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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 — South Carolina US-SC

Domains covered
8 of 8
Sources
142
Role actions
8
Horizon <90d
1
Jurisdiction profile
FATF status: Compliant Tier: B Risk direction: Increasing Enablement vs enforcement: Mixed

South Carolina operates entirely within the uniform US federal AML/CFT/CPF perimeter (BSA, FinCEN rules, OFAC sanctions); it has no independent state sanctions regime.

MoreLike most US states, SC imposes no beneficial-ownership disclosure at LLC/corporate formation, relying on the now sharply narrowed federal Corporate Transparency Act backstop.

Key deficiencies
  • No state-level beneficial ownership disclosure requirement for LLC/corporation formation at the SC Secretary of State's office
  • 2025 FinCEN interim final rule exempting domestic reporting companies from CTA BOI reporting removes the principal federal check on SC-formed shell-company anonymity
  • No visible dedicated state AML/CFT supervisory unit independent of federal examiners for state-chartered institutions
  • Sparse public disaggregation of SC-specific federal enforcement data, limiting independent verification of state-level enforcement intensity
Recent developments (18m)
  • FinCEN interim final rule (March 2025) exempted all domestic reporting companies and US beneficial owners of foreign entities from CTA BOI reporting
  • BOI reporting deadline reinstated then narrowed to foreign reporting companies only (effective March-April 2025)
  • FinCEN Residential Real Estate Rule for non-financed transfers took effect December 1, 2025, extending AML coverage to real-estate closings nationally including SC
  • FinCEN convened a regional FinCEN Exchange examining SAR filings with a transactional nexus to South Carolina among five southeastern states
  • National FATF grey-list update (Feb 2026 plenary) added Kuwait and Papua New Guinea; US status unaffected

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

Brief

Lead signal

Lead Signal

South Carolina has enacted the Guarantee Banking Act (Act No. 257, H.5538), a state-level anti-debanking statute that bars banks with more than 100 billion dollars in assets and payment processors with more than 100 billion dollars in annual volume from declining, closing, or restricting covered financial services on non-quantitative, non-risk-based grounds such as protected speech, religion, or business sector. The statute explicitly exempts compliance with legitimate legal or regulatory requirements, including risk-based AML/CFT decisioning, so the underlying anti-money-laundering and counter-terrorist-financing regime that covered institutions already operate under is preserved rather than altered. The Act takes effect six months after the signature of the Governor, with a commencement date of December 30, 2026, and will be enforced by the Attorney General as an unfair or deceptive trade practice. The correct reading of this development is architectural: it is a fair-access and anti-debanking statute with an AML/CFT carve-out built into its text, not an AML instrument in its own right, and its enactment does not change South Carolina's substantive AML/CFT obligations for covered institutions.

Read full brief

Lead Signal

South Carolina has enacted the Guarantee Banking Act (Act No. 257, H.5538), a state-level anti-debanking statute that bars banks with more than 100 billion dollars in assets and payment processors with more than 100 billion dollars in annual volume from declining, closing, or restricting covered financial services on non-quantitative, non-risk-based grounds such as protected speech, religion, or business sector. The statute explicitly exempts compliance with legitimate legal or regulatory requirements, including risk-based AML/CFT decisioning, so the underlying anti-money-laundering and counter-terrorist-financing regime that covered institutions already operate under is preserved rather than altered. The Act takes effect six months after the signature of the Governor, with a commencement date of December 30, 2026, and will be enforced by the Attorney General as an unfair or deceptive trade practice. The correct reading of this development is architectural: it is a fair-access and anti-debanking statute with an AML/CFT carve-out built into its text, not an AML instrument in its own right, and its enactment does not change South Carolina's substantive AML/CFT obligations for covered institutions.

Other Developments

A supervisory-leadership transition is pending at the state level. David Stumbo (R) was elected on November 3, 2026 to succeed Alan Wilson, who was elected Governor, as Attorney General. The Attorney General's office administers money-services licensing under the South Carolina AML Uniform Money Services Act in the capacity of Commissioner, so this is a supervisory-architecture transition worth tracking into the January 2027 inauguration window, though no substantive AML policy change has been observed to accompany it.

Cross-Monitor Connections

The Guarantee Banking Act sits at the intersection of fair-access banking policy and financial-crime compliance architecture: its carve-out language is the operative boundary between what a covered institution may still do under risk-based AML/CFT decisioning and what it may no longer do on other grounds. The pending change in the Attorney General's office is relevant to any monitor tracking state-level supervisory personnel, given the office's dual role as both the Act's enforcer and the licensing authority for money-services businesses under the state's AML statute.

Outlook

As scheduled, covered banks and payment processors in South Carolina will need to document, ahead of the December 30, 2026 commencement date, that adverse-action decisions on covered accounts rest on a quantitative, impartial, risk-based standard, including any AML/CFT risk-based de-risking determinations that are to be preserved under the statutory exemption. Separately, the Attorney General transition reaches its next formal milestone at inauguration in the first quarter of 2027; whether the change in officeholder carries any substantive adjustment to money-services licensing practice is not yet established and should be read as an open supervisory-architecture question rather than an anticipated policy shift.

Earlier periodic briefs (5)
25 Oct 2026 · fim-2026-10-25

Lead Signal

South Carolina's financial-crime framework for digital assets now sits on firmer documentary ground, though the underlying law predates the current observation window. Act No. 208 (S.163), signed into law on 19 May 2026, inserts a new Chapter 47 into Title 34 of the South Carolina Code of Laws. Its most consequential provision for financial-integrity purposes is Section 34-47-60, which places four digital-asset activities beyond the reach of the state money transmitter licence requirement: digital-asset mining, blockchain node operation, on-chain software development, and crypto-to-crypto exchange that never touches fiat currency. The same Act separately bars state governmental authorities from accepting or requiring payment in a central bank digital currency, a provision that is structurally distinct from the licensing carve-out but was enacted in the same instrument.

Alongside this, the standing state anti-money-laundering architecture is now documented in more detail. The 2024 Act No. 218 substantially adopted the Money Transmission Modernization Act model law, revising net-worth, surety-bond, permissible-investment and control-definition requirements for money transmitter licensees, with the new terms binding on licensees from 1 January 2025. Neither development is a change within the immediate reporting window; both are newly captured, durable features of the state's regime that materially inform how the state licenses, or declines to license, money-services activity touching digital assets.

Other Developments

A pending kiosk-licensing bill remains stalled. House Bill 4592, which would create a licensing and disclosure regime for virtual-currency kiosks by amending Chapter 3 of Title 34, has not moved beyond a committee referral dated 13 January 2026. Absent revival, it is effectively dead for the 2025-2026 legislative biennium. In its absence, oversight of crypto-ATM operators in the state continues to rest on an older interpretive order rather than statute, leaving a documented gap between enforcement practice and codified law for this specific channel.

The crypto-to-crypto carve-out leaves a federal question open. Section 34-47-60 removes non-fiat crypto-to-crypto exchange from the state money transmitter licence requirement, but whether that state-level exemption affects a firm's underlying federal obligation to register as a money services business with FinCEN under the Bank Secrecy Act has not been independently confirmed. The state exemption narrows state licensing exposure only; it does not, on its own terms, speak to the federal registration question.

Cross-Monitor Connections

The licensing-exemption architecture described here has a direct counterpart in payment-sector market-access analysis, where the same Section 34-47-60 carve-out and the stalled kiosk bill define which digital-asset activities require state authorisation before operating. Readers tracking state-level digital-asset frameworks more broadly should note that South Carolina is one of a small number of states that does not require a licence for standalone virtual-currency transmission, a structural feature of its market that an illicit-finance lens reads primarily as a documentation and registration question rather than an enforcement one, since no enforcement action in this space has surfaced.

Outlook

So long as House Bill 4592 remains in committee, the regulatory treatment of crypto-kiosk operators in South Carolina will continue to rest on administrative interpretation rather than statute, a gap that could persist through the remainder of the legislative biennium absent a revival effort. The durability of the Section 34-47-60 carve-outs and the Act No. 218 licensing baseline is not itself in question, but the interaction between the state-level crypto-to-crypto exemption and federal money-services-business registration obligations remains an open question worth monitoring, since a federal determination on that point could change the practical compliance burden for firms otherwise exempt at the state level.

11 Oct 2026 · fim-2026-10-11

Lead Signal

South Carolina has enacted S.163 (South Carolina Act No. 208), signed by the Governor on 19 May 2026, adding a new Chapter 47 to Title 34 of the South Carolina Code of Laws. The instrument narrows the states money-transmitter licensing perimeter by exempting digital-asset mining, blockchain node operation, blockchain software development, and non-fiat crypto-to-crypto exchange from the licensing requirement that otherwise applies under Title 35, Chapter 11. The carve-out is architectural rather than incidental: it redraws the boundary of what counts as regulated money transmission in the state, rather than resolving a single enforcement matter. The South Carolina Attorney Generals authority to prosecute fraud by persons falsely claiming to offer digital-asset mining-as-a-service or staking-as-a-service is expressly preserved notwithstanding the licensing carve-out, though this backstop is untested as of this cycle.

The same instrument bans South Carolina state agencies and political subdivisions from accepting, requiring, or testing payment in a central bank digital currency, including barring participation in any Federal Reserve CBDC pilot. This finding is newly scoped for the jurisdiction this cycle and is accordingly carried at a Probable confidence tier notwithstanding its Tier 1 legislative sourcing.

Other Developments

Baseline money-transmission licensing is unchanged outside the carve-out. South Carolina Code Title 35, Chapter 11 continues to require that a person may not engage in the business of money transmission, or advertise, solicit, or hold himself out as providing it, unless licensed under Article 2 or acting as an authorised delegate of a licensee. Licensees and authorised delegates remain obliged to file with the Commissioner all reports required under federal currency reporting, recordkeeping, and suspicious-transaction requirements. S.163 narrows the perimeter of what activity falls inside this licensing-and-reporting regime; it does not alter the regime itself for money transmission generally.

No sanctions, beneficial-ownership, enabler-jurisdiction, or compliance-technology signal specific to South Carolina was identified this cycle. Sanctions exposure in the state remains governed federally through OFAC, and no state-level beneficial-ownership registry development was located, leaving the federal Corporate Transparency Act framework as the operative baseline.

Cross-Monitor Connections

The crypto-infrastructure carve-out in S.163 and the parallel CBDC-acceptance ban sit at the boundary between this monitors AML/CTF lens and the digital-payments policy questions tracked elsewhere in the fleet: the licensing narrowing changes which digital-asset activities fall inside the states money-services-business perimeter, which in turn determines which actors owe the federal currency-reporting and suspicious-activity obligations that remain the backbone of the states AML/CTF posture.

Outlook

The durability of the S.163 carve-out depends on how the Attorney Generals preserved fraud-enforcement authority is actually exercised against mining-as-a-service and staking-as-a-service schemes; as of this cycle that backstop remains an express statutory power rather than an observed enforcement pattern. The baseline Title 35 Chapter 11 licensing-and-reporting regime continues to apply to money transmission generally, and the narrowed perimeter established by S.163 is the structural development to watch for enforcement activity in coming cycles.

28 Sep 2026 · fim-2026-09-28

Lead Signal

South Carolina enacted S.163, the Digital Asset / Anti-CBDC Act, on May 19, 2026 (ratified May 14, 2026), narrowing the scope of the state's money-transmitter-licensing regime as it applies to core crypto infrastructure activity. The law exempts digital-asset mining, node operation, blockchain-software development, and fiat-free crypto-to-crypto exchange from the licensing requirement set out in the South Carolina Uniform Money Services Act (Title 35, Chapter 11), while preserving the Attorney General's fraud-enforcement authority over mining-as-a-service and staking-as-a-service claims. This is a deliberate liberalisation of state licensing scope, not a gap in enforcement: the exemption is narrow and activity-specific, and it sits alongside a pending bill, S.4592, that would move in the opposite direction for a different activity class.

Other Developments

S.4592, the kiosk-licensing bill, would require owners and operators of virtual-currency kiosks to obtain a money transmitter licence and to post on-screen fraud-risk disclosures before completing a transaction. This is a tightening-direction proposal aimed specifically at consumer-facing cash-to-crypto on/off-ramp risk, the inverse of S.163's infrastructure-level liberalisation, and the two together describe a state legislature drawing a distinction between wholesale crypto infrastructure (mining, nodes, software, peer exchange) and retail-facing points of contact (kiosks) that carry consumer-fraud exposure.

The standing AML/CTF framework for money transmitters in South Carolina remains the Uniform Money Services Act, administered by the Money Services Division of the state Attorney General's Office. This framework was renamed from the "South Carolina Anti-Money Laundering Act" in 2024 via Act No. 218, which substantially adopted the multistate Money Transmission Modernization Act. Neither S.163 nor S.4592 disturbs this baseline architecture; S.163 carves narrow exemptions out of it for specific activity types, and S.4592 would bring an additional activity type within its scope.

Cross-Monitor Connections

The licensing-scope narrowing in S.163 is a direct payments-and-licensing question as much as an AML/CFT one, and the same underlying legislative facts inform the payments monitor's read on South Carolina's money-transmitter perimeter. The consumer-facing kiosk bill, S.4592, likewise sits at the intersection of financial-crime typology (cash-to-crypto layering risk at unattended kiosks) and consumer-protection framing; a kiosk-specific licensing and disclosure regime, if enacted, would be a meaningful new compliance-technology and monitoring surface for South Carolina-licensed money transmitters operating kiosks.

Outlook

Watch for S.4592's progress through the South Carolina General Assembly; it remains at the proposed stage with an estimated effective horizon in 2027, and there is no evidence in this cycle's sourcing of committee movement beyond its introduction. Should it advance, the compliance obligation for kiosk operators would represent a new, narrowly-scoped state AML/consumer-protection control layered onto the existing Uniform Money Services Act framework, rather than a change to the baseline AML/CTF regime itself.

11 Aug 2026 · fim-2026-08-05

Lead Signal

The FATF June 2026 Plenary reset the grey list, adding Iraq and Bosnia and Herzegovina while removing Algeria and Namibia, holding the total number of monitored jurisdictions at twenty-two. The Plenary also adopted a strengthened humanitarian-assistance carve-out under Recommendation 6, narrowing but not eliminating the scope for divergent national humanitarian-exemption practice across the EU, US, and UK autonomous-listing regimes. The blacklist of Iran, North Korea, and Myanmar was unchanged, and Giles Thomson of the United Kingdom succeeds Elisa de Anda Madrazo as FATF President. Read architecturally rather than as a simple headcount, this is a churn-not-expansion cycle: the monitored-jurisdiction total held steady even as the underlying membership shifted, and the Recommendation 6 update signals continued multilateral tightening of the sanctions-humanitarian interface.

Other Developments

A dense OFAC enforcement cluster spanned three geographies. The Treasury issued a supplemental FinCEN alert on CJNG-linked fuel-theft and tax-evasion schemes alongside an OFAC sanctions action against two Mexican nationals and nine entities. Separately, OFAC sanctioned more than a dozen individuals and entities tied to a Sinaloa Cartel financial cell converting fentanyl cash proceeds into cryptocurrency for cross-border transfer into Mexico, and designated twenty-nine individuals and entities tied to the cyber-fraud and scam-casino economy of Cambodia, a network anchored by a sitting Cambodian senator. OFAC also updated its 2019 Central Bank of Iran designation alongside a Tether stablecoin freeze of associated Tron addresses.

The central bank of Cambodia is publicly racing against a third grey-list placement. Governor Chea Serey warned in January 2026 that continued failure to improve anti-money-laundering capacity risks a third FATF grey-list placement, and the National Bank of Cambodia has launched a second national risk assessment. The Golden Triangle Special Economic Zone in Bokeo Province, Laos, under a ninety-nine-year lease to Kings Romans Group, continues to operate as a cross-border laundering and scam-centre enclave with limited effective Lao state jurisdictional access.

