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 — Wyoming US-WY

Domains (D1–D6)

Sources

Role actions

Horizon <90d

Jurisdiction profile

Largely CompliantTier ARisk: IncreasingEnabler

Wyoming operates under standard US federal AML/CFT law (BSA, CTA, OFAC sanctions) but its state corporate/trust statutes impose no beneficial-ownership disclosure, ID verification, or registered-agent licensing for LLC/trust formation, driving the highest per-capita US incorporation rate.

Since 2019 Wyoming built parallel crypto-specific frameworks (SPDI bank charter, DAO-LLC statute, state-issued FRNT stablecoin) under its Division of Banking — a leading crypto regulatory sandbox that ICIJ also documents as a top domestic secrecy jurisdiction.

Key deficiencies

No beneficial ownership disclosure required for Wyoming LLC, corporation, or trust formation
No certified ID verification required to form a company or trust — weaker than Cayman/Bermuda per academic comparative study
Registered-agent industry is unlicensed and unsupervised, enabling large-scale anonymous entity mills (e.g., 30 N. Gould St., Sheridan)
2025 federal CTA rollback removes the principal backstop (federal BOI reporting) to Wyoming's state-level opacity for domestic entities

Recent developments (18m)

FinCEN March 2025 interim final rule exempts all US domestic reporting companies (including Wyoming LLCs) from CTA beneficial ownership reporting
Wyoming bill signed Feb 24, 2025 streamlines state authority to dissolve shell companies linked to foreign adversaries
Wyoming Stable Token Commission launched FRNT, the first US state-issued stablecoin, August 2025
OFAC designations (Jul 2025, Mar 2026) targeting DPRK IT-worker crypto-laundering networks, with ICIJ/FBI-documented nexus to Wyoming-registered shell entities
ICIJ Cyprus Confidential/Pandora Papers follow-up reporting (Dec 2024–Apr 2025) documents Wyoming overtaking Delaware as the top per-capita US incorporation secrecy hub
FinCEN flagged (Sept 2025) plans to delete previously collected domestic-company BOI data from the registry

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

Brief

Lead signal

Lead Signal

Read full brief

Lead Signal

Wyoming's digital-asset supervisory architecture moved on two fronts this cycle. On 1 October 2026, the New York State Department of Financial Services and the Wyoming Division of Banking signed a memorandum of understanding covering licensing and chartering coordination, joint examinations, and the sharing of supervisory reports, market trend data and notifications of potential enforcement actions for virtual-currency and digital-asset firms operating in both states. The arrangement narrows, without eliminating, a long-standing regulatory seam between New York's BitLicense regime and Wyoming's Special Purpose Depository Institution and money-transmitter-exemption regime. Separately, on 29 September 2026 the Wyoming Select Committee on Blockchain, Financial Technology and Digital Innovation Technology heard bill draft 27LSO-0138 v0.4, which would replace a capped civil-penalty ceiling with uncapped civil money penalties backing the Division of Banking's kiosk-enforcement toolkit established under 2026's HB0075. Both developments respond to the same underlying kiosk-facilitated fraud typology tied to FinCEN money-services-business and Bank Secrecy Act obligations, and together they represent the most concentrated movement in Wyoming's enabler-jurisdiction posture in recent cycles.

The interstate MOU is a supervisory-coordination instrument, not a harmonisation of substantive law: Wyoming's SPDI charter and money-transmitter exemption for virtual currency remain in place, and New York's BitLicense regime remains separately administered. What changes is the information flow between the two regulators and, by extension, the practical cost of regulatory arbitrage for firms that previously could operate under one state's lighter perimeter while avoiding scrutiny from the other.

Other Developments

Sanctions cadence against Sinaloa Cartel finance infrastructure. On 29 September 2026, the Office of Foreign Assets Control added 21 individuals and 25 entities tied to the Los Mayos faction of the Sinaloa Cartel to the SDN List, including Alfonso Arzate Garcia, targeting fentanyl-trafficking revenue, money laundering, and an alleged protection network within regional Mexican authorities. The action continues a standing cartel-finance corridor already tracked across prior cycles and sustains, rather than newly opens, FIM's Mexico risk line.

