persistent regulatory-design gap rather than a resource-constrained enforcement failure: New Hampshire has the same general legislative capacity as the eighteen-plus states that have already enacted such statutes, and the absence of equivalent legislation reflects a policy choice, or at minimum a policy inertia, rather than a demonstrated incapacity to legislate. The retail crypto-kiosk footprint that New Hampshire hosts through nationally distributed kiosk chains exposes the state to the same elder-fraud typology documented in Massachusetts and Iowa litigation, without the equivalent statutory backstop those states have since put in place.

The elder-fraud cash-to-bitcoin conversion pipeline addressed under this cycle digital-asset assessment operates through the same class of nationally distributed kiosk outlets present in New Hampshire retail footprint, underscoring that the enabler dimension of this jurisdiction crypto-kiosk exposure is not confined to the disrupted Freeman scheme alone (fim-2026-W28-012). This enabler-jurisdiction posture also intersects directly with the supervisory-capacity picture addressed elsewhere this cycle: the same federal examination apparatus whose capacity has contracted nationally is the primary mechanism through which any comparable front-entity or unregistered-money-services scheme would be detected in New Hampshire going forward, given the state continuing absence of a dedicated state-level crypto-AML examination unit (fim-2026-W28-004).

Taken together, the durable Freeman-case typology reference and the continuing statutory gap describe an enabler-jurisdiction posture that is structural rather than episodic: New Hampshire demonstrated, prosecuted, and helped codify into national guidance a specific front-entity laundering typology, while its own state-level consumer-protection framework for the underlying kiosk infrastructure remains unchanged relative to peer states that have already closed the equivalent gap.

Outlook

The principal open question for New Hampshire enabler-jurisdiction posture is legislative rather than enforcement-driven: whether any 2026 New Hampshire General Court bill addressing crypto-ATM consumer protection will be introduced to close the gap that eighteen-plus other states have already closed. No such bill has been identified this cycle, and the research coverage register notes this specifically as an open tracking item. Absent state-level legislative action, the enabler-jurisdiction trajectory for New Hampshire is assessed as deteriorating, reflecting the persistence of a documented statutory design gap even as enforcement follow-through on the disrupted Freeman-scheme prosecution continues.

D4 Conflict Finance

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Judgment: No NH-specific conflict-finance signal identified this cycle. Uncertain

D5 Crypto / Digital Assets / Financial Innovation

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Crypto, Digital Assets, and Financial Innovation

New Hampshire enacted two materially significant digital-asset instruments within the same legislative window. SB 482 (Chapter 187), signed by the Governor on 19 June 2026 and effective 16 December 2026, establishes the state's first statutory response to a documented elder-fraud laundering channel operating through digital asset transaction kiosks. The Attorney General's office had testified that roughly 250 such kiosks operate statewide, with losses exceeding $2.6 million in the single municipality of Hampton. The statute responds with a $2,000-per-day per-customer transaction cap, a mandatory 48-hour hold with a refund right on a customer's first transaction, mandatory identity verification before funds are accepted, conspicuous fraud-risk warnings, and screening of transactions against flagged wallet addresses using blockchain analytics.

Continue reading

Separately, HB 639 — the state's Blockchain Basic Laws, current law as of 18 August 2026 — created new RSA chapter 359-V, exempting node operators, home and business digital-asset miners, and stakers from money-transmitter licensing under RSA 399-G. A parallel provision exempts mining and staking conducted with personal funds from securities treatment under RSA 421-B. Notably, the exemption applies regardless of whether a federal FinCEN money-services-business obligation also attaches to the same activity — New Hampshire's exemption operates at the state licensing layer only and does not purport to override federal requirements.

Taken together, these two statutes describe a crypto-integrity posture that is escalating rather than static, in both directions. The kiosk measure is the more AML-adjacent of the two: it targets a specific, quantified fraud-laundering vector at the point where value crosses from cash into digital assets and back, using tools — transaction caps, holds, and wallet screening — that are recognisably anti-money-laundering controls even though the statute is framed in consumer-protection terms. The infrastructure exemption, by contrast, removes a licensing requirement rather than adding one, and does so for the layer of activity — running nodes, mining, staking — that has historically drawn far less AML scrutiny than exchange or custody activity, precisely because it does not typically involve direct customer-facing fiat conversion.

Outlook

The kiosk rules take effect 16 December 2026, and the first indicator of their real-world effect will be whether reported elder-fraud losses attributable to kiosk conversion decline in the following reporting cycles, or whether the fraud simply migrates to channels the statute does not reach — person-to-person transfers, kiosks operated outside the regulated footprint, or out-of-state machines accessible to New Hampshire residents. On the infrastructure side, HB 639 is now settled law with no signal of imminent revisitation; the state's choice to exempt miners, stakers, and node operators from licensing should be read as a durable structural feature of its digital-asset regime, not a temporary gap awaiting closure. Readers should watch for whether federal action — a FinCEN guidance update or a federal AML rule specific to node operators or miners — eventually supersedes the practical significance of the state-level exemption.

Judgment: NH enacted two material crypto-integrity instruments this cycle window: SB 482 (kiosk consumer/AML-adjacent protections) and HB 639 (MTL exemption for node operators/miners/stakers). Probable
Cumulative analysis

Crypto, Digital Assets, and Financial Innovation — Cumulative Analysis

This is the first cycle of structured tracking for New Hampshire under the crypto and digital-asset domain, and the baseline it establishes is one of national outlier status combined with unresolved supervisory exposure. In May 2025 New Hampshire enacted House Bill 302, its Strategic Bitcoin Reserve statute, authorizing the state treasury to invest up to five percent of state funds in bitcoin or digital assets exceeding a five-hundred-billion-dollar market capitalization threshold, a threshold only bitcoin currently satisfies, making New Hampshire the first US state with a legislated reserve of this kind (fim-2026-W28-001). That statutory commitment was reinforced when the New Hampshire Business Finance Authority received a provisional Ba2 rating from Moodys Ratings in March 2026 for a limited-recourse, pass-through bitcoin-backed conduit bond carrying no state credit backing (fim-2026-W28-002). Taken together, these two baseline developments place New Hampshire in a category distinct from every other US state on direct state-level digital-asset integration.

