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 — Michigan US-MI

Domains (D1–D6)
2
Sources
9
Role actions
8
Horizon <90d
1
Jurisdiction profile
CompliantTier BRisk: StableMixed

Michigan operates entirely within the federal BSA/AML, OFAC-sanctions and FinCEN CTA architecture; the state layer consists of Department of Licensing and Regulatory Affairs (LARA) corporate formation (no beneficial-ownership verification), DIFS licensing of money transmitters under the Uniform Money Services Act, and Attorney General consumer-protection alerts on crypto fraud.

MoreNo independent state FIU exists; Michigan financial institutions rely wholly on federal supervisory and enforcement infrastructure.

Key deficiencies
  • No state-level beneficial ownership verification at LARA business-entity formation
  • Federal CTA's March 2025 interim final rule exempts domestic reporting companies from BOI reporting, leaving Michigan-formed LLCs/corporations effectively unverified at both state and federal levels
  • Cash-intensive licensed cannabis sector (Michigan Regulation and Taxation of Marihuana Act) remains structurally underbanked absent federal Schedule I reform
  • No dedicated Michigan state financial-intelligence unit; state-specific enforcement visibility is incidental to national DOJ/FinCEN reporting
  • Diaspora remittance corridors (Somali, Yemeni and other immigrant communities) present persistent unlicensed money-transmission risk absent robust state MSB supervision capacity
Recent developments (18m)
  • Michigan physician sentenced to four years and ordered to pay restitution for $6.3M Medicare fraud scheme with money-laundering nexus (DOJ, June 26, 2025)
  • DOJ's largest-ever National Health Care Fraud Takedown (324 defendants, $14.6B, 50 federal districts) reshaping the enforcement environment in which Michigan-based providers and financial institutions operate (June 30, 2025)
  • FinCEN's March 2025 interim final rule narrowing Corporate Transparency Act BOI reporting to foreign reporting companies only, materially reducing beneficial-ownership visibility into Michigan-formed entities
  • FinCEN Health Care Fraud Advisory (March 2026) citing the Michigan physician case as an evidentiary typology exemplar for financial institutions nationwide
  • FinCEN proposed rule to refocus AML/CFT program requirements on effectiveness rather than technical compliance (NPRM, April 2026), applicable to all Michigan-chartered and federally regulated financial institutions

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

Brief

Lead signal

Lead Signal

Read full brief

Lead Signal

Michigan this cycle presents a partial picture concentrated in two threads: a state-level enforcement and litigation conflict touching crypto-adjacent prediction markets, and a pending legislative overhaul of the state money-transmission regime. A Michigan state court issued a preliminary injunction against KalshiEx LLC, with geofencing and a 500,000-dollar-per-day penalty, over sports-event contracts the state alleges constitute unlicensed gambling under the Lawful Sports Betting Act, Public Act 149 of 2019. The platform operates via a partnership that includes Coinbase Financial Markets Inc., which has separately and preemptively sued the State of Michigan in federal court, a suit that continues. Read together, this is less a single enforcement incident than a jurisdictional boundary dispute: a state gambling-law perimeter colliding with a financial-innovation product whose architecture sits adjacent to, but is not itself, a crypto-asset custody or exchange function.

In parallel, House Bill 5544, the Money Transmission Modernization Act, continues to move through the Michigan Legislature. It passed the House 97-10 on 25 June 2026 and was referred to the Senate Committee on Finance, Insurance, and Consumer Protection on 1 July 2026, with no further action recorded as of this cycle. The bill would repeal the 2006 Money Transmission Services Act (MCL 487.1001-487.1047) in its entirety and replace it with a regime based on the Conference of State Bank Supervisors model law, including a virtual-currency exclusion clause for non-custodial, non-exchange activity. This is a structural development: it would re-architect the statutory basis on which every money transmitter, including crypto-asset operators conducting transmission-adjacent activity, is licensed in the state.

Other Developments

The standing AML architecture is unchanged. Michigan's financial-integrity baseline remains state money-transmitter licensing administered by the Department of Insurance and Financial Services under the 2006 Money Transmission Services Act, layered beneath the federal Bank Secrecy Act and FinCEN money-services-business registration, with attendant SAR and CTR filing obligations. DIFS guidance continues to warn that failure to renew a license in a timely manner may prevent a firm from conducting money transmission in the state. No change to this layered architecture was found this cycle beyond the pending status of HB 5544 itself.

