Financial Integrity Monitor

United States — Montana US-MT

Domains (D1–D6)
1
Sources
8
Role actions
8
Jurisdiction profile
Not MemberTier CRisk: IncreasingMixed

Montana's AML/CTF framework is almost entirely federally-mediated via the Bank Secrecy Act, FinCEN registration, and OFAC sanctions screening.

MoreState-level oversight runs through the Montana Division of Banking & Financial Institutions (MSB/bank licensing) and the Commissioner of Securities and Insurance (securities/crypto-fraud enforcement). Montana has no state beneficial-ownership registry, and the March 2025 federal CTA rollback removed the sole remaining BOI backstop for domestically-formed LLCs.

Key deficiencies
  • No state-level beneficial ownership registry; reliance on now-curtailed federal CTA/BOI reporting regime
  • Minimal-disclosure LLC formation regime consistent with the broader US pattern of anonymous shell-company formation
  • State securities/crypto enforcement capacity increasingly exposed to federal preemption (OCC national trust charters, potential CLARITY Act market-structure preemption)
  • Sparse independently-documented state-level BSA/AML enforcement record distinct from federal FinCEN/OFAC action
Recent developments (18m)
  • FinCEN's March 2025 interim final rule exempted all domestic reporting companies (including Montana-formed LLCs) from Corporate Transparency Act beneficial ownership reporting
  • Montana lawmakers voted against establishing a state-level strategic Bitcoin reserve (February 2025)
  • Montana state securities regulators joined a multi-state warning to Congress that pending crypto market-structure legislation (CLARITY Act) could diminish state capacity to prosecute crypto fraud (October 2025)
  • OCC granted conditional national trust bank charters to five digital-asset firms (December 2025), enabling nationwide operation that bypasses state-by-state licensing including Montana's regime

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

Brief

Lead signal

Lead Signal

Read full brief

Lead Signal

Montana's crypto exposure has escalated this cycle against a backdrop of structural regulatory absence that has not itself changed. The state's own Commissioner of Securities and Insurance briefed a legislative Blockchain and Digital Innovation Task Force on rising crypto-ATM-facilitated fraud, reporting approximately $3.4 million in reported crypto-scam losses in 2025, driven substantially by cash-out schemes of the pig-butchering typology, against roughly 400 crypto ATMs operating statewide. Separately, the Montana State Auditor's Office recorded 25 fraud complaints in the first quarter of 2026, up from 11 in the same quarter of 2025, totalling approximately $3.3 million in reported losses. Neither figure is corroborated by a primary regulatory publication this cycle; both trace to a single aggregator report of an official briefing and to state press reporting respectively, and the Commissioner's own dataset was not independently opened.

Other Developments

Structural enabler condition confirmed at source. Montana's Division of Banking and Financial Institutions states directly on its own site that it does not regulate money transmitters, and this is confirmed as the sole applicable AML compliance gate: federal FinCEN BSA/MSB registration under 31 U.S.C. 5318(h), with no state-level licensing, reporting-threshold, or obliged-entity designation regime of any kind. This structural condition is stable and long-standing; it is not new this cycle, but it is the backdrop against which the crypto-ATM fraud escalation must be read, since it means no state licensing authority stands between an unlicensed money-services actor and Montana consumers.

Policy response under discussion, not yet enacted. The task force briefing that surfaced the fraud figures also outlined possible countermeasures under consideration, including transaction limits, consumer warnings, and a possible money-transmitter-licensing regime for crypto ATMs specifically. None of these has been enacted as of this cycle; the record reflects discussion at the task-force stage only.

Cross-Monitor Connections

The crypto-ATM fraud escalation documented here is the same underlying fact set that the crypto monitor's consumer_protection module and the world-payments monitor's W10 (Consumer Protection & APP Fraud) module address from their respective lenses: crypto foregrounds the token/product-classification angle and the absence of an enacted crypto-ATM statute, while world-payments foregrounds the payment-corridor and money-transmission-licensing angle. All three readings trace to the same Commissioner of Securities and Insurance briefing and the same Daily Montanan complaint-volume reporting; none introduces a fact the others do not share.