That crypto-forward legislative trajectory sits against a national illicit-finance typology in which New Hampshire is directly implicated as an evidentiary source. FinCEN August 2025 nationwide advisory on convertible virtual currency kiosk risk cites prior New Hampshire prosecutions directly, and documents that FBI Internet Crime Complaint Center kiosk-related complaints rose ninety-nine percent year-on-year in 2024 to more than ten thousand nine hundred fifty-six, with reported losses of approximately two hundred forty-six point seven million dollars (fim-2026-W28-003). The underlying elder-fraud cash-to-bitcoin conversion pipeline remains active nationally, including through nationally distributed kiosk outlets present in New Hampshire own retail footprint (fim-2026-W28-012). Bitcoin Depot, one major operator within that kiosk architecture, filed for Chapter 11 bankruptcy in May 2026 after operating more than nine thousand locations globally, citing compliance costs, transaction limits, and Massachusetts and Iowa attorney-general litigation as drivers (fim-2026-W28-005); this baseline cycle assesses that exit as reducing attack surface only at the margin, since the underlying conversion risk persists through remaining operators.

A compounding structural finding anchors this baseline: federal Bank Secrecy Act and AML examiner headcount assigned to money-services-business and crypto-firm oversight fell thirty-three percent in fiscal year 2025 (fim-2026-W28-004), thinning the supervisory layer New Hampshire depends on most heavily given its absence of any dedicated state-level crypto-AML examination unit. Two federal legislative horizon items will shape how this tension resolves going forward: finalization of GENIUS Act stablecoin implementing regulations ahead of a January 2027 deadline (fim-2026-W28-013), and the pending Clarity Act market-structure legislation, which law-enforcement and banking groups warn could open AML oversight gaps through decentralized-service exemptions (fim-2026-W28-014).

This baseline cycle supports two durable assessed judgments carried forward for future tracking: that New Hampshire simultaneous embrace of bitcoin as a sovereign treasury asset and its absence of state-level crypto-AML provenance controls constitutes a structural, not episodic, enabler gap, and that federal examination-capacity contraction combined with New Hampshire own lack of independent examination capability creates a compounding, two-sided supervisory gap. The trajectory established at this baseline is deteriorating, and future cycles should track State Treasurer bitcoin-allocation disclosures, GENIUS Act finalization, Clarity Act outcome, and any New Hampshire-specific crypto-ATM consumer-protection legislation as the principal variables that could shift this trajectory in either direction.

domain_sub_briefs · D5 · Cumulative analysis
Periodic updates (1)
14 Jul 2026 · fim-2026-07-14

Crypto, Digital Assets, and Financial Innovation

New Hampshire own regulatory and legislative posture toward digital assets is the direct subject of this cycle assessment, ahead of any broader national or global digital-asset framework. In May 2025 the state enacted House Bill 302, its Strategic Bitcoin Reserve statute, authorizing the state treasury to invest up to five percent of state funds in bitcoin or digital assets with a market capitalization exceeding five hundred billion dollars, a threshold bitcoin alone currently satisfies, making New Hampshire the first US state with a legislated Strategic Bitcoin Reserve of this kind (fim-2026-W28-001). That statutory posture was reinforced when the New Hampshire Business Finance Authority received a provisional Ba2 rating from Moodys Ratings in March 2026 for a bitcoin-backed conduit bond structured on a limited-recourse, pass-through basis, such that the bonds carry no New Hampshire state credit backing and place no public funds at risk (fim-2026-W28-002). Together these two developments make New Hampshire a national outlier in direct state-level digital-asset integration, distinguishing it from every other US state.

That crypto-forward posture sits alongside a national kiosk-based illicit-finance typology in which New Hampshire figures directly. FinCEN August 2025 nationwide advisory on convertible virtual currency kiosk illicit-finance risk cites prior prosecutions from the District of New Hampshire directly as part of its evidentiary basis, and records that the FBI Internet Crime Complaint Center logged more than ten thousand nine hundred fifty-six kiosk-related complaints in 2024, a ninety-nine percent year-on-year increase, with reported victim losses of approximately two hundred forty-six point seven million dollars (fim-2026-W28-003). The cash-to-bitcoin elder-fraud conversion pipeline that advisory targets remains active nationally, including through nationally distributed kiosk outlets present within New Hampshire own retail footprint, converting scam-victim cash instantly into bitcoin routed through cross-border laundering networks connected to Southeast Asian scam-compound operations (fim-2026-W28-012).

One node within that same kiosk architecture has since exited the market. Bitcoin Depot, which operated more than nine thousand kiosk locations globally as of August 2025, filed for Chapter 11 bankruptcy in May 2026, citing stringent state and municipal compliance obligations, transaction limits, and litigation including Massachusetts and Iowa attorney-general lawsuits as drivers of its exit (fim-2026-W28-005). Applying an architecture-over-incident lens, this single operator exit reduces near-term elder-fraud attack surface at the margin but does not resolve the underlying cash-to-crypto conversion risk, which persists through remaining kiosk operators still active in New Hampshire retail footprint and nationally. This exit and the broader kiosk-based elder-fraud architecture also intersect with the federal supervisory-capacity contraction addressed elsewhere this cycle, given that the same shrinking examiner population is responsible for identifying comparable unregistered or under-controlled money-services activity within New Hampshire crypto-kiosk sector going forward (fim-2026-W28-004).

Two federal legislative and regulatory horizon items will materially shape the compliance environment New Hampshire crypto-forward programmes and money-services-business population operate within going forward. Federal regulators must finalize GENIUS Act stablecoin implementing regulations ahead of a January 2027 applicability deadline, shaping custody and AML-provenance expectations directly relevant to state-level programmes such as the Strategic Bitcoin Reserve and the bitcoin-bond conduit (fim-2026-W28-013). Separately, law-enforcement and banking-sector groups have warned that the pending Clarity Act crypto market-structure legislation could create AML oversight gaps through exemptions for decentralized and automated crypto services, exploitable by sophisticated criminal actors (fim-2026-W28-014); passage or failure of that legislation ahead of the 2026 midterm cycle will materially reset the federal crypto-AML perimeter within which New Hampshire crypto-forward money-services and kiosk population operates.

These developments together support an assessed key judgment that New Hampshire simultaneous embrace of bitcoin as a sovereign treasury asset and its absence of state-level crypto-AML provenance controls constitutes a structural, not episodic, enabler gap, and a second assessed judgment that federal AML examination-capacity contraction combined with New Hampshire own lack of independent crypto-AML examination capability creates a compounding, two-sided supervisory gap.