Colombia received its first Majors List adverse finding in nearly thirty years. Colombia was designated among five countries that failed demonstrably to meet counternarcotics obligations under the FY2026 Majors List review, amid record coca cultivation, though sanctions were waived on national-interest grounds.

AMLA advanced two concrete supervisory milestones. The Anti-Money Laundering Authority of the European Union published a reporting package on 12 May 2026 to identify provisionally eligible obliged entities and finalised supervisory-cooperation standards on 21 July 2026, governing the handover of supervisory powers from national authorities to the EU level ahead of the 2027 selection cycle and 2028 direct supervision of up to forty high-risk cross-border institutions.

South Carolina moved on two fronts in its own digital-asset perimeter. Governor McMaster signed S.163 on 19 May 2026, barring South Carolina governmental entities from accepting or piloting a central bank digital currency and exempting blockchain-software development, node operation, and crypto-to-crypto exchange from money-transmitter licensing. A separate pending bill, H.4592, would require virtual-currency-kiosk operators to hold a money-transmitter licence and post mandatory fraud warnings, and remains in House committee with no recorded vote.

FinCEN and OFAC jointly proposed a stablecoin AML and sanctions framework. A joint FinCEN and OFAC Notice of Proposed Rulemaking issued 8 April 2026 would treat permitted payment stablecoin issuers as Bank Secrecy Act financial institutions under a new standalone Part 1033, mandating AML/CFT and sanctions-compliance programs; the comment period closed 9 June 2026 with final rules expected around July 2026.

Cross-Monitor Connections

The anchoring of the Cambodian scam-casino network by a sitting senator is a direct state-capture signal that connects to governance-focused monitoring of enabler-jurisdiction political economy, distinct from the AML-architecture lens applied here. The characterisation by FinCEN of CJNG fuel-theft as the most significant non-drug illicit revenue source for the cartel connects to commodity-flow monitoring of fuel and extractive-industry theft as a financing vector, an intersection between AML enforcement and physical-commodity integrity. Record coca cultivation in Colombia, alongside its adverse Majors List finding, is a conflict-finance signal with narcotics-economy dimensions that a dedicated commodity or conflict-finance monitor would track independently. The crypto-to-crypto licensing exemption for South Carolina under S.163 has a direct payments-monitor dimension: a narrower money-transmitter licensing perimeter for a category of digital-asset activity is, by construction, a narrower perimeter for the licensing-anchored obligations that a payments-focused monitor would track from the market-access side rather than the AML side addressed here.

Outlook

Watch for the AMLA provisional eligible-entity list, due to finalise at the end of September 2026, as the next concrete step toward the 2027 selection cycle, and for the GENIUS Act stablecoin final rule, expected around July 2026 with a proposed twelve-month implementation runway before most permitted payment stablecoin issuers have operational AML and sanctions-compliance programs. Southeast Asian enabler-jurisdiction risk, Cambodia and Laos in particular, is assessed as structurally entrenched despite visible enforcement activity, because state-capture and enclave dynamics limit the practical reach of both domestic and international sanctions pressure; the outcome of the second national risk assessment in Cambodia is the signal most likely to move that assessment in either direction next cycle.

14 Jul 2026 · fim-2026-07-14

Lead Signal

The defining development for South Carolina financial-integrity exposure this cycle is not a discrete enforcement action but a structural regression in United States beneficial-ownership transparency architecture. A FinCEN interim final rule issued in March 2025 exempted all domestic reporting companies, including every South Carolina formed LLC and corporation, and US beneficial owners of foreign entities, from Corporate Transparency Act beneficial-ownership reporting, leaving only foreign reporting companies covered. This removed the sole federal backstop against a state framework that already imposes no beneficial-ownership disclosure requirement at LLC or corporation formation. South Carolina now sits at the intersection of two coincident opacity conditions: an absent state registry, and, following the federal rollback, an absent operative federal registry for domestically formed entities as well.

Under the architecture-over-incident principle that governs this assessment, this structural rollback outweighs any single enforcement action reviewed in this cycle, at High confidence. The jurisdiction risk tracker records South Carolina risk direction as increasing, the enforcement-versus-enablement balance as mixed, and the underlying drivers as structural rather than episodic. South Carolina carries no independent state sanctions or beneficial-ownership regulatory perimeter of its own; its risk profile is a direct function of the federal BSA, OFAC, and FinCEN architecture it inherits wholesale, with state-specific variance confined to corporate-formation permissiveness and to the presence of strategically significant trade infrastructure at the Port of Charleston and the Boeing final-assembly site in North Charleston.

Other Developments

Gatekeeper professionals identified as sanctions-evasion enablers. OFAC advisory guidance documents realtors, investment advisers, attorneys, and trust and corporate-service providers as capable of enabling a sanctioned person to retain a concealed interest in United States property through layered LLC and trust structures and post-designation transfers, at Assessed confidence. This bears directly on South Carolina professional-services and real-estate sectors, which share the disclosure-free formation regime described above without a distinguishing state gatekeeper-licensing framework.

Anonymous incorporation was exploited in a documented multi-state fraud. Approximately seventy million dollars was reported stolen from federal healthcare and procurement programs using companies anonymously incorporated across Florida, Georgia, North Carolina, South Carolina, and Louisiana, at Assessed confidence, corroborated by tier one FinCEN LLC risk analysis.

A regional analytics exchange reviewed suspicious-activity reporting with a South Carolina nexus. FinCEN convened a regional FinCEN Exchange reviewing SAR statistics and typology trends with a transactional nexus to Alabama, Florida, Georgia, Mississippi, and South Carolina, indicating South Carolina domiciled activity is materially represented in national typology analysis rather than marginal, at Assessed confidence; the source carried no specific event date, a noted gap.

The uniform federal sanctions perimeter processed two nationally significant actions. OFAC settled with IPI Partners LLC for eleven point five million dollars over fifty one apparent Russia-sanctions violations, at High confidence. OFAC and FinCEN, coordinated same day with the United Kingdom, designated the Prince Group transnational criminal organization and applied a Section 311 special measure against Huione Group, alongside a Department of Justice fifteen billion dollar forfeiture action; both apply nationwide with no South Carolina specific gap identified.

The digital-asset compliance perimeter tightened federally. OFAC settled with ShapeShift AG for seven hundred fifty thousand dollars over sanctions violations, at High confidence. Huione Group, reported to have received over thirty nine point six billion dollars in 2025 per vendor analytics, was severed from the United States financial system, at Assessed confidence. The National Credit Union Administration and the Office of the Comptroller of the Currency issued GENIUS Act stablecoin issuer implementing rules in February and March 2026 respectively, with Treasury state-equivalence determinations pending in the fourth quarter of 2026.

Residential real estate coverage was extended nationally. The FinCEN Residential Real Estate Rule for non financed transfers took effect December 1, 2025, extending reporting to real-estate closings nationally, including South Carolina, the principal offsetting development against the beneficial-ownership rollback described above, at Assessed confidence.

A Financial Action Task Force coverage gap was flagged. The baseline captured only the February 2026 plenary, which added Kuwait and Papua New Guinea to increased monitoring without affecting United States standing; a later June 2026 plenary adding Bosnia and Herzegovina and Iraq while removing Algeria and Namibia was identified only through reviewer challenge review, at Assessed confidence pending direct corroboration.

Sanctions-regime divergence remains structural. The Prince Group and Huione action was coordinated same day with the United Kingdom, while other targets have been sanctioned unilaterally by the United States without parallel United Kingdom or European Union listings, creating listing-scope mismatches for South Carolina firms trading through the Port of Charleston or the Boeing North Charleston supply chain, a structural watch item at Possible confidence.

No dedicated state compliance-technology or supervisory function was identified. No public evidence establishes an independent South Carolina supervisory unit distinct from federal examiners, at Assessed confidence; adoption of analytics-driven monitoring by South Carolina chartered institutions is shaped entirely by national priorities.

Cross-Monitor Connections

The findings in this cycle route most directly to two adjacent monitoring lenses. The Port of Charleston and Boeing North Charleston aerospace-supply-chain exposure, while carrying no documented South Carolina specific designation or seizure this cycle, is the natural cross-reference point for commodity and trade-flow monitoring given rising trade friction between the United States and both Russia and China; that adjacency is tracked here as a watch item rather than an active finding. The coordinated versus unilateral pattern in the Prince Group, Huione, and related designations is a structural sanctions-regime divergence relevant to macro-level sanctions-transmission analysis, since listing-scope mismatches between the United States, the United Kingdom, and the European Union directly shape compliance friction for any South Carolina trade counterparty operating across those jurisdictions. No conflict-finance or extractive-industry nexus specific to South Carolina was identified this cycle, and that absence is recorded rather than assumed.

Outlook

Three federal-level uncertainties dominate the forward view for South Carolina, and none carries a state-specific instrument. The scope of the eventual final Corporate Transparency Act rule will determine whether the shell-entity opacity created by the March 2025 rollback is narrowed or entrenched, with a decision anticipated toward the fourth quarter of 2026. Treasury substantially similar determinations under the GENIUS Act will decide whether state-level stablecoin regimes, none of which currently exist in South Carolina, receive federal deference, shaping the licensing pathway available to any South Carolina chartered issuer. The October 2026 Financial Action Task Force plenary will reassess global deficiency lists and issue further Iran, North Korea, and Myanmar countermeasure guidance that flows through FinCEN advisories to South Carolina regulated institutions unchanged. All three resolve nationally and apply to South Carolina without modification.

Domain intelligence (D1–D8)

D1 Sanctions

no_changestanding position

Sanctions Architecture and Evasion

South Carolina carries no independent sanctions authority and no state-specific sanctions-evasion node identified in this research window; its entire exposure runs through the uniform federal OFAC and FinCEN architecture, and this cycle two nationally significant actions define that inherited perimeter. OFAC settled with IPI Partners LLC for eleven million four hundred eighty five thousand three hundred fifty two dollars, resolving fifty one apparent violations of Russia sanctions arising from 2017 to 2018 investment solicitations, at High confidence; the settlement applies to any South Carolina domiciled investor or counterparty without a distinguishing state nexus. Separately, OFAC and FinCEN, coordinated same day with the United Kingdom Foreign, Commonwealth and Development Office, designated the Prince Group transnational criminal organization, one hundred forty six targets including Chen Zhi, and applied a Section 311 special measure severing Huione Group from the United States financial system, accompanied by a Department of Justice indictment and a record fifteen billion dollar forfeiture action, at High confidence. Section 311 is a United States specific FinCEN mechanism with no direct Office of Financial Sanctions Implementation or European Union equivalent, illustrating a structural sanctions-regime divergence that applies nationwide, including to any South Carolina based institution carrying correspondent exposure to the designated network.

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The most direct South Carolina relevant sanctions-architecture finding this cycle is not a designation but an enablement typology. OFAC advisory guidance documents realtors, investment advisers, attorneys, and trust and corporate-service providers as capable of enabling a designated person to retain a concealed interest in United States property through layered LLC and trust structures, nominee arrangements, and post-designation transfers, at Assessed confidence. This typology intersects directly with the corporate-formation and real-estate architecture examined elsewhere in this brief: South Carolina imposes no beneficial-ownership disclosure at company formation and no distinguishing state gatekeeper-licensing or anti-money-laundering regime for the professionals named in the advisory, meaning the enabling conditions the advisory describes are structurally present in South Carolina absent any state-level countermeasure.

The gatekeeper-enablement finding is classified as a HIGH severity, evolving scheme rather than a static one, reflecting an assessment that the underlying enforcement precedent continues to develop; OFAC and FinCEN are named as the primary enforcement actors capable of extending future scrutiny to the same professional categories, at Assessed confidence. This is distinct from the digital-asset and beneficial-ownership regulatory-gap findings addressed elsewhere in this brief, both of which are also classified at HIGH severity following a reviewer correction; the shared HIGH severity ceiling across these active findings reflects the absence, in this research window, of documented state-complicity or conflict-consequence evidence that would support a higher calibration under this program methodology.

A second structural finding concerns listing-scope divergence. The Prince Group and Huione action was coordinated same day between the United States and the United Kingdom, while other targets, including a Chinese oil-terminal operator, have been sanctioned unilaterally by the United States without parallel United Kingdom or European Union listings, at Assessed confidence. This pattern is assessed as stable and structural rather than episodic, and it creates compliance friction for any South Carolina firm trading through the Port of Charleston or through the Boeing North Charleston aerospace final-assembly supply chain, where strategically significant export and dual-use trade infrastructure elevates theoretical trade-based money-laundering and export-control exposure relative to the national average, at Possible confidence given the absence of any documented South Carolina specific designation or seizure in the window. The jurisdiction risk tracker places D1 among the five primary domains through which South Carolina overall risk direction is assessed as increasing, alongside D2, D3, D5, and D6, with the enforcement-versus-enablement balance recorded as mixed and the underlying drivers as structural rather than episodic, at High confidence. Finally, the baseline research captured the February 2026 Financial Action Task Force plenary, which added Kuwait and Papua New Guinea to increased monitoring without affecting United States standing, at High confidence, but did not capture the subsequent June 2026 plenary, identified only through reviewer challenge review, which added Bosnia and Herzegovina and Iraq while removing Algeria and Namibia, at Assessed confidence pending direct corroboration.

Outlook

The sanctions-architecture picture for South Carolina through the remainder of 2026 is defined by three federal-level developments rather than any state-specific instrument. The October 2026 Financial Action Task Force plenary will reassess global deficiency lists and issue further Iran, North Korea, and Myanmar countermeasure statements, which flow through FinCEN advisories to South Carolina regulated institutions unchanged. Continued OFAC enforcement against Russia-sanctions violations and further Section 311 style actions against virtual-asset-service-provider networks remain likely watch items given the volume of activity already observed this cycle, though no South Carolina specific escalation is anticipated. The structural listing-scope divergence between the United States and its United Kingdom and European Union partners is expected to persist rather than resolve, meaning South Carolina firms with cross-border trade exposure through the Port of Charleston or the Boeing supply chain should expect continued mismatch between which counterparties are captured under which regime.

Judgment: No SC-specific sanctions-architecture or evasion development this cycle. Probable
Cumulative analysis

Sanctions Architecture and Evasion — Cumulative Analysis

As of this first assessment cycle for South Carolina, issue 28, the sanctions-architecture picture is defined entirely by the uniform federal perimeter that the state inherits, since South Carolina holds no independent sanctions authority of its own. Two nationally significant enforcement actions anchor the record to date: an eleven point five million dollar OFAC settlement with IPI Partners LLC resolving fifty one apparent Russia-sanctions violations arising from 2017 to 2018 solicitations, at High confidence, and a coordinated United States and United Kingdom action in October 2025 designating the Prince Group transnational criminal organization, one hundred forty six targets including Chen Zhi, alongside a FinCEN Section 311 special measure severing Huione Group from the United States financial system and a Department of Justice fifteen billion dollar forfeiture action, at High confidence. Section 311 remains a United States specific mechanism without a direct United Kingdom or European Union equivalent, a structural divergence point carried forward as a standing tracker.

Running alongside these enforcement actions is an enablement typology of comparable analytical weight: OFAC advisory guidance identifying realtors, investment advisers, attorneys, and trust and corporate-service providers as capable of enabling a sanctioned person to retain a concealed United States property interest through layered LLC and trust structures and post-designation transfers, at Assessed confidence, classified as an evolving HIGH severity scheme. This typology connects directly to the state corporate-formation condition addressed under Beneficial Ownership and Corporate Transparency: South Carolina imposes no beneficial-ownership disclosure at formation and no distinguishing gatekeeper-licensing regime, meaning the structural conditions the OFAC advisory describes are present in this jurisdiction without a state-level countermeasure.

