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 — Washington State US-WA

Domains (D1–D6)

Sources

Role actions

Jurisdiction profile

CompliantTier BRisk: IncreasingMixed

Washington operates within the federal BSA/FinCEN AML/CFT/CPF architecture (US is a FATF member, not grey-listed).

State-level oversight runs through the WA Department of Financial Institutions (DFI) under the Uniform Money Services Act (RCW 19.230), covering money transmitters and virtual-currency businesses. No WA-specific AML enforcement action or MER event was identified in the 18-month window; risk instead flows from federal-level deregulatory shifts (BOI/CTA narrowing, IRS crypto-examiner cuts, OCC preemption of state chartering authority) that dilute DFI's practical supervisory reach over the state's dense crypto-ATM/VASP and global tech-corporate population.

Key deficiencies

No identified WA-specific AML/CFT enforcement action in the 18-month window despite the state hosting a significant VASP/crypto-ATM commercial base
Federal CTA/BOI interim final rule (March 2025) exempts domestic reporting companies from beneficial-ownership disclosure, removing the federal transparency backstop for WA-incorporated shell entities with no substitute state BO registry
OCC national trust charter preemption trend erodes WA DFI's practical supervisory authority over crypto firms that obtain federal charters
Federal IRS crypto-AML examiner staffing reductions (33% cut in 2025) shrink supervisory bandwidth over WA-domiciled money-services businesses

Recent developments (18m)

FinCEN Section 311 designation of Huione Group as a primary money-laundering concern (Oct 2025), binding on WA-domiciled BSA-covered institutions and VASPs
OFAC/DOJ sanctions and record $15bn forfeiture action against Prince Group TCO (Oct 2025), applicable to WA-based crypto exchanges' sanctions-screening obligations
OFAC designation of DPRK-linked Cheil Credit Bank crypto addresses (Nov 2025), relevant to WA tech-sector and crypto-ATM exposure to DPRK laundering typologies
CTA/BOI interim final rule (March 2025) exempting domestic reporting companies from federal beneficial-ownership disclosure

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

Brief

Lead signal

Lead Signal

Read full brief

Lead Signal

The defining development this cycle is structural rather than punitive: FinCEN finalized a rule, effective August 14, 2026, permanently exempting U.S. companies and U.S.-person beneficial owners from Corporate Transparency Act beneficial-ownership-information reporting, leaving only foreign registrants in scope. Treasury's own materials frame this as relief for small businesses, but the architecture consequence is that the domestic beneficial-ownership registry FinCEN built under the CTA is now effectively hollowed out for the U.S. entities that make up the overwhelming majority of the register. Previously submitted U.S.-person BOI is to be deleted. This is the most consequential domestic beneficial-ownership transparency reversal since the CTA's 2022 implementing rule, and it lands at a moment when FATF's own Recommendation 24 on beneficial ownership remains a live international benchmark against which the U.S. registry will now be measured with a materially narrower domestic scope.

Other Developments

Sanctions architecture continues to route through already-sanctioned and third-country nodes. OFAC re-designated VTB Bank Public Joint Stock Company on September 14, 2026, this time for facilitating Iranian sanctions evasion under Operation Economic Outcast, layered atop VTB's existing Russia-related SDN listing dating to February 2022. The same period saw FinCEN issue a notice of proposed rulemaking finding five UAE-based branches of Egypt's Banque Misr to be a primary money-laundering concern for facilitating sanctions evasion, consistent with the UAE's recurring role as a secondary-sanctions transit point. Conflict-finance enforcement reached the DRC gold trade. On June 25, 2026, OFAC designated Gasabo Gold Refinery Ltd, its chairman and managing director, and three affiliated Rwandan mining companies for refining and exporting an estimated sixty kilograms or more of gold smuggled from mines in eastern DRC controlled by M23 and supervised by the Rwanda Defence Force, implementing the December 2025 Washington Accords. FATF's grey list moved at the June Plenary. At the June 19, 2026 Plenary, FATF removed Algeria and Namibia from increased monitoring following successful on-site visits; secondary reporting indicates Bosnia and Herzegovina and Iraq were added, which would bring the list to twenty-two jurisdictions ahead of the October 2026 Plenary. The UK narrowed its enhanced-due-diligence trigger. From June 30, 2026, S.I. 2026/621 amended MLR 2017 regulation 33(1)(b) and (3)(a) so that mandatory enhanced due diligence applies only to a FATF call-for-action country; the UK no longer maintains a separate high-risk third-countries list, and FATF grey-list status is now a risk factor rather than a UK EDD trigger, a divergence from the EU's own twenty-six-country high-risk list. Digital-asset laundering of sanctioned oil proceeds was documented. Chainalysis's 2026 Crypto Crime Report traces more than one hundred million dollars tied to Iranian oil sales, brokered by an OFAC-designated individual, laundered through stablecoin purchases and decentralized-finance protocols and bridges between 2023 and 2025.

