25 Oct 2026 · fim-2026-10-25
Lead Signal
Texas has become a working illustration of how a federal preemption event lands on an actively enforced state gateway before that gateway's reach has actually narrowed. On 23 October 2026 the Office of the Comptroller of the Currency published implementing regulations for the GENIUS Act, confirming that from 18 January 2027 a federally qualified payment stablecoin issuer -- and an approved subsidiary of an insured depository institution -- will be licensed, regulated and supervised exclusively at the federal level, with Section 5(h) of the Act (12 U.S.C. 5904(h)) expressly preempting any state charter, licence or other authorisation requirement for that category of firm. That commencement sits alongside, rather than replacing, continued Texas enforcement: in September 2026 the Texas Department of Banking issued consent orders against two cryptocurrency and payment firms resolving allegations that they conducted money transmission involving stablecoin activity in Texas without the required licence under the state's Money Services Modernization Act (Chapter 152). The two developments describe one coherent story -- a state regulator still actively policing its general money-transmission gateway against stablecoin activity in the months immediately before a large slice of that gateway's future relevance is removed by federal law.
The practical reading for firms operating in or into Texas is that the state licensing requirement does not disappear on the Federal Register's publication date; it disappears, for a defined category of issuer, only once the implementing regulations take effect in January 2027. Until then, and for any issuer that does not qualify as a federal qualified payment stablecoin issuer thereafter, the Chapter 152 gateway remains the operative control, and the Texas Banking Commissioner has just demonstrated a willingness to use it.
Other Developments
Beneficial ownership exposure confirmed stable, closing a prior gap. Reporting reviewed confirms that FinCEN's March 2025 interim final rule exempts domestically formed companies -- including Texas-formed LLCs and corporations -- from Corporate Transparency Act beneficial-ownership reporting, leaving only foreign entities registered to do business in the United States within scope. The residual nationwide injunction in the litigation brought by Texas-forming plaintiffs in the Eastern District of Texas (Smith v. U.S. Department of the Treasury) remains the live venue for any further challenge, but it addresses a narrower question than the exemption itself. This closes a beneficial-ownership coverage gap that had been outstanding in prior assessment of the jurisdiction.
Multistate AML/CFT supervision continuing on the standing examination framework. A joint consent order entered on 22 June 2026 between the Texas Department of Banking and the Colorado Division of Banking addressed alleged deficiencies in a licensed multistate money transmitter's anti-money-laundering and countering-the-financing-of-terrorism programme, including allegations touching currency transaction reporting timeliness and agent monitoring. The action illustrates that the standing Bank Secrecy Act examination regime -- applied to money services businesses under the risk-rated 12/18/24-month examination cycle referenced in Texas Department of Banking supervisory guidance -- continues to generate active multistate enforcement, independent of the stablecoin-specific gateway questions raised above.
Cross-Monitor Connections
The GENIUS Act implementing regulations are a payments-infrastructure event as much as a financial-integrity one: the same federal preemption that narrows Texas's money-transmission gateway for qualified stablecoin issuers also reshapes how those issuers' access to settlement and banking infrastructure will be supervised going forward, a question more squarely in the remit of payments-market analysis than of illicit-finance typology. The beneficial-ownership exemption finding likewise has a structural-transparency dimension that extends beyond financial-crime risk into the broader corporate-transparency and registry-architecture questions tracked elsewhere; a jurisdiction's withdrawal of domestic beneficial-ownership reporting is a fact relevant to any analysis of how ownership information is or is not available to counterparties and regulators outside the financial-integrity lens specifically.
Outlook
The period between now and 18 January 2027 is the operative window to watch: any federally qualified payment stablecoin issuer currently navigating or avoiding the Texas Chapter 152 gateway has a defined, near-term date on which that calculus changes, while non-qualifying issuers and other money transmitters will continue to face the state gateway exactly as the OKX and Triple A consent orders illustrate it is currently being applied. Separately, the beneficial-ownership position is better characterised as settled for domestic Texas entities than as actively moving, though the Eastern District of Texas litigation remains a venue where that could change. Firms should treat the Texas Department of Banking's demonstrated willingness to enforce the general money-transmission licence against stablecoin activity as the present reality, with the federal preemption date as a known, dated inflection point rather than an immediate relief.