A third standing element is listing-scope divergence: the same-day coordination on Prince Group and Huione contrasts with unilateral United States action against other targets, including a Chinese oil-terminal operator, without parallel United Kingdom or European Union listings, at Assessed confidence, a pattern assessed as structural and stable rather than episodic. This divergence is the compliance-friction channel most relevant to any South Carolina firm trading through the Port of Charleston or the Boeing North Charleston aerospace supply chain, infrastructure carried forward as a Possible-confidence watch item given the absence of any South Carolina specific designation or seizure to date. Finally, the Financial Action Task Force coverage baseline captured the February 2026 plenary, at High confidence, but not the June 2026 plenary update, identified only through reviewer challenge review at Assessed confidence and flagged for direct corroboration in the next cycle.

The jurisdiction risk tracker situates D1 as one of five primary domains, alongside D2, D3, D5, and D6, driving an overall South Carolina risk-direction assessment of increasing, with the enforcement-versus-enablement balance recorded as mixed and the underlying drivers as structural rather than episodic, at High confidence in the underlying jurisdiction-level assessment. No SC-specific dark-fleet or shadow-banking node has been identified against the standing Russian sanctions-evasion-architecture tracker as of this cycle, leaving the Charleston and North Charleston trade-infrastructure adjacency as the primary watch item carried into future cycles.

Outlook

Going forward, the sanctions-architecture record for South Carolina will be shaped by three federal-level tracks: continued OFAC enforcement against Russia-sanctions violations and virtual-asset-service-provider networks, the October 2026 Financial Action Task Force plenary and its associated Iran, North Korea, and Myanmar countermeasure guidance, and the persistence or narrowing of the United States, United Kingdom, and European Union listing-scope divergence. None of these tracks currently carries a South Carolina specific instrument, and the next cycle should confirm whether the June 2026 Financial Action Task Force plenary outcomes have been independently corroborated.

domain_sub_briefs · D1 · Cumulative analysis
Standing baseline position

FATF grey list holds at 22 jurisdictions following June 2026 Plenary additions (Iraq, Bosnia and Herzegovina) and removals (Algeria, Namibia); Recommendation 6 strengthened with a humanitarian-assistance carve-out.

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

Sanctions

The FATF June 2026 Plenary reset the grey list, adding Iraq and Bosnia and Herzegovina while removing Algeria and Namibia, and held the total number of monitored jurisdictions at twenty-two; the blacklist of Iran, North Korea, and Myanmar was unchanged. The addition of Bosnia and Herzegovina follows a December 2024 MONEYVAL mutual evaluation identifying strategic AML/CFT deficiencies. The Plenary also adopted a strengthened humanitarian-assistance carve-out under Recommendation 6, narrowing but not eliminating scope for divergent national humanitarian-exemption practice across the EU, US, and UK autonomous-listing regimes; no new cross-bloc delisting asymmetry was independently confirmed this cycle beyond that Recommendation 6 update. Giles Thomson of the United Kingdom succeeds Elisa de Anda Madrazo as FATF President.

Two of the jurisdictions leaving the list illustrate the opposite trajectory. The removal of Algeria is read as an enforcement outcome following completed risk-based supervision and targeted-financial-sanctions reforms, and the removal of Namibia followed beneficial-ownership-framework and enforcement reforms. The net effect, a steady headcount of twenty-two jurisdictions with different members entering and leaving, is assessed as a churn-not-expansion dynamic: multilateral tightening at the level of individual jurisdictions without a net widening of the monitored perimeter.

Sanctions-designation activity this cycle ran dense and cross-geographic. FinCEN issued a supplemental alert on CJNG-linked fuel-theft and tax-evasion schemes alongside an OFAC sanctions action against two Mexican nationals and nine entities. OFAC separately sanctioned more than a dozen individuals and entities tied to a Sinaloa Cartel financial cell that converts fentanyl cash proceeds into cryptocurrency for cross-border transfer into Mexico, and designated twenty-nine individuals and entities tied to the cyber-fraud and scam-casino economy of Cambodia, a network including Kok An, Crown Resorts, Anco Brothers, K99 Group, Bolai, and Heng Feng Cambodia Bank, anchored by a sitting Cambodian senator. OFAC also updated its 2019 Central Bank of Iran designation alongside a Tether stablecoin freeze of associated Tron addresses. Read as architecture rather than incident, this cluster spans three distinct typologies within a single cycle, fuel-theft and tax-evasion, narcotics-to-crypto layering, and state-linked scam-casino financing, evidencing a sanctions-evasion landscape that increasingly routes through digital-asset rails alongside conventional channels.

The Mexico-focused designations sit apart from the Cambodia and Laos enabler dynamics on the structural-versus-episodic axis: the jurisdiction risk tracker classifies the risk trajectory for Mexico as increasing and enforcement-driven but episodic, reflecting a cluster of discrete designations rather than a standing structural condition. A standing gap register entry notes that no Tier-1 source was located this cycle for the standing Russian dark-fleet and technology-procurement sanctions-evasion tracker, and a further gap notes that no new cross-bloc delisting-asymmetry designation was independently confirmed beyond the Recommendation 6 update itself; both gaps are carried forward rather than resolved this cycle.

Outlook

Watch the next FATF Plenary for whether the churn-not-expansion pattern in the grey list continues, and watch for further OFAC designations extending the current Mexico, Cambodia, and Iran cluster, particularly any follow-on asset-tracing action tied to the CJNG fuel-theft designations. The Recommendation 6 humanitarian-carve-out update is the most durable structural development this cycle and merits tracking for its effect on national implementation divergence, since the standing sanctions-regime-divergence tracker registered no new cross-bloc delisting asymmetry beyond it this cycle.

D2 Beneficial Ownership

no_changestanding position

Beneficial Ownership and Corporate Transparency

South Carolina sits entirely outside the European Union AML Package perimeter; the developments directly relevant to its own regulatory exposure this cycle are domestic and federal rather than European. Most consequential is a March 2025 FinCEN interim final rule that exempted all domestic reporting companies, including every South Carolina formed LLC and corporation, and US beneficial owners of foreign entities, from Corporate Transparency Act beneficial-ownership reporting; only foreign reporting companies remain covered, at High confidence. This removed the sole federal backstop against a South Carolina corporate-formation regime that, like most United States states, imposes no beneficial-ownership disclosure requirement at the Secretary of State office, at High confidence. The two conditions compound: South Carolina formed entities are now untracked by any operative beneficial-ownership registry, state or federal. The one offsetting national development this cycle is the FinCEN Residential Real Estate Rule for non financed transfers, effective December 1, 2025, which extends anti-money-laundering adjacent reporting to real-estate closings nationally, including South Carolina, at Assessed confidence, though it addresses only the real-estate transaction point rather than the underlying formation-stage opacity.

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Globally, the European Union AML Package sets the structural direction toward harmonized beneficial-ownership transparency, and this is durable backdrop against which the South Carolina picture should be read even though South Carolina itself falls outside its scope. The Package comprises three distinct instruments: the AML Regulation, or AMLR, Regulation (EU) 2024/1624, which is directly applicable across member states; the sixth AML Directive, or 6AMLD, which is transposed individually by each member state; and the AMLA Regulation, Regulation (EU) 2024/1620, which establishes the Anti-Money Laundering Authority. Together these shift the European Union supervisory perimeter from a purely national model toward a hybrid regime in which the Authority exercises direct supervision over a defined set of higher-risk cross-border obliged entities, with indirect supervision extending further, while national authorities retain primary responsibility for the remainder. The AMLR application date is 2027. This architecture is a structural fact rather than a single-cycle development, and it is the durable comparator against which the South Carolina condition, a narrowed federal registry sitting atop an absent state registry, should be assessed: the divergence between the two regimes is widening rather than narrowing, at Assessed confidence, and it is expected to create increasing cross-border compliance friction for South Carolina firms with European Union counterparties as the AMLR application date approaches, since South Carolina transposition status of any equivalent instrument is not applicable and third-country risk assessment of the United States by European Union authorities becomes the relevant transmission channel rather than any direct South Carolina obligation.

This finding was subject to an internal severity correction this cycle: the federal rollback was initially characterized in baseline research as a criminal scheme of critical severity, but a reviewer challenge determined that a regulatory instrument creating a structural enabler condition, absent documented state-complicity or conflict-consequence evidence, does not meet the evidentiary bar for that classification, and the finding was reclassified as a HIGH severity structural regulatory-gap finding, at High confidence. This correction does not diminish the durability of the underlying structural fact; it recalibrates only the severity label attached to it, consistent with the architecture-over-incident principle that governs findings of this kind. The domain tracker records this trajectory as deteriorating, one of five primary domains, alongside D1, D3, D5, and D6, through which South Carolina overall risk direction is assessed as increasing. A remaining gap in this assessment is that the scope and timeline of the pending final Corporate Transparency Act rule is not yet determinable, precluding a confident projection of whether the current opacity condition will be narrowed or entrenched, a limitation carried forward into the outlook below.

Outlook

The forward picture for South Carolina beneficial-ownership transparency turns on a single pending federal instrument: FinCEN is expected to publish a final Corporate Transparency Act rule, tentatively toward the fourth quarter of 2026, and the scope of any restored domestic reporting-company coverage in that rule will determine whether South Carolina formed shell-entity anonymity is narrowed or entrenched, at Assessed confidence. Absent restoration, South Carolina formed entities will remain untracked by any operative registry. Separately, the European Union equivalence and third-country risk-list review process, and the pace of the AMLA direct-supervision perimeter announcements ahead of the 2027 AMLR application date, will continue to shape indirect pressure on the United States framework without imposing any direct South Carolina obligation.

Judgment: No SC-specific beneficial-ownership development this cycle. Probable
Cumulative analysis

Beneficial Ownership and Corporate Transparency — Cumulative Analysis

As of this first assessment cycle for South Carolina, issue 28, the beneficial-ownership and corporate-transparency picture is dominated by a single structural regression rather than by any state-specific instrument. A March 2025 FinCEN interim final rule exempted all domestic reporting companies, including every South Carolina formed LLC and corporation, and US beneficial owners of foreign entities, from Corporate Transparency Act reporting, leaving only foreign reporting companies covered, at High confidence. This removed the sole federal backstop against a South Carolina corporate-formation regime that, like most United States states, imposes no beneficial-ownership disclosure requirement at the Secretary of State office, at High confidence. The two conditions compound into a standing tracker finding: South Carolina formed entities are untracked by any operative beneficial-ownership registry, state or federal, as of this cycle.

An internal severity correction was applied to this finding during interpretation: baseline research initially characterized the federal rollback as a criminal scheme of critical severity, but reviewer challenge determined that a regulatory instrument creating a structural enabler condition, absent documented state-complicity or conflict-consequence evidence, does not meet the evidentiary bar for that classification. It is now carried as a HIGH severity structural regulatory-gap finding, at High confidence, a recalibration of label rather than of the underlying durability of the finding. The one offsetting national development identified to date is the FinCEN Residential Real Estate Rule for non financed transfers, effective December 1, 2025, extending reporting to real-estate closings nationally, including South Carolina, at Assessed confidence, though it addresses only the transaction point rather than the underlying formation-stage opacity.

Globally, the European Union AML Package sets the structural direction toward harmonized beneficial-ownership transparency, and this stands as durable backdrop against which the South Carolina condition should be read even though South Carolina itself falls outside its scope entirely. The Package comprises three distinct instruments: the AML Regulation, or AMLR, Regulation (EU) 2024/1624, directly applicable across member states; the sixth AML Directive, or 6AMLD, transposed individually by each member state; and the AMLA Regulation, Regulation (EU) 2024/1620, establishing the Anti-Money Laundering Authority. Together these shift the European Union supervisory perimeter from a purely national model toward a hybrid regime combining direct supervision of a defined set of higher-risk cross-border obliged entities with indirect supervision extending further, ahead of the AMLR 2027 application date. This architecture is a structural fact rather than a single-cycle development, and the divergence between it and the narrowed United States domestic regime is assessed as widening rather than narrowing, at Assessed confidence, expected to create increasing cross-border compliance friction for South Carolina firms with European Union counterparties as the 2027 date approaches, transmitted through European Union third-country risk assessment of the United States rather than through any direct South Carolina obligation.

Outlook

The determining forward event remains a single pending federal instrument: FinCEN is expected to publish a final Corporate Transparency Act rule, tentatively toward the fourth quarter of 2026, and the scope of any restored domestic reporting-company coverage will determine whether the South Carolina shell-entity opacity condition established this cycle is narrowed or entrenched in the next assessment. Absent restoration, the untracked-entity condition documented here should be treated as the standing baseline. The pace of AMLA direct-supervision perimeter announcements and European Union third-country risk-list reviews ahead of the 2027 AMLR application date will continue to shape indirect pressure without imposing any direct South Carolina obligation, and should be monitored for their effect on cross-border compliance friction in subsequent cycles.

domain_sub_briefs · D2 · Cumulative analysis
Standing baseline position

AMLA published a provisional-eligible-entity reporting package (12 May 2026) and finalised supervisory-cooperation standards (21 July 2026); AMLR remains on track for 10 July 2027 direct application.

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

Beneficial Ownership

No US-SC-specific beneficial-ownership or corporate-transparency development surfaced this cycle; the jurisdiction risk tracker's primary-domain tagging for South Carolina this cycle runs through the crypto and digital-assets domain rather than beneficial ownership. Globally, the durable structural backdrop against which any beneficial-ownership signal should be read is the EU AML Package, which comprises three distinct instruments: the directly-applicable AML Regulation, known as the AMLR (Regulation (EU) 2024/1624), the sixth AML Directive, known as 6AMLD (transposed per Member State), and the AMLA Regulation (Regulation (EU) 2024/1620) establishing the Anti-Money Laundering Authority. The direct- and indirect-supervision perimeter of AMLA is shifting AML supervision from purely national authorities toward a hybrid EU-level regime, and this cycle produced two concrete procedural milestones on that path: a reporting package published 12 May 2026 to identify provisionally eligible obliged entities, and finalised supervisory-cooperation standards published 21 July 2026 governing the handover of supervisory powers from national to EU level. The provisional eligible-entity list is due to finalise at the end of September 2026, ahead of a 2027 selection cycle and 2028 direct supervision of up to forty high-risk cross-border institutions. Per-Member-State 6AMLD transposition status was not independently established this cycle. For South Carolina specifically, this architecture remains contextual rather than directly applicable; no state-level beneficial-ownership registry or corporate-transparency development was evidenced this cycle.

Outlook

Watch for the AMLA provisional eligible-entity list at the end of September 2026 as the next concrete milestone, and for any South Carolina-specific corporate-transparency development that would newly engage this domain for the jurisdiction.

D3 Enabler Jurisdictions

no_changestanding position

Enabler Jurisdictions and Professional Facilitators

South Carolina functions as one enabler node within a documented multi-state pattern of anonymous-incorporation exploitation rather than as an outlier jurisdiction. Approximately seventy million dollars was reported stolen from federal healthcare and procurement programs using companies anonymously incorporated across Florida, Georgia, North Carolina, South Carolina, and Louisiana, at Assessed confidence, tier two sourced and corroborated by tier one FinCEN LLC risk assessment. The scheme illustrates concrete exploitation of the same disclosure-free formation regime addressed under beneficial ownership above: fraudsters used the absence of beneficial-ownership disclosure at incorporation to obscure true ownership, receive program funds, and layer proceeds across a cluster of neighboring-state shell entities before detection, with FinCEN, the Department of Justice, and the Department of Health and Human Services Office of Inspector General named as the primary enforcement actors.

