Final rule: Special measure regarding Huione Group (90 FR 48295) (Part 1 of 2)

Bitcoin Research — Law, Regulation, Markets & Origins (2026)

Fincen

1

2025-10-16

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Research, not advice. Part of the Bitcoin research archive (October 2026). Claims labelled unverified, contested or fringe are reported, not endorsed; statuses of bills and rules are as of the date checked. Government, court and patent records are public domain; the research notes are CC BY 4.0.

48295

                                            Rules and Regulations                                                                                          Federal Register
                                                                                                                                                           Vol. 90, No. 198

                                                                                                                                                           Thursday, October 16, 2025

                                            This section of the FEDERAL REGISTER                       • One or more financial institutions                Secretary is required to consult with
                                            contains regulatory documents having general            operating outside of the United States;                both the Secretary of State and the
                                            applicability and legal effect, most of which              • One or more classes of transactions               Attorney General.5 In addition, in the
                                            are keyed to and codified in the Code of                within, or involving, a jurisdiction                   case of a decision to apply one or more
                                            Federal Regulations, which is published under           outside of the United States; or                       of the special measures, in making a
                                            50 titles pursuant to 44 U.S.C. 1510.                      • One or more types of accounts.’’ 1                finding that reasonable grounds exist for
                                                                                                       Upon making such a finding, the                     concluding that a financial institution
                                            The Code of Federal Regulations is sold by
                                            the Superintendent of Documents.                        Secretary is authorized to require                     outside of the United States is of
                                                                                                    domestic financial institutions and                    primary money laundering concern, the
                                                                                                    domestic financial agencies to take                    Secretary is required to consider such
                                            DEPARTMENT OF THE TREASURY                              certain ‘‘special measures.’’ 2 The five               information as the Secretary determines
                                                                                                    special measures set out in section 311                to be relevant, including the following
                                            Financial Crimes Enforcement Network                    are safeguards that may be employed to                 potentially relevant institutional factors:
                                                                                                    defend the U.S. financial system from                     • The extent to which such a
                                            31 CFR Part 1010                                        money laundering and terrorist                         financial institution is used to facilitate
                                                                                                    financing risks. The Secretary may                     or promote money laundering in or
                                            RIN 1506–AB68                                           impose one or more of these special                    through a jurisdiction outside the
                                                                                                    measures to protect the U.S. financial                 United States, including any money
                                            Imposition of Special Measure                           system from such threats. Through                      laundering activity by organized
                                            Regarding Huione Group, as a Foreign                    special measures one through four, the                 criminal groups, international terrorists,
                                            Financial Institution of Primary Money                  Secretary may impose additional                        or entities involved in the proliferation
                                            Laundering Concern                                      recordkeeping, information collection,                 of weapons of mass destruction (WMD)
                                                                                                    and reporting requirements on covered                  or missiles;
                                            AGENCY: Financial Crimes Enforcement
                                            Network (FinCEN), Treasury.
                                                                                                    domestic financial institutions and                       • The extent to which such a
                                                                                                    domestic financial agencies—                           financial institution is used for
                                            ACTION: Final rule.                                     collectively, ‘‘covered financial                      legitimate business purposes in the
                                                                                                    institutions.’’ 3 Through special measure              jurisdiction; and
                                            SUMMARY: FinCEN is issuing this final
                                                                                                    five, the Secretary may ‘‘prohibit, or                    • The extent to which such action is
                                            rule to prohibit covered U.S. financial