11 Oct 2026 · fim-2026-10-11
Lead Signal
Texas Department of Banking enforcement actions resolved in September 2026 against OKX, Inc. and Triple A Technologies Pte Ltd. confirm that state money-transmission licensing in Texas continues to operate as a live supervisory backstop for stablecoin activity, independent of the federal GENIUS Act framework. OKX accepted a consent order and a 95,000 dollar administrative penalty, effective 11 September 2026, over conduct alleged to span 2018 to 2024, in which the firm received sovereign currency and stablecoins for transmission and provided custody services to Texas customers without a Chapter 152 money transmitter licence. Triple A Technologies accepted a parallel consent order and a 20,000 dollar penalty, effective 23 September 2026, for processing merchant payments in stablecoins and non-convertible cryptocurrency without the same licence. Both matters were resolved under the Texas Money Services Modernization Act, Texas Finance Code Chapter 152, and both rest on Texas DOB Supervisory Memorandum 1037, which treats a sovereign-currency-pegged, fully reserve-backed, issuer-redeemable stablecoin as money or monetary value for licensing purposes. The Commissioner's own June 2026 testimony states plainly that Texas does not currently have a framework substantially similar to the federal GENIUS Act, meaning the state has no certification pathway for GENIUS Act state-qualified payment-stablecoin issuers and continues to rely on the pre-existing Chapter 152 licensing route to reach stablecoin transmission activity.
The practical reading is that federal stablecoin legislation has not displaced state money-transmission authority in Texas; it has instead left two regimes running in parallel, with the state licensing regime doing the enforcement work in the interim.
Other Developments
A joint multi-state AML consent order against Ramad Pay, Inc. was entered by the Texas Department of Banking together with the Colorado Division of Banking, effective 18 June 2026, carrying a 200,000 dollar penalty for deficiencies in the firm's AML/CFT program, including conduct alleged to touch Bank Secrecy Act implementing regulations and the FTC Safeguards Rule. The order was stated directly in the Texas DOB's own press release and sits within the standing Chapter 152 supervisory architecture administered by the Department, reflecting continued multi-state coordination on money-services-business oversight.
A federal beneficial-ownership reporting rule took effect on 14 August 2026 when FinCEN issued a final rule permanently removing the requirement for United States companies and United States persons to report beneficial-ownership information, narrowing the federal Corporate Transparency Act register to foreign reporting companies only. No Texas state-level beneficial-ownership registry has been identified that fills the gap this creates for domestic entities formed or operating in the state.
Cross-Monitor Connections
The OKX and Triple A Technologies matters sit at the intersection of financial-integrity and world-payments concerns: the underlying conduct is a payments-licensing failure, but the consent orders rest on Chapter 152, the same statute that anchors Texas's AML/CFT supervisory architecture for money-services businesses, so the enforcement record informs both monitors' read of state-level stablecoin oversight. The Ramad Pay consent order is more squarely an AML/CFT matter, given its explicit BSA and Safeguards Rule grounding, but it was entered through the same Chapter 152 channel and the same Department of Banking that licenses and polices payment firms more broadly, reinforcing the reading that Texas treats payments licensing and financial-crime compliance as a single supervisory perimeter rather than two distinct tracks. The federal BOI exemption is a cross-cutting development with no Texas-specific financial-integrity angle beyond the standing observation that the state has no registry of its own to substitute for the narrowed federal one.
Outlook
Texas DOB enforcement against unlicensed MSBs and crypto firms has been sustained rather than escalating or receding, and the Commissioner's testimony that the state currently lacks a GENIUS Act-equivalent certification framework signals that Chapter 152 licensing, not a new stablecoin-specific regime, will remain the operative enforcement lever through at least the next legislative session, with the Department stating it looks forward to working with the Legislature on a future framework. The federal beneficial-ownership exemption leaves a visible transparency gap at the Texas state level that, absent a state registry, is likely to persist as a standing observation rather than a near-term legislative fix.
28 Sep 2026 · fim-2026-09-28
Lead Signal
The most consequential development touching Texas this cycle is federal, not state, in origin, but it lands squarely on the states baseline corporate-transparency posture. FinCENs interim final rule exempting essentially all United States-formed companies from Corporate Transparency Act beneficial ownership information reporting was finalized effective August 14, 2026. That change removes the federal backstop that had, in principle, sat behind Texas own manager-only LLC disclosure practice, under which a Texas certificate of formation and the annual Public Information Report disclose only the managers of a manager-managed limited liability company, not its underlying members or beneficial owners. With the federal reporting requirement narrowed to foreign reporting companies, Texas existing entity-formation opacity now carries more independent analytical weight than it did a cycle ago, because there is materially less federal disclosure sitting behind it for U.S.-person beneficial owners.