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A second enabler-relevant finding concerns professional facilitators rather than the corporate shell itself. OFAC advisory guidance documents realtors, investment advisers, attorneys, and trust and corporate-service providers as gatekeepers capable of enabling a sanctioned person to retain a concealed interest in United States property through layered LLC and trust structures, nominee arrangements, and post-designation transfers, at Assessed confidence. This is a nationally applicable typology, but it bears with particular force on South Carolina, whose professional-services and real-estate sectors operate under the same disclosure-free formation regime without a distinguishing state-level gatekeeper-licensing or anti-money-laundering framework that might otherwise interrupt the enabling pathway. Both findings, together with the beneficial-ownership regulatory-gap finding addressed elsewhere in this brief, are classified at HIGH severity, and the professional-facilitator finding is recorded as an evolving rather than static scheme, reflecting continuing OFAC and FinCEN enforcement development in this space.

A third finding concerns whether South Carolina activity is being actively surveilled as part of this enabler pattern. FinCEN convened a regional FinCEN Exchange with financial-industry and law-enforcement participants to review Bank Secrecy Act suspicious-activity-report filing statistics and typology trends carrying a transactional nexus to Alabama, Florida, Georgia, Mississippi, and South Carolina, at Assessed confidence. This indicates South Carolina domiciled financial activity is materially represented in national illicit-finance typology analysis, functioning in a transit rather than purely passive enabler role for structuring, third-party laundering, and cross-border layering typologies, rather than sitting as a marginal node in national SAR analytics. The underlying source did not carry a specific event date, a gap flagged in the research register, which precludes confirming the convening falls within the eighteen-month baseline recency window.

Taken together, these three findings support a domain trajectory assessed as deteriorating rather than stable: South Carolina disclosure-free corporate-formation statutes and permissive registered-agent practices continue to be exploited alongside neighboring southeastern states, both in documented fraud and in the nationally applicable gatekeeper typology, while at the same time functioning as a node of interest in regional SAR-analytics review. No independent state enabler-jurisdiction countermeasure, such as a state beneficial-ownership registry or a distinguishing gatekeeper-licensing regime, was identified to offset this exposure. The jurisdiction risk tracker lists D3 among the five primary domains, alongside D1, D2, D5, and D6, through which overall South Carolina risk direction is assessed as increasing, with source quality resting on a floor of ten sources spanning tiers one through three and including both a national primary and an institutional primary source, at High confidence in the underlying source-quality assessment.

Outlook

The enabler-jurisdiction exposure for South Carolina is unlikely to change materially absent one of two federal developments: restoration of meaningful domestic reporting-company coverage in the pending final Corporate Transparency Act rule, or a state-level legislative response establishing an independent beneficial-ownership disclosure requirement, neither of which has legislative timeline visibility in the current research window. Continued OFAC enforcement development against the gatekeeper-professional typology, and further regional FinCEN Exchange convenings touching South Carolina, remain the most likely near-term signals, though no South Carolina specific enforcement escalation is presently indicated. Absent a change in either lever, the transit and enabler dual role documented this cycle should be treated as a structural, not episodic, condition for planning purposes.

Judgment: No SC-specific enabler-jurisdiction development this cycle; research awaiting primary source. Uncertain
Cumulative analysis

Enabler Jurisdictions and Professional Facilitators — Cumulative Analysis

As of this first assessment cycle for South Carolina, issue 28, the enabler-jurisdiction record establishes South Carolina as one node within a documented multi-state pattern of anonymous-incorporation exploitation rather than as an outlier. A reported seventy million dollar fraud against federal healthcare and procurement programs used companies anonymously incorporated across Florida, Georgia, North Carolina, South Carolina, and Louisiana, at Assessed confidence, tier two sourced and corroborated by tier one FinCEN LLC risk assessment, with FinCEN, the Department of Justice, and the Department of Health and Human Services Office of Inspector General named as enforcement actors. This scheme is the concrete evidentiary anchor for the structural opacity condition established under Beneficial Ownership and Corporate Transparency.

A second standing element is the professional-facilitator typology: OFAC advisory guidance identifies realtors, investment advisers, attorneys, and trust and corporate-service providers as gatekeepers capable of enabling a sanctioned person to retain a concealed United States property interest through layered LLC and trust structures, nominee arrangements, and post-designation transfers, at Assessed confidence, classified as an evolving HIGH severity scheme. This typology is nationally applicable but bears with particular force on South Carolina, whose professional-services and real-estate sectors share the disclosure-free formation regime without a distinguishing state-level gatekeeper-licensing or anti-money-laundering framework that might interrupt the enabling pathway.

A third standing element establishes South Carolina as a monitored rather than marginal node in national typology analysis: FinCEN convened a regional FinCEN Exchange reviewing Bank Secrecy Act suspicious-activity-report filings and typology trends with a transactional nexus to Alabama, Florida, Georgia, Mississippi, and South Carolina, at Assessed confidence, indicating a transit rather than purely passive enabler role for structuring, third-party laundering, and cross-border layering typologies. The underlying source carries no specific event date, a gap that should be resolved in a future cycle to confirm the convening falls within the relevant recency window.

Taken together, these three elements establish the D3 baseline trajectory as deteriorating: disclosure-free corporate-formation statutes and permissive registered-agent practices continue to be exploited alongside neighboring southeastern states, both in documented fraud and in the nationally applicable gatekeeper typology, while South Carolina simultaneously functions as a node of interest in regional SAR-analytics review. No independent state enabler-jurisdiction countermeasure was identified in this baseline to offset the exposure. The jurisdiction risk tracker places D3 among five primary domains, alongside D1, D2, D5, and D6, driving an overall South Carolina risk-direction assessment of increasing, resting on a source-quality floor of ten sources spanning tiers one through three including both a national and an institutional primary source, at High confidence in that underlying assessment.

Outlook

The enabler-jurisdiction exposure established in this baseline is unlikely to change materially absent one of two federal or state developments: restoration of meaningful domestic reporting-company coverage in the pending final Corporate Transparency Act rule, or a state-level legislative response establishing an independent beneficial-ownership disclosure requirement, neither of which carries legislative timeline visibility as of this cycle. Continued OFAC enforcement development against the gatekeeper-professional typology and further regional FinCEN Exchange convenings touching South Carolina remain the most likely near-term signals to track in subsequent cycles, and the transit-and-enabler dual role documented here should be treated as the structural baseline going forward.

domain_sub_briefs · D3 · Cumulative analysis
Standing baseline position

Cambodia faces active OFAC enforcement against a senator-linked scam/casino network while self-acknowledging grey-list-avoidance pressure; Laos's Golden Triangle SEZ remains a quasi-sovereign cross-border laundering enclave.

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

Enabler Jurisdictions

Cambodia and Laos anchor this cycle's enabler-jurisdiction picture, and both illustrate the tension between visible enforcement activity and structurally entrenched capacity deficits. Cambodia's own central-bank leadership is signalling the risk: Governor Chea Serey warned in January 2026 that continued failure to improve anti-money-laundering capacity risks a third FATF grey-list placement for the country, and the National Bank of Cambodia has launched a second national risk assessment in response. That warning sits uneasily against the same-cycle OFAC designation of twenty-nine individuals and entities tied to the cyber-fraud and human-trafficking scam-casino economy of Cambodia, a network including Kok An, Crown Resorts, Anco Brothers, K99 Group, Bolai, and Heng Feng Cambodia Bank, anchored by a sitting Cambodian senator. Direct involvement of a sitting legislator in a newly-designated scam-casino network is a state-capture signal in its own right, distinct from ordinary enforcement-capacity weakness: it indicates that at least part of the enabling architecture runs through, rather than around, the formal political structures of the country.

Laos presents a more purely structural enabler condition. The Golden Triangle Special Economic Zone in Bokeo Province, under a ninety-nine-year lease to Kings Romans Group, controlled by Zhao Wei, continues to operate as a cross-border laundering and scam-centre enclave, with cash-for-chips exchange described in reporting as an open display of money laundering. Laos remains on the FATF grey list as of the June 2026 Plenary, and the concession structure of the SEZ is assessed as limiting effective Lao state jurisdictional access to the enclave, a standing condition rather than a new development this cycle.

The jurisdiction risk tracker classifies both Cambodia and Laos as increasing-risk, with Cambodia coded as a capacity deficit on the enforcement-versus-enablement axis and a mixed structural and episodic profile, and Laos coded more purely as enablement and structural. Read together, the two jurisdictions illustrate a recurring enabler-jurisdiction pattern in Southeast Asia: visible enforcement action, whether public grey-list-avoidance messaging from a central bank or an OFAC designation tranche, coexisting with an underlying architecture, whether political capture or a quasi-sovereign concession zone, that enforcement pressure has not yet dislodged. A gaps-register entry notes that enabler-jurisdiction coverage for Sub-Saharan Africa, Central Asia, and the Pacific was not actively searched this cycle, a standing under-coverage gap pending the next monthly regional-balance pass.

Outlook

Watch the outcome of the second national risk assessment in Cambodia as the signal most likely to move this domain's trajectory, alongside any follow-on designations connected to the Kok An-anchored network. For Laos, the Golden Triangle SEZ is assessed as a standing structural condition unlikely to shift materially absent a change in the underlying concession arrangement or grey-list status.

D4 Conflict Finance

no_changestanding position

Conflict Finance and Extractive-Industry Integrity

No conflict-finance or extractive-industry-integrity development specific to South Carolina was identified in this research window, and this absence is recorded rather than assumed, consistent with the domain tracker status of no_change for this jurisdiction this cycle. The one structural factor carried forward as a watch item is South Carolina strategically significant trade infrastructure: the Port of Charleston and the Boeing North Charleston aerospace final-assembly site elevate theoretical trade-based money-laundering and dual-use export-control exposure relative to the national average, at Possible confidence, though no South Carolina specific designation, seizure, or documented conflict-finance nexus was identified this cycle tying that infrastructure to an actual illicit flow. This finding is carried at the lowest confidence tier used in this brief, reflecting that it is a structural and geographic risk factor rather than a documented incident, and it is flagged as a watch item given rising trade friction between the United States and both Russia and China rather than as an active finding.

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The absence of a South Carolina specific conflict-finance signal should be read within the broader national sanctions and export-control architecture addressed under Sanctions Architecture and Evasion above, rather than as an independent null result: South Carolina inherits the uniform federal perimeter, including recent Russia-sanctions enforcement and Section 311 action against Huione Group, and any future conflict-finance nexus touching this jurisdiction would most likely surface through that inherited perimeter rather than through any independent state channel.

Outlook

Absent a change in trade patterns through the Port of Charleston or the Boeing supply chain, or a new federal export-control or sanctions action naming a South Carolina counterparty, this domain is expected to remain quiet for South Carolina specifically, while continuing to warrant a watch-item designation given the strategic significance of the underlying infrastructure. Any future signal is more likely to be transmitted through the national sanctions architecture than to originate independently within South Carolina.

Judgment: Not applicable in this regime; no conflict-finance nexus for South Carolina. Probable
Cumulative analysis

Conflict Finance and Extractive-Industry Integrity — Cumulative Analysis

As of this first assessment cycle for South Carolina, issue 28, no conflict-finance or extractive-industry-integrity development specific to this jurisdiction has been identified, and this absence is recorded as the baseline rather than assumed. The one structural factor carried forward as a standing watch item is South Carolina strategically significant trade infrastructure: the Port of Charleston and the Boeing North Charleston aerospace final-assembly site elevate theoretical trade-based money-laundering and dual-use export-control exposure relative to the national average, at Possible confidence, the lowest confidence tier used in this baseline, reflecting that it is a structural and geographic risk factor rather than a documented incident. No South Carolina specific designation, seizure, or documented conflict-finance nexus ties this infrastructure to an actual illicit flow as of this cycle. This absence should be read against the broader national sanctions and export-control architecture addressed under Sanctions Architecture and Evasion, since South Carolina inherits the uniform federal perimeter and any future conflict-finance nexus touching this jurisdiction would most likely surface through that inherited perimeter rather than through an independent state channel. This baseline establishes the D4 quiet-row status as the starting point for future comparison, consistent with the cycle_delta record marking this domain as a new but quiet row for the jurisdiction this cycle.

Outlook

Absent a change in trade patterns through the Port of Charleston or the Boeing supply chain, or a new federal export-control or sanctions action naming a South Carolina counterparty, this domain is expected to remain a quiet watch item for South Carolina specifically in the next cycle, continuing to warrant monitoring given the strategic significance of the underlying infrastructure rather than any active development.

domain_sub_briefs · D4 · Cumulative analysis
Standing baseline position

Colombia designated a 'failed demonstrably' major-trafficker country under the FY2026 FRAA amid record coca cultivation; Mexican cartel fuel-theft revenue remains the most significant non-drug illicit revenue source financing cartel violence.

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

Conflict Finance

Two developments define this cycle's conflict-finance picture, one narcotics-economy and one commodity-theft, and both are assessed as worsening rather than stable. Colombia was designated among five countries that failed demonstrably to meet counternarcotics obligations under the FY2026 Majors List review, the first such adverse finding in nearly thirty years, occurring amid record coca cultivation; sanctions attached to the designation were waived on national-interest grounds despite the adverse finding itself. The jurisdiction risk tracker codes the risk trajectory for Colombia as increasing, a capacity deficit on the enforcement-versus-enablement axis, and episodic rather than structural in profile, consistent with a single-cycle adverse finding rather than a new standing condition.

Separately, a supplemental alert from FinCEN on CJNG-linked fuel-theft and tax-evasion schemes, issued alongside an OFAC sanctions action against two Mexican nationals and nine entities, characterises fuel theft as among the most significant non-drug illicit revenue sources for the cartel. This is a commodity-integrity finding as much as a narcotics-finance one: it identifies a physical-commodity theft and smuggling architecture, rather than drug proceeds alone, as a primary financing channel for a designated cartel. The jurisdiction risk tracker codes the conflict-finance-relevant risk for Mexico as increasing and enforcement-driven, but episodic, reflecting this cycle's designation cluster rather than a newly-identified standing structural condition.

Both findings sit against a backdrop of thin comparative coverage this cycle: a gaps-register entry notes that no dedicated conflict-finance finding beyond the Colombia designation was located, and that Sahel and Democratic Republic of Congo conflict-mineral coverage remains thin. That gap matters for how the Colombia and Mexico findings should be read: they are the two conflict-finance signals this monitor is able to evidence this cycle, not necessarily the two most significant conflict-finance developments globally, given the acknowledged regional coverage imbalance.

Outlook

Watch for any follow-on consequence attaching to the Majors List designation for Colombia despite the national-interest sanctions waiver, and for further FinCEN or OFAC action tracing CJNG fuel-theft proceeds. The standing coverage gap in Sahel and DRC conflict-mineral reporting is flagged for the next monthly regional-balance pass rather than resolved this cycle.

D5 Crypto / Digital Assets / Financial Innovation

no_changestanding position

Crypto / Digital Assets / Financial Innovation

South Carolina's digital-asset licensing architecture has become clearer this cycle, even though the underlying statute predates the reporting window. Act No. 208 (S.163), signed on 19 May 2026, added Chapter 47 to Title 34 of the state code. Section 34-47-60 of that chapter places four categories of digital-asset activity outside the scope of the state's money transmitter licence requirement: digital-asset mining, blockchain node operation, on-chain software development, and crypto-to-crypto exchange that does not touch fiat currency. This is a structural carve-out, not an enforcement posture; it narrows the universe of activity that requires state authorisation at all, rather than describing how the state polices activity that remains licensable.