Kiosk-enforcement toolkit tightening. The same 29 September hearing that considered the civil-penalty draft sits atop an enforcement structure Wyoming built earlier in 2026 under HB0075, restricting kiosk operation to Money Transmitters Act licensees or Title 13 financial institutions. Draft 27LSO-0138 would remove the ceiling on civil penalties available against operators who run kiosks outside that licensed perimeter, a structural tightening of the deterrent rather than a new category of obligation.

Interstate coordination mechanics. The NY DFS-Wyoming Division of Banking MOU establishes licensing and chartering coordination alongside joint examinations and enforcement-notification sharing. Full enforcement-coordination practice under the MOU remains untested, and the arrangement's effect on actual cross-border supervisory outcomes will only become observable in future cycles as examinations and notifications occur.

Cross-Monitor Connections

The NY-WY supervisory MOU and the kiosk-penalty draft both carry direct relevance to WPM's licensing and market-access tracking for the same jurisdiction, since the instruments at issue are the same underlying regulatory actions viewed through a payments-market-structure lens rather than an integrity lens. The OFAC Sinaloa Cartel designations connect to SCEM's conflict- and organised-crime-finance tracking given the cartel-finance and alleged official-corruption dimensions of the action, and to any monitor tracking correspondent-banking de-risking pressure arising from heightened Mexico-corridor sanctions exposure.

Outlook

The NY-WY MOU's practical effect depends on how examination coordination and enforcement notifications are actually used going forward; as scheduled, this is a structural enabler-jurisdiction narrowing whose enforcement-coordination practice has not yet been tested. The kiosk civil-penalty draft, if enacted, would complete a toolkit that began with HB0075's licensing restriction earlier in 2026, moving Wyoming's kiosk-fraud response from a capped-penalty regime to an uncapped one. The Sinaloa Cartel designation cadence is likely to continue absent a change in the underlying conflict-finance dynamics in Mexico, and the alleged official-corruption dimension of the September 2026 action may generate follow-on correspondent-banking scrutiny in future cycles.

weekly_brief_draft · JID US-WY

Domain intelligence (D1–D6)

D1 Sanctions Architecture and Evasion

Sanctions Architecture and Evasion

On 29 September 2026, the Office of Foreign Assets Control designated 21 individuals and 25 entities tied to the Los Mayos faction of the Sinaloa Cartel, including Alfonso Arzate Garcia, onto the SDN List. The designation targets fentanyl-trafficking revenue, money laundering, and an alleged protection network within regional Mexican authorities. This is a Confirmed-tier development, corroborated directly against OFAC's own recent-actions page, and it continues a sanctions-architecture line FIM has tracked across prior cycles rather than opening a new one.

From a sanctions-architecture perspective, the significant element is not the designation count alone but the alleged official-corruption dimension: naming a protection network within regional Mexican authorities signals that OFAC's targeting logic is extending from direct narcotics and laundering conduct into the state-adjacent enablement layer that permits cartel finance to move. This is the kind of structural framing that distinguishes an architecture-level reading from a single-incident one — the designation is one data point in a continuing pattern of US sanctions pressure applied to the Sinaloa Cartel's financial infrastructure, and its corruption framing suggests continued willingness to designate beyond the immediate trafficking network.

No Wyoming-specific sanctions-architecture development was identified this cycle; the designation's nexus to US-WY in this brief is at the level of the federal sanctions framework within which Wyoming-chartered and Wyoming-regulated financial institutions, including SPDIs, must operate screening and compliance obligations. The designation itself was made under the general OFAC Sinaloa Cartel sanctions program rather than any Wyoming-specific instrument.

Outlook

The sustained OFAC designation cadence against Sinaloa Cartel finance infrastructure, including the alleged official-corruption network named in this action, indicates continuity rather than escalation of the existing enforcement posture, and further designations against the same network's financial facilitators are plausible as scheduled in coming cycles. Any correspondent-banking or de-risking effects flowing from the corruption-network framing would surface in subsequent OFAC actions or in guidance to US financial institutions, neither of which has yet been reported.