Outlook

The question worth tracking is whether Montana's Blockchain and Digital Innovation Task Force converts its discussion of transaction limits, consumer warnings, or crypto-ATM-specific licensing into enacted policy. Until that happens, the structural enabler condition (no state money-transmitter statute) and the escalating fraud-loss trend continue to run in parallel rather than intersect through any new compliance obligation.

weekly_brief_draft · JID US-MT
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

Crypto / Digital Assets / Financial Innovation

Continue reading

Montana's crypto-related financial-integrity picture this cycle is defined by an escalating fraud signal against an unchanged structural backdrop. The Montana Commissioner of Securities and Insurance briefed a legislative Blockchain and Digital Innovation Task Force reporting approximately $3.4 million in reported crypto-scam losses in 2025, driven substantially by crypto-ATM cash-out schemes matching the pig-butchering typology, against a base of roughly 400 crypto ATMs operating statewide. This is a probable-confidence finding: it traces to a single tier-four aggregator's account of the official briefing, and was not independently corroborated against a primary Commissioner publication this cycle.

The complaint-volume trend corroborates the direction, if not the precise figures. The Montana State Auditor's Office reported 25 fraud complaints in the first quarter of 2026, versus 11 in the same quarter a year earlier, totalling approximately $3.3 million in reported losses. This is tier-three press reporting rather than a primary regulatory dataset, but it independently supports the same rising-trend read as the Commissioner's briefing.

This escalation sits against a structural enabler condition that is itself stable and unrelated to any recent change: Montana has no state money-transmitter licensing statute of any kind, confirmed directly on the state banking regulator's own site, which states plainly that the Montana Division of Banking does not regulate money transmitters. The sole applicable compliance layer for any Montana-based or Montana-facing crypto-asset operator or payment company is federal FinCEN BSA/MSB registration under 31 U.S.C. 5318(h). There is no state-level reporting threshold, licensing test, or obliged-entity designation that would otherwise apply to crypto-ATM operators specifically. Read together, the structural absence of state oversight and the rising fraud-loss trend describe a capacity deficit rather than a change in enforcement posture: the state is not failing to enforce an existing crypto-ATM rule, because no such rule exists to enforce.

The Blockchain and Digital Innovation Task Force briefing indicates the state is aware of the gap and is discussing policy responses, including transaction limits, consumer warnings, and a possible money-transmitter-licensing regime targeted at crypto ATMs. None of these has been enacted. This positions Montana's crypto-asset financial-integrity exposure as a live, discussed, but not yet legislated risk.

Outlook

The development to track is whether the Blockchain and Digital Innovation Task Force's discussion converts into an enacted transaction-limit, warning, or licensing requirement for crypto ATMs. Enactment of any such measure would be the first state-level compliance layer specific to crypto payment infrastructure in Montana, altering the structural enabler condition that has otherwise persisted unchanged. Absent enactment, the fraud-loss trend and the licensing gap will likely continue to move in parallel, with reported losses as the visible symptom of an oversight structure that has not adapted to the crypto-ATM cash-out vector specifically.

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-2026-07-05
Role action cards
MLRO

Montana crypto-ATM fraud losses reported at approximately $3.4 million in 2025 against zero state money-transmission licensing oversight.

For MSBs and crypto-asset operators with Montana exposure, the absence of any state licensing test means federal FinCEN BSA/MSB registration remains the entire compliance perimeter; rising reported fraud losses through crypto-ATM channels increase the analytical case for enhanced transaction monitoring on that corridor even though no new state SAR-equivalent trigger has been created.

3 evidence refs
Compliance

No new state-level obliged-entity designation or reporting threshold has been created in Montana this cycle.

The compliance function should note that Montana's structural licensing gap persists unchanged; the only live variable is a task-force discussion of possible crypto-ATM transaction limits, warnings, or licensing that has not been enacted.

2 evidence refs
Legal

No material change this cycle.