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The same Act includes a separate and distinct provision prohibiting state governmental authorities from accepting or requiring payment using a central bank digital currency. This is a public-sector payment-acceptance rule, not a private-sector licensing or custody rule, and it should not be read as evidence of a broader state stance on private stablecoins or digital-asset custody, for which South Carolina has no dedicated regime.

Separately, a bill that would have closed a documented gap in this architecture remains stalled. House Bill 4592 would create a licensing and disclosure framework specifically for virtual-currency kiosks, amending Title 34 Chapter 3 to add digital-asset vending definitions and a corresponding money-transmitter-licence requirement for kiosk operators, along with mandated fraud-warning disclosures on kiosk screens. The bill has not advanced beyond a House committee referral recorded on 13 January 2026, and it is effectively dead for the 2025-2026 legislative biennium absent a revival. In the interim, oversight of crypto-ATM operators in the state continues to rely on an older interpretive administrative order rather than statute, meaning the state's most consumer-facing digital-asset channel is the one with the thinnest codified AML and disclosure footing.

Taken together, these two findings describe a jurisdiction with a narrow, deliberately drawn licensing perimeter for crypto-to-crypto and infrastructure-level digital-asset activity, and an unresolved gap for kiosk-based retail digital-asset access. The non-fiat crypto-to-crypto exemption at the state level also raises an open question this cycle did not resolve: whether firms operating under that state exemption remain separately obligated to register as a money services business with the federal Financial Crimes Enforcement Network under the Bank Secrecy Act. The state carve-out speaks only to state licensing exposure; it does not, by its own terms, address the federal registration question, and no independent confirmation either way was located this cycle.

Outlook

The near-term trajectory for this domain in South Carolina depends substantially on whether House Bill 4592 is revived. As scheduled, the bill would not see further action before the close of the current legislative biennium, leaving crypto-kiosk oversight dependent on administrative interpretation rather than statute for the foreseeable period. The Section 34-47-60 carve-outs and the CBDC-acceptance prohibition are both now in force and are not expected to be revisited absent a new legislative initiative. The open question of state-federal interaction on money-services-business registration for non-fiat crypto-to-crypto exchange is a reasonable item to watch, since any federal guidance addressing it directly would materially affect the practical compliance picture for firms that currently rely on the state-level exemption alone.

Judgment: No SC-specific crypto/digital-asset AML development this cycle. Probable
Cumulative analysis

Crypto, Digital Assets, and Financial Innovation — Cumulative Analysis

As of this first assessment cycle for South Carolina, issue 28, the digital-asset record establishes that the state maintains no state-specific virtual-asset-service-provider licensing or supervisory regime, leaving its entire compliance exposure running through the national federal perimeter. Two enforcement actions anchor this baseline: an OFAC settlement with ShapeShift AG, a Switzerland incorporated exchange operating from Colorado, for seven hundred fifty thousand dollars over apparent sanctions violations, at High confidence, and a FinCEN Section 311 special measure severing Huione Group, reported to have received over thirty nine point six billion dollars in 2025 alone per vendor analytics data, from the United States financial system, at Assessed confidence given the vendor sourcing of the flow figure. Both apply nationally, and any South Carolina relevance is transmitted through VASP-user exposure or correspondent-banking relationships rather than through direct designation.

The most consequential forward-looking element established this cycle is the GENIUS Act stablecoin issuer rollout: the National Credit Union Administration in February 2026 and the Office of the Comptroller of the Currency in March 2026 issued implementing rules establishing federal stablecoin issuer frameworks, at Assessed confidence, applicable to any South Carolina chartered institution seeking issuance authority, while Treasury substantially similar determinations on state-federal equivalence remain pending, expected toward the fourth quarter of 2026. No South Carolina specific stablecoin framework exists as of this baseline, meaning any South Carolina chartered issuer currently operates exclusively under the federal frameworks.

This national-perimeter dependency compounds a related compliance-technology finding: no public evidence establishes an independent South Carolina state supervisory unit for state-chartered institutions distinct from federal examiners, meaning adoption of digital-asset-specific analytics or monitoring tooling by South Carolina chartered institutions tracks national FinCEN and federal-banking-agency priorities rather than state-level pressure. Standing tracker context situates the two anchor enforcement actions within an eighteen-month trajectory that also includes an April 2025 Department of Justice policy memorandum deprioritizing regulation-by-prosecution in favor of traditional fraud and anti-money-laundering charges for crypto-enabled misuse nationally, at Assessed confidence. No South Carolina specific crypto-laundering enforcement action has been identified across this window; exposure has remained indirect throughout. The jurisdiction risk tracker records D5 among five primary domains, alongside D1, D2, D3, and D6, driving the overall South Carolina risk-direction assessment of increasing.

Outlook

The determining forward event remains the Treasury substantially similar determination under the GENIUS Act, expected toward the fourth quarter of 2026, which will decide whether any future South Carolina state-level stablecoin framework, should one be enacted, would qualify for federal deference; in the interim, any South Carolina chartered institution seeking stablecoin issuance authority operates exclusively under the federal frameworks established this cycle. Continued FinCEN Section 311 style action against globally significant virtual-asset-service-provider networks remains the most likely near-term enforcement signal to track in subsequent cycles, with South Carolina relevance transmitted through correspondent-banking exposure rather than direct designation, and any emergent South Carolina legislative proposal for a state money-transmitter or virtual-currency framework should also be monitored, though none has been identified to date.

domain_sub_briefs · D5 · Cumulative analysis
Standing baseline position

South Carolina enacted S.163 (SC Act No. 208, Title 34 Ch.47), effective 2026-05-19, exempting mining, node operation, blockchain software development, and non-fiat crypto-to-crypto exchange from money-transmitter licensing, banning state-agency CBDC acceptance, and preserving AG fraud-enforcement authority.

Periodic updates (5)
25 Oct 2026 · fim-2026-10-25

Crypto / Digital Assets / Financial Innovation

South Carolina's digital-asset licensing architecture has become clearer, even though the underlying statute predates the reporting window. Act No. 208 (S.163), signed on 19 May 2026, added Chapter 47 to Title 34 of the state code. Section 34-47-60 of that chapter places four categories of digital-asset activity outside the scope of the state's money transmitter licence requirement: digital-asset mining, blockchain node operation, on-chain software development, and crypto-to-crypto exchange that does not touch fiat currency. This is a structural carve-out, not an enforcement posture; it narrows the universe of activity that requires state authorisation at all, rather than describing how the state polices activity that remains licensable.

The same Act includes a separate and distinct provision prohibiting state governmental authorities from accepting or requiring payment using a central bank digital currency. This is a public-sector payment-acceptance rule, not a private-sector licensing or custody rule, and it should not be read as evidence of a broader state stance on private stablecoins or digital-asset custody, for which South Carolina has no dedicated regime.

Separately, a bill that would have closed a documented gap in this architecture remains stalled. House Bill 4592 would create a licensing and disclosure framework specifically for virtual-currency kiosks, amending Title 34 Chapter 3 to add digital-asset vending definitions and a corresponding money-transmitter-licence requirement for kiosk operators, along with mandated fraud-warning disclosures on kiosk screens. The bill has not advanced beyond a House committee referral recorded on 13 January 2026, and it is effectively dead for the 2025-2026 legislative biennium absent a revival. In the interim, oversight of crypto-ATM operators in the state continues to rely on an older interpretive administrative order rather than statute, meaning the state's most consumer-facing digital-asset channel is the one with the thinnest codified AML and disclosure footing.

Taken together, these two findings describe a jurisdiction with a narrow, deliberately drawn licensing perimeter for crypto-to-crypto and infrastructure-level digital-asset activity, and an unresolved gap for kiosk-based retail digital-asset access. The non-fiat crypto-to-crypto exemption at the state level also raises an open question did not resolve: whether firms operating under that state exemption remain separately obligated to register as a money services business with the federal Financial Crimes Enforcement Network under the Bank Secrecy Act. The state carve-out speaks only to state licensing exposure; it does not, by its own terms, address the federal registration question, and no independent confirmation either way was located.

Outlook

The near-term trajectory for this domain in South Carolina depends substantially on whether House Bill 4592 is revived. As scheduled, the bill would not see further action before the close of the current legislative biennium, leaving crypto-kiosk oversight dependent on administrative interpretation rather than statute for the foreseeable period. The Section 34-47-60 carve-outs and the CBDC-acceptance prohibition are both now in force and are not expected to be revisited absent a new legislative initiative. The open question of state-federal interaction on money-services-business registration for non-fiat crypto-to-crypto exchange is a reasonable item to watch, since any federal guidance addressing it directly would materially affect the practical compliance picture for firms that currently rely on the state-level exemption alone.

11 Oct 2026 · fim-2026-10-11

Crypto / Digital Assets / Financial Innovation

South Carolina enacted S.163, South Carolina Act No. 208, signed by the Governor on 19 May 2026, adding Chapter 47 to Title 34 of the South Carolina Code of Laws. The instrument is structural in character: it adds digital-asset mining, blockchain node operation, blockchain software development, and non-fiat crypto-to-crypto exchange to the list of activities exempt from the money-transmitter licensing requirement that otherwise governs under Title 35, Chapter 11. Prior to this amendment, any entity conducting these activities in or from South Carolina was, on the face of the Uniform Money Services Act, potentially within scope of the states licensing-and-reporting perimeter applicable to money transmission. S.163 removes that exposure for the specified activities, narrowing the set of digital-asset operators who must hold a state money-transmitter licence and, correspondingly, who owe the federal currency-reporting, recordkeeping, and suspicious-transaction obligations that attach to licensees under Section 35-11-200.

The statute simultaneously addresses a second typology question: central bank digital currency exposure. S.163 bars South Carolina state agencies and political subdivisions from accepting, requiring, or testing payment in a CBDC, and expressly forecloses state participation in any Federal Reserve CBDC pilot programme. This is a state-level policy position on an instrument type that has not reached the state in operational form, and the finding is treated as newly scoped for this jurisdiction this cycle; it is carried at Probable confidence notwithstanding the Tier 1 legislative record because the characterisation of downstream effect — rather than the existence of the statutory text — is the limiting factor on confidence.

A structural feature of the carve-out, and one with direct relevance to typology exposure, is that the South Carolina Attorney Generals office retains express authority to prosecute fraud committed by any person who falsely claims to offer digital-asset mining-as-a-service or staking-as-a-service, notwithstanding the licensing exemption that now applies to the underlying mining and node-operation activity itself. In other words, the legislature narrowed the regulatory perimeter for the legitimate conduct of mining, node operation, and blockchain software development, while leaving an enforcement channel open for fraudulent solicitation schemes that dress themselves in the same vocabulary. This is the kind of enablement-with-backstop architecture that merits attention independent of any single enforcement action: the backstop is, as of this cycle, an express statutory power rather than a pattern of exercised authority, and its practical reach against layered or cross-border mining-as-a-service schemes has not yet been tested.

For typology purposes, the carve-out activities — mining, node operation, blockchain software development, and non-fiat crypto-to-crypto exchange — are precisely the categories of activity that a sanctions-evasion or layering scheme seeking to minimise state-level licensing friction would seek to exploit, given that a non-fiat crypto-to-crypto exchange, in particular, now sits outside the Title 35 Chapter 11 licensing-and-reporting perimeter in South Carolina specifically. This does not mean exploitation is occurring; it means the architecture has shifted in a direction that a sophisticated actor optimising for minimal licensing friction would notice. The AML/CTF baseline under Title 35 Chapter 11 continues to apply, unmodified, to money transmission generally, including fiat-involving crypto activity and other MSB conduct that falls outside the specific carve-out categories.

Outlook

The principal open question is whether and how the Attorney Generals preserved fraud authority is exercised against entities operating in the carved-out space. No enforcement action under this backstop has been identified this cycle, and the statute is less than six months old as of the most recent recency date available (19 May 2026). The CBDC-acceptance ban is a policy position rather than an operational constraint at present, given the absence of a live Federal Reserve CBDC pilot to which South Carolina might otherwise have been exposed; its significance lies in foreclosing a future state of affairs rather than altering a current one. Future cycles should watch for: any enforcement action invoking the preserved AG fraud authority against mining-as-a-service or staking-as-a-service solicitation; any expansion or narrowing of the carve-out's scope through subsequent legislative session activity; and any divergence between South Carolinas approach and that of other states addressing similar crypto-infrastructure licensing questions, which would bear on the enabler-jurisdiction dimension of this typology even though no such divergence has been identified in South Carolina specifically this cycle.

28 Sep 2026 · fim-2026-09-28

Crypto, Digital Assets, and Financial Innovation

South Carolina's S.163 (Digital Asset / Anti-CBDC Act), enacted May 19, 2026 following ratification on May 14, 2026, is this cycle's material D5 development for the jurisdiction. The statute exempts digital-asset mining, node operation, blockchain-software development, and fiat-free crypto-to-crypto exchange from South Carolina's money transmitter licensing requirement under Title 35, Chapter 11. This is a state-level liberalisation of licensing scope specifically targeted at infrastructure-layer crypto activity — the kind of activity that does not touch fiat on/off-ramps or custody of customer funds in the sense the Uniform Money Services Act was built to capture. The Attorney General's fraud-enforcement authority over mining-as-a-service and staking-as-a-service claims is explicitly preserved, meaning the exemption narrows licensing scope without narrowing anti-fraud enforcement reach.

Against this liberalisation sits a pending bill moving the opposite direction for a different activity class. S.4592 would require owners and operators of virtual-currency kiosks to obtain a money transmitter licence and to post on-screen fraud-risk disclosures before completing a transaction. Kiosks are the consumer-facing point of contact in the crypto ecosystem most associated with cash-based fraud typologies — victims sending funds to scammers via unattended terminals — and a licensing-plus-disclosure regime targeted there is a materially different regulatory instinct than the infrastructure exemptions in S.163. Read together, the two bills describe a legislature distinguishing between wholesale/infrastructure crypto activity, which it is willing to de-license, and retail/consumer-facing crypto activity, which it is moving to bring more tightly within licensing and disclosure requirements.

The general money-transmitter licensing and AML framework governing crypto exchange and custody businesses that do not qualify for the S.163 exemptions remains the South Carolina Uniform Money Services Act (Title 35, Chapter 11), administered by the Money Services Division of the state Attorney General's Office. This framework was substantially modernised in 2024 via Act No. 218, which renamed it from the "South Carolina Anti-Money Laundering Act" and adopted the multistate Money Transmission Modernization Act's provisions. S.163's exemptions sit as narrow carve-outs within this broader, unchanged architecture rather than as a wholesale replacement of it.

Outlook

S.4592 remains at the proposed stage in the South Carolina General Assembly, with an estimated effective horizon in 2027 if enacted; no evidence of committee movement beyond introduction was located this cycle. Should it advance, kiosk operators would face a new state-specific licensing and disclosure obligation layered onto the existing Uniform Money Services Act framework. The trajectory to watch is whether South Carolina continues on its current bifurcated path — infrastructure liberalisation paired with retail-facing tightening — or whether one direction comes to dominate the state's crypto regulatory posture as further bills are introduced in subsequent sessions.