                                                                                                    impose conditions upon, the opening or                 sufficient to ensure, with respect to
                                            institutions from opening or
                                                                                                    maintaining in the United States of a                  transactions involving the jurisdiction
                                            maintaining a correspondent account
                                                                                                    correspondent account or payable-                      and institutions operating in the
                                            for, or on behalf of Huione Group, a
                                                                                                    through account’’ for or on behalf of a                jurisdiction, that the purposes of section
                                            foreign financial institution based in
                                                                                                    foreign banking institution, if such                   311 continue to be fulfilled, and to
                                            Cambodia found to be of primary money
                                                                                                    correspondent account or payable-                      guard against international money
                                            laundering concern pursuant to section
                                                                                                    through account involves the foreign                   laundering and other financial crimes.6
                                            311 of the USA PATRIOT Act. The rule                    financial institution found to be of                      In selecting one or more special
                                            further requires covered financial                      primary money laundering concern.4                     measures, the Secretary ‘‘shall consult
                                            institutions to apply special due                          Before making a finding that                        with the Chairman of the Board of
                                            diligence to their foreign correspondent                reasonable grounds exist for concluding                Governors of the Federal Reserve
                                            accounts that is reasonably designed to                 that a financial institution outside of the            System, any other appropriate Federal
                                            guard against the use of such accounts                  United States (or other jurisdiction,                  banking agency (as defined in section 3
                                            to process transactions involving                       account, or class of transactions) is of               of the Federal Deposit Insurance Act),
                                            Huione Group.                                           primary money laundering concern, the                  the Secretary of State, the Securities and
                                            DATES: This final rule is effective                                                                            Exchange Commission, the Commodity
                                            November 17, 2025.                                        1 31 U.S.C. 5318A(a)(1).                             Futures Trading Commission, the
                                            FOR FURTHER INFORMATION CONTACT:
                                                                                                       2 On October 26, 2001, the President signed into
                                                                                                                                                           National Credit Union Administration
                                                                                                    law the Uniting and Strengthening America by           Board, and in the sole discretion of the
                                            FinCEN’s Regulatory Support Section at                  Providing Appropriate Tools Required to Intercept
                                            www.fincen.gov/contact.                                 and Obstruct Terrorism Act of 2001, Public Law         Secretary, such other agencies and
                                            SUPPLEMENTARY INFORMATION:                              107–56 (USA PATRIOT Act). Title III of the USA         interested parties as the Secretary may
                                                                                                    PATRIOT Act amended the anti-money laundering          find appropriate.’’ 7 When imposing
                                            I. Background                                           (AML) provisions of the Bank Secrecy Act (BSA) to
                                                                                                    promote the prevention, detection, and prosecution
                                                                                                                                                           special measure five, the Secretary must
                                            A. Statutory Provisions                                 of international money laundering and the              do so ‘‘in consultation with the
                                                                                                    financing of terrorism. The BSA, as amended, is the    Secretary of State, the Attorney General,
                                              Section 311 of the USA PATRIOT Act                    popular name for a collection of statutory             and the Chairman of the Board of
                                            (section 311), codified at 31 U.S.C.                    authorities that FinCEN administers that is codified
                                                                                                    at 12 U.S.C. 1829b, 1951–1960 and 31 U.S.C. 5311–
                                                                                                                                                           Governors of the Federal Reserve
                                            5318A, grants the Secretary of the                      5314, 5316–5336, and includes other authorities
                                            Treasury (Secretary) the authority to                   reflected in notes thereto. Regulations                  5 31 U.S.C. 5318A(c)(1).