Cross-Monitor Connections

The Gasabo Gold Refinery designation connects directly to conflict-finance and commodity-flow monitoring: a documented mine-to-refinery-to-market chain running from M23-controlled extraction through Rwanda Defence Force-supervised transit to refining and onward sale is the kind of extractive-industry integrity finding that a commodity-flow monitor would track alongside this sanctions action. The Banque Misr NPRM and VTB re-designation both bear on state-capture and enablement questions relevant to a monitor tracking how sanctioned or adjacent state and quasi-state actors route financial activity through permissive third-country banking nodes. The Chainalysis finding on Iranian oil-proceeds laundering through stablecoins and DeFi is directly relevant to any monitor tracking illicit-finance use of digital-asset infrastructure to obscure sanctioned-actor flows.

Outlook

Watch the October 2026 FATF Plenary, the first under UK Presidency, for confirmation of the Bosnia and Herzegovina and Iraq grey-list additions reported after the June Plenary; a T1 FATF confirmation would resolve the current Probable-confidence secondary-reporting gap. Watch also whether FinCEN's Banque Misr NPRM proceeds to a final special-measures rule, which would be the first concrete enforcement outcome of the UAE-facilitation theory documented this cycle. On the beneficial-ownership front, the practical downstream effect of the CTA exemption on U.S. law-enforcement and international-cooperation access to ownership data is one of the more consequential open questions raised, though not resolved, by this cycle's developments.

weekly_brief_draft · JID US-WA

Domain intelligence (D1–D6)

D1 Sanctions Architecture and Evasion

Sanctions Architecture and Evasion

Sanctions architecture this cycle shows evasion routing increasingly through institutions that are already sanctioned or through third-country facilitation nodes, rather than through freshly-designated primary targets. OFAC re-designated VTB Bank Public Joint Stock Company on September 14, 2026 for facilitating Iranian sanctions evasion under Operation Economic Outcast, a designation layered on top of VTB's existing Russia-related SDN listing that dates to February 2022. Read architecturally rather than as an isolated incident, a second designation against an institution already on the SDN list for one program, now designated again for facilitating evasion of a separate sanctions program, indicates the institution's continued utility to sanctioned actors despite an existing blocking action, and signals that primary designation alone did not sever its role in the broader evasion architecture. This reading is Probable rather than Confirmed: the finding traces to a T3 law-firm summary of the OFAC action rather than an independently pulled T1 OFAC SDN record for this specific re-designation.

Alongside the VTB re-designation, FinCEN issued a notice of proposed rulemaking on August 28, 2026 finding five UAE-based branches of Egypt's Banque Misr to be a primary money-laundering concern for facilitating sanctions evasion. The UAE's appearance here as the jurisdiction hosting the facilitation vector is consistent with its recurring role as a secondary-sanctions transit point, a pattern that recurs across sanctions-evasion architecture generally: primary targets sanctioned directly, secondary facilitation increasingly proposed for action through foreign-bank branches domiciled in permissive jurisdictions. Both developments this cycle sit at the Probable confidence tier and derive from the same T3 secondary source, a limitation on independent primary-source corroboration that should be read alongside the substance of the findings.