This is a structural finding, not an incident. Nothing changed in Texas own statute; what changed is the federal architecture around it, and the effect is to elevate a pre-existing structural feature into a more significant enabler-jurisdiction consideration, particularly measured against the Financial Action Task Force Recommendation 24 standard on beneficial ownership transparency for legal persons.
Other Developments
A correction to the standing AML/CTF baseline. Texas Finance Code Chapter 151 was repealed outright and replaced by Chapter 152, the Money Services Modernization Act, effective September 1, 2023, under Senate Bill 895 of the 88th Legislature; House Bill 3833, effective September 1, 2025, made further technical amendments at the Department of Bankings request. The operative money-services and money-transmission licensing chapter for Texas is Chapter 152, not Chapter 151. This is a baseline-descriptive correction: any standing record still citing Chapter 151 as current law describes a repealed statute.
Department of Banking reaffirms a narrow stablecoin perimeter. Testimony from the Texas Department of Banking, dated July 30, 2026, confirms that money or monetary value under Chapter 152 includes a stablecoin only where it is pegged to a sovereign currency, fully backed by assets held in reserve, and redeemable for that sovereign currency. Bitcoin and similar non-redeemable tokens sit outside this definition and are therefore excluded from Chapter 152 money-transmission licensing. This is consistent with the Departments own Supervisory Memorandum 1037 and represents a reaffirmation, not a change, of the existing licensing perimeter.
The Texas Strategic Bitcoin Reserve moves from statute into implementation. Under the Texas Strategic Bitcoin Reserve and Investment Act (Senate Bill 21), the Comptroller of Public Accounts named a five-person statutory advisory committee on May 28, 2026, and issued a custody and liquidity-services procurement solicitation, SmartBuy solicitation number 908-26-1778WS, posted May 7, 2026 with responses due June 15, 2026. This is a novel form of state-sovereign digital-asset holding and introduces a custody-vendor due-diligence question that compliance-technology functions have not previously had to consider at the level of a U.S. state treasury function.
A parallel, non-sanctions economic-pressure architecture continues to operate. The Texas Comptroller of Public Accounts administers statutory scrutinized-companies lists covering energy-sector boycotts, boycotts of Israel, ties to foreign terrorist organizations, and Sudan- and Iran-related exposure, which trigger mandatory state-contract exclusion and public-fund divestment. These lists were updated in August 2026. This mechanism operates under state procurement and investment statute, independent of and parallel to federal OFAC sanctions administration, and functions as a state-level enabler-denial tool even though it is not a sanctions programme in the federal sense.
Cross-Monitor Connections
The beneficial-ownership finding connects directly to World Payments Monitor coverage of the same Chapter 151-to-Chapter 152 recodification, which that monitor reads through a licensing-perimeter lens rather than an enabler-jurisdiction lens; the two readings are complementary rather than duplicative. The Strategic Bitcoin Reserve implementation activity is also relevant to the Crypto monitors licensing coverage, where the same Department of Banking stablecoin-classification testimony is the anchoring source, and to compliance-technology functions assessing custody-vendor risk for a state-sovereign digital-asset holding, a novelty with no close precedent elsewhere in the fleets jurisdiction set.
Outlook
The federal CTA narrowing is now in force and its effect on Texas enabler-jurisdiction standing should be treated as a durable baseline shift rather than a one-cycle event; watch for any state-level legislative response that either tightens Texas own LLC disclosure requirements independent of the federal backstop, or leaves the gap as-is. The Strategic Bitcoin Reserve custody procurement outcome, expected as scheduled around the fourth quarter of 2026, will be the next concrete implementation milestone and will determine which custodian bears responsibility for the states digital-asset holding. No near-term change is expected to the Chapter 152 stablecoin-licensing perimeter, which the Department of Banking has now reaffirmed twice in substance this year.