Outlook

New Hampshire crypto-asset integrity trajectory is assessed as deteriorating this cycle, driven by the compounding effect of continued Strategic Bitcoin Reserve build-out toward its statutory cap, an active national elder-fraud kiosk typology with a documented New Hampshire retail-footprint nexus, and pending federal legislative outcomes whose direction remains genuinely uncertain. The State Treasurer continuing operationalisation of bitcoin allocations during 2026 leaves custody, audit, and AML-provenance controls for treasury-held bitcoin as an open supervisory question that no primary source located this cycle has yet resolved. Whether the Bitcoin Depot market exit meaningfully reduces New Hampshire-specific elder-fraud exposure, or whether volume simply migrates to remaining kiosk operators, is the most immediate near-term watch point within this domain.

D6 Compliance Technology & Active Defence

no_changeno_changestanding position

Compliance Technology and Active Defence

The single most consequential development for New Hampshire compliance-technology and active-defence posture this cycle is a national one with direct jurisdictional bite: Internal Revenue Service Bank Secrecy Act and anti-money-laundering examiner headcount assigned to money-services-business and crypto-asset-firm oversight fell thirty-three percent in fiscal year 2025, from two hundred eight agents to one hundred thirty nine (fim-2026-W28-004). Applying an architecture-over-incident lens, this is a structural capacity shift in the federal supervisory architecture rather than an isolated staffing adjustment, and it carries disproportionate significance for New Hampshire specifically because the state has no dedicated state-level crypto-AML examination unit of its own and therefore depends on federal examination capacity more heavily than states that maintain independent supervisory infrastructure for this sector.

Continue reading

That dependency is compounded rather than offset by New Hampshire own regulatory trajectory this cycle. The state has simultaneously become the most crypto-forward jurisdiction in the country, hosting a legislated Strategic Bitcoin Reserve and a Moodys-rated bitcoin-backed conduit bond, expanding precisely the category of activity, money-services-business and crypto-asset-firm activity, whose federal examination capacity is contracting. The result is a compounding, two-sided supervisory gap: examination demand generated by New Hampshire own crypto-forward policy choices is rising at the same time that the federal supply of examination capacity available to meet that demand is falling, with no New Hampshire-specific mitigating measure, such as a new state examination unit or an equivalent third-party assurance mechanism, identified this cycle to offset the reduction.

This compliance-technology and active-defence assessment also connects directly to the enabler-jurisdiction and beneficial-ownership dimensions addressed elsewhere this cycle. The Ian Freeman unlicensed-money-services-business scheme, which relied on disabled know-your-customer controls and undisclosed nonprofit-front bank accounts, was itself detected and prosecuted through federal law-enforcement and examination channels of the kind now operating at reduced capacity nationally; and the federal beneficial-ownership visibility narrowing produced by the March 2025 Corporate Transparency Act domestic-reporting-company exemption removes a second, independent source of information that active-defence and compliance-technology functions might otherwise have relied upon to identify comparable front-entity structures going forward. Neither the examiner-capacity contraction nor the beneficial-ownership exemption is, individually, a New Hampshire-specific policy decision; both are federal-level structural developments that happen to bear with particular force on a state that has chosen an unusually crypto-forward regulatory posture without building equivalent independent state-level examination or transparency infrastructure to match it.

Outlook

Fiscal year 2026 Internal Revenue Service examiner headcount data is not yet available, and obtaining it is the principal near-term item that would clarify whether the fiscal year 2025 capacity reduction represents a one-off adjustment or a continuing trend with compounding significance for New Hampshire-dependent federal oversight. Absent any New Hampshire-specific state-level examination capacity build-out, and absent clarity on whether the federal contraction continues into fiscal year 2026, the compliance-technology and active-defence trajectory for this jurisdiction is assessed as deteriorating, reflecting a widening gap between the volume and complexity of crypto-asset activity New Hampshire own policy choices are generating and the federal examination capacity available to supervise it.

Judgment: No RegTech or active-defence development identified for NH this cycle; D6 is exempt from the substantive-finding floor. Uncertain
Cumulative analysis

Compliance Technology and Active Defence — Cumulative Analysis

This is the first cycle of structured tracking for New Hampshire under the compliance-technology and active-defence domain, and the baseline it establishes centers on a single but structurally consequential federal development. Internal Revenue Service Bank Secrecy Act and anti-money-laundering examiner headcount assigned to money-services-business and crypto-asset-firm oversight fell thirty-three percent in fiscal year 2025, from two hundred eight agents to one hundred thirty nine (fim-2026-W28-004). Because New Hampshire has no dedicated state-level crypto-AML examination unit of its own, this national capacity contraction bears on the state with disproportionate weight relative to jurisdictions that maintain independent supervisory infrastructure for this sector.

This baseline finding sits alongside, and is compounded by, New Hampshire own simultaneous emergence as the most crypto-forward US state, through its legislated Strategic Bitcoin Reserve and Moodys-rated bitcoin-backed conduit bond recorded elsewhere this cycle. The result, established at this baseline point, is a two-sided supervisory gap: New Hampshire policy choices are expanding the category of activity requiring federal examination at the same time that federal examination supply for that category is contracting, with no New Hampshire-specific mitigating measure identified to offset the reduction.

This domain also connects at baseline to two other findings recorded this cycle. The Ian Freeman unlicensed-money-services-business scheme, which relied on disabled know-your-customer controls and undisclosed nonprofit-front bank accounts, was detected and prosecuted through the same class of federal examination and law-enforcement channels now operating at reduced capacity (fim-2026-W28-006); and the March 2025 federal exemption of domestic reporting companies from Corporate Transparency Act beneficial-ownership reporting removes an independent information source that compliance-technology functions might otherwise draw upon to identify comparable front-entity structures in the future (fim-2026-W28-008). Neither of these federal-level developments is New Hampshire-specific in origin, but both bear with particular force on a state that has adopted an unusually crypto-forward posture without matching independent state-level examination or transparency infrastructure.

The baseline trajectory for this domain is deteriorating. The principal item to track in future cycles is whether fiscal year 2026 Internal Revenue Service examiner headcount data, not yet available at this baseline point, shows the fiscal year 2025 reduction to be a one-off adjustment or a continuing trend, and whether any New Hampshire-specific state-level examination capacity is subsequently built out to narrow the compounding gap identified here.

domain_sub_briefs · D6 · Cumulative analysis

D7 AML/CTF Regime

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AML/CTF Regime

New Hampshire's standing money-transmitter supervisory architecture under RSA 399-G was strengthened this cycle by HB 1207, signed 10 July 2026, which amends the Banking Department commissioner's examination powers effective 1 October 2026. Two specific new provisions take effect on that date: the commissioner may require a licensee's books and records to be translated into English, with both the translation and an interpreter chargeable to the licensee's own expense, and delegate locations operating under a money-transmitter's authority must post a certificate of authority on-site. The New Hampshire Banking Department remains the designated supervisor of money transmitters under RSA 399-G, overseeing a population that its FY2026 annual report placed at 202 active licensees operating through 1,638 authorised delegates.