The Kalshi and Coinbase matters remain unresolved. The preliminary injunction against KalshiEx is a court order, not a final judgment, and the Coinbase Financial Markets federal preemption suit is ongoing. Coverage available this cycle is press reporting rather than a primary court-docket record, and the research notes record this gap explicitly rather than treating the press account as a substitute for the underlying filing.

Cross-Monitor Connections

The Kalshi and Coinbase Financial Markets matters sit at the boundary between financial-integrity typology and the digital-asset and financial-innovation tracking more properly housed in a crypto-focused monitor; the financial-integrity angle here is the state-versus-federal licensing and preemption contest, not the underlying asset-class mechanics. The HB 5544 legislative thread connects to the standing Crypto and Digital-Asset Integrity tracker (T5 on the fleet-wide spine), since the bill's virtual-currency exclusion clause would determine, prospectively, which crypto-adjacent money-transmission activity falls inside or outside the state licensing perimeter. Neither thread this cycle produced a sanctions, beneficial-ownership, enabler-jurisdiction, or conflict-finance finding, and those domains were not actively re-swept given the search budget committed to the bound jurisdiction.

Outlook

The Kalshi injunction and the Coinbase preemption suit are both live and procedurally unresolved as at this cycle; whether the state's gambling-law theory or the federal preemption argument prevails will determine, for Michigan at least, whether prediction-market products distributed through a partner with crypto-exchange affiliations are treated as licensed gambling, as money transmission, or as neither. HB 5544 had not been enacted as of this cycle and remained before the Senate Committee on Finance, Insurance, and Consumer Protection; whether it proceeds un-amended, is amended to narrow or broaden the virtual-currency exclusion, or stalls, is not yet determinable from the record available this cycle. Michigan's underlying AML architecture is unaffected by either thread unless and until HB 5544 is enacted.

weekly_brief_draft · JID US-MI
Domain intelligence (D1–D6)

D1 Sanctions

Not covered

Sanctions is not yet covered for this jurisdiction in this report.

D2 Beneficial Ownership

Not covered

Beneficial Ownership is not yet covered for this jurisdiction in this report.

D3 Enabler Jurisdictions

Not covered

Enabler Jurisdictions is not yet covered for this jurisdiction in this report.

D4 Conflict Finance

Not covered

Conflict Finance is not yet covered for this jurisdiction in this report.

D5 Crypto, Digital Assets, and Financial Innovation

Crypto, Digital Assets, and Financial Innovation

Continue reading

In Michigan, the digital-asset signal this cycle runs through a litigation thread rather than a crypto-native regulatory action. A Michigan state court issued a preliminary injunction against KalshiEx LLC, with geofencing requirements and a penalty of 500,000 dollars per day, over sports-event contracts that the state alleges amount to unlicensed gambling under the Lawful Sports Betting Act, Public Act 149 of 2019. KalshiEx operates in partnership with Coinbase Financial Markets Inc., and it is that partnership, not the underlying sports-event contract product itself, that gives this matter its crypto-adjacency. Coinbase Financial Markets has, separately and preemptively, sued the State of Michigan in federal court; that suit continues. The structural question the pairing raises is one of characterisation: whether a prediction-market product distributed in partnership with a regulated crypto-asset entity is a gambling product subject to state licensing, a money-transmission or derivatives product subject to a different regulatory lens, or something the existing statutory categories in Michigan do not cleanly capture. No primary court-docket record was retrieved this cycle; the available substrate is press reporting of the injunction and of the Coinbase filing, and that limitation is recorded rather than papered over.

The second, and structurally more durable, D5-relevant thread is House Bill 5544, the Money Transmission Modernization Act. The bill passed the Michigan House 97-10 on 25 June 2026 and was referred to the Senate Committee on Finance, Insurance, and Consumer Protection on 1 July 2026, with no further Senate action recorded as of this cycle. It would repeal the 2006 Money Transmission Services Act, MCL 487.1001 through 487.1047, and replace it with a licensing, bonding, and reporting regime built on the Conference of State Bank Supervisors model law. Material to the digital-asset lens, the bill carries a virtual-currency exclusion clause that would carve non-custodial, non-exchange virtual-currency activity out of the state money-transmission licensing perimeter. This is the kind of provision that determines, at a structural level, which crypto-asset business models require a Michigan money-transmitter license and which do not; it is architecture, not incident, and its eventual final text will matter more to the state's crypto-asset perimeter than any single enforcement action.