D2 Beneficial Ownership

Not covered

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

D3 Enabler Jurisdictions and Professional Facilitators

Enabler Jurisdictions and Professional Facilitators

The signing of a memorandum of understanding between the New York State Department of Financial Services and the Wyoming Division of Banking on 1 October 2026 is this cycle's lead enabler-jurisdiction development. The MOU covers licensing and chartering coordination, joint examinations, and the sharing of supervisory reports, market trend data and notifications of potential enforcement actions for virtual-currency and digital-asset firms operating in both states. Read architecturally, this is a narrowing of a long-standing regulatory-arbitrage seam between two of the most consequential US state-level digital-asset regimes: New York's BitLicense, widely regarded as a stringent authorisation framework, and Wyoming's Special Purpose Depository Institution charter paired with its money-transmitter exemption for virtual currency, widely regarded as a more permissive one. A firm previously able to select the more favourable regulatory posture while limiting the other state's visibility into its conduct now faces two regulators that share supervisory reports and enforcement notifications with one another.

The probable-tier confidence attached to this reading reflects that the MOU's practical enforcement-coordination effect has not yet been demonstrated; the instrument establishes the information-sharing and joint-examination mechanism, but whether the two regulators actually use it to close gaps in practice is a separate question that will only be answered by subsequent examinations. This is the structural distinction that matters for an enabler-jurisdiction analysis: the existence of a coordination mechanism reduces the theoretical arbitrage opportunity, but enablement is a function of practice, not just architecture, and the absence of demonstrated joint-enforcement action to date is itself a data point worth surfacing rather than treating the MOU's signing as a completed remediation.

Wyoming's own regulatory posture toward virtual-currency activity — the Money Transmitter Act's exemption for virtual currency alongside direct Division of Banking prudential supervision of SPDIs — remains unchanged by the MOU. What has changed is the degree to which New York's generally stricter licensing lens now has visibility into firms operating under Wyoming's lighter-touch regime, and vice versa.

Outlook

The coordination mechanism's value will be tested by whether joint examinations and enforcement notifications actually occur and alter supervisory outcomes for dual-state-operating firms; as scheduled, this remains unproven in practice at this stage. If subsequent cycles report an actual joint examination or an enforcement notification flowing from one state to the other under the MOU's terms, that would represent the first evidence that the architecture Wyoming and New York agreed to has closed, rather than merely narrowed on paper, the regulatory-arbitrage seam between the two regimes.

D4 Conflict Finance and Extractive-Industry Integrity

Conflict Finance and Extractive-Industry Integrity

OFAC's 29 September 2026 SDN List additions targeting the Los Mayos faction of the Sinaloa Cartel sit squarely within FIM's standing conflict and organised-crime finance corridor tracking Mexico-linked illicit finance, alongside fuel-theft and cross-border cash and casino laundering vehicles tracked in prior cycles. The designations target 21 individuals and 25 entities tied to fentanyl-trafficking revenue and money laundering, and notably also name an alleged protection network within regional Mexican authorities — a corruption dimension that extends the conflict-finance reading beyond pure narcotics-proceeds laundering into the state-enablement layer that permits that laundering to continue with reduced local interdiction risk.

This Confirmed-tier development, evidenced directly against OFAC's own recent-actions page, continues rather than newly establishes the standing Sinaloa Cartel finance corridor. The architecture-over-incident framing that applies here is that a single designation action is less significant on its own than the sustained cadence of designations it forms part of: OFAC's continued willingness to designate new individuals and entities within the same organised-crime network over successive cycles indicates an active, ongoing enforcement posture against this specific conflict-finance architecture rather than a one-off response to a discrete triggering event.

No Wyoming-specific nexus to this conflict-finance corridor was identified this cycle beyond the general federal sanctions-compliance obligations applicable to Wyoming-chartered financial institutions, including SPDIs, that must screen counterparties against the SDN List as updated by this action.

Outlook

The alleged official-corruption dimension of this designation action is the element most likely to generate follow-on developments: if the protection-network allegation leads to further designations of specific Mexican officials or state-adjacent entities, that would mark an escalation of OFAC's targeting logic from narcotics-and-laundering conduct into direct state-corruption designations. Whether that escalation occurs will only be observable in subsequent designation actions; at this stage, the development represents continuity of the existing cartel-finance enforcement cadence.

D5 Crypto, Digital Assets, and Financial Innovation

Crypto, Digital Assets, and Financial Innovation

Wyoming's digital-asset regulatory posture moved on two coordinated fronts this cycle, both traceable to the same underlying kiosk-facilitated fraud typology. First, the Wyoming Select Committee on Blockchain, Financial Technology and Digital Innovation Technology heard bill draft 27LSO-0138 v0.4 on 29 September 2026, which would replace the current capped civil-penalty ceiling with uncapped civil money penalties backing the Division of Banking's kiosk-enforcement toolkit established earlier in 2026 under HB0075. Second, the New York DFS-Wyoming Division of Banking memorandum of understanding signed 1 October 2026 extends interstate supervisory reach over virtual-currency and digital-asset firms operating in both states through shared examinations and enforcement-notification protocols.