Outlook

The Banque Misr NPRM is a proposed special-measures action, not yet final; its progression to a final rule would be the concrete enforcement outcome to watch, and would test whether FinCEN's special-measures authority reaches foreign-bank branch facilitation of sanctions evasion in practice. Whether OFAC issues further designations connected to the VTB Iran-evasion theory, or extends similar re-designation treatment to other already-sanctioned Russian institutions, would confirm whether this is a template being applied systematically rather than an isolated action.

D2 Beneficial Ownership and Corporate Transparency

Beneficial Ownership and Corporate Transparency

For a non-EEA jurisdiction such as the United States, the directly relevant beneficial-ownership development this cycle is domestic: FinCEN finalized a rule, effective August 14, 2026, permanently exempting U.S. companies and U.S.-person beneficial owners from Corporate Transparency Act beneficial-ownership-information reporting, with only foreign registrants remaining in scope. FinCEN's own materials state the rule directly, and Treasury's press release frames it as relief for American small businesses; the two sources corroborate at Confirmed confidence. Previously submitted beneficial-ownership information for U.S. persons is to be deleted from the registry FinCEN built under the CTA's 2022 implementing rule. This is the most consequential domestic beneficial-ownership transparency reversal since that 2022 rule, hollowing out the domestic registry to foreign registrants only, and it reduces the pool of ownership data available to U.S. law enforcement and to international information-sharing requests that previously could draw on domestic BOI. This bears directly on the FATF Recommendation 24 benchmark on beneficial ownership, against which the U.S. registry will now be measured with substantially narrower domestic scope.

Globally, the EU AML Package sets the structural direction for beneficial-ownership and corporate-transparency supervision, but it is not the primary subject matter for the United States' own regulatory perimeter. As standing architecture, the EU AML Package comprises three distinct instruments: the AML Regulation (Regulation (EU) 2024/1624), which is directly applicable across Member States without domestic transposition; the sixth AML Directive, transposed individually by each Member State; and the AMLA Regulation (Regulation (EU) 2024/1620), which establishes the Anti-Money Laundering Authority and shifts supervision of certain obliged entities from purely national authorities toward a hybrid EU-level regime combining direct and indirect AMLA supervision. No new AMLR application milestone, 6AMLD transposition delta, or AMLA supervisory-perimeter change was independently verified this cycle; search allocation was concentrated on the bound US-WA jurisdiction and on mandatory global items, so this paragraph states the durable architecture as standing context rather than a fresh development.

Outlook

The open question raised but not resolved by the CTA exemption is its practical effect on U.S. law-enforcement and international-cooperation access to beneficial-ownership data previously captured for domestic entities; any GAO or congressional oversight follow-up assessing that effect would be the next concrete marker. On the EU side, the next AMLA supervisory-perimeter milestone remains the item to watch for confirming how the hybrid direct/indirect supervision regime concretely reshapes obliged-entity oversight.

D3 Enabler Jurisdictions and Professional Facilitators

Enabler Jurisdictions and Professional Facilitators

The UAE is this cycle's clearest enabler-jurisdiction signal. FinCEN's notice of proposed rulemaking, issued August 28, 2026, finds five UAE-based branches of Egypt's Banque Misr to be a primary money-laundering concern for facilitating sanctions evasion. Architecturally, what is notable is not the identity of the underlying sanctioned program but the location of the facilitation node: a foreign bank's UAE branches, rather than its home-jurisdiction operations, is where FinCEN identifies the money-laundering concern. This is consistent with the UAE's recurring role as a secondary-sanctions transit point, a pattern in which jurisdictions with deep correspondent-banking connectivity and comparatively permissive supervisory capacity become the through-point for evasion flows that cannot move directly through the primary sanctioning jurisdiction's own financial system. The finding sits at Probable confidence, sourced to a T3 law-firm summary of the FinCEN action.

Enablement is itself a form of signal independent of enforcement volume: the absence of a parallel UAE domestic enforcement action against the same branches, at least as far as this cycle's evidence base extends, is analytically notable alongside the U.S. proposed special-measures action. A proposed rule under U.S. authority targeting foreign bank branches is a different enforcement register than a host-jurisdiction supervisory action against the same branches, and the difference in registers is itself part of the enabler-jurisdiction picture this cycle presents.