Continue reading

These amendments sit alongside, rather than replace, the broader body of money-transmitter law the Department administers, and they matter because they expand the Department's practical examination toolkit rather than its formal licensing scope. A commissioner empowered to demand translated records and to compel an interpreter's presence during an examination — at the licensee's cost — gains meaningfully greater visibility into the operations of money transmitters whose documentation, correspondence, or customer records are not maintained in English, a capability gap that supervisory bodies in jurisdictions with growing immigrant or cross-border customer populations have often identified as a practical constraint on effective examination. Similarly, the delegate certificate-of-authority posting duty is a modest but concrete transparency measure, making it easier for a customer, investigator, or examiner to confirm on the spot that a given location is in fact operating under a valid delegated authority rather than holding itself out as such without one.

This cycle's development should be read as incremental strengthening of an already-established regime rather than a new regulatory architecture. New Hampshire has long required money-transmitter licensing under RSA 399-G, subject to the standing exemption for standalone virtual-currency transmission; HB 1207 does not touch that exemption boundary. It instead reinforces the Department's capacity to supervise the population that does require licensing, including any fiat-touching crypto exchange or custody business operating in the state.

Outlook

The practical significance of HB 1207's amendments will depend on how actively the Banking Department deploys its new translated-records and interpreter authority once it takes effect on 1 October 2026. If used selectively in examinations of money transmitters whose customer base or corporate structure crosses linguistic or jurisdictional lines, the provision could meaningfully improve the Department's ability to detect compliance gaps that English-only examination previously missed. The delegate certificate-of-authority requirement is more straightforward to assess: compliance should be visible and verifiable at the point of inspection, and any gap between the number of certificates issued and the number of delegate locations the Department has on file would itself be a notable supervisory finding in a future cycle.

Judgment: NH Banking Department remains the designated money-transmitter supervisor under RSA 399-G; HB 1207 strengthened examination powers effective 1 October 2026. Probable
Cumulative analysis

AML/CTF Regime

New Hampshire's AML/CTF regime for money transmitters, including crypto-asset operators, rests on RSA 399-G, with RSA 399-G:17 requiring licensees to create and implement plans to comply with the Bank Secrecy Act. This governance obligation is unchanged this period and has a demonstrated enforcement history: the New Hampshire Banking Department's 2025 order to show cause against BAM Trading Services Inc. was tied to controlling-person BSA/AML compliance failures, illustrating the state's willingness to use its enforcement leverage under the existing statute.

The material development this period is federal: FinCEN, jointly with federal banking agencies, proposed on 10 April 2026 a fundamental reform of AML/CFT program-rule requirements under the Bank Secrecy Act, covering banks, casinos/card clubs, and money services businesses. The proposal would set new minimum standards for AML programs and mandate that all AML programs explicitly incorporate countering the financing of terrorism. This has direct downstream effect on New Hampshire's RSA 399-G-licensed money transmitters once finalised, though the NH baseline regime itself has not changed. No Federal Register primary text was retrieved this period; the development rests at Probable confidence on two independent trade-press sources, and the NH-specific D7 baseline — RSA 399-G and its BSA-compliance obligation — remains the stable architecture against which this federal development should be read.

Outlook

The FinCEN NPRM carries a year-level uncertainty band with an expected impact window in early 2027. Once primary Federal Register text is retrieved, the development's confidence can move beyond Probable. NH-specific SAR/CTR volume and FIU-coordination data were not located this period, leaving a standing gap in the state-level granularity of the AML/CFT picture.

domain_sub_briefs · D7 · Cumulative analysis
Periodic updates (1)
25 Oct 2026 · fim-2026-10-25

AML/CTF Regime

New Hampshire's standing money-transmitter supervisory architecture under RSA 399-G was strengthened by HB 1207, signed 10 July 2026, which amends the Banking Department commissioner's examination powers effective 1 October 2026. Two specific new provisions take effect on that date: the commissioner may require a licensee's books and records to be translated into English, with both the translation and an interpreter chargeable to the licensee's own expense, and delegate locations operating under a money-transmitter's authority must post a certificate of authority on-site. The New Hampshire Banking Department remains the designated supervisor of money transmitters under RSA 399-G, overseeing a population that its FY2026 annual report placed at 202 active licensees operating through 1,638 authorised delegates.

These amendments sit alongside, rather than replace, the broader body of money-transmitter law the Department administers, and they matter because they expand the Department's practical examination toolkit rather than its formal licensing scope. A commissioner empowered to demand translated records and to compel an interpreter's presence during an examination — at the licensee's cost — gains meaningfully greater visibility into the operations of money transmitters whose documentation, correspondence, or customer records are not maintained in English, a capability gap that supervisory bodies in jurisdictions with growing immigrant or cross-border customer populations have often identified as a practical constraint on effective examination. Similarly, the delegate certificate-of-authority posting duty is a modest but concrete transparency measure, making it easier for a customer, investigator, or examiner to confirm on the spot that a given location is in fact operating under a valid delegated authority rather than holding itself out as such without one.

The development should be read as incremental strengthening of an already-established regime rather than a new regulatory architecture. New Hampshire has long required money-transmitter licensing under RSA 399-G, subject to the standing exemption for standalone virtual-currency transmission; HB 1207 does not touch that exemption boundary. It instead reinforces the Department's capacity to supervise the population that does require licensing, including any fiat-touching crypto exchange or custody business operating in the state.

Outlook

The practical significance of HB 1207's amendments will depend on how actively the Banking Department deploys its new translated-records and interpreter authority once it takes effect on 1 October 2026. If used selectively in examinations of money transmitters whose customer base or corporate structure crosses linguistic or jurisdictional lines, the provision could meaningfully improve the Department's ability to detect compliance gaps that English-only examination previously missed. The delegate certificate-of-authority requirement is more straightforward to assess: compliance should be visible and verifiable at the point of inspection, and any gap between the number of certificates issued and the number of delegate locations the Department has on file would itself be a notable supervisory finding in a future cycle.