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                                            make a finding that ‘‘reasonable grounds                implementing the BSA appear at 31 CFR Chapter             6 31 U.S.C. 5318A(c)(2)(B)(i)–(iii). In addition, in

                                            exist for concluding’’ that any of the                  X.                                                     the case of a finding relating to a particular
                                                                                                       3 31 U.S.C. 5318A(b)(1)–(4). The term ‘‘covered     jurisdiction, section 311 sets out certain
                                            following ‘‘is of primary money
                                                                                                    financial institution’’ has the same meaning as        ‘‘jurisdictional factors’’ that the Secretary may
                                            laundering concern:                                     provided at 31 CFR 1010.605(e)(1); see infra section   consider, which are not relevant here. See 31 U.S.C.
                                              • A jurisdiction outside of the United                IV.A.3.                                                5318A(c)(2)(A)(i)–(vii).
                                            States;                                                    4 31 U.S.C. 5318A(b)(5).                               7 31 U.S.C. 5318A(a)(4)(A).

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                                            48296            Federal Register / Vol. 90, No. 198 / Thursday, October 16, 2025 / Rules and Regulations

                                            System.’’ 8 In addition, the Secretary is                 parent company of, or otherwise                        foreign financial institution of primary
                                            required to consider the following                        controls, several subsidiaries, affiliates,            money laundering concern pursuant to
                                            factors:                                                  and components—including, but not                      31 U.S.C. 5318A.17
                                               • Whether similar action has been or                   limited to: Haowang Guarantee, Huione                     As described in the NPRM, since its
                                            is being taken by other nations or                        Pay PLC, and Huione Crypto (the                        establishment, Huione Group has set up
                                            multilateral groups;                                      ‘‘Components’’)—that coordinate to                     a network of businesses, each playing a
                                               • Whether the imposition of any                        provide services that are useful for                   different role in its money laundering
                                            particular special measure would create                   money laundering and carrying out                      enterprise. However, FinCEN’s analysis
                                            a significant competitive disadvantage,                   cyber scams. FinCEN assesses that, as
                                            including any undue cost or burden                                                                               of Huione Group has identified the
                                                                                                      discussed below, Huione Group and its
                                            associated with compliance, for                                                                                  sharing of CVC infrastructure by Huione
                                                                                                      Components operate as a coordinated
                                            financial institutions organized or                                                                              Group’s constituent entities, indicating
                                                                                                      collective, and for that reason, FinCEN
                                            licensed in the United States;                                                                                   that the entities, including the
                                                                                                      will correspondingly refer to Huione
                                               • The extent to which the action or                                                                           controlling entity Huione Group, are
                                                                                                      Group and its Components as the
                                            the timing of the action would have a                                                                            functionally operating as one and the
                                                                                                      ‘‘Huione Group.’’
                                            significant adverse systemic impact on                       Although it was originally                          same, despite the various branding.
                                            the international payment, clearance,                     incorporated in Hong Kong in 2018 as                   Because Huione Group shares CVC
                                            and settlement system, or on legitimate                   Huione Group Limited, Huione Group,                    infrastructure, the structure makes it
                                            business activities involving the                         the controlling entity of the                          challenging to ascertain the specific
                                            particular jurisdiction, institution, class               conglomerate, does not appear to be                    Component involved in any particular
                                            of transactions, or type of account; and                  registered as a business in any                        transaction.
                                               • The effect of the action on United                   jurisdiction,13 and several of Huione                     The overall Huione Group network
                                            States national security and foreign                      Group’s Components have been                           offers services ranging from an online
                                            policy.9                                                  registered outside of Cambodia.                        marketplace selling items useful for
                                               The authority of the Secretary to                      Nevertheless, Huione Group’s website is                carrying out cyber scams to money
                                            administer the Bank Secrecy Act (BSA)                     registered 14 to an individual with a                  laundering services that accept both fiat
                                            and its implementing regulations,                         listed location of Phnom Penh,                         currencies and CVC. Huione Group has
                                            including the authority under section                     Cambodia and Huione Group’s                            also created its own stablecoin, a type
                                            311 to make such a finding and to                         operations are principally carried out in              of CVC that is usually backed by a pre-