Outlook

Whether FinCEN's Banque Misr NPRM is finalized, and on what terms, is the concrete near-term marker. A finalized special-measures rule would test the practical reach of U.S. authority over foreign-bank branches operating in a third jurisdiction, and would be the clearest evidence yet of how the enabler-jurisdiction facilitation theory translates into enforceable measures rather than remaining at the proposal stage.

D4 Conflict Finance and Extractive-Industry Integrity

Conflict Finance and Extractive-Industry Integrity

On June 25, 2026, OFAC designated Gasabo Gold Refinery Ltd, its chairman and managing director, and three affiliated Rwandan mining companies for refining and exporting an estimated sixty kilograms or more of gold smuggled from mines in eastern DRC controlled by M23 and supervised by the Rwanda Defence Force. The finding is Confirmed, stated directly in T1 releases from both the U.S. Department of State and the U.S. Department of the Treasury, and implements the December 2025 Washington Accords. Read architecturally, this is a documented mine-to-refinery-to-market chain: extraction under M23 control, transit supervised by the Rwanda Defence Force, refining at Gasabo, and onward export and sale, now under direct U.S. sanction at multiple points in that chain rather than at extraction alone. Treasury's own materials describe minerals sourced from eastern DRC as smuggled through Rwanda before being transported to major refining operations, corroborating the structural chain independently of the State Department release naming Gasabo specifically.

The designation reaches beyond the refinery itself to the individuals controlling it and to three affiliated mining companies, indicating an enforcement approach aimed at the network rather than a single corporate entity. That the chain runs through state-supervised territory, with the Rwanda Defence Force cited as supervising the mines from which the smuggled gold originated, gives this finding a state-complicity dimension that distinguishes it from a purely private conflict-finance typology; this is conflict finance operating with apparent state-military involvement in the supervision of extraction and transit, not merely private illicit trade occurring within a conflict zone.

Outlook

Whether OFAC extends this network-designation approach to additional refineries or trading entities in the same eastern DRC-to-Rwanda-to-market chain is the concrete marker to watch, as is whether the Washington Accords framework produces further coordinated designations across the U.S. and other signatory governments targeting the same conflict-gold supply chain.

D5 Crypto, Digital Assets, and Financial Innovation

Crypto, Digital Assets, and Financial Innovation

The United States' own digital-asset regulatory perimeter is the anchor for this domain, and this cycle's clearest signal within it is analytical rather than regulatory: Chainalysis's 2026 Crypto Crime Report documents more than one hundred million dollars tied to Iranian oil sales, brokered by an OFAC-designated individual, laundered through stablecoin purchases and decentralized-finance protocols and bridges between 2023 and 2025. The finding sits at Probable confidence, sourced to Chainalysis's own T2 published research, and illustrates a full sanctions-evasion chain: oil-sale proceeds converted into stablecoins, then moved through DeFi protocols and cross-chain bridges, ultimately reaching wallets associated with a sanctioned entity's proxies. Chainalysis's own reporting notes that the broker hired to purchase the stablecoins has exposure to other regime proxies, indicating the laundering network extends beyond the single broker identified.

This sits alongside a continuing softening of Treasury's post-Tornado Cash mixer posture, a trend the domain tracker characterizes as part of the same escalating trajectory: sanctioned or sanctions-adjacent actors increasingly routing value through stablecoin conversion and DeFi infrastructure rather than through traditional correspondent banking, at the same time as U.S. mixer-designation posture has been trending less aggressive than in the immediate post-Tornado Cash period. Read together, these two threads describe a digital-asset environment in which the laundering techniques documented by private-sector blockchain analytics are advancing at a pace that the current enforcement posture toward the underlying mixing infrastructure has not fully kept in step with.

Outlook

Whether Treasury issues any further mixer or DeFi-protocol designations in response to the specific stablecoin-and-bridge chain Chainalysis documents is the concrete marker to watch, as is whether OFAC pursues action against the broker identified as facilitating the stablecoin purchases, given Chainalysis's own note that this broker has exposure to other sanctioned-regime proxies beyond the Iranian oil-sale proceeds specifically documented.