Taken together, the two threads illustrate a jurisdiction where crypto-adjacent financial innovation is being tested against two different regulatory frames at once: an established gambling-law frame being applied to a prediction-market product with a crypto-exchange partner, and a money-transmission licensing frame that is itself mid-rewrite and explicitly contemplates carving out certain virtual-currency activity. Michigan has not, this cycle, taken a crypto-native enforcement action in the conventional sense; what it has done is apply an adjacent statute to a crypto-adjacent product while leaving the money-transmission statute that would otherwise govern many such products in legislative limbo.

Outlook

Both threads remain open. The preliminary injunction against KalshiEx is interlocutory, not a final ruling, and the Coinbase Financial Markets preemption suit in federal court was ongoing as at this cycle; which theory prevails, state gambling law or federal preemption, will determine whether this category of product is treated in Michigan as licensed gambling, as a financial-innovation product falling outside that frame, or as something requiring a new statutory answer. HB 5544 had not been enacted as of this cycle and sat before the Senate Finance, Insurance, and Consumer Protection Committee; whether its virtual-currency exclusion clause survives Senate consideration intact, is narrowed, or is broadened will shape the money-transmission licensing exposure of crypto-asset operators in the state going forward. Neither outcome can be read from the record available this cycle, and no inference beyond what is stated here should be drawn from the pending status of either matter.

D6 Compliance Technology & Active Defence

Not covered

Compliance Technology & Active Defence is not yet covered for this jurisdiction in this report.

D7 AML/CTF Regime

AML/CTF Regime

Continue reading

Michigan's AML/CTF regime sits, structurally, on two layers that remained unchanged this cycle in their current form, with one of those layers now mid-overhaul through pending legislation. The operative layer is state money-transmitter licensing, administered by the Department of Insurance and Financial Services under the 2006 Money Transmission Services Act, MCL 487.1001 through 487.1047. DIFS guidance continues to warn licensees that failure to renew in a timely manner may prevent a firm from conducting money transmission in the state, underscoring that licensing currency, not merely initial authorisation, is the operative control point. Beneath that state layer sits the federal Bank Secrecy Act framework: money-services-business registration with FinCEN, and the associated Suspicious Activity Report and Currency Transaction Report filing obligations that apply regardless of state licensing status. No change to this two-layer architecture was identified this cycle.

What has changed, in status if not yet in effect, is the statutory basis for the state layer. House Bill 5544, the Money Transmission Modernization Act, passed the Michigan House of Representatives 97-10 on 25 June 2026 and was referred to the Senate Committee on Finance, Insurance, and Consumer Protection on 1 July 2026. As of this cycle, no further Senate action had been recorded. The bill would repeal the 2006 Act in full and replace it with a licensing, bonding, and reporting regime based on the Conference of State Bank Supervisors model law, a template that a number of other states have adopted or are adopting in parallel. This is a structural development rather than an incident: it concerns the architecture a licensee must comply with, not a single enforcement episode, and the ratified designation language for FATF grey-list, EU high-risk, or sanctions status has no application here, since this is sub-national licensing modernisation, not a mutual-evaluation or sanctions-list action.

The AML/CTF significance of HB 5544 is primarily structural and prospective. Replacing a 2006-vintage, bespoke state statute with a model-law-based regime tends to standardise licensing, bonding, and examination practice across states that adopt the same template, which has downstream implications for how multi-state money-services businesses structure their compliance programs. The bill's virtual-currency exclusion clause is the most consequential single provision from an AML-architecture perspective, since it defines the boundary of what counts as money transmission subject to the state's licensing and, by extension, its state-level compliance expectations, for virtual-currency activity that is non-custodial and non-exchange in nature. Until the bill is enacted, however, the 2006 Act remains the operative instrument, and DIFS examination and licensing practice under it continues on its existing basis.

Outlook

HB 5544 had not been enacted as of this cycle and remained before the Senate Committee on Finance, Insurance, and Consumer Protection, with no further action recorded beyond the 1 July 2026 referral. Whether the bill advances un-amended, is amended, or stalls in committee will determine whether Michigan's money-transmission licensing regime converts to the CSBS model-law basis and, with it, how the virtual-currency exclusion clause is ultimately drawn. Until enactment, the existing two-layer structure, state MTL licensing under the 2006 Act beneath the federal BSA/FinCEN framework, remains the governing architecture, and no change to SAR, CTR, or registration obligations under that existing structure was identified this cycle.