Taken together, these are two distinct mechanisms responding to the same structural gap: a kiosk-facilitated fraud and money-laundering-adjacent typology that the Division of Banking has tied to FinCEN money-services-business and Bank Secrecy Act obligations. HB0075 earlier in 2026 restricted kiosk operation to Money Transmitters Act licensees or Title 13 financial institutions; draft 27LSO-0138 would complete that toolkit by removing the ceiling on civil penalties available against operators who continue to run kiosks outside that licensed perimeter. This is a probable-tier, escalating-trajectory development: Wyoming is actively tightening enforcement capacity rather than merely restating an existing rule.

The interstate MOU operates on a different axis — supervisory coordination rather than penalty severity — but it, too, bears on the digital-asset-innovation space because Wyoming's Special Purpose Depository Institution charter and money-transmitter exemption for virtual currency are the very features that make the state attractive to digital-asset firms. Greater supervisory visibility between New York and Wyoming narrows, without eliminating, the degree to which that attractiveness can be leveraged for cross-border regulatory arbitrage specifically within crypto and digital-asset business models.

Outlook

If enacted, draft 27LSO-0138 would mark the completion of a two-part legislative response to kiosk-facilitated fraud that began with HB0075's licensing restriction earlier in 2026, moving Wyoming from a capped to an uncapped civil-penalty deterrent for unlicensed kiosk operation. Separately, a further Wyoming Digital Asset Authority proposal (draft 27LSO-0010 v0.9), which would create an eight-member authority with rulemaking, custody and procurement powers over government-issued digital assets distinct from the existing Wyoming Stable Token Commission, remains under consideration for the 2027 legislative session; its structural separation from existing institutions means its eventual scope relative to Wyoming's broader digital-asset architecture is not yet assessed.

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

Proposed2027-Q1 · ±year

Wyoming Digital Asset Authority (27LSO-0010 v0.9)

A new state body with rulemaking, custody and procurement authority over government digital assets, structurally separate from the existing Wyoming Stable Token Commission, is under consideration for the 2027 session.

Source

1 dated · 4 pending date · baseline financial-integrity-2026-07-05

Role action cards

MLRO

OFAC designated 21 individuals and 25 entities tied to the Sinaloa Cartel Los Mayos faction, including an alleged regional-corruption network.

Screening lists require updating against the 29 September 2026 SDN additions; the alleged official-corruption dimension may warrant enhanced scrutiny of Mexico-linked correspondent and counterparty relationships.

2 evidence refs

Compliance

A new NY DFS-Wyoming Division of Banking supervisory MOU narrows the regulatory-arbitrage gap between BitLicense and Wyoming's SPDI/money-transmitter-exemption regime.

Firms operating under Wyoming's regime with New York exposure, or vice versa, face increased supervisory information-sharing between the two states, including shared examination findings and enforcement notifications.

1 evidence refs

Legal

Wyoming is considering uncapped civil penalties for unlicensed virtual-currency kiosk operation under draft 27LSO-0138.

Clients operating or facilitating virtual-currency kiosks in Wyoming face a materially higher potential penalty exposure if the draft is enacted, removing the existing cap on civil money penalties.

1 evidence refs

Board

Wyoming's digital-asset regulatory architecture is moving on interstate coordination and domestic enforcement fronts simultaneously.

The combined effect of the NY-WY supervisory MOU and the kiosk-penalty draft signals a less permissive operating environment for digital-asset business in Wyoming than in recent prior cycles, though enforcement-coordination practice under the MOU remains untested.

2 evidence refs

CTO

Interstate supervisory data-sharing between New York and Wyoming now covers virtual-currency and digital-asset firms operating in both states.

Technical architecture supporting multi-state digital-asset operations should anticipate that supervisory reports and enforcement notifications generated in one state are now shared with the other under the MOU's terms.

1 evidence refs

Risk

Two concurrent Wyoming instruments — the NY-WY MOU and the kiosk-penalty draft — both respond to a kiosk-facilitated fraud typology tied to BSA/MSB obligations.