22 Sep 2026 · fim-2026-09-14
Lead Signal
Texas closed a previously under-regulated cash-to-crypto laundering vector this cycle by enacting Finance Code Chapter 161 under SB 1705, effective September 1, 2025, which requires virtual-currency-kiosk operators to hold a Chapter 152 money-transmission license, register with the Finance Commission of Texas and the Texas Department of Licensing and Regulation, deploy blockchain-analytics and antifraud policies, and furnish limited transaction-identifying information to law enforcement within a fixed window without subpoena. This is architecture, not incident: a state legislature moving preemptively to bring a physical, cash-facing crypto access channel inside a licensing and analytics perimeter before that channel generated a documented enforcement scandal of its own.
Alongside the kiosk regime, HB 4233 amended Finance Code Chapter 160 to consolidate a quarterly customer-accounting requirement for digital-asset custodians, effective the same date. Both statutes sit on top of the confirmed foundation that Texas's core money-services statute was repealed and replaced in 2023 — Chapter 151 succeeded by Chapter 152, the Money Services Modernization Act, with HB 3833 in 2025 making further Department-requested clarifications. Chapter 151 should now be treated as dead law wherever any downstream tracker still cites it.
Other Developments
Lottery Commission abolition carries an explicit money-laundering thread. Following 2023 and 2025 bulk-ticket jackpot controversies, Texas lawmakers voiced explicit concern about the potential for money laundering through couriers or bulk purchase of lottery tickets. The Legislature abolished the Texas Lottery Commission, formally dissolved September 1, 2025, and former executive director Gary Grief was indicted in 2026 on a felony abuse-of-official-capacity charge, with the defunct Commission itself also indicted. This finding is held at Probable confidence: the money-laundering characterization derives from legislator statements reported in the press rather than a primary regulatory finding, even though the abolition and indictment themselves are independently corroborated.
Cross-Monitor Connections
The virtual-currency-kiosk licensing regime connects directly to the world-payments monitor's W1a (Licensing, Authorisation & Market Access) coverage of the same Chapter 161 development, and to the crypto monitor's crypto_licensing and consumer_protection modules, which read the identical statutory text for its digital-asset-market and consumer-disclosure implications rather than its AML-architecture implications. The lottery-abolition and indictment thread also intersects with advennt's gambling-regulatory coverage of the same Texas Lottery Commission events, though the money-laundering framing rendered here is specific to the financial-integrity lens on legislator statements about courier and bulk-purchase risk.
Outlook
The Finance Commission of Texas has not yet finalized implementing rules for Chapter 161's kiosk registration and blockchain-analytics standards; these are expected around 2026-Q4 and, once adopted, will convert the statute's framework-level analytics and antifraud requirements into concrete tooling and reporting-format obligations. The next cycle should also watch for any further primary-source documentation of the Lottery Commission successor-governance mechanics under TDLR, which remain under-documented at the T1 tier despite the significance of the abolition itself.
28 Aug 2026 · fim-2026-08-21
Lead Signal
OFAC has designated two Mexican nationals and nine entities linked to Cartel Jalisco Nueva Generacion fuel-smuggling and tax-evasion schemes, an action paired with a FinCEN supplemental alert issued in coordination with the South Texas Homeland Security Task Force. Fiscal fuel theft, known regionally as huachicoleo, has become the largest non-narcotics illicit-revenue stream for Mexican cartels, laundered through falsified customs documentation and cross-border tanker and rail movement directly into South Texas. The joint OFAC-FinCEN posture, explicitly naming a South Texas task force as a partner, signals that border fuel-theft laundering is now treated as a standing cross-border architecture rather than a series of unconnected incidents, with direct relevance to banks, trade-finance desks and correspondent-banking relationships operating along the Texas-Mexico corridor.
This finding is assessed as high confidence and grounded in a primary FinCEN release. It arrives alongside a second, independently significant development: a joint Texas Department of Banking and Colorado Division of Banking consent order against a licensed money transmitter for anti-money-laundering program deficiencies, including allegedly late currency-transaction and cross-border-currency reporting and inadequate agent monitoring, resolved with a 200,000 dollar penalty and an independent compliance monitor without admission of wrongdoing. The pairing of a federal sanctions action with a state-level AML consent order in the same reporting cycle illustrates the three-pillar balance this monitor tracks: the CJNG action is squarely a sanctions-evasion and CTF architecture matter, while the joint consent order is a domestic AML program-adequacy finding, and both bear on the same underlying exposure along a border state structurally positioned to intermediate illicit value movement.