11 Aug 2026 · fim-2026-08-05

Crypto / Digital Assets / Financial Innovation

South Carolina's own digital-asset perimeter moved on two fronts this cycle, in opposite directions. Governor McMaster signed S.163 on 19 May 2026, barring South Carolina governmental entities from accepting or piloting a central bank digital currency and exempting blockchain-protocol software development, node operation, and crypto-to-crypto exchange, where there is no conversion to legal tender or bank deposits, from money-transmitter licensing under Title 35, Chapter 11. This is a deliberate narrowing of the AML perimeter of the state itself for a growing category of digital-asset activity: a category of activity that would otherwise sit within money-transmitter licensing, and the AML program obligations that licence carries, is now exempted from it. Separately, H.4592, still pending in the House Labor, Commerce and Industry Committee with no recorded vote, would require virtual-currency-kiosk owners and operators to hold a money-transmitter licence and post mandatory fraud warnings, targeting a known elder-fraud and scam-conversion vector associated with cash-to-crypto kiosks. Read together, South Carolina is simultaneously loosening its licensing perimeter for one category of digital-asset activity, peer-to-peer crypto exchange and infrastructure operation, while a separate pending bill would tighten it for another, kiosk-based cash conversion, creating a state-level divergence pattern within a single digital-asset policy area.

That state-level movement sits against a federal backdrop that is moving toward tighter, not looser, AML and sanctions obligations for stablecoin issuers specifically. A joint FinCEN and OFAC Notice of Proposed Rulemaking issued 8 April 2026 would treat permitted payment stablecoin issuers as Bank Secrecy Act financial institutions under a new standalone Part 1033, mandating AML/CFT and sanctions-compliance programs; the comment period closed 9 June 2026 and final rules are expected around July 2026, with a proposed twelve-month implementation runway meaning most permitted payment stablecoin issuers will not have operational programs immediately upon finalisation. Concurrently, the OFAC designation cluster this cycle had a distinct crypto dimension: the Sinaloa Cartel-linked financial cell converting fentanyl cash proceeds into cryptocurrency, the financial infrastructure associated with the Cambodia scam-casino network, and the updated Central Bank of Iran designation paired with a Tether stablecoin freeze of associated Tron addresses. Each instance places crypto rails inside, rather than outside, standing sanctions-evasion architecture, reinforcing the case for the AML and sanctions program mandate under the GENIUS Act framework.

Outlook

Watch for the GENIUS Act final rule, expected around July 2026, and for whether its twelve-month implementation runway produces a supervisory gap for newly-BSA-regulated stablecoin issuers. For South Carolina specifically, watch whether H.4592 advances past committee, which would create the first kiosk-specific licensing-and-disclosure regime in the state for virtual-currency conversion points, sitting alongside the more permissive treatment under S.163 of peer-to-peer crypto activity.

14 Jul 2026 · fim-2026-07-14

Crypto, Digital Assets, and Financial Innovation

South Carolina maintains no state-specific virtual-asset-service-provider licensing or supervisory regime; its entire digital-asset compliance exposure runs through the national federal perimeter, and three developments this cycle define that perimeter directly. OFAC settled with ShapeShift AG, a Switzerland incorporated digital-asset exchange operating from Colorado, for seven hundred fifty thousand dollars over apparent sanctions violations, at High confidence, illustrating the federal virtual-asset sanctions compliance perimeter that governs any South Carolina based VASP user or operator regardless of where the exchange itself is domiciled. Separately, FinCEN applied a Section 311 special measure severing Huione Group from the United States financial system, coordinated same day with a broader Prince Group transnational criminal organization designation involving one hundred forty six targets; Huione Group is reported to have received over thirty nine point six billion dollars in 2025 alone per vendor analytics data, at Assessed confidence given the vendor sourcing of that figure, and this action applies to any South Carolina regulated bank carrying correspondent exposure to the designated network.

The most consequential forward-looking development for South Carolina chartered institutions is the GENIUS Act stablecoin issuer rollout. The National Credit Union Administration in February 2026 and the Office of the Comptroller of the Currency in March 2026 issued implementing rules establishing federal stablecoin issuer frameworks, at Assessed confidence, applicable to any South Carolina chartered institution seeking stablecoin issuance authority. Treasury substantially similar determinations, deciding whether state-level stablecoin regulatory regimes qualify for federal deference, remain pending and are expected toward the fourth quarter of 2026, at Assessed confidence; no South Carolina specific stablecoin framework exists to date, meaning any South Carolina chartered issuer will operate exclusively under the federal frameworks pending that determination.

This national-perimeter dependency is compounded by a related compliance-technology gap addressed further below: no public evidence establishes an independent South Carolina state supervisory unit for state-chartered institutions distinct from federal examiners, meaning adoption of any proactive or analytics-driven monitoring specific to digital-asset risk by South Carolina chartered institutions is shaped entirely by national FinCEN and federal-banking-agency priorities rather than by state-level supervisory pressure or divergence. The domain trajectory is accordingly assessed as deteriorating, driven by the scale of the enforcement actions and the still-unsettled stablecoin equivalence question rather than by any adverse South Carolina specific development. Standing tracker context situates these developments within an eighteen-month trajectory: OFAC settled with ShapeShift AG in September 2025, FinCEN applied the Section 311 designation against Huione Group in October 2025, and the Department of Justice April 2025 policy memorandum deprioritized regulation-by-prosecution in favor of traditional fraud and anti-money-laundering charges for crypto-enabled misuse nationally, at Assessed confidence. No South Carolina specific crypto-laundering enforcement action was identified across this eighteen-month window; exposure has remained indirect throughout, transmitted via the national VASP and sanctions perimeter rather than through any South Carolina specific node. The jurisdiction risk tracker records D5 among the five primary domains driving South Carolina overall risk direction, assessed as increasing, alongside D1, D2, D3, and D6.

Outlook

The determining forward event for South Carolina digital-asset exposure is the Treasury substantially similar determination under the GENIUS Act, expected toward the fourth quarter of 2026, which will decide whether any future South Carolina state-level stablecoin framework, should one be enacted, would qualify for federal deference; in the interim, any South Carolina chartered institution seeking stablecoin issuance authority operates exclusively under the National Credit Union Administration and Office of the Comptroller of the Currency federal frameworks. Continued FinCEN Section 311 style action against virtual-asset-service-provider networks with global reach, of the kind applied to Huione Group this cycle, remains the most likely near-term enforcement signal, with any South Carolina relevance transmitted through correspondent-banking exposure rather than direct designation. Firms should also monitor whether any South Carolina legislative proposal for a state money-transmitter or virtual-currency framework emerges, though none was identified in this research window.

D6 Compliance Technology & Active Defence

no_changestanding position

Compliance Technology and Active Defence

No dedicated South Carolina state-level anti-money-laundering or counter-terrorist-financing supervisory function, and no independent RegTech or SupTech initiative, was identified in this research window, at Assessed confidence. The only identified collaborative analytics or typology-sharing mechanism touching South Carolina this cycle is the regional FinCEN Exchange reviewing suspicious-activity-report filings with a transactional nexus to South Carolina alongside Alabama, Florida, Georgia, and Mississippi; this convening is regional rather than South Carolina specific, and it is the sole observed instance of South Carolina participation in any structured compliance-technology or typology-sharing exercise in the window.

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The practical consequence is that compliance-technology posture for South Carolina chartered institutions is driven entirely by national FinCEN and federal-banking-agency priorities rather than by any independent state-level supervisory pressure or acceleration, at Assessed confidence. This is consistent with the broader jurisdictional finding that South Carolina carries no independent sanctions or supervisory authority: state-chartered institutions are examined by federal agencies, including the FDIC, the Federal Reserve, and the Office of the Comptroller of the Currency, rather than by a distinct state AML/CFT unit, and any adoption of proactive or artificial-intelligence-driven monitoring tooling by those institutions therefore tracks national rather than state-level expectations or timelines. This status is recorded as a watch item rather than an active finding, reflecting the absence of evidence rather than a documented negative development.

Outlook

Absent the emergence of a dedicated South Carolina state supervisory or RegTech initiative, which was not indicated in any source reviewed this cycle, compliance-technology posture for South Carolina chartered institutions is expected to continue tracking national FinCEN and federal-banking-agency priorities directly, including any further regional FinCEN Exchange convenings with a South Carolina nexus.

Judgment: No SC-specific RegTech/compliance-technology development this cycle. Probable
Cumulative analysis

Compliance Technology and Active Defence — Cumulative Analysis

As of this first assessment cycle for South Carolina, issue 28, no dedicated state-level anti-money-laundering or counter-terrorist-financing supervisory function, and no independent RegTech or SupTech initiative, has been identified for this jurisdiction, at Assessed confidence. The only identified collaborative analytics or typology-sharing mechanism touching South Carolina in this baseline is the regional FinCEN Exchange reviewing suspicious-activity-report filings with a transactional nexus to South Carolina alongside Alabama, Florida, Georgia, and Mississippi, a regional rather than South Carolina specific convening and the sole observed instance of South Carolina participation in a structured compliance-technology or typology-sharing exercise to date. The practical consequence established this cycle is that compliance-technology posture for South Carolina chartered institutions is driven entirely by national FinCEN and federal-banking-agency priorities, since state-chartered institutions are examined by federal agencies, including the FDIC, the Federal Reserve, and the Office of the Comptroller of the Currency, rather than by a distinct state AML/CFT unit. This status is recorded as a watch item rather than an active finding, reflecting the absence of evidence rather than a documented negative development, and establishes the baseline against which future cycles should be compared.

Outlook

Absent the emergence of a dedicated South Carolina state supervisory or RegTech initiative, compliance-technology posture for South Carolina chartered institutions is expected to continue tracking national FinCEN and federal-banking-agency priorities directly in the next cycle, including any further regional FinCEN Exchange convenings with a South Carolina nexus, which should be monitored for signs of increasing South Carolina specific representation.

domain_sub_briefs · D6 · Cumulative analysis

D7 AML/CTF Regime

stable

AML/CTF Regime

South Carolina's AML/CTF regime itself has not changed this cycle, but a new statute has altered the legal environment in which covered institutions apply that regime. The Guarantee Banking Act (Act No. 257, H.5538) bars banks with more than 100 billion dollars in assets and payment processors with more than 100 billion dollars in annual volume from declining, closing, or restricting covered financial services on non-quantitative, non-risk-based grounds, such as protected speech, religion, or business sector. Critically, the statute carves out an explicit exemption for compliance with legitimate legal or regulatory requirements, including risk-based AML/CFT decisioning. This means a covered institution's existing authority to decline or terminate a relationship on genuine money-laundering or terrorist-financing risk grounds is preserved in full; what the Act removes is the latitude to use other, non-risk-based criteria as a pretext or substitute for that analysis. The Act takes effect six months after the Governor's signature, landing at a commencement date of December 30, 2026, and will be enforced by the Attorney General under the state's unfair or deceptive trade practices authority rather than through a financial-crime supervisory channel.

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The architectural significance of this development lies in where it draws the line. By requiring that adverse account actions rest on quantitative, impartial, risk-based criteria, the Act effectively requires covered institutions to be able to show their work: an account closure or service restriction that cannot be tied to a documented, risk-based rationale - AML/CFT or otherwise - now carries legal exposure under the new statute that it would not previously have carried under ordinary contractual discretion. For AML/CTF compliance functions, this raises the practical bar for documentation of de-risking decisions, even though it does not raise or lower the underlying AML/CFT standard itself. The statute is best read as a boundary-setting exercise around the exercise of institutional discretion, with AML/CFT risk-based decisioning expressly placed on the permitted side of that boundary.

A second, structurally separate development touches the same regime indirectly. David Stumbo was elected Attorney General, succeeding Alan Wilson, who was elected Governor. The Attorney General's office administers money-services licensing under the South Carolina AML Uniform Money Services Act in the capacity of Commissioner, and the same office is the designated enforcer of the new Guarantee Banking Act. The convergence of these two functions in a single incoming officeholder is a supervisory-architecture fact worth tracking, though no substantive change to AML/CFT licensing policy or practice has been observed to accompany the election result itself.

Outlook

Covered banks and payment processors operating in South Carolina have until the December 30, 2026 commencement date, as scheduled, to ensure that account-level adverse actions, including those grounded in AML/CFT risk assessment, are documented against a quantitative, impartial, risk-based standard capable of withstanding scrutiny under the new statute's enforcement regime. The more open question is how the incoming Attorney General's office, which both enforces the Act and administers money-services licensing, will approach the practical interplay between the two roles once the new officeholder is inaugurated in the first quarter of 2027; at this stage no policy direction has been signalled, and the correct posture is to treat the transition as a supervisory fact to monitor rather than a change to anticipate.

Judgment: The new Guarantee Banking Act narrows the scope of lawful large-institution de-risking to quantitative, impartial, risk-based grounds while expressly preserving AML/CFT risk-based decisions as an exemption; the underlying AML/CFT regime itself is unchanged. Probable
Cumulative analysis

AML/CTF Regime

South Carolina's anti-money-laundering and money-services licensing baseline is now documented with more precision, reflecting newly captured detail on a standing statutory framework rather than any new development inside the current window. The 2024 Act No. 218 substantially adopted the Money Transmission Modernization Act model law, amending Chapter 11 of Title 35 of the state code. The adoption revised net-worth requirements, surety-bond requirements, permissible-investment rules, and control-definition provisions applicable to money transmitter licensees. These revised terms became binding on new licensees from 1 January 2025, establishing the current prudential and governance baseline against which money transmitters, including those handling crypto-to-fiat activity, are assessed in the state.

This state-level licensing and prudential framework operates alongside, and independently of, the federal Bank Secrecy Act regime that governs money services businesses nationally. No amendment to the Act No. 218 framework was located inside the reporting window, and the state's AML/CTF posture should be read as structurally stable rather than in a period of active legislative change.

The interaction between this state framework and the narrower digital-asset licensing carve-outs enacted via Act No. 208 in May 2026 is worth noting from an AML/CTF regime perspective: activities exempted from the state money transmitter licence requirement, such as non-fiat crypto-to-crypto exchange, mining, node operation, and on-chain software development, fall outside the scope of the MTMA-derived governance and prudential requirements that Act No. 218 established for licensed money transmitters. This is a deliberate statutory choice to narrow the perimeter of state-licensed activity rather than a gap in the AML/CTF regime's internal consistency, but it does mean that the net-worth, bonding, and control-definition protections built into Act No. 218 do not extend to the exempted digital-asset activities.

No enforcement action, supervisory guidance update, or regulatory interpretation bearing on this framework was identified for South Carolina. The absence of such material should be read as consistent with a stable, recently clarified statutory baseline rather than as evidence of reduced supervisory attention.

Outlook

Absent a new legislative initiative, the Act No. 218 prudential and governance baseline for money transmitter licensees is expected to remain the controlling framework for the foreseeable period. The clearer documentation of this baseline alongside the Act No. 208 digital-asset carve-outs sharpens the picture of which activities sit inside the state's licensed, MTMA-governed perimeter and which sit outside it, but does not itself signal an imminent change to either framework. Continued monitoring of whether any legislative or administrative action narrows the current gap around virtual-currency kiosk oversight, which remains outside both the MTMA framework and any dedicated statute, would be a reasonable point of attention going forward.

domain_sub_briefs · D7 · Cumulative analysis
Standing baseline position

South Carolina's Guarantee Banking Act (Act 257, effective Dec 30, 2026) bars the largest banks and payment processors from non-risk-based debanking while expressly exempting legitimate legal/regulatory (including AML/CFT risk-based) decisions.

Periodic updates (1)
8 Nov 2026 · fim-2026-11-08

AML/CTF Regime

South Carolina's AML/CTF regime itself has not changed, but a new statute has altered the legal environment in which covered institutions apply that regime. The Guarantee Banking Act (Act No. 257, H.5538) bars banks with more than 100 billion dollars in assets and payment processors with more than 100 billion dollars in annual volume from declining, closing, or restricting covered financial services on non-quantitative, non-risk-based grounds, such as protected speech, religion, or business sector. Critically, the statute carves out an explicit exemption for compliance with legitimate legal or regulatory requirements, including risk-based AML/CFT decisioning. This means a covered institution's existing authority to decline or terminate a relationship on genuine money-laundering or terrorist-financing risk grounds is preserved in full; what the Act removes is the latitude to use other, non-risk-based criteria as a pretext or substitute for that analysis. The Act takes effect six months after the Governor's signature, landing at a commencement date of December 30, 2026, and will be enforced by the Attorney General under the state's unfair or deceptive trade practices authority rather than through a financial-crime supervisory channel.