Exposure concentration in Wyoming-domiciled virtual-currency kiosk operations carries rising enforcement risk as the state moves to remove the civil-penalty cap for unlicensed operation.

1 evidence refs

Operations

No material change for this persona this cycle.

No material change for this persona this cycle

Audit

The NY DFS-Wyoming Division of Banking MOU establishes joint examinations and supervisory-report sharing but its enforcement-coordination practice is not yet demonstrated.

Audit trail adequacy for cross-border examination findings under the new MOU cannot yet be assessed against actual practice; this is a gap worth monitoring as examinations occur.

1 evidence refs

Decision lens

MLRO

OFAC designated 21 individuals and 25 entities tied to the Sinaloa Cartel Los Mayos faction, including an alleged regional-corruption network.

Compliance

A new NY DFS-Wyoming Division of Banking supervisory MOU narrows the regulatory-arbitrage gap between BitLicense and Wyoming's SPDI/money-transmitter-exemption regime.

Legal

Wyoming is considering uncapped civil penalties for unlicensed virtual-currency kiosk operation under draft 27LSO-0138.

Board

Wyoming's digital-asset regulatory architecture is moving on interstate coordination and domestic enforcement fronts simultaneously.

CTO

Interstate supervisory data-sharing between New York and Wyoming now covers virtual-currency and digital-asset firms operating in both states.

Risk

Two concurrent Wyoming instruments — the NY-WY MOU and the kiosk-penalty draft — both respond to a kiosk-facilitated fraud typology tied to BSA/MSB obligations.

Operations

No material change for this persona this cycle.

Audit

The NY DFS-Wyoming Division of Banking MOU establishes joint examinations and supervisory-report sharing but its enforcement-coordination practice is not yet demonstrated.

Shared evidence: 2 refs

Scenario sketches

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

Illustrative scenario for analytical orientation only. As the Anti-Money Laundering Authority (Reg (EU) 2024/1620) builds out direct supervision of a defined population of higher-risk cross-border obliged entities alongside the directly applicable AML Regulation (Reg (EU) 2024/1624) and per-state 6AMLD transposition, a structural possibility is that entities previously supervised only at national level shift activity toward obliged entities still under purely national supervision, or toward jurisdictions and sectors not yet brought within the AMLA perimeter. This is an illustrative structural mechanism, not an observed development this cycle, and is not specific to US-WY.

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	no_change	No material US-WY-scoped development this cycle.
T2 · EU AML Package / AMLA	no_change	Not applicable to US-WY (subnational US jurisdiction; AMLR/6AMLD/AMLA bind EEA members only).
T3 · FATF Grey List	no_change	No US-WY-scoped FATF plenary action this cycle.
T4 · Beneficial-Ownership Register Status	no_change	No US-WY-specific BO-registry development this cycle.
T5 · Crypto & Digital-Asset Integrity	escalating	NY DFS-WY Division of Banking MOU (Oct 1, 2026) and WY's draft uncapped kiosk civil-penalty bill (27LSO-0138, heard Sept 29, 2026) both move WY's digital-asset-integrity posture this cycle.
T6 · Sanctions Regime Divergence	no_change	No US-WY-scoped sanctions-divergence development this cycle.

Registers

Enforcement actions

Wyoming signed into law (Feb 24, 2025) a bill streamlining the Secretary of State's authority to dissolve companies submitting false formation records or linked to foreign adversaries, following a 2024 dissolution of three shell entities at a Sheridan registered-agent address named in an FBI North Korea sanctions-evasion affidavit. 24 Feb 2025
FinCEN issued an interim final rule (published March 26, 2025) redefining 'reporting company' to cover only foreign entities, formally exempting all US-formed entities and their beneficial owners — including Wyoming LLCs and trusts — from CTA beneficial ownership reporting to FinCEN. 26 Mar 2025
OFAC designated a DPRK cyber actor and a Russia-based DPRK IT-worker network for orchestrating a fraudulent remote-employment scheme funneling wages into DPRK weapons programs; the parallel DOJ civil forfeiture action (June 5, 2025) targeted over $7.7 million in crypto/NFTs tied to the same laundering network, which US shell-entity investigations (including Wyoming) have documented. 8 Jul 2025
OFAC designated a further six individuals and two entities for operating DPRK IT-worker fraud schemes generating close to $800 million in 2024 for DPRK's WMD and ballistic missile programs, converting proceeds through mainstream exchanges, DeFi services and cross-chain bridges across Vietnam, Laos and Spain. 12 Mar 2026