D8 Commercial Activity

stableactive

Commercial Activity

The single commercial-activity development identified for New Hampshire this cycle is Hometown Financial Group's agreement to acquire Primary Bank, based in Bedford, New Hampshire, for $160 million. The transaction adds approximately $743 million in assets and four New Hampshire branches to the Massachusetts-based acquirer, which intends to operate the combined franchise under the TruNorth Bank brand. Nothing in the available reporting identifies an anti-money-laundering, sanctions, or beneficial-ownership dimension to the deal; it presents as a routine community-bank consolidation of the kind that occurs regularly across New England's smaller-bank sector.

Continue reading

The analytical interest of this transaction for a financial-integrity reading is limited precisely because it is unremarkable. A cross-border or cross-state acquisition of a regulated depository institution ordinarily triggers a standard set of prudential and change-of-control reviews by state and federal banking regulators, and the absence of any disclosed integrity concern in this instance is consistent with those reviews proceeding as expected rather than surfacing anything requiring escalation. This is worth stating explicitly rather than leaving silent: a transaction of this kind, involving a depository institution rather than a money-services business or digital-asset firm, carries a materially different risk profile from the kiosk-related and crypto-infrastructure developments addressed elsewhere this cycle, and readers should not infer any connection between the two threads of New Hampshire activity.

Outlook

Absent any disclosed integrity concern, the Hometown Financial Group acquisition of Primary Bank is not expected to generate further financial-integrity findings in subsequent cycles unless regulatory review surfaces an issue not yet reported. The transaction is noted here chiefly for completeness and to distinguish it clearly from New Hampshire's more structurally significant digital-asset and money-transmitter developments addressed elsewhere in this brief.

Judgment: Hometown Financial Group's $160M acquisition of Primary Bank (Bedford, NH) is a routine community-bank consolidation with no disclosed AML or sanctions dimension. Probable
Regulatory horizon
No dated horizon items this cycle. 3 items tracked without a confirmed date.
3 pending date · baseline financial-integrity-2026-07-05
Role action cards
MLRO

New Hampshire enacted kiosk-specific transaction controls and strengthened money-transmitter examination powers this cycle, while separately exempting crypto infrastructure operators from licensing.

A new $2,000 daily cap, 48-hour first-transaction hold, and wallet screening apply to digital asset kiosks from 16 December 2026, giving MLROs operating or supervising kiosk-adjacent business a concrete new control set to implement. Separately, the Banking Department gained translated-records and interpreter authority in examinations from 1 October 2026, which may surface in future money-transmitter exams.

2 evidence refs
Compliance

Two enacted statutes materially change the compliance landscape for digital-asset kiosk operators and money transmitters in New Hampshire.

Kiosk operators must build toward the SB 482 requirements ahead of the 16 December 2026 effective date, while any NH-licensed money transmitter should anticipate the Banking Department's expanded examination toolkit from 1 October 2026. Node operators, miners, and stakers remain outside money-transmitter licensing under HB 639.

3 evidence refs
Legal

New Hampshire's crypto-infrastructure licensing exemption under HB 639 is now current law, confirmed in parallel with a new kiosk consumer-protection statute.

Counsel advising digital-asset infrastructure clients in New Hampshire can rely on the HB 639 exemption from money-transmitter licensing and from RSA 421-B securities treatment for personal-fund mining and staking as settled current law, while noting that fiat-touching exchange or custody activity remains within the licensing perimeter.

1 evidence refs
Board

New Hampshire is pursuing a bifurcated regulatory strategy toward digital assets, tightening at retail conversion points while exempting infrastructure operators.

Institutions with exposure to New Hampshire-licensed money transmitters or kiosk operators should expect increased examination scrutiny and new consumer-facing controls, while any strategic interest in crypto-infrastructure operations (mining, staking, node operation) in the state benefits from a confirmed, settled licensing exemption.

2 evidence refs
CTO

New Hampshire requires blockchain-analytics wallet screening at digital asset kiosks and confirms a licensing exemption for node operators, miners, and stakers.

Technical teams supporting kiosk operators need wallet-screening integration against flagged-address lists in place by 16 December 2026. Teams running node infrastructure, mining, or staking operations in New Hampshire operate under a confirmed state-law exemption from money-transmitter licensing, though federal FinCEN obligations are unaffected by the state exemption.

2 evidence refs
Risk

A documented elder-fraud laundering channel through digital-asset kiosks prompted New Hampshire's new statutory controls this cycle.

The scale cited by the Attorney General's office — roughly 250 kiosks statewide and over $2.6 million in losses in one municipality alone — indicates the typology was material before the new controls existed; risk functions should treat the new caps and holds as a mitigant to monitor for effectiveness, not an eliminated exposure.

1 evidence refs
Operations

No material change for this persona this cycle.

No material change for this persona this cycle

Audit

The New Hampshire Banking Department gained new examination evidence-gathering powers effective 1 October 2026.

The translated-records and interpreter authority, and the delegate certificate-of-authority posting duty, give auditors a new basis to test whether money-transmitter licensees and their delegates can demonstrate compliance with documentation and on-site posting requirements going forward.

1 evidence refs
Scenario sketches

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

Illustrative scenario for analytical orientation only. As the EU moves from purely national AML supervision toward a hybrid regime under the AMLA Regulation (Reg (EU) 2024/1620), with the directly-applicable AML Regulation (Reg 2024/1624) and per-state Sixth AML Directive transposition operating alongside it, a cross-border obliged entity newly within AMLA's direct-supervision perimeter could, in principle, respond by shifting marginal volume toward affiliated entities or counterparties in jurisdictions outside that perimeter, including permissive non-EEA venues. This is an illustrative structural mechanism only, not an observed development in any jurisdiction named in this brief, and does not describe New Hampshire specifically.