D8 Commercial Activity

Not covered

Commercial Activity is not yet covered for this jurisdiction in this report.

Regulatory horizon
Proposed2027-Q3 · ±year

Money Transmission Modernization Act (HB 5544)

Replacement of the 2006 Money Transmission Services Act with a CSBS-model-law-based licensing, bonding and reporting regime for money transmitters, including a virtual-currency exclusion clause.
Source
1 dated · 3 pending date · baseline fim-2026-07-05
Role action cards
MLRO

Michigan money-transmission licensing architecture (DIFS MTL plus federal BSA/FinCEN layer) is unchanged, while HB 5544 would replace its statutory basis.

The current SAR, CTR, and MSB-registration obligations continue on their existing basis under the 2006 Money Transmission Services Act. Enactment of HB 5544 would not take effect on the timeline visible this cycle, so no immediate filing-threshold change is indicated, but the bill is a structural development worth tracking given its CSBS model-law basis and virtual-currency exclusion clause.

2 evidence refs
Compliance

HB 5544 continues through the Michigan Senate and would repeal and replace the 2006 Money Transmission Services Act with a CSBS model-law-based regime.

A firm licensed as a money transmitter in Michigan should track this bill's progress, since the replacement regime and its virtual-currency exclusion clause would alter the licensing basis for crypto-adjacent money-services activity if enacted. The existing 2006 Act and DIFS licensing renewal practice remain the operative control framework in the interim.

2 evidence refs
Legal

A Michigan state court injunction against KalshiEx and a parallel federal preemption suit by Coinbase Financial Markets raise an unresolved state-versus-federal characterisation question for crypto-adjacent prediction-market products.

Both the state gambling-law theory underlying the KalshiEx injunction and the federal preemption theory underlying the Coinbase Financial Markets suit were unresolved as at this cycle. Only press reporting of the filings and order was available; no primary court-docket record was retrieved, which should be noted when assessing litigation exposure for similarly structured products distributed in partnership with a crypto-asset entity.

3 evidence refs
Board

Michigan is mid-overhaul on its money-transmission statute while simultaneously litigating the boundary between gambling law and crypto-adjacent financial innovation.

These are two distinct structural threads rather than a single incident: a pending legislative rewrite of the licensing basis for money transmitters, and an unresolved court dispute over how a prediction-market product with a crypto-exchange partner should be characterised under existing gambling law. Neither has reached a final resolution as at this cycle.

3 evidence refs
CTO

Pending Michigan legislation (HB 5544) carries a virtual-currency exclusion clause that would define which crypto-asset activity falls inside state money-transmission licensing.

The eventual scope of the exclusion clause has direct architectural implications for which crypto-asset business models require state money-transmitter licensure in Michigan, separate from the unresolved KalshiEx/Coinbase Financial Markets litigation, which concerns a different statutory frame (gambling law) rather than money-transmission licensing itself.

1 evidence refs
Risk

Two concurrent, unresolved Michigan threads, a licensing-statute rewrite and a gambling-law-versus-preemption dispute, both bear on exposure for crypto-adjacent financial-innovation products.

Concentration risk exists for any firm whose Michigan business model depends on either the current money-transmission statute remaining in force unchanged or on the KalshiEx/Coinbase Financial Markets characterisation questions resolving in a particular direction; neither outcome is yet determinable.

3 evidence refs
Operations

No change to current Michigan money-transmission licensing or filing thresholds this cycle.

DIFS licensing renewal and federal BSA/FinCEN SAR/CTR filing obligations continue under the existing 2006 Money Transmission Services Act basis; no operational threshold or workflow change is indicated by HB 5544 at this stage, since the bill remained unenacted as at this cycle.

1 evidence refs
Audit

DIFS guidance continues to flag licence-renewal timeliness as a control point for continued money-transmission authority in Michigan.

Audit scope for Michigan-licensed money transmitters should continue to test licence renewal timeliness against DIFS requirements under the current statute; no additional control-testing scope is indicated by HB 5544 pending its enactment.

1 evidence refs
Decision lens
MLRO

Michigan money-transmission licensing architecture (DIFS MTL plus federal BSA/FinCEN layer) is unchanged, while HB 5544 would replace its statutory basis.