The architectural significance of this development lies in where it draws the line. By requiring that adverse account actions rest on quantitative, impartial, risk-based criteria, the Act effectively requires covered institutions to be able to show their work: an account closure or service restriction that cannot be tied to a documented, risk-based rationale - AML/CFT or otherwise - now carries legal exposure under the new statute that it would not previously have carried under ordinary contractual discretion. For AML/CTF compliance functions, this raises the practical bar for documentation of de-risking decisions, even though it does not raise or lower the underlying AML/CFT standard itself. The statute is best read as a boundary-setting exercise around the exercise of institutional discretion, with AML/CFT risk-based decisioning expressly placed on the permitted side of that boundary.

A second, structurally separate development touches the same regime indirectly. David Stumbo was elected Attorney General, succeeding Alan Wilson, who was elected Governor. The Attorney General's office administers money-services licensing under the South Carolina AML Uniform Money Services Act in the capacity of Commissioner, and the same office is the designated enforcer of the new Guarantee Banking Act. The convergence of these two functions in a single incoming officeholder is a supervisory-architecture fact worth tracking, though no substantive change to AML/CFT licensing policy or practice has been observed to accompany the election result itself.

Outlook

Covered banks and payment processors operating in South Carolina have until the December 30, 2026 commencement date, as scheduled, to ensure that account-level adverse actions, including those grounded in AML/CFT risk assessment, are documented against a quantitative, impartial, risk-based standard capable of withstanding scrutiny under the new statute's enforcement regime. The more open question is how the incoming Attorney General's office, which both enforces the Act and administers money-services licensing, will approach the practical interplay between the two roles once the new officeholder is inaugurated in the first quarter of 2027; at this stage no policy direction has been signalled, and the correct posture is to treat the transition as a supervisory fact to monitor rather than a change to anticipate.

D8 Commercial Activity

no_change
Judgment: No SC-specific financial-integrity-sector commercial event this cycle. Probable
Regulatory horizon
In Force Pending30 Dec 2026 · ±quarter

Guarantee Banking Act (Act 257) commencement

From December 30, 2026, covered banks and payment processors in South Carolina may not decline, close, or restrict covered financial services on non-risk-based criteria such as protected speech, religion, or business sector.
Source
Proposed2027-Q1 · ±year

H.4592 — Vending of Digital Assets (virtual-currency kiosk MTL + disclosure mandate)

If revived and enacted, virtual-currency kiosk owners/operators in SC would be required to hold a money transmitter licence and display fraud warnings on kiosk screens.
South Carolina General Assembly (House) Source
Adopted2027-Q1 · ±quarter

South Carolina Attorney General transition (Stumbo succeeds Wilson)

David Stumbo was elected to succeed Alan Wilson as Attorney General; the office administers money-services licensing under the state AML Uniform Money Services Act. No substantive AML policy change has occurred; this flags a pending supervisory-leadership transition at inauguration.
Source
3 dated · 2 pending date · baseline financial-integrity-2026-07-05
Role action cards
MLRO

A new South Carolina statute preserves risk-based AML/CFT decisioning as an explicit exemption while restricting other grounds for account closure.

Existing AML/CFT risk-based de-risking authority is unaffected by the Guarantee Banking Act, but documentation supporting that a closure or restriction was risk-based rather than pretextual becomes more consequential once the Act commences on December 30, 2026.

1 evidence refs
Compliance

South Carolina enacted a fair-access statute with an AML/CFT carve-out, effective December 30, 2026.

Covered banks and payment processors operating in South Carolina will need policies that can demonstrate adverse account actions, including AML/CFT-driven ones, rest on quantitative, impartial, risk-based criteria once the statute commences.

1 evidence refs
Legal

The Guarantee Banking Act is enforced by the Attorney General as an unfair or deceptive trade practice, with a pending change in that office.

Enforcement exposure under the new Act sits with the Attorney General, whose office will transition to a new officeholder, David Stumbo, following the November 2026 election; no change to enforcement posture has yet been signalled.

2 evidence refs
Board

A new state-level fair-access law narrows permissible grounds for institutional debanking while preserving AML/CFT risk-based decisioning.

Large covered institutions face a documentation requirement ahead of the December 30, 2026 commencement date; the underlying AML/CFT regime is unchanged, limiting the strategic significance to a compliance-documentation matter rather than a shift in financial-crime risk appetite.

1 evidence refs
Risk

The Guarantee Banking Act creates a new documentation-exposure vector tied to account-closure decisioning in South Carolina.

Risk functions should note that the quantitative, impartial, risk-based standard required by the Act applies across all covered account actions, raising the evidentiary bar for AML/CFT risk-based de-risking decisions specifically, even though that authority itself is preserved.

1 evidence refs
Audit

Documentation standards for account-closure decisions in South Carolina are set to tighten under a new statute.

Internal audit scope for covered institutions should extend to evidencing that account-level adverse actions, including AML/CFT risk-based ones, meet the quantitative, impartial, risk-based standard required once the Act commences on December 30, 2026.

1 evidence refs
Scenario sketches

Illustrative supervisory-perimeter shift under the EU AML Package

As an illustrative matter of structural orientation only, the move within the EU AML Package from purely national AML supervision toward direct and indirect supervision of cross-border obliged entities by the Anti-Money Laundering Authority, operating alongside the directly applicable AML Regulation and per-state transposition of the sixth AML Directive, could over time reshape where evasion-typology pressure concentrates, shifting it from nationally supervised entities toward those outside the direct-supervision perimeter. This is architecture-over-incident framing describing a possible structural mechanism; it is not a prediction and not a statement of observed fact about any specific jurisdiction, including this one.

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

Standing trackers (T1–T6)
TrackerStatusNote
T1 · Russian Sanctions-Evasion Architectureno_changeNo SC-specific signal this cycle.
T2 · EU AML Package / AMLAno_changeNot applicable at subnational state level.
T3 · FATF Grey Listno_changeNo SC-specific development; set at US national level.
T4 · Beneficial-Ownership Register Statusno_changeNo SC state-level BO registry development; federal CTA tracked nationally.
T5 · Crypto & Digital-Asset Integrityno_changeNo new SC crypto-AML development this cycle.
T6 · Sanctions Regime Divergenceno_changeNo SC-specific sanctions-enforcement divergence signal this cycle.
Registers

Enforcement actions

  • 21 Mar 2025
  • 2 Dec 2025
  • 22 Sep 2025
  • 14 Oct 2025
  • 25 Jun 2025
  • 23 Apr 2026
  • 24 Oct 2025
  • 23 Apr 2026
  • 20 May 2026
  • 30 Jun 2026
  • 24 Apr 2026
  • FinCEN issued an interim final rule and reinstated BOI reporting deadlines (March 21, 2025) before narrowing CTA coverage to exempt nearly all domestic reporting companies and US beneficial owners of foreign entities, applying uniformly to South Carolina-formed LLCs and corporations. 21 Mar 2025
  • OFAC settled with IPI Partners, LLC for $11,485,352 to resolve 51 apparent violations of Russia sanctions arising from 2017-2018 investment solicitations, part of the uniform federal sanctions perimeter applicable to any SC-domiciled investors or counterparties. 2 Dec 2025
  • OFAC settled with ShapeShift AG, a Switzerland-incorporated digital asset exchange operating from Colorado, for $750,000 over apparent sanctions violations, illustrating the federal virtual-asset sanctions compliance perimeter that governs any SC-based VASP users or operators. 22 Sep 2025
  • OFAC designated the Prince Group TCO (146 targets including Chen Zhi) and FinCEN issued a Section 311 special measure severing Huione Group from the US financial system, both actions forming part of the national sanctions/AML perimeter applicable to any SC-based financial institution processing related flows. 14 Oct 2025

Sanctions changes

  • 14 Oct 2025
  • 23 Apr 2026
  • 24 Oct 2025
  • 29 Jun 2026
  • 30 Jun 2026
  • 23 Apr 2026
  • 20 May 2026
  • 30 Jun 2026
  • 24 Apr 2026
  • OFAC designated the Prince Group Transnational Criminal Organization and 146 associated targets (Oct 14, 2025), later adding 25 additional Bitcoin addresses to Chen Zhi's SDN listing (Oct 30, 2025), applicable to the uniform US sanctions-screening perimeter covering SC-based financial institutions. 14 Oct 2025
  • FinCEN designated Huione Group as a foreign financial institution of primary money laundering concern under Section 311 of the USA PATRIOT Act (Oct 14, 2025), severing its access to the US financial system nationwide, applicable to any SC-regulated bank with correspondent exposure. 14 Oct 2025

Regulatory horizon (register)

  • GENIUS Act stablecoin AML/sanctions final rule (FinCEN/OFAC)
  • S.4592 (Vending of Digital Assets) kiosk MTL requirement
  • H.4592 — Vending of Digital Assets (virtual-currency kiosk MTL + disclosure mandate)
  • Guarantee Banking Act (Act 257) commencement
  • South Carolina Attorney General transition (Stumbo succeeds Wilson)
  • GENIUS Act stablecoin state-federal equivalence determinations
  • FinCEN final CTA beneficial ownership rule
  • FATF next plenary review of US standing