Other Developments
A federal rollback of beneficial-ownership transparency arrived via a FinCEN final rule, effective August 14, 2026, permanently ending Corporate Transparency Act beneficial-ownership-information reporting for United States companies and United States persons, retaining reporting only for the foreign beneficial owners of foreign reporting companies, and providing for deletion of previously filed US-person beneficial-ownership data. No Texas-specific variance from this federal posture was identified this cycle, meaning Texas-registered entities are subject to the same national rollback affecting the rest of the country, without any offsetting state-level beneficial-ownership regime identified to fill the resulting transparency gap.
A new state-level virtual-currency-kiosk regime took shape in Texas Finance Code Chapter 161, created by SB 1705 and effective September 1, 2025, requiring kiosk operators to register with the Texas Department of Banking, deploy blockchain-analytics and anti-fraud policies, cap daily transactions at 3,000 dollars, impose a 72-hour hold on first-time customers, and respond to law-enforcement information requests within 72 hours. The statute is explicitly aimed at elder-fraud and money-laundering typologies associated with kiosk-based cash-to-crypto conversion.
Securities enforcement against a fraudulent crypto-mining investment scheme came from the Texas State Securities Board, which issued an emergency cease-and-desist order against TEXITcoin, MineTXC, Blockchain Mint and their founder for the fraudulent offer and sale of cryptocurrency-mining investment packages to Texas residents.
Unlicensed and non-compliant money-transmission enforcement continued through Texas Department of Banking consent orders against Brotherhood Works, LLC, for conducting money transmission without a license, and against SeedTrust, LLC, for related Chapter 152 violations, each carrying an administrative penalty.
Cross-Monitor Connections
The Texas Department of Banking enforcement against a licensed money transmitter, together with the Brotherhood Works and SeedTrust consent orders, sits directly alongside the World Payments Monitor licensing and market-access tracking of the same statute and, in the first case, the same underlying entity; where the World Payments Monitor reads these actions as licensing-authorisation events, this monitor reads the identical facts as an AML/CTF program-adequacy finding. The Chapter 161 virtual-currency-kiosk regime is a shared substrate with the Crypto Monitor licensing and consumer-protection modules: the kiosk statute blockchain-analytics mandate, transaction cap and customer hold are, from this monitor vantage, AML/CTF and financial-innovation controls responding to elder-fraud and layering typologies, even as the Crypto Monitor treats the same statute primarily as a market-structure and consumer-protection development. Neither reading displaces the other; the same legislative and enforcement record supports both an illicit-finance lens and a market-structure lens without duplication of underlying fact-finding.
Outlook
The compensatory state-supervisory posture adopted by Texas is likely to remain the dominant AML/CTF signal for this jurisdiction while the federal beneficial-ownership architecture continues to unwind. FinCEN proposed reform of BSA AML/CFT program requirements toward a risk-based, outcomes-focused standard, expected around the first quarter of 2027, would touch Texas-licensed money-services businesses directly if finalised, and is a horizon item worth tracking alongside continuing Department of Banking examination activity, including the multistate coordination pattern evidenced by the joint Texas-Colorado order. Internationally, Cambodia exposure to a third FATF grey-listing amid scam-centre and casino money-laundering concerns remains an assessed-confidence watch item with no confirmed plenary action yet, illustrating the enforcement-versus-enablement divergence this monitor tracks across jurisdictions even where no direct Texas nexus is established this cycle. Continued monitoring will also track whether any state-level substitute for the CTA rollback emerges, given the absence of a comparable Texas beneficial-ownership disclosure regime identified to date.
11 Aug 2026 · fim-2026-08-05
Lead Signal
The clearest signal this cycle is a bifurcated sanctions posture at OFAC: on 24 June 2026 the agency removed seven individuals and two Turkish intermediary entities from the Specially Designated Nationals list, following a similar mass removal on 28 May 2026, while the underlying Russia sanctions architecture under EO 14024 remains fully in force and OFAC simultaneously escalated designations against casino- and scam-linked laundering infrastructure. On 6 March 2026, OFAC designated the Bolai/Brilliancy Sihanoukville Investment and Development network under EO 14390 for laundering at least USD 73 million in victim funds through US-linked accounts, coordinated with the Department of Justice's Scam Center Strike Force. This calibrated posture, assessed at Assessed confidence, indicates a strategy of narrowing accumulation on lapsed-grounds individual designations while intensifying enforcement on high-severity laundering nodes, rather than a broad recalibration of the sanctions program itself.