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_change
T2 · EU AML Package / AMLAno_change
T3 · FATF Grey Listno_change
T4 · Beneficial-Ownership Register Statusno_change
T5 · Crypto & Digital-Asset IntegrityescalatingNH enacted SB 482 (kiosk protections, eff. 16 Dec 2026) and HB 639 (MTL exemption, eff. 18 Aug 2026, current law).
T6 · Sanctions Regime Divergenceno_change
Registers

Enforcement actions

  • 4 Aug 2025
  • 17 Feb 2026
  • 18 May 2026
  • 12 Feb 2026
  • 9 Dec 2025
  • 6 Mar 2026
  • 30 Jun 2026
  • FinCEN issued Notice FIN-2025-NTC1 urging financial institutions to increase vigilance around CVC kiosk illicit-finance risk, citing prior USAO-District of New Hampshire prosecutions (unlicensed virtual-currency exchange businesses) among its evidentiary typology basis for red-flag indicators. 4 Aug 2025
  • IRS AML examiner headcount assigned to oversee BSA/AML compliance at crypto firms and other money transmitters fell 33 percent in FY2025 (to 139 agents from 208 in FY2024), reducing federal supervisory bandwidth precisely in the sector (unlicensed/underlicensed MSBs, crypto kiosks) that produced New Hampshire's landmark Freeman prosecution. 17 Feb 2026
  • Bitcoin Depot, formerly the world's largest crypto-ATM operator (~9,700 kiosks), filed for bankruptcy and ceased operations, citing increasingly stringent state and municipal compliance obligations, transaction limits and outright restrictions as the direct cause of business infeasibility. 17 May 2026

Sanctions changes

  • 23 Apr 2026
  • 30 Jun 2026
  • 30 Jun 2026
  • 1 Jul 2026
  • 1 Jul 2026
  • 13 Jul 2026
  • 28 May 2026
  • OFAC reached a settlement agreement with Exodus Movement, Inc. (a self-custody crypto wallet software provider) resolving apparent sanctions violations, a national enforcement/licence action directly applicable to virtual-asset software firms in NH's crypto-forward regulatory environment via standard OFAC jurisdiction over all US persons/entities. 12 Feb 2026
  • OFAC assessed a civil monetary penalty against Gracetown, Inc. for apparent sanctions violations, part of the continuing national OFAC enforcement cadence that NH-chartered banking organizations must monitor under the standing NH Banking Department/OFAC information-sharing Memorandum of Understanding covering sanctions-compliance supervision of state-licensed entities. 9 Dec 2025

Regulatory horizon (register)

  • US Treasury National Risk Assessment refresh (NMLRA/NTFRA/NPFRA)
  • FinCEN / federal banking agencies NPRM: fundamental reform of BSA AML/CFT program rules
  • NH SB 482 digital asset transaction kiosk consumer protections
  • GENIUS Act stablecoin implementing regulations finalization
  • NH Strategic Bitcoin Reserve treasury allocation build-out
  • Congressional Clarity Act crypto market-structure legislation outcome

