D1 Sanctions
Sanctions is not yet covered for this jurisdiction in this report.
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.
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.
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.
Sanctions is not yet covered for this jurisdiction in this report.
Beneficial Ownership is not yet covered for this jurisdiction in this report.
Enabler Jurisdictions is not yet covered for this jurisdiction in this report.
Conflict Finance is not yet covered for this jurisdiction in this report.
Crypto / Digital Assets / Financial Innovation is not yet covered for this jurisdiction in this report.
Compliance Technology & Active Defence is not yet covered for this jurisdiction in this report.
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.
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.
Commercial Activity is not yet covered for this jurisdiction in this report.
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.
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.
No material change for this persona this cycle
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.
No material change for this persona this cycle
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.
No material change for this persona this cycle
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.
FinCEN has proposed a fundamental reform of AML/CFT program requirements that would mandate CFT integration across bank, casino, and MSB programs.
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.
No material change this cycle.
A federal AML/CFT program-rule overhaul is in consultation and would affect regulated money-transmitter and gambling-operator licensees once finalised.
No material change this cycle.
FinCEN's proposed BSA AML/CFT program-rule reform is a structural federal development with downstream effect on NH-licensed money transmitters.
No material change this cycle.
The NH Banking Department's 2025 order to show cause against BAM Trading Services Inc.
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.
| Tracker | Status | Note |
|---|---|---|
| T1 · Russian Sanctions-Evasion Architecture | stable | No material change identified in Russian sanctions-evasion architecture specific to US-NH this cycle. |
| T2 · EU AML Package / AMLA | no_change | Not applicable to US-NH; not an EEA/UK jurisdiction. |
| T3 · FATF Grey List | no_change | No change to US FATF standing this cycle; not directly applicable at the US-NH subnational level. |
| T4 · Beneficial-Ownership Register Status | no_change | No NH-specific beneficial-ownership registry development identified this cycle. |
| T5 · Crypto & Digital-Asset Integrity | stable | NH's HB 639 node/mining/staking money-transmitter exemption remains the standing position; no new development this cycle. |
| T6 · Sanctions Regime Divergence | no_change | No new US/EU/UK autonomous-listing divergence material identified this cycle bearing on US-NH. |