Other Developments
The EU's AML Package reaches a structural inflection point. On 10 July 2026, the sixth Anti-Money Laundering Directive's core beneficial-ownership register provisions (Articles 11 to 13 and 15) and the Anti-Money Laundering Authority's package of 23 regulatory and implementing technical standards both fell due, a full year ahead of the AML Regulation's 10 July 2027 full direct-applicability date. Eleven member states remain in open infringement proceedings over the earlier 2025 register-access deadline, meaning the beneficial-ownership supervisory perimeter will remain uneven even as the technical-standards architecture matures.
Laos's Golden Triangle Special Economic Zone persists as an enabler-jurisdiction enclave. The Kings Romans-anchored zone continues to operate under a 99-year Lao concession to Zhao Wei's Magnitsky-sanctioned network, co-locating casino, crypto-exchange, and underground-banking activity outside effective state policing.
The United Kingdom's failure-to-prevent-fraud offence is now operative. The Economic Crime and Corporate Transparency Act 2023's corporate offence took effect on 1 September 2025, with Home Office guidance built on six Bribery-Act-style principles; it is a distinct, non-replacing overlay on the Money Laundering Regulations 2017 for large UK and foreign organisations with a UK nexus.
Colombia receives an unprecedented counternarcotics designation. The FY2026 Presidential Foreign Relations Authorization Act determination named Colombia as having failed demonstrably to meet its counternarcotics obligations, citing record coca cultivation, the first such finding in nearly thirty years, though sanctions were waived on national-interest grounds.
FinCEN and OFAC widen enforcement against Mexico-based gambling establishments. Ten gambling establishments and their leadership were found to be of primary money-laundering concern in connection with Sinaloa Cartel laundering, coordinated with the Government of Mexico, identifying gambling as a trade-based money-laundering channel for narcotics proceeds. A related June 2026 FinCEN supplemental alert extended prior cross-border money-laundering-network typologies to fuel-smuggling and tax-evasion activity tied to the CJNG.
Treasury advances stablecoin AML/CFT rulemaking. A proposed rule published 10 April 2026 sets AML/CFT and sanctions-compliance program requirements for GENIUS Act Permitted Payment Stablecoin Issuers, closing a structural gap between the Act's federal floor and existing Bank Secrecy Act obligations; the comment period closed 9 June 2026. Separately, Chainalysis reported USD 158 billion in illicit crypto flows in 2025, a 145 percent year-on-year increase.
Cross-Monitor Connections
The Cambodia and Laos enabler-jurisdiction findings sit squarely at the intersection of this monitor's sanctions and enabler-jurisdiction pillars and a state-capture reading: both jurisdictions illustrate weak or ceded state oversight converting casino and crypto infrastructure into laundering platforms rather than active state direction of the laundering itself. The Colombia and Mexico developments connect directly to conflict- and narco-finance monitoring of the Andean-Caribbean and Mexican corridors, where gambling and trade-finance channels are being used to launder narcotics proceeds. The GENIUS Act stablecoin rulemaking and the Chainalysis illicit-flows data point together toward a widening digital-asset risk-vector picture that intersects with sanctions-evasion monitoring wherever mixers, DeFi protocols, or self-hosted wallets are used to obscure counterparty exposure.
Outlook
Watch the AMLA technical-standards package's submission to the European Commission and the continuing infringement proceedings against the eleven-member-state cohort as the near-term test of whether the EU's beneficial-ownership supervisory perimeter closes the gap ahead of the AML Regulation's 2027 application date. On the US side, the GENIUS Act's state-certification review and the stablecoin AML/CFT final rule are the developments most likely to reshape the digital-asset compliance perimeter this year. Colombia's designation, though sanctions-waived on national-interest grounds, elevates counterparty-risk scrutiny for Colombia-exposed firms and is worth tracking for whether the waiver posture persists into the next review cycle. Southeast Asian casino-linked laundering enclaves in Cambodia and Laos remain the most acute enabler-jurisdiction risk surfaced this cycle and warrant continued monitoring for further designations or a possible additional FATF grey-list placement.