Active schemes

  • [HIGH] Unlicensed bitcoin-kiosk laundering via church-front entities
  • [HIGH] Crypto-ATM cash-to-crypto elder-fraud conversion pipeline
Sources
  1. New Hampshire Banking Department
  2. New Hampshire Banking Department
  3. Norton Rose Fulbright
  4. American Bankers Association
  5. https://legiscan.com/NH/bill/SB482/2026?guid=59Wh0SvggocImLuteAfjZH
  6. https://legiscan.com/NH/text/HB639/id/3063137
  7. https://gc.nh.gov/rsa/html/xxxvi/399-g/399-g-mrg.htm
  8. https://www.bankingdive.com/news/massachusetts-lender-acquires-nh-bank-160m/824608/
  9. FinCEN Notice, FIN-2025-NTC1, August 4, 2025
  10. MSB Registrant Search | FinCEN.gov
  11. Enforcement Actions for Failure to Register as a Money Services Business | FinCEN.gov
  12. Fact Sheet on MSB Registration Rule | FinCEN.gov
  13. Enforcement Actions | FinCEN.gov
  14. FinCEN Consent Order Imposing Civil Money Penalty
  15. News Releases on Unregistered Money Transmitter Enforcement Actions | FinCEN.gov
  16. GUIDANCE TO MONEY SERVICES BUSINESSES ON OBTAINING AND MAINTAINING BANKING SERVICES | FinCEN.gov
  17. Application of the Definition of Money Transmitter to Brokers and Dealers in Currency and Other Commodities | FinCEN.gov
  18. Definition of Money Transmitter (Merchant Payment Processor) | FinCEN.gov
  19. MEMORANDUM OF UNDERSTANDING U.S. Department of ...
  20. Answers to Frequently Asked Bank Secrecy Act (BSA) Questions | FinCEN.gov
  21. The Bank Secrecy Act | FinCEN.gov
  22. FinCEN’s Legal Authorities | FinCEN.gov
  23. 1st Review of the Suspicious Activity Reporting System (SARS) | FinCEN.gov
  24. Case Examples | FinCEN.gov
  25. Fact Sheet for Bank Secrecy Act Effectiveness and Efficiency | FinCEN.gov
  26. Requests by Law Enforcement for Financial Institutions to Maintain Accounts | FinCEN.gov
  27. 1 Financial Crimes Enforcement Network (FinCEN)
  28. Civil Penalties and Enforcement Information | Office of Foreign Assets Control
  29. Recent Actions | Office of Foreign Assets Control
  30. Frequently Asked Questions | FinCEN.gov
  31. Alerts/Advisories/Notices/Bulletins/Fact Sheets | FinCEN.gov
  32. Press Releases | FinCEN.gov
  33. 2025 Crypto Regulatory Round-Up
  34. Guidance | FinCEN.gov
  35. 2026 Crypto Crime Report: Scams
  36. Retailers keep cashing in on crypto ATMs as scams surge - ICIJ
  37. Amid a scam crackdown, crypto giants keep fueling bitcoin ATMs - ICIJ
  38. How Crypto ATMs in the U.S. Became A Favorite Tool for Scammers | OCCRP
  39. Massachusetts sues Bitcoin Depot, alleging the crypto ATM operator knowingly facilitated crypto scams - ICIJ
  40. The State of Crypto Scams 2025: Keeping our industry safe with blockchain analytics
  41. Crypto scams and elder financial exploitation: cracking down on fraud targeting the vulnerable
  42. Crypto ATM operator Bitcoin Depot files for bankruptcy - ICIJ
  43. 2026 Crypto Crime Report – Illicit Crypto Trends & Typologies | TRM Labs
  44. Rate of Illicit Activity at Crypto ATMs is Double That of Overall Crypto Industry | TRM Labs
  45. Cryptocurrency Regulation: How Governments Around the World Regulate Crypto
  46. 2025 Regulatory outlook: It’s crunch time for the US Congress on crypto legislation
  47. How crypto regulation changed in 2025: a global review
  48. Bitcoin ATMs: amid recent UK enforcement action, what are the risks of crypto kiosks?
  49. Blockchain Legal Library
  50. How the USAO New Hampshire Returned $3.5 Million to Scam Victims | TRM Labs
  51. Financial Fraud Enforcement Task Force (FFETF) | FinCEN.gov
  52. 1 The U.S. Department of the Treasury’s (Treasury) Financial
  53. Attorney Sentenced in Fraud Case | FinCEN.gov
  54. State & Federal Agencies Seize $8.9 Million—Brought Together by Gateway Alert Match Program | FinCEN.gov
  55. New failure to prevent fraud guidance published - GOV.UK
  56. Membership of the Parole Board between 1 April 2024 and ...
  57. DEPARTMENT OF THE TREASURY BANK SECRECY ACT ADVISORY GROUP
  58. Published on 29 February 2024 Effective from 29 May 2024 Attorney General’s
  59. Ian Freeman Sentenced to Eight Years In Bitcoin Money Laundering Scheme In “Church of the Invisible Hand” Case | TRM Labs
  60. SBF Faces Skeptical Judges at Appeal of FTX Fraud Verdict - Bloomberg
  61. Asset Seizure and Cryptocurrency - Chainalysis
  62. How Cryptocurrencies Are Frozen, Seized, and Forfeited
  63. DIGEST OF CYBER ORGANIZED CRIME SECOND EDITION
  64. Bankman-Fried to Appeal 25-Year Sentence, Conviction for Fraud - Bloomberg
  65. SBF Sentencing: 8 Other Crypto Executives Accused Facing Fraud Cases - Bloomberg
  66. Sam Bankman-Fried Asks for New Trial on FTX Fraud Charges - Bloomberg
  67. Sam Bankman-Fried Sentencing: SBF Gets 25 Years in Prison Over FTX Collapse - Bloomberg
  68. US: Two Charged In $1.89 Billion Crypto Fraud Scheme, Third Member Pleads Guilty | OCCRP
  69. Trump Tells New Hampshire Voters He’d Prevent a Federal Reserve Digital Dollar - Bloomberg
  70. Bitcoin Strategic Reserves - Chainalysis
  71. Enhancing Law Enforcement’s Role in Expanding the US Strategic Bitcoin Reserve | TRM Labs
  72. Trump Signs Executive Order Creating Strategic Bitcoin Reserve, Crypto Stockpile - Bloomberg
  73. How Will Trump’s US Strategic Bitcoin Reserve Work? - Bloomberg
  74. Strategy CEO Says Reserve Reduces Pressure to Sell Bitcoin - Bloomberg
  75. Crypto Execs Head to White House Amid US Bitcoin Reserve Questions - Bloomberg
  76. What the GENIUS and Market Structure Bills Mean for Crypto Compliance
  77. Trump Team’s Bitcoin Reserve Strategy Takes a Market Beating - Bloomberg
  78. CCRC refers convictions of Clive Freeman to the Court of Appeal - Criminal Cases Review Commission
  79. Tribunal decisions
  80. Arianna J Freeman, United States Court of Appeals for the Third Circuit: Profile and Biography - Bloomberg Markets
  81. Court of Appeal cases fixed for hearing (Criminal Division) - GOV.UK
  82. Decision (Permission to Appeal) [AP]
  83. The Criminal Procedure Rules 2025
  84. https://www.gov.uk/planning-inspectorate Appeal Decision
  85. Consultation Paper 268 Criminal Appeals A consultation paper
  86. DB v 1) Lancashire & South Cumbria NHS Foundation Trust 2) Secretary of State for Justice: [2026] UKUT 28 (AAC) - GOV.UK
  87. Bitcoin-Backed Municipal Bond Earns Ba2 Rating From Moody’s - Bloomberg
  88. Bitcoin Reserve Bills Are Failing in Quick Succession in States - Bloomberg
  89. Watch Trump Establishes First US Bitcoin Reserve - Bloomberg
  90. Crypto Regulatory Affairs: New York state passes Bitcoin mining moratorium
  91. New Jersey Governor Race: NJ Democratic Hopefuls Warm Up to Crypto - Bloomberg
  92. Trump administration curbs state oversight of crypto industry - ICIJ
  93. Whether a Company that Provides Online Real-Time Deposit, Settlement, and Payment Services for Banks, Businesses and Consumers is a Money Transmitter rather | FinCEN.gov
  94. Money Services Business (MSB) Registration | FinCEN.gov
  95. Virtual Asset Service Provider (VASP): Definition, Compliance & Examples
  96. MONEY TRANSMITTER REGULATORS ASSOCIATION
  97. Am I an MSB? | FinCEN.gov
  98. MONEY TRANSMITTER REGULATORS ASSOCIATION
  99. Money Services Business (MSB) Registration | FinCEN.gov
  100. The National Money Transmitters Association, Inc.
  101. As crypto industry expands, US slashes office examining dirty money safeguards of cryptocurrency exchanges - ICIJ
  102. Law enforcement, banks warn of money laundering gaps in major US crypto bill - ICIJ
  103. From trading bans to total embrace, a global guide to crypto regulation
  104. cryptocurrency Archives - ICIJ
  105. Latest News from ICIJ | The Global Muckraker
  106. Politics Archives - ICIJ
  107. Crypto giants moved billions linked to money launderers, drug traffickers and North Korean hackers
  108. The Coin Laundry, a global cryptocurrency investigation
  109. The Coin Laundry Archives - ICIJ
  110. Landmark cryptocurrency legislation passes US House, to be signed into law by President Trump - ICIJ
  111. Trump-Appointed Group Urges Regulators to Clarify Crypto Trading Rules - Bloomberg
  112. Crypto regulatory affairs: US Congress starts work on stablecoin and digital asset legislation
  113. 1 BILLING CODE: 4810-02 DEPARTMENT OF THE TREASURY
  114. Ian Freeman Sentenced to Eight Years In Bitcoin Money Laundering Scheme In “Church of the Invisible Hand” Case | TRM Labs
  115. U.S. Department of the Treasury / Office of Foreign Assets Control
  116. Financial Crimes Enforcement Network (FinCEN)
  117. U.S. Department of the Treasury / Office of Foreign Assets Control
  118. TRM Labs
  119. International Consortium of Investigative Journalists (ICIJ)
  120. Chainalysis
  121. Bloomberg
Coverage gaps
fim-int-2026-07-07-G001: No newly-initiated NH-specific stat…
fim-int-2026-07-07-G001: No newly-initiated NH-specific state-level enforcement action independent of national advisories was identified within the 18-month window beyond the July 2025 appellate affirmation of the Freeman conviction; additional NH-specific docket monitoring would clarify whether this reflects genuinely reduced activity or thinner public reporting. [resolved]
fim-int-2026-07-07-G002: No evidence of any 2026 New Hampshi…
fim-int-2026-07-07-G002: No evidence of any 2026 New Hampshire legislative-session bill addressing crypto-ATM consumer protection was located; tracking NH General Court bill introductions would resolve whether the state intends to close this statutory gap. [resolved]
fim-int-2026-07-07-G003: FY2026 IRS BSA/AML examiner headcou…
fim-int-2026-07-07-G003: FY2026 IRS BSA/AML examiner headcount data is not yet available; obtaining it would clarify whether the FY2025 33% capacity reduction is a one-off adjustment or a continuing trend affecting NH-dependent federal oversight. [resolved]
fim-int-2026-07-07-G004: No NH State Treasurer disclosure or…
fim-int-2026-07-07-G004: No NH State Treasurer disclosure or procurement documentation describing AML-provenance or custody screening procedures for state-acquired bitcoin was located; Treasurer filings or audit reports would materially improve confidence on the Strategic Bitcoin Reserve provenance-control horizon item. [resolved]
fim-int-2026-07-14-G001: No independently verified EU AMLR/6…
fim-int-2026-07-14-G001: No independently verified EU AMLR/6AMLD transposition or AMLA supervisory-perimeter development this cycle; T1 primary EU sources not retrieved. [resolved]
fim-int-2026-07-14-G002: No conflict-finance domain developm…
fim-int-2026-07-14-G002: No conflict-finance domain development identified or sourced this cycle. [resolved]
fim-int-2026-07-14-G003: Global beneficial-ownership registr…
fim-int-2026-07-14-G003: Global beneficial-ownership registry effectiveness data not independently verified this cycle. [resolved]
fim-int-2026-07-14-G004: UK ECCTA2023 'large organisation' t…
fim-int-2026-07-14-G004: UK ECCTA2023 'large organisation' threshold scope and updated SFO/FCA guidance not reconfirmed this cycle. [resolved]
fim-int-2026-10-04-G001: No T1 Federal Register NPRM text fo…
fim-int-2026-10-04-G001: No T1 Federal Register NPRM text for the FinCEN AML/CFT program-rule reform was retrieved this cycle; confidence capped at Probable pending primary-source retrieval. [open]
fim-int-2026-10-04-G002: NH-specific SAR/CTR volume and FIU-…
fim-int-2026-10-04-G002: NH-specific SAR/CTR volume and FIU-coordination data were not located this cycle. [open]
fim-int-2026-10-04-G003: Tier D watch jurisdictions (KH, LA,…
fim-int-2026-10-04-G003: Tier D watch jurisdictions (KH, LA, MX, CO) were not independently searched this cycle given the US-NH union dispatch allocation. [open]
fim-int-2026-10-25-G001: Tier D jurisdiction collection (Cam…
fim-int-2026-10-25-G001: Tier D jurisdiction collection (Cambodia, Laos, Mexico, Colombia) was not performed this cycle because this research run was dispatched single-JID to US-NH only. [open]
fim-int-2026-10-25-G002: D1 (Sanctions), D2 (Beneficial Owne…
fim-int-2026-10-25-G002: D1 (Sanctions), D2 (Beneficial Ownership), D4 (Conflict Finance), and D6 (Compliance Technology) carry thin coverage for US-NH this cycle; no NH-specific signal was found or sought beyond a confirmation of no change. [open]
FIM-GAP-001 (D3): Despite New Hampshire's landmark unlicense…
FIM-GAP-001 (D3): Despite New Hampshire's landmark unlicensed-MSB prosecution (Ian Freeman), no newly-dated, NH-specific federal or state enforcement action was identified within the strict 18-month baseline window (Jan 2025–Jul 2026); available NH-nexus material consists predominantly of national-scope advisories/policy shifts with NH relevance rather than fresh state-specific actions.
FIM-GAP-002 (D5): New Hampshire has not enacted a crypto-ATM…
FIM-GAP-002 (D5): New Hampshire has not enacted a crypto-ATM-specific consumer-protection or fraud-prevention statute, unlike at least 18 U.S. states (including neighboring Massachusetts) that had done so by September 2025; this leaves the elder-fraud cash-to-crypto vector addressed only through general fraud/MSB law and federal advisories rather than kiosk-specific transaction limits or ID-verification mandates.
FIM-GAP-003 (D6): National IRS AML examiner capacity assigne…
FIM-GAP-003 (D6): National IRS AML examiner capacity assigned to MSB/crypto-firm oversight fell 33 percent in FY2025, thinning the federal supervisory layer that NH — lacking its own dedicated crypto-AML examination unit — relies upon most heavily given its history as the situs of a major unlicensed-MSB laundering scheme.
FIM-GAP-004 (D1): New Hampshire, as a U.S. state, has no aut…
FIM-GAP-004 (D1): New Hampshire, as a U.S. state, has no autonomous sanctions-designation authority; all sanctions listings/delistings applicable to NH-regulated entities flow uniformly from OFAC at the federal level. The sanctions_change_register above therefore reflects national OFAC actions applicable to NH via the state's standing OFAC/NH Banking Department information-sharing MOU rather than any NH-originated sanctions action.