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

Not covered

AML/CTF Regime is not yet covered for this jurisdiction in this report.

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 fim-2026-07-06

Role action cards

MLRO

FinCEN permanently exempted U.S. persons and companies from CTA beneficial-ownership reporting, effective August 14, 2026.

The domestic BOI data pool an MLRO's institution could reference for U.S.-person beneficial-ownership verification is now narrowed to foreign registrants only, and previously submitted U.S.-person BOI is to be deleted, reducing the practical utility of the CTA registry for domestic customer due diligence.

1 evidence refs

Compliance

VTB Bank was re-designated by OFAC for Iran sanctions-evasion facilitation, and FinCEN proposed special measures against UAE branches of Banque Misr.

Sanctions-screening lists and correspondent-relationship risk assessments should reflect the VTB re-designation and the proposed Banque Misr special measures, both indicating evasion routing through already-sanctioned or third-country facilitation nodes.

1 evidence refs

Legal

The UK narrowed its mandatory enhanced-due-diligence trigger to FATF call-for-action countries only, from June 30, 2026.

Legal teams advising on UK EDD obligations should note that the UK no longer maintains a standalone high-risk third-countries list; S.I. 2026/621 amended MLR 2017 regulation 33(1)(b) and (3)(a), and FATF grey-list status is now a risk factor rather than an automatic UK EDD trigger, diverging from the EU's own high-risk list.

1 evidence refs

Board

FinCEN's CTA exemption is the most consequential domestic beneficial-ownership transparency reversal since the 2022 implementing rule.

This is a structural regulatory reversal with reputational and policy-exposure dimensions for institutions that had built compliance processes around the CTA registry; the Board should be aware the U.S. domestic beneficial-ownership transparency landscape has materially narrowed.

1 evidence refs

CTO

Chainalysis documented Iranian oil-sale proceeds laundered through stablecoin purchases and DeFi bridges into sanctioned-proxy wallets.

Digital-asset infrastructure and monitoring architecture should account for the documented laundering chain from stablecoin conversion through DeFi protocols and cross-chain bridges, a technical evasion vector distinct from traditional correspondent-banking sanctions evasion.

Risk

OFAC's Gasabo Gold Refinery designation documents a mine-to-refinery-to-market conflict-gold chain involving Rwanda Defence Force-supervised extraction.

Extractive-industry and trade-finance exposure to the eastern DRC-Rwanda gold corridor now carries a confirmed sanctions nexus implicating state-military supervision of extraction, a concentration-risk signal for any counterparty or trade-finance exposure touching that corridor.

1 evidence refs

Operations

FATF's grey list moved at the June 2026 Plenary, with Algeria and Namibia delisted and Bosnia and Herzegovina and Iraq reportedly added.

Screening and country-risk-rating workflows should reflect the confirmed Algeria and Namibia delisting; the Bosnia and Herzegovina and Iraq additions remain at Probable confidence pending T1 confirmation at the October 2026 Plenary.

1 evidence refs

Audit

FinCEN's CTA exemption requires deletion of previously submitted U.S.-person beneficial-ownership information.

Audit trails and documentation practices that relied on the CTA registry as a beneficial-ownership evidentiary source for U.S. persons should be reassessed, as the underlying registry data for those persons is being deleted rather than retained.

1 evidence refs

Decision lens

MLRO

FinCEN permanently exempted U.S.

Compliance

VTB Bank was re-designated by OFAC for Iran sanctions-evasion facilitation, and FinCEN proposed special measures against UAE branches of Banque Misr.

Legal

The UK narrowed its mandatory enhanced-due-diligence trigger to FATF call-for-action countries only, from June 30, 2026.

Board

FinCEN's CTA exemption is the most consequential domestic beneficial-ownership transparency reversal since the 2022 implementing rule.

CTO

Chainalysis documented Iranian oil-sale proceeds laundered through stablecoin purchases and DeFi bridges into sanctioned-proxy wallets.

