Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved.

Financial Integrity Monitor

United States — New Hampshire US-NH

Domains (D1–D6)
1
Sources
7
Role actions
8
Jurisdiction profile
Largely CompliantTier BRisk: IncreasingMixed

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

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

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

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

Brief

Lead signal

Lead Signal

Read full brief

Lead Signal

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

Other Developments

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

Cross-Monitor Connections

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

Outlook

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

weekly_brief_draft · JID US-NH
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 / Financial Innovation

Not covered

Crypto / Digital Assets / Financial Innovation is not yet covered for this jurisdiction in this report.

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

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

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

Outlook

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

D8 Commercial Activity

Not covered

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

Regulatory horizon
No dated horizon items this cycle. 3 items tracked without a confirmed date.
3 pending date · baseline financial-integrity-2026-07-05
Role action cards
MLRO

FinCEN has proposed a fundamental reform of AML/CFT program requirements that would mandate CFT integration across bank, casino, and MSB programs.

Once finalised, the NPRM would reset minimum AML program-content standards affecting NH RSA 399-G-licensed money transmitters' BSA compliance plans; MLROs at affected entities should track the proposal's progress toward a final rule.

3 evidence refs
Compliance

No change to New Hampshire's own RSA 399-G AML/CFT baseline this period, but a federal NPRM would reset minimum program standards once finalised.

The RSA 399-G:17 BSA-compliance-plan requirement remains the governing NH-level obligation; compliance functions should monitor FinCEN's NPRM process rather than expect any imminent NH-level rule change.

3 evidence refs
Legal

No material change this cycle.

No material change for this persona this cycle

Board

A federal AML/CFT program-rule overhaul is in consultation and would affect regulated money-transmitter and gambling-operator licensees once finalised.

The Board should be aware of a structural federal reform in progress; it is not yet final and carries a year-level uncertainty band on timing.

1 evidence refs
CTO

No material change this cycle.

No material change for this persona this cycle

Risk

FinCEN's proposed BSA AML/CFT program-rule reform is a structural federal development with downstream effect on NH-licensed money transmitters.

Risk functions should flag the NPRM as a forward-looking structural change to minimum AML program standards, distinct from any NH-specific enforcement signal this period.

2 evidence refs
Operations

No material change this cycle.

No material change for this persona this cycle

Audit

The NH Banking Department's 2025 order to show cause against BAM Trading Services Inc. illustrates active controlling-person BSA/AML compliance enforcement under RSA 399-G.

Audit functions should note the standing enforcement record as context for testing the adequacy of BSA-compliance-plan documentation required under RSA 399-G:17.

2 evidence refs
Decision lens
MLRO

FinCEN has proposed a fundamental reform of AML/CFT program requirements that would mandate CFT integration across bank, casino, and MSB programs.

Compliance

No change to New Hampshire's own RSA 399-G AML/CFT baseline this period, but a federal NPRM would reset minimum program standards once finalised.

Legal

No material change this cycle.

Board

A federal AML/CFT program-rule overhaul is in consultation and would affect regulated money-transmitter and gambling-operator licensees once finalised.

CTO

No material change this cycle.

Risk

FinCEN's proposed BSA AML/CFT program-rule reform is a structural federal development with downstream effect on NH-licensed money transmitters.

Operations

No material change this cycle.

Audit

The NH Banking Department's 2025 order to show cause against BAM Trading Services Inc.

Shared evidence: 3 refs
Scenario sketches

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

Illustrative scenario for analytical orientation only: as the EU moves 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 AMLR (Reg (EU) 2024/1624) and per-state 6AMLD transposition, illicit actors could probe the seams between national and EU-level supervisory remits during the transition period, seeking jurisdictions or entity types where supervisory responsibility is momentarily unclear. This is architecture-over-incident illustration, not a prediction of any specific event, and has no direct bearing on New Hampshire's own non-EEA regulatory perimeter beyond the standing global structural backdrop.