Sanctions changes

OFAC added Song Kum Hyok and four Russia-based entities to the SDN List for facilitating DPRK IT-worker fraud and cryptocurrency laundering supporting DPRK weapons programs, building on a 2023 designation wave (Sim Hyon Sop, Wu Huihui, Cheng Hung Man) targeting the same laundering ecosystem. 8 Jul 2025
OFAC designated six individuals and two entities on March 12, 2026 for DPRK IT-worker fraud schemes generating close to $800 million in 2024, expanding the sanctioned-address set across multiple blockchain networks reflecting DPRK's multi-chain laundering approach. 12 Mar 2026

Regulatory horizon (register)

GENIUS Act federal stablecoin framework full implementation
FinCEN/OFAC joint stablecoin illicit-finance risk rulemaking
Wyoming legislature: further registered-agent/corporate-registration reform bills
FinCEN third CTA rulemaking: customer due diligence rule revision

Active schemes

[HIGH] The 'Cowboy Cocktail' LLC-Trust Secrecy Layering
[HIGH] Wyoming Registered-Agent Mill Exploited for Fraud/Sanctions Evasion
[CRITICAL] DPRK IT-Worker Crypto Laundering via US Shell-Entity Nexus
Wyoming Crypto-Bank/Stablecoin Architecture (SPDI, DAO-LLC, FRNT)

Sources

Coverage gaps

FinCEN's March 2025 interim final rule exempts all US domest…

FinCEN's March 2025 interim final rule exempts all US domestic entities — including Wyoming LLCs and trusts — from federal beneficial ownership reporting, removing the principal federal backstop against Wyoming's state-level absence of BO disclosure requirements. FinCEN has additionally signaled plans to delete already-collected domestic-company BOI data.

Wyoming's legislature has repeatedly rejected registered-age…

Wyoming's legislature has repeatedly rejected registered-agent oversight and trust-transparency reforms (2016, 2022, 2023), with the trust-formation lawyer industry and free-speech arguments cited as effective opposition; only a narrow foreign-adversary dissolution-authority bill passed in February 2025, leaving the broader registered-agent licensing gap unaddressed.

An academic comparative study (Sharman) found Wyoming and Ne…

An academic comparative study (Sharman) found Wyoming and Nevada require no certified ID documents to form a company or open an associated bank account — weaker verification than notorious offshore centers such as Bermuda and the Cayman Islands, which impose stricter certified-ID requirements on beneficial owners.

No direct Wyoming state-government (.gov) primary URL (e.g.,…

No direct Wyoming state-government (.gov) primary URL (e.g., Wyoming Secretary of State business-filings portal or Division of Banking regulatory page) could be independently retrieved via search at baseline; state-specific supervisory detail is sourced via a federal OFAC–Wyoming supervisory MOU and investigative journalism rather than a Wyoming-issued primary document.

Evidence

Confidence-tiered claims

MOU covering licensing/chartering coordination, joint examinations, and supervisory-report and enforcement-notification sharing for virtual-currency and digital-asset firms operating in both states, signed 2026-10-01. SRC-fim-US-WY-001

Probable · 1 source

Bill draft 27LSO-0138 v0.4 would replace a capped civil-penalty ceiling with uncapped civil money penalties backing the Division of Banking's kiosk-enforcement toolkit established under 2026's HB0075, heard 2026-09-29. SRC-fim-US-WY-002

Probable · 1 source

21 individuals and 25 entities tied to the Los Mayos faction of the Sinaloa Cartel, including Alfonso Arzate Garcia, targeting fentanyl trafficking, money laundering and an alleged protection network within regional Mexican authorities. SRC-fim-US-WY-003

Probable · 1 source

SDN List update dated 2026-09-29 adding Sinaloa-Cartel-linked individuals, part of a broader cartel-finance/corruption designation action. SRC-fim-US-WY-003

Probable · 1 source

Wyoming's money-transmission AML perimeter continues to run through the federal BSA/FinCEN framework plus the state Money Transmitter Act, which exempts virtual-currency activity from licensure while leaving SPDIs under direct Division of Banking prudential supervision. SRC-fim-US-WY-004

Probable · 1 source