Active schemes

  • [HIGH] SC-incorporated anonymous LLCs enabling multi-state fraud
  • [HIGH] Federal CTA rollback widens SC shell-entity anonymity (corrected classification)
  • [HIGH] Gatekeeper professionals enabling sanctions evasion
  • SAR-flagged transactional nexus to South Carolina
Sources
  1. South Carolina Legislature
  2. South Carolina Legislature
  3. South Carolina Legislature
  4. https://www.scstatehouse.gov/sess126_2025-2026/bills/163.htm
  5. https://www.scstatehouse.gov/code/t35c011.php
  6. https://www.cryptotimes.io/2026/05/20/south-carolina-governor-signs-s-163-protects-bitcoin-bans-fed-cbdcs/
  7. South Carolina Legislature Online
  8. South Carolina Attorney General
  9. South Carolina Legislature Online
  10. https://www.scstatehouse.gov/sess126_2025-2026/bills/5538.htm
  11. https://www.herecolumbia.com/2026/11/02/sc-guarantee-banking-act-big-banks-beliefs/
  12. https://www.multistate.us/elections/results/south-carolina-2026
  13. FinCEN Exchange Brings Together Public and Private Stakeholders to Discuss Bank Secrecy Act Suspicious Activity Reporting Statistics | FinCEN.gov
  14. Enforcement Actions | FinCEN.gov
  15. United States Department of the Treasury Financial Crimes Enforcement Network - Home | FinCEN.gov
  16. Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
  17. Treasury Convenes Financial Institutions and Law Enforcement to Identify and Dismantle Money Laundering Networks | FinCEN.gov
  18. Guidance | FinCEN.gov
  19. News | FinCEN.gov
  20. FinCEN Year in Review for FY 2024
  21. FinCEN Issues Expanded Southwest Border Geographic Targeting Order | FinCEN.gov
  22. FinCEN Announces Data-Driven Border Operation to Address Potential Money Laundering | FinCEN.gov
  23. An urgent call for action: Stop anonymous shell companies from fleecing American tax payers | Global Witness
  24. The Role of Domestic Shell Companies in Financial Crime ...
  25. D SANCTIONS ADVISORY Guidance on Sham Transactions and Sanctions Evasion
  26. Treasury Department won’t enforce beneficial ownership rule under the Corporate Transparency Act - ICIJ
  27. US Treasury Department removes ‘escape hatch’ for criminals from beneficial ownership reporting form - ICIJ
  28. Beneficial Ownership Information Reporting | FinCEN.gov
  29. How anonymously owned companies are used to rip off government budgets | Global Witness
  30. BOI E-FILING - FinCEN
  31. Experts Warn US Treasury Rule Will Aid Criminal Shell Firms | OCCRP
  32. Concealment of Beneficial Ownership July 2018 of Financial Intelligence Units
  33. The DOJ's NCET Disbanded: What This Means for Digital Assets - Chainalysis
  34. 2026 Crypto Crime Report – Illicit Crypto Trends & Typologies | TRM Labs
  35. PPSI-AMLCFT-NPRM.pdf
  36. Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
  37. Blockchain Legal Library
  38. How IRS-CI Seized Billions From Silk Road Hacker James Zhong
  39. 1 1. See 31 U.S.C. § 5312(a)(2); 31 C.F.R. § 1010.100(t). 2.
  40. Money Laundering Scheme Transferred Over $12 Million to South American Countries | FinCEN.gov
  41. Money Laundering Advisory Notice: June 2026 - GOV.UK
  42. International Co-operation on Money Laundering Detection, Investigation, and
  43. MSB Registration
  44. Money Services Business (MSB) Registration | FinCEN.gov
  45. Money Services Business (MSB) Agent List | FinCEN.gov
  46. MSB Registrant Search | FinCEN.gov
  47. Financial Crimes Enforcement Network Registration of Money Services Business
  48. Registration of Money Services Business (RMSB) ...
  49. GUIDANCE TO MONEY SERVICES BUSINESSES ON OBTAINING AND MAINTAINING BANKING SERVICES | FinCEN.gov
  50. Definition of Money Services Business (Money Transmitter/Currency Dealer or Exchanger) | FinCEN.gov
  51. SOUTH CAROLINA LIMITED overview - Find and update company information - GOV.UK
  52. Registration and De-Registration of Money Services Businesses | FinCEN.gov
  53. The SAR Activity Review
  54. DOJ Seizes USD 61 Million Tied to Pig Butchering Scam in North Carolina | TRM Labs
  55. Financial Fraud Enforcement Task Force (FFETF) | FinCEN.gov
  56. U.S. DEPARTMENT OF THE TREASURY OFFICE OF FOREIGN ASSETS CONTROL
  57. Recent Actions | Office of Foreign Assets Control
  58. Left out of the Bargain Settlements in Foreign Bribery Cases
  59. Real Estate Title and Escrow Companies: A BSA Filing Study
  60. Advisories | FinCEN.gov
  61. Fincen
  62. Civil Penalties and Enforcement Information | Office of Foreign Assets Control
  63. 2024 Civil Penalties and Enforcement Information | Office of Foreign Assets Control
  64. 2025 Civil Penalties and Enforcement Information | Office of Foreign Assets Control
  65. 2023 Civil Penalties and Enforcement Information | Office of Foreign Assets Control
  66. U.S. DEPARTMENT OF THE TREASURY OFFICE OF FOREIGN ASSETS CONTROL
  67. Settlement Agreement between the U.S. Department of the Treasury's Office of Foreign Assets Control and ShapeShift AG | Office of Foreign Assets Control
  68. Settlement Agreement between the U.S. Department of the Treasury's Office of Foreign Assets Control and C.H. Robinson International Inc. | Office of Foreign Assets Control
  69. ENFORCEMENT INFORMATION FOR July 15, 2010
  70. Settlement Agreement between the U.S. Department of the Treasury's Office of Foreign Assets Control and IPI Partners, LLC | Office of Foreign Assets Control
  71. DOJ Charges OmegaPro Founder and Promoter in $650M Global Fraud Scheme | TRM Labs
  72. 1 The U.S. Department of the Treasury’s (Treasury) Financial
  73. $15 billion seized by US originates from Iran/China bitcoin miner "theft"
  74. Questions swirl around US plans for record $15B Prince Group crypto seizure - ICIJ
  75. DOJ Seizes $15 Billion in Bitcoin
  76. 1 The U.S. Department of the Treasury’s (Treasury)
  77. International Action Dismantles Notorious Russian Crypto Exchange Garantex - Chainalysis
  78. SAR Filing Leads to 125-Count Indictment in $2.7 Million Embezzlement Case | FinCEN.gov
  79. Fact Sheet: Beneficial Ownership Information Reporting Notice of Proposed Rulemaking (NPRM) | FinCEN.gov
  80. Financial Crimes Enforcement Network The Role of Domestic Shell Companies in
  81. Millions in Covid relief funds went to shadowy companies registered at a Wyoming storefront that hundreds of thousands of firms used as an address - ICIJ
  82. How America’s biggest law firm drives global wealth into tax havens - ICIJ
  83. Panamanian Law Firm Is Gatekeeper To Vast Flow of Murky Offshore Secrets - ICIJ
  84. SC SERVICES LIMITED overview - Find and update company information - GOV.UK
  85. South Carolina Association of School Administrators - Company Profile and News - Bloomberg Markets
  86. SC LIMITED overview - Find and update company information - GOV.UK
  87. SOUTH CAROLINA ENTERPRISES LTD more information - Find and update company information - GOV.UK
  88. South Carolina Ports Authority - Company Profile and News - Bloomberg Markets
  89. United States Attorney's Office for the District of South Carolina - Company Profile and News - Bloomberg Markets
  90. Answers to Frequently Asked Bank Secrecy Act (BSA) Questions | FinCEN.gov
  91. FinCEN Issues Ruling (FIN-2008-R012)on Whether a Money Services Business Must Establish and Maintain Separate Deposit Accounts for its Separate Check Cashing and Money Transmission Lines of Business | FinCEN.gov
  92. The Bank Secrecy Act | FinCEN.gov
  93. BSA Timeline | FinCEN.gov
  94. Financial Crimes Enforcement Network 37 U.S. Department of the Treasury
  95. UNITED STATES OF AMERICA FINANCIAL CRIMES ENFORCEMENT NETWORK
  96. 1 Financial Crimes Enforcement Network U.S. Department of the Treasury
  97. A Quick Reference Guide for Money Services Businesses
  98. Legal Reference for Bank Secrecy Act Forms and Filing Requirements | FinCEN.gov
  99. FinCEN TD Bank Consent Order, Number 2024-02
  100. DOJ Uses Organized Crime Statute in $263 Million Cryptocurrency Theft, Money Laundering and Home Invasion Conspiracy | TRM Labs
  101. U.S.: Ex-Judge Pleads Guilty in Major Social Security Fraud Case | OCCRP
  102. Economic Crime Strategy 2025 - final progress report, May 2025 | The Crown Prosecution Service
  103. CPS News Centre | The Crown Prosecution Service
  104. Country Policy and Information Note Pakistan: Political parties and
  105. CPS data summary Quarter 1 2024-2025 | The Crown Prosecution Service
  106. Economic Crime Plan 2 (2023-2026)
  107. Sanctions Programs and Country Information | Office of Foreign Assets Control
  108. China Slaps Symbolic Sanctions on US Firms Over Taiwan Arms Sale - Bloomberg
  109. China Hits Boeing Defense With Sanctions as Taiwan President Is Inaugurated - Bloomberg
  110. OFAC Consolidated Frequently Asked Questions | Office of Foreign Assets Control
  111. China Tells Airlines Stop Taking Boeing Jets as Trump Tariffs Expand Trade War - Bloomberg
  112. China Southern Halts Sale of Boeing Jets on US New-Plane Freeze (BA) - Bloomberg
  113. China Sanctions Boeing, Raytheon Executives for Taiwan Arms Deal - Bloomberg
  114. Sanctions List Search Tool | Office of Foreign Assets Control
  115. China to Sanction Boeing (BA), Lockheed Martin (LMT), Raytheon (RTN) Over Taiwan - Bloomberg
  116. U.S. Delves Into 787 Factory Issues as Boeing Probe Expands - Bloomberg
  117. Definition of Money Transmitter (Merchant Payment Processor) | FinCEN.gov
  118. Fact Sheet on MSB Registration Rule | FinCEN.gov
  119. STATE CONTACT INFORMATION FOR MSBs
  120. 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
  121. Definition of Money Services Business (Money Transmitter/Currency Dealer or Exchanger) | FinCEN.gov
  122. Enforcement Actions for Failure to Register as a Money Services Business | FinCEN.gov
  123. Important Information for MSBs | FinCEN.gov
  124. FinCEN Exchange in the Press | FinCEN.gov
  125. FinCEN Exchange | FinCEN.gov
  126. Press Releases | FinCEN.gov
  127. FinCEN Year In Review | FinCEN.gov
  128. READOUT: FinCEN Gathers Public and Private Sector Officials in Charlotte, North Carolina to Discuss Efforts to Combat the Fentanyl Epidemic | FinCEN.gov
  129. READOUT: FinCEN, Law Enforcement, and Financial Industry Representatives Meet to Discuss Collaborative Efforts to Combat Illicit Finance Related to Fentanyl Trafficking | FinCEN.gov
  130. FinCEN Combats Ransomware | FinCEN.gov
  131. READOUT: FinCEN Exchange Sessions in Miami Encourage Public-Private Collaboration to Fight Fentanyl Trafficking and Third-Party Money Laundering | FinCEN.gov
  132. In Boston, Treasury Launches New Public-Private FinCEN Exchange Series to Fight Fentanyl Trafficking | FinCEN.gov
  133. FinCEN, U.S. Department of the Treasury
  134. FinCEN, U.S. Department of the Treasury
  135. FinCEN, U.S. Department of the Treasury
  136. Office of Foreign Assets Control, U.S. Department of the Treasury
  137. Office of Foreign Assets Control, U.S. Department of the Treasury
  138. Office of Foreign Assets Control, U.S. Department of the Treasury
  139. Global Witness
  140. ICIJ
  141. OCCRP
  142. TRM Labs
Coverage gaps
fim-int-2026-07-07-G001: Public, disaggregated South Carolin…
fim-int-2026-07-07-G001: Public, disaggregated South Carolina-specific enforcement data (state banking regulator orders, USAO-SC financial-crime prosecutions) remains sparse relative to national FinCEN/OFAC releases, limiting independent verification of state-level enforcement intensity. [resolved]
fim-int-2026-07-07-G002: The scope and timeline of the pendi…
fim-int-2026-07-07-G002: The scope and timeline of the pending FinCEN final CTA beneficial-ownership rule is not yet determinable, precluding a confident projection of whether SC-formed-entity BO opacity will be narrowed or entrenched. [resolved]
fim-int-2026-07-07-G003: No evidence establishes whether Sou…
fim-int-2026-07-07-G003: No evidence establishes whether South Carolina-chartered institutions operate under any state-specific RegTech/SupTech supervisory expectation distinct from federal banking-agency guidance. [resolved]
fim-int-2026-07-07-G004: The June 17-19, 2026 FATF plenary o…
fim-int-2026-07-07-G004: The June 17-19, 2026 FATF plenary outcomes (Bosnia and Herzegovina and Iraq added to increased monitoring, Algeria and Namibia removed, UK Presidency transition) were not captured in the baseline research window and require direct primary-source corroboration beyond the reviewer challenge citation. [resolved]
fim-int-2026-07-07-G005: The FinCEN Exchange event reviewing…
fim-int-2026-07-07-G005: The FinCEN Exchange event reviewing SAR filings with a transactional nexus to South Carolina lacks a specific event date in the cited source, precluding verification that it falls within the 18-month baseline recency window. [resolved]
fim-int-2026-07-14-G001: Colombia was queried but no fresh v…
fim-int-2026-07-14-G001: Colombia was queried but no fresh verifiable primary-source material was located this cycle — a genuine coverage gap, not a no-material-change finding. [resolved]
fim-int-2026-07-14-G002: D4 conflict-finance coverage this c…
fim-int-2026-07-14-G002: D4 conflict-finance coverage this cycle is limited to Yemen; no fresh Sahel conflict-mineral, DRC mining-governance, or oil-revenue-corruption material was located. [resolved]
fim-int-2026-07-14-G003: No direct FCA/JMLSG citation was lo…
fim-int-2026-07-14-G003: No direct FCA/JMLSG citation was located to corroborate the D6 AI/AMLA compliance-gap claim this cycle; it rests on a single Tier-4 commentary source. [resolved]
fim-int-2026-07-14-G004: No new OFAC or OFSI Houthi-specific…
fim-int-2026-07-14-G004: No new OFAC or OFSI Houthi-specific designation was independently confirmed this cycle beyond the routine UN 12-month sanctions renewal. [resolved]
fim-int-2026-07-14-G005: The Carolina Forest, South Carolina…
fim-int-2026-07-14-G005: The Carolina Forest, South Carolina asset-forfeiture claim rests on a single Tier-4 vendor source with no primary DOJ/FinCEN record located this cycle. [resolved]
fim-int-2026-08-05-G001: No T1 source_url located for the st…
fim-int-2026-08-05-G001: No T1 source_url located for the standing Russian dark-fleet/tech-procurement sanctions-evasion tracker this cycle. [resolved]
fim-int-2026-08-05-G002: No dedicated conflict-finance findi…
fim-int-2026-08-05-G002: No dedicated conflict-finance finding beyond the Colombia narco-designation was located this cycle; Sahel and DRC conflict-mineral coverage remains thin. [resolved]
fim-int-2026-08-05-G003: No dedicated RegTech/AI-monitoring …
fim-int-2026-08-05-G003: No dedicated RegTech/AI-monitoring supervisory-guidance development was located this cycle beyond the FinCEN NPRM's passing reference to AI/federated-learning tools. [resolved]
fim-int-2026-08-05-G004: No standing T6 sanctions-regime-div…
fim-int-2026-08-05-G004: No standing T6 sanctions-regime-divergence primary designation delta (autonomous-listing asymmetry) was located this cycle beyond the FATF Recommendation 6 update. [resolved]
fim-int-2026-08-05-G005: Sub-Saharan Africa, Central Asia an…
fim-int-2026-08-05-G005: Sub-Saharan Africa, Central Asia and Pacific enabler-jurisdiction coverage was not actively searched this cycle. [resolved]
fim-int-2026-09-28-G001: D1, D2, D3, D4 and D6 domain assess…
fim-int-2026-09-28-G001: D1, D2, D3, D4 and D6 domain assessments carry no US-SC-specific signal this cycle; this run's search budget was concentrated on the crypto/MTL delta rather than a full global sweep for this subnational cell. [resolved]
fim-int-2026-09-28-G002: No jurisdiction_risk_movements data…
fim-int-2026-09-28-G002: No jurisdiction_risk_movements data was located this cycle for US-SC. [resolved]
fim-int-2026-10-11-G001: No SC-specific state-level benefici…
fim-int-2026-10-11-G001: No SC-specific state-level beneficial-ownership registry development was located this cycle (D2). [resolved]
fim-int-2026-10-11-G002: Tier D mandatory watch (Cambodia, L…
fim-int-2026-10-11-G002: Tier D mandatory watch (Cambodia, Laos, Mexico, Colombia) was not independently re-researched within this single-jurisdiction US-SC dispatch; recorded as not reached, not as no-signal. [resolved]
fim-int-2026-10-11-G003: No RegTech/compliance-technology (D…
fim-int-2026-10-11-G003: No RegTech/compliance-technology (D6) development specific to South Carolina was located this cycle. [resolved]
fim-int-2026-10-25-G001: Tier D jurisdictions (KH/LA/MX/CO) …
fim-int-2026-10-25-G001: Tier D jurisdictions (KH/LA/MX/CO) were not actively re-swept this cycle; pooled research budget concentrated on US-SC primary sources per this run's JID-binding instruction. [open]
fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): Whether SC's non-fiat crypto-to-crypto MTL exemption interacts with federal FinCEN MSB registration for the same activity was not independently confirmed this cycle. [open]
fim-int-2026-11-08-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-11-08-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): No D1-D6/D8 SC-specific findings located this cycle; a direct search of OFAC/OFSI/SLED press releases and SC Secretary of State beneficial-ownership filings would close this gap. [open]
FIM-GAP-001 (D3): Public, disaggregated South Carolina-speci…
FIM-GAP-001 (D3): Public, disaggregated South Carolina-specific enforcement data (state banking regulator orders, USAO-SC financial-crime prosecutions) is sparse in open-source reporting relative to national FinCEN/OFAC releases, limiting independent verification of state-level enforcement intensity distinct from the federal aggregate.
FIM-GAP-002 (D2): South Carolina, like most US states, impos…
FIM-GAP-002 (D2): South Carolina, like most US states, imposes no beneficial-ownership disclosure requirement at LLC/corporation formation. Combined with the 2025 federal CTA rollback exempting domestic reporting companies, this leaves a compounding transparency gap for SC-formed entities with no operative registry, state or federal, capturing true ownership.
FIM-GAP-003 (D6): No public evidence was found of a dedicate…
FIM-GAP-003 (D6): No public evidence was found of a dedicated South Carolina state-level AML/CFT supervisory or RegTech/SupTech function independent of federal examiners (FDIC/Federal Reserve/OCC) for state-chartered institutions, suggesting compliance-technology adoption expectations for SC-chartered banks derive wholly from federal guidance rather than any state-specific supervisory posture.

Evidence

Confidence-tiered claims

Exempts digital-asset mining, node operation, blockchain software development, and non-fiat crypto-to-crypto exchange from the Title 35 Ch.11 money-transmitter licensing requirement. [Source 1]
Probable · 1 source
A person may not engage in money transmission, or advertise/solicit/hold out as providing it, unless licensed under Article 2 of Chapter 11 or an authorised delegate. [Source 1]
Probable · 1 source
S.163 expressly preserves AG authority to prosecute fraud by anyone falsely claiming to offer digital-asset mining-as-a-service or staking-as-a-service, notwithstanding the licensing/securities carve-outs. [Source 1]
Probable · 1 source
S.163 bans SC state agencies and political subdivisions from accepting, requiring, or testing payment in a CBDC, including barring participation in any Federal Reserve CBDC pilot. [Source 1]
Probable · 1 source
Licensees and authorised delegates must file with the Commissioner all reports required by federal currency reporting, recordkeeping and suspicious-transaction requirements. [Source 1]
Probable · 1 source
S.C. Code § 34-47-60 exempts digital-asset mining, blockchain node operation, on-chain software development, and non-fiat crypto-to-crypto exchange from the state MTL requirement [Source 1]
Probable · 1 source
2024 Act No. 218 substantially adopted the Money Transmission Modernization Act model, revising net-worth, surety-bond, permissible-investment and control definitions; new-licensee terms bound from 2025-01-01 [Source 1]
Probable · 1 source
H.4592 (virtual-currency kiosk MTL + disclosure bill) remains pending in House committee since 2026-01-13 referral; dead for the 2025-2026 biennium absent revival [Source 1]
Probable · 1 source
Digital-asset mining, node/blockchain-protocol operation, blockchain-protocol software development, and crypto-to-crypto exchange (not into legal tender/bank deposits) from the Title 35, Article 2 money-transmitter licence. [Source 1]
Probable · 1 source
Bars banks >$100bn assets and payment processors >$100bn annual volume from declining/closing/restricting covered services on non-risk-based grounds; exempts legitimate legal/regulatory requirements including AML/CFT risk-based decisions [Source 1]
Probable · 1 source
David Stumbo (R) elected Nov 3, 2026 to succeed Alan Wilson (elected Governor); AG administers SC AML Uniform Money Services Act licensing as 'Commissioner' [Source 1]
Probable · 1 source