Compliance

HB 5544 continues through the Michigan Senate and would repeal and replace the 2006 Money Transmission Services Act with a CSBS model-law-based regime.

Legal

A Michigan state court injunction against KalshiEx and a parallel federal preemption suit by Coinbase Financial Markets raise an unresolved state-versus-federal characterisation question for crypto-adjacent prediction-market products.

Board

Michigan is mid-overhaul on its money-transmission statute while simultaneously litigating the boundary between gambling law and crypto-adjacent financial innovation.

CTO

Pending Michigan legislation (HB 5544) carries a virtual-currency exclusion clause that would define which crypto-asset activity falls inside state money-transmission licensing.

Risk

Two concurrent, unresolved Michigan threads, a licensing-statute rewrite and a gambling-law-versus-preemption dispute, both bear on exposure for crypto-adjacent financial-innovation products.

Operations

No change to current Michigan money-transmission licensing or filing thresholds this cycle.

Audit

DIFS guidance continues to flag licence-renewal timeliness as a control point for continued money-transmission authority in Michigan.

Shared evidence: 4 refs
Scenario sketches

Illustrative pathway: state money-transmission modernization and virtual-currency perimeter drift

As an illustrative orientation only, consider how a state-level transition from a bespoke 2006-vintage money transmission statute to a CSBS model-law-based regime, as contemplated by pending Michigan legislation, could in principle interact with the virtual-currency exclusion clause such a bill carries. If the exclusion is drawn narrowly, non-custodial and non-exchange virtual-currency activity could still fall inside the licensing perimeter depending on how a given business model is structured; if drawn broadly, a wider range of crypto-adjacent activity could sit outside state money-transmission licensing while remaining subject only to the federal BSA/FinCEN layer. This is architecture-level illustration of a possible structural mechanism, not an observed fact or a prediction of how the pending bill will ultimately be drawn or enacted.

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

Illustrative scenario: EU AML Package / AMLA supervisory transition structural mechanism

As a standing illustrative orientation, consider how the ongoing transition from purely national AML supervision toward AMLA direct and indirect supervision of cross-border obliged entities, under the AMLA Regulation (Reg (EU) 2024/1620), alongside the directly applicable AML Regulation (Reg (EU) 2024/1624) and per-state sixth AML Directive transposition, could in principle reshape the supervisory and evasion landscape for cross-border entities over time. This is architecture-over-incident illustration of a possible structural mechanism operating at EU level; it is not a prediction and not an observed fact, and it is not specific to Michigan, which sits outside the EU AML Package perimeter entirely.

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 material change surfaced this cycle; not actively re-swept.
T2 · EU AML Package / AMLAno_changeNo material change surfaced this cycle; not actively re-swept.
T3 · FATF Grey Listno_changeNo material change surfaced this cycle; not actively re-swept.
T4 · Beneficial-Ownership Register Statusno_changeNo material change surfaced this cycle.
T5 · Crypto & Digital-Asset IntegritywatchUS-MI's HB 5544 continues through the Senate; would bring crypto exchange/custody activity within the state MSB licensing perimeter via the CSBS model law's virtual-currency provisions.
T6 · Sanctions Regime Divergenceno_changeNo material change surfaced this cycle.
Registers

Enforcement actions

  • A Michigan doctor was sentenced to four years in federal prison for orchestrating a $6.3 million Medicare fraud scheme, part of the broader national health-care fraud enforcement push cited in FinCEN's 2026 Health Care Fraud Advisory as a typology exemplar involving money-laundering conduct. 26 Jun 2025
  • DOJ's largest-ever National Health Care Fraud Takedown charged 324 defendants across 50 federal districts and 12 state Attorneys General's offices for schemes involving more than $14.6 billion in intended losses, with a renewed emphasis on convergence of health-care fraud and modern laundering techniques including cryptocurrency — directly shaping the enforcement and BSA-reporting environment for Michigan-based providers and financial institutions. 30 Jun 2025
  • FinCEN issued an Advisory urging financial institutions to be vigilant about health-care fraud schemes targeting Medicare, Medicaid and other federal/state health benefit programs, explicitly citing the Michigan physician's $6.3M scheme as an evidentiary typology, and directing enhanced SAR filing on associated laundering red flags. 25 Mar 2026