No material change for this persona this cycle

Board

Montana's crypto-fraud loss trend is rising, but no enacted regulatory response yet exists to force an institutional posture change.

Board-level exposure from Montana operations is reputational and trend-driven rather than compliance-driven at this stage; the state auditor's Q1 2026 complaint volume more than doubling year-on-year is a signal worth monitoring for its trajectory rather than for any immediate obligation.

3 evidence refs
CTO

Crypto-ATM infrastructure in Montana (roughly 400 machines statewide) is the specific technical vector behind the reported fraud escalation.

Any technical integration touching Montana crypto-ATM rails should account for the cash-out (pig-butchering) fraud pattern as the dominant loss vector reported by the state securities regulator, independent of any change to the underlying licensing architecture.

1 evidence refs
Risk

Montana's jurisdiction risk direction is assessed as increasing, driven by crypto-ATM fraud escalation against a stable structural enabler condition.

This is an analytical judgment synthesising the fraud-loss briefing against the pre-existing statutory absence of money-transmitter licensing; risk models incorporating jurisdiction-level enabler scoring for Montana should reflect the escalating trajectory while noting the underlying structural condition itself has not changed.

2 evidence refs
Operations

No material change this cycle.

No material change for this persona this cycle

Audit

The Montana structural enabler finding rests on a single Tier-1 source; the fraud-loss figures rest on Tier-3/Tier-4 sources not independently corroborated.

Audit trail documentation for any Montana-related file should record that the money-transmitter-licensing-absence finding is Confirmed against a primary regulator statement, while the $3.4 million and $3.3 million fraud-loss figures remain Probable-tier pending primary-source corroboration.

3 evidence refs
Decision lens
MLRO

Montana crypto-ATM fraud losses reported at approximately $3.4 million in 2025 against zero state money-transmission licensing oversight.

Compliance

No new state-level obliged-entity designation or reporting threshold has been created in Montana this cycle.

Legal

No material change this cycle.

Board

Montana's crypto-fraud loss trend is rising, but no enacted regulatory response yet exists to force an institutional posture change.

CTO

Crypto-ATM infrastructure in Montana (roughly 400 machines statewide) is the specific technical vector behind the reported fraud escalation.

Risk

Montana's jurisdiction risk direction is assessed as increasing, driven by crypto-ATM fraud escalation against a stable structural enabler condition.

Operations

No material change this cycle.

Audit

The Montana structural enabler finding rests on a single Tier-1 source; the fraud-loss figures rest on Tier-3/Tier-4 sources not independently corroborated.

Shared evidence: 3 refs
Scenario sketches

AMLA transition and cross-border obliged-entity supervision

Illustrative orientation only: as the EU AML Package matures, with the directly-applicable AML Regulation (Reg (EU) 2024/1624), the sixth AML Directive transposed per Member State, and the AMLA Regulation (Reg (EU) 2024/1620) establishing the Anti-Money Laundering Authority, supervision of cross-border obliged entities could gradually shift from purely national authorities toward a hybrid EU-level regime combining direct and indirect AMLA supervision. This structural transition, if it proceeds as designed, could reshape how enabler-jurisdiction gaps in non-EU markets are perceived by EU-supervised obliged entities engaging in cross-border correspondent or payment relationships. This is an illustrative structural sketch, not an observed development, and is not specific to Montana or any US subnational jurisdiction.

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_change
T2 · EU AML Package / AMLAno_changeNot applicable to a US subnational jurisdiction.
T3 · FATF Grey Listno_changeNot applicable at the US-MT subnational level.
T4 · Beneficial-Ownership Register Statusno_changeMontana has no state-level BO registry; federal CTA reporting is the only applicable layer.
T5 · Crypto / VASP Regulatory FrameworkescalatingRising CSI-reported crypto-ATM fraud losses ($3.4M in 2025) and a live Blockchain and Digital Innovation Task Force discussing MTL-style policy responses.
T6 · Sanctions Regime Divergenceno_changeNot applicable at the US-MT subnational level.
Registers