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 ArchitecturestableNo material change identified in Russian sanctions-evasion architecture specific to US-NH this cycle.
T2 · EU AML Package / AMLAno_changeNot applicable to US-NH; not an EEA/UK jurisdiction.
T3 · FATF Grey Listno_changeNo change to US FATF standing this cycle; not directly applicable at the US-NH subnational level.
T4 · Beneficial-Ownership Register Statusno_changeNo NH-specific beneficial-ownership registry development identified this cycle.
T5 · Crypto & Digital-Asset IntegritystableNH's HB 639 node/mining/staking money-transmitter exemption remains the standing position; no new development this cycle.
T6 · Sanctions Regime Divergenceno_changeNo new US/EU/UK autonomous-listing divergence material identified this cycle bearing on US-NH.
Registers

Enforcement actions

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

Sanctions changes

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

Regulatory horizon (register)

  • GENIUS Act stablecoin implementing regulations finalization
  • NH Strategic Bitcoin Reserve treasury allocation build-out
  • Congressional Clarity Act crypto market-structure legislation outcome

Active schemes

  • [HIGH] Unlicensed bitcoin-kiosk laundering via church-front entities
  • [HIGH] Crypto-ATM cash-to-crypto elder-fraud conversion pipeline
Sources
  1. U.S. Department of the Treasury / Office of Foreign Assets Control
  2. Financial Crimes Enforcement Network (FinCEN)
  3. U.S. Department of the Treasury / Office of Foreign Assets Control
  4. TRM Labs
  5. International Consortium of Investigative Journalists (ICIJ)
  6. Chainalysis
  7. Bloomberg
Coverage gaps
Despite New Hampshire's landmark unlicensed-MSB prosecution …
Despite New Hampshire's landmark unlicensed-MSB prosecution (Ian Freeman), no newly-dated, NH-specific federal or state enforcement action was identified within the strict 18-month baseline window (Jan 2025–Jul 2026); available NH-nexus material consists predominantly of national-scope advisories/policy shifts with NH relevance rather than fresh state-specific actions.
New Hampshire has not enacted a crypto-ATM-specific consumer…
New Hampshire has not enacted a crypto-ATM-specific consumer-protection or fraud-prevention statute, unlike at least 18 U.S. states (including neighboring Massachusetts) that had done so by September 2025; this leaves the elder-fraud cash-to-crypto vector addressed only through general fraud/MSB law and federal advisories rather than kiosk-specific transaction limits or ID-verification mandates.
National IRS AML examiner capacity assigned to MSB/crypto-fi…
National IRS AML examiner capacity assigned to MSB/crypto-firm oversight fell 33 percent in FY2025, thinning the federal supervisory layer that NH — lacking its own dedicated crypto-AML examination unit — relies upon most heavily given its history as the situs of a major unlicensed-MSB laundering scheme.
New Hampshire, as a U.S. state, has no autonomous sanctions-…
New Hampshire, as a U.S. state, has no autonomous sanctions-designation authority; all sanctions listings/delistings applicable to NH-regulated entities flow uniformly from OFAC at the federal level. The sanctions_change_register above therefore reflects national OFAC actions applicable to NH via the state's standing OFAC/NH Banking Department information-sharing MOU rather than any NH-originated sanctions action.

Evidence

Confidence-tiered claims

The main NH law applicable to money transmitters is RSA 399-G SRC-fim-US-NH-001
Probable · 1 source
Licensees must create and implement plans to comply with the Bank Secrecy Act SRC-fim-US-NH-002
Probable · 1 source
A 'fundamental' reform of AML/CFT program requirements under the Bank Secrecy Act, covering banks, casinos/card clubs and MSBs SRC-fim-US-NH-003
Probable · 1 source
All AML programs would be required to include countering the financing of terrorism (CFT) SRC-fim-GLOBAL-001
Probable · 1 source
2025 order to show cause against BAM Trading Services Inc. tied to controlling-person BSA/AML compliance failures SRC-fim-US-NH-002
Probable · 1 source