Sanctions changes

  • US Departments of Treasury and State designated eight organizations, including six major Mexico-based drug cartels, as Foreign Terrorist Organizations and Specially Designated Global Terrorists, imposing new BSA/OFAC screening obligations on all US financial institutions, including Michigan-based banks and MSBs handling cross-border remittance and trade-finance flows. 20 Feb 2025
  • On December 18, 2025, OFAC removed the remaining name from the Foreign Sanctions Evaders (FSE) list under E.O. 13608 (Iran/Syria-related), fully clearing that list — a national-level change affecting due-diligence screening obligations for all US financial institutions, including those in Michigan with Iran-adjacent trade-finance exposure. 18 Dec 2025
  • OFAC issued Russia-related General License 134C, authorizing the delivery and sale of Russian-origin crude oil and petroleum products loaded on vessels as of April 17, 2026 — a licensing carve-out relevant to Michigan-based energy, logistics and trading firms handling permitted transactions. 18 May 2026

Regulatory horizon (register)

  • FinCEN AML/CFT program effectiveness-based reform finalization
  • GENIUS Act stablecoin implementing regulations enter into force
  • Next FATF Plenary review cycle bearing on US follow-up status

Active schemes

  • [HIGH] Pig-butchering crypto investment fraud targeting Michigan residents
  • Unlicensed MSB remittance channels serving Michigan diaspora corridors
  • Dual-use technology diversion risk via Michigan manufacturing supply chains
  • [HIGH] Health-care fraud proceeds layering through Michigan-linked shell accounts
Sources
  1. FinCEN (US Department of the Treasury)
  2. FinCEN (US Department of the Treasury)
  3. TRM Labs
  4. FinCEN (US Department of the Treasury)
  5. Office of Foreign Assets Control (OFAC)
  6. Office of Foreign Assets Control (OFAC)
  7. US Department of the Treasury
  8. Financial Action Task Force (FATF)
  9. International Consortium of Investigative Journalists (ICIJ)
Coverage gaps
Michigan has no state-level beneficial-ownership verificatio…
Michigan has no state-level beneficial-ownership verification at LARA business-entity formation. FinCEN's March 2025 interim final rule exempting all domestic reporting companies from Corporate Transparency Act BOI reporting means Michigan-formed LLCs and corporations now face no beneficial-ownership disclosure requirement at either the state or federal level, absent a foreign nexus.
Michigan's licensed cannabis industry (recreational and medi…
Michigan's licensed cannabis industry (recreational and medical, under the Michigan Regulation and Taxation of Marihuana Act) remains largely unbanked and cash-intensive because federal Schedule I status continues to deter depository institutions from providing banking services, absent SAFE Banking Act passage.
Michigan operates no dedicated state financial-intelligence …
Michigan operates no dedicated state financial-intelligence unit; nearly all Michigan-specific financial-crime enforcement visibility in the current window derives incidentally from national DOJ/FinCEN releases (e.g., citation of Michigan cases in national health-care-fraud or crypto-scam advisories) rather than from a standalone Michigan reporting channel.

Evidence

Confidence-tiered claims

Michigan state court issued a preliminary injunction against KalshiEx LLC, with geofencing and a $500,000-per-day penalty, over sports-event contracts alleged to be unlicensed gambling. SRC-fim-US-MI-004
Probable · 1 source
Coinbase Financial Markets Inc., which partners with Kalshi, preemptively sued the State of Michigan in federal court; the suit continues. SRC-fim-US-MI-005
Probable · 1 source
Passed Michigan House 97-10 on 2026-06-25 and referred to Senate Committee on Finance, Insurance, and Consumer Protection on 2026-07-01; would repeal the 2006 Money Transmission Services Act (MCL 487.1001-487.1047) and replace it with a CSBS model-law-based Money Transmission Modernization Act, with a virtual-currency exclusion clause for non-custodial/non-exchange activity. SRC-fim-US-MI-001
Probable · 1 source
Michigan's AML architecture remains state money-transmitter licensing under DIFS (Money Transmission Services Act, MCL 487.1001 et seq.), layered under the federal BSA/FinCEN MSB-registration regime (Form 107, CTR/SAR filing); no change found this cycle beyond pending HB 5544 status. SRC-fim-US-MI-003
Probable · 1 source
Public Act 149 of 2019 remains the statutory basis for licensed sports betting in Michigan, cited in the Kalshi litigation as the standard allegedly violated by unlicensed sports-event contracts. SRC-fim-US-MI-004
Probable · 1 source