Risk

OFAC's Gasabo Gold Refinery designation documents a mine-to-refinery-to-market conflict-gold chain involving Rwanda Defence Force-supervised extraction.

Operations

FATF's grey list moved at the June 2026 Plenary, with Algeria and Namibia delisted and Bosnia and Herzegovina and Iraq reportedly added.

Audit

FinCEN's CTA exemption requires deletion of previously submitted U.S.-person beneficial-ownership information.

Shared evidence: 1 refs

Scenario sketches

AMLA direct/indirect supervision transition and cross-border evasion routing

Illustrative scenario for analytical orientation: as AMLA's direct and indirect supervisory perimeter over cross-border obliged entities takes shape under the AMLA Regulation, alongside the directly-applicable AMLR and per-state 6AMLD transposition, evasion architecture that currently routes through purely nationally-supervised entities could, in principle, shift toward obliged entities calibrated to sit just outside AMLA's direct-supervision threshold, testing the boundary between direct and indirect supervision rather than the substance of AML controls themselves. This is illustration only, not an observed development.

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

Standing trackers (T1–T6)

Tracker	Status	Note
T1 · Russian Sanctions-Evasion Architecture	material_change	A7 Network TCO designation and FinCEN special-measure NPRM (Oct 1, 2026) target a Russia-linked shadow-banking/crypto network used by Iran/IRGC.
T2 · EU AML Package / AMLA	no_change	No AMLR application, 6AMLD transposition, or AMLA supervisory-perimeter development was located this cycle; not actively re-searched (budget-limited).
T3 · FATF Grey List	watch	List stands at 22 jurisdictions after the June 2026 plenary; October 2026 plenary (first under UK Presidency) pending with possible removals not yet confirmed.
T4 · Beneficial-Ownership Register Status	no_change	No material BO-register development identified this cycle; not actively re-searched.
T5 · Crypto & Digital-Asset Integrity	material_change	A7 Network designation blocks the A7A5 ruble-pegged token, a rare instance of a sanctions designation reaching a specific crypto settlement rail; WA DFI continues active UMSA enforcement against crypto money transmitters.
T6 · Sanctions Regime Divergence	watch	The Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 requires OFAC to begin SDN designations under it by Oct 18, 2026; no independent EU/UK mirroring of the A7 designation confirmed this cycle.

Registers

Enforcement actions

FinCEN issued a Section 311 finding designating Huione Group a foreign financial institution of primary money-laundering concern, severing its US correspondent/payable-through account access. The finding and subsequent final rule bind all US BSA-covered institutions and VASPs, including those domiciled in Washington, to cease processing transactions for the network. 14 Oct 2025
OFAC designated the Prince Group TCO and 146 associated targets for cryptocurrency scam operations and forced-labor compounds; DOJ concurrently unsealed an indictment against chairman Chen Zhi and filed a record $15bn civil forfeiture against approximately 127,000 bitcoin. The designation applies sanctions-screening obligations to all US financial institutions and VASPs, including Washington-domiciled crypto exchanges. 14 Oct 2025
OFAC listed over fifty crypto addresses belonging to sanctioned North Korean bank Cheil Credit Bank plus another DPRK financial institution and several bankers, for facilitating DPRK cybercrime and espionage financing. Washington-based crypto exchanges and MSBs are required to screen against the newly listed addresses. 4 Nov 2025
DOJ, coordinating with German and Finnish authorities, disrupted Garantex, seizing domains/servers and freezing over $26 million in illicit funds, and unsealed criminal charges against its administrators for laundering hundreds of millions in cybercrime and sanctions-evasion proceeds. WA-domiciled VASPs and crypto-ATM operators are subject to ongoing screening obligations against Garantex-linked wallets and successor entities (e.g., Grinex). 7 Mar 2025