Evidence

Confidence-tiered claims

The main NH law applicable to money transmitters is RSA 399-G [Source 1]
Probable · 1 source
Licensees must create and implement plans to comply with the Bank Secrecy Act [Source 1]
Probable · 1 source
A 'fundamental' reform of AML/CFT program requirements under the Bank Secrecy Act, covering banks, casinos/card clubs and MSBs [Source 1]
Probable · 1 source
All AML programs would be required to include countering the financing of terrorism (CFT) [Source 1]
Probable · 1 source
2025 order to show cause against BAM Trading Services Inc. tied to controlling-person BSA/AML compliance failures [Source 1]
Probable · 1 source
$2,000/day per-customer cap, 48-hour hold with refund right on first transaction, mandatory ID verification, fraud-risk warnings, blockchain-analytics wallet screening on digital asset transaction kiosks [Source 1]
Probable · 1 source
Node operators, miners (home and business digital-asset mining), and stakers are exempt from RSA 399-G money-transmitter licensing under new RSA chapter 359-V; a parallel exemption from RSA 421-B securities treatment also applies to mining/staking with personal funds [Source 1]
Probable · 1 source
HB 1207 (signed 10 July 2026) grants the NH Banking Department new powers effective 1 October 2026: requiring translated books/records and an interpreter at licensee expense (RSA 399-G:6, para. V), and a new certificate-of-authority posting duty for delegate locations (RSA 399-G:10, para. VIII) [Source 1]
Probable · 1 source