Enforcement actions

  • State securities regulators, including Montana's, formally warned Congress that the CLARITY Act's market-structure provisions could strip states of authority to pursue crypto fraud, at a moment when crypto criminal activity is rising alongside record investor demand. 2 Oct 2025
  • OCC granted conditional national trust bank charters to five digital-asset firms, permitting nationwide custody, settlement and fiduciary crypto services without state-by-state chartering, superseding state licensing regimes including Montana's. 12 Dec 2025
  • FinCEN issued an interim final rule removing the requirement for all US-formed companies and their beneficial owners to report beneficial ownership information under the Corporate Transparency Act, retaining reporting only for foreign entities registered to do business in a US state. 26 Mar 2025
  • FinCEN designated Huione Group as a foreign financial institution of primary money laundering concern under Section 311 special measures, following identification of over $4 billion in illicit proceeds laundered through the group, applicable nationwide including to Montana-domiciled financial institutions' sanctions/AML screening obligations. 1 Oct 2025

Sanctions changes

  • OFAC and UK's OFSI dually sanctioned Chen Zhi, Prince Group, and Jin Bei Group Co. Ltd for operating Cambodia-based scam compounds tied to forced labor and cryptocurrency fraud, alongside a DOJ indictment and a $15 billion Bitcoin seizure. 30 Oct 2025
  • OFAC designated six individuals and two entities for facilitating North Korean IT-worker schemes that generated nearly $800 million in 2024 to fund DPRK weapons of mass destruction and ballistic missile programs, applicable to all US financial institutions' sanctions screening, including any Montana-based firms unwittingly engaging DPRK-linked remote IT contractors. 12 Mar 2026
  • President Trump's March 2025 executive order established a US Strategic Bitcoin Reserve and a separate digital-asset stockpile, centralizing forfeited/seized crypto assets rather than auctioning them, changing the national posture on asset disposition that Montana law-enforcement forfeiture referrals now feed into. 6 Mar 2025

Regulatory horizon (register)

  • GENIUS Act stablecoin AML/sanctions implementing rules
  • FinCEN AML/CFT Program reform final rule
  • CLARITY Act crypto market-structure bill Senate action

Active schemes

  • [HIGH] Anonymous LLC formation post-CTA rollback
  • Crypto MLM/pyramid fraud targeting Montana residents
  • Federal preemption erodes state crypto oversight
Sources
  1. FinCEN / US Department of the Treasury
  2. FinCEN / US Department of the Treasury
  3. ICIJ
  4. Bloomberg
  5. Bloomberg
  6. ICIJ
  7. Chainalysis
  8. FinCEN / US Department of the Treasury
Coverage gaps
The March 2025 federal CTA/BOI rollback removed the last tra…
The March 2025 federal CTA/BOI rollback removed the last transparency backstop for beneficial ownership of Montana-formed domestic entities; Montana itself collects no beneficial-ownership information at LLC/corporate formation, leaving no public or law-enforcement-accessible register of true owners for the large majority of Montana legal entities.
Federal actions in 2025-2026 (OCC national trust charters by…
Federal actions in 2025-2026 (OCC national trust charters bypassing state licensure; pending CLARITY Act preemption of state crypto enforcement scope) are structurally reducing Montana's independent supervisory reach over digital-asset firms operating in or serving the state.
Publicly available, Montana-specific BSA/AML enforcement act…
Publicly available, Montana-specific BSA/AML enforcement action documentation within the 18-month baseline window is sparse; most identifiable AML/CTF/CPF-relevant events touching Montana are national-level FinCEN/OFAC/OCC actions with indirect state nexus rather than actions taken directly by or against Montana-domiciled entities.
State money-transmitter regulators nationally, including in …
State money-transmitter regulators nationally, including in smaller states like Montana, have historically operated with constrained examiner resources relative to the scale of the money-services and digital-asset industry they are tasked with supervising, a structural tension long noted by the Money Transmitter Regulators Association.

Evidence

Confidence-tiered claims

No structured claims published for this jurisdiction yet.