Sanctions changes

OFAC designated the Prince Group TCO and 146 associated individuals/entities (including Cambodian Senator Kok An's business empire in a follow-on April 2026 action) for cryptocurrency scam operations, forced labor and money laundering, applicable to WA-domiciled financial institutions' sanctions-screening programs. 14 Oct 2025
OFAC designated over fifty crypto addresses belonging to DPRK's Cheil Credit Bank plus another North Korean financial institution and several bankers involved in cybercrime and espionage financing. 4 Nov 2025
FinCEN issued a notice implementing the FATF's February 2026 plenary outcome, informing US financial institutions that Kuwait and Papua New Guinea were added to the Jurisdictions Under Increased Monitoring list, while the High-Risk Jurisdictions Subject to a Call for Action list (Iran, DPRK, Burma) remained unchanged. 13 Feb 2026
National Security Presidential Memorandum-2 (Feb 4, 2025) reimposed a 'maximum pressure' campaign on Iran; the Government of Iran and Iranian financial institutions remain blocked under E.O. 13599 and the ITSR, with US restrictions on correspondent accounts continuing to exceed baseline FATF recommendations. 4 Feb 2025

Regulatory horizon (register)

GENIUS Act stablecoin implementing regulations deadline
FinCEN AML/CFT program reform rule finalization
FATF next plenary review of grey/high-risk lists

Active schemes

Crypto-ATM/kiosk cash-out pipeline exploiting WA VASP base
[HIGH] DPRK IT-worker infiltration of WA tech-employment sector
Aerospace dual-use parts diversion to sanctioned Russian carriers

Sources

Coverage gaps

Extensive search across FinCEN, OFAC, DOJ press archives, IC…

Extensive search across FinCEN, OFAC, DOJ press archives, ICIJ, OCCRP, and quality-press financial-crime coverage identified no Washington State DFI-specific consent order or state-level AML enforcement action in the 18-month window, despite the state's significant regulated MSB/VASP population.

IRS examiners assigned to review AML compliance of crypto fi…

IRS examiners assigned to review AML compliance of crypto firms and other MSBs fell 33% in 2025, from 208 to 139 agents nationally, reducing federal supervisory bandwidth over Washington-domiciled crypto-ATM operators and VASPs that rely on federal examination as a backstop to state DFI licensing supervision.

A reinterpretation of OCC rules has allowed crypto firms to …

A reinterpretation of OCC rules has allowed crypto firms to obtain national trust charters affording federal preemption from state AML/consumer-protection oversight, reducing Washington DFI's practical supervisory reach over crypto entities that migrate to federal charters (mirroring the Paxos/New York DFS precedent cited by ICIJ).

FinCEN's March 2025 interim final rule exempted all entities…

FinCEN's March 2025 interim final rule exempted all entities created in the United States (including Washington-incorporated LLCs/corporations) and their beneficial owners from Corporate Transparency Act BOI reporting; only foreign companies registered to do business in the US remain subject.

Evidence

Confidence-tiered claims

WA's AML/CTF-adjacent regime is the general Uniform Money Services Act (UMSA, RCW 19.230; WAC 208-690) money-transmitter licensing overlay atop the federal BSA/FinCEN framework; no bespoke state AML statute exists. SRC-fim-US-004

Confirmed · 1 source

Treasury/FinCEN designated the Russia-linked A7 Network (and its A7A5 ruble-pegged token) a significant transnational criminal organization under Operation Economic Outcast, Oct 1, 2026; FinCEN proposed a BSA special measure against its Sub-Agents. SRC-fim-US-001

Confirmed · 1 source

FinCEN's Sept 3, 2026 alert (FIN-2026-Alert005) flags money laundering associated with digital-asset investment scam centers in Cambodia, concurrent with Treasury sanctions against Cambodian scam-center operators. SRC-fim-KH-001

Probable · 1 source

OFAC's Sept 29, 2026 action sanctioned Sinaloa Cartel leadership and associated corruption networks (Los Mayos faction, Baja California). SRC-fim-US-003

Confirmed · 1 source

FATF grey list stands at 22 jurisdictions after the June 17-19, 2026 plenary (Bosnia and Herzegovina, Iraq added; Algeria, Namibia removed); October 2026 plenary (first under UK Presidency) pending. SRC-fim-GLOBAL-001

Probable · 1 source