                                            impose special measures, has been                         Cambodia.                                              determined quantity of fiat currency,
                                            delegated to the Director of FinCEN.10                       For years, Huione Group has                         most often the U.S. dollar (USD). The
                                            B. Huione Group                                           laundered illicit proceeds from                        stablecoin, ‘‘USDH,’’ which is a ticker
                                                                                                      cybercrimes—namely, cyber heists                       symbol for ‘‘U.S. Dollar Huione,’’ is
                                              Huione Group 11 is a financial                          carried out by the Lazarus Group,15 an                 pegged to the USD at a one-to-one ratio
                                            services conglomerate based in Phnom                      entity sanctioned by Treasury’s Office of              and is represented as a stablecoin that
                                            Penh, Cambodia.12 Huione Group is the                     Foreign Assets Control (OFAC)—and                      cannot be frozen.18 In contrast, many
                                                                                                      Convertible Virtual Currency (CVC)                     stablecoin issuers develop their
                                              8 31 U.S.C. 5318A(b)(5).
                                              9 31 U.S.C. 5318A(a)(4)(B)(i)–(iv).
                                                                                                      investment scams carried out by                        stablecoins to retain the ability to freeze
                                              10 See Treasury Order 180–01 (Jan. 14, 2020).
                                                                                                      transnational criminal organizations                   funds, which they have sometimes done
                                               11 Huione Group is the parent company of several       (TCOs) based in Southeast Asia.16                      in cases of known criminal activity, or
                                            subsidiaries and components, including Haowang            II. FinCEN’s Section 311 Rulemaking                    at the request of law enforcement.
                                            Guarantee, Huione Pay PLC, and Huione Crypto.                                                                    Because Huione Group claims that
                                            FinCEN assesses that this grouping of exchange            Regarding Huione Group
                                            services operates as a coordinative collective, and
                                                                                                                                                             USDH cannot be frozen, this service
                                                                                                         In a notice of proposed rulemaking                  offers Huione Group’s clientele a
                                            for that reason, FinCEN will correspondingly refer
                                            to the collective as the ‘‘Huione Group.’’                (NPRM) published in the Federal                        virtually risk-free ecosystem to move or
                                               12 Cambodia Corporate Registry, ‘‘Huione’’             Register on May 5, 2025, FinCEN found                  store CVC without the possibility of
                                            Search, https://www.businessregistration.                 that reasonable grounds exist for                      interception or ‘‘freezing’’ by law
                                            moc.gov.kh/cambodia-master/service/create.html?           concluding that Huione Group is a
                                            targetAppCode=cambodia-master&                                                                                   enforcement.
                                            targetRegisterAppCode=cambodia-br-                          13 Hong Kong Companies Registry, Huione Group           Indeed, much of the illicit revenue
                                            companies&service=registerItemSearch (last
                                            accessed Oct. 7, 2025); Huione Pay, Index, formerly       Limited, at p. 54, https://www.cr.gov.hk/docs/wrpt/    laundered through Huione Group
                                            available at https://www.huionepay.com.kh/index/          RNC063_2018.12.17-2018.12.23.pdf.                      originates from well-documented
                                                                                                        14 The registration is valid through June 3, 2026.
                                            help; Huione Group, About, which is no longer                                                                    criminal activity, and numerous
                                            accessible and will be discussed later in this            See ICANN, Huione.com, https://lookup.icann.org/
                                                                                                      en/huione.com (last accessed Oct. 7, 2025).
                                                                                                                                                             publicly available reports describe the
                                            section, formerly available at https://huione.com/
                                            html/about.jsp (last accessed Sept. 24, 2024).              15 The Lazarus Group is an agency,                   failings of Huione Group’s anti-money
                                            Huione Crypto has numerous job announcements              instrumentality, or controlled entity of the           laundering/know your customer (AML/
                                            with a work location in Phnom Penh, Cambodia.             government of the Democratic People’s Republic of      KYC) program. Despite these reports
                                            See Huione Crypto, Career Opportunities, formerly         Korea, that has stolen large volumes of Convertible    and Huione Group’s public
                                            available at https://www.huione.io/en-US/                 Virtual Currency in numerous and often widely
                                            careerOpportunities (last accessed Mar. 27, 2025).        reported cyber heists. On September 13, 2019, the
                                                                                                      Lazarus Group was sanctioned by OFAC. See                17 FinCEN, Special Measure Regarding Huione
                                            Haowang Guarantee also lists job announcements
                                            with a work location in Phnom Penh, Cambodia.             Department of the Treasury, Press Release, Treasury    Group, as a Foreign Financial Institution of Primary
                                            See Haowang Guarantee, About, formerly available          Sanctions North Korean State-Sponsored Malicious       Money Laundering Concern, 90 FR 18934 (May 5,
                                            at https://www.hwdb.la/about/ (last accessed Mar.         Cyber Groups, (Sept. 13, 2019), https://               2025).
                                                                                                      home.treasury.gov/news/press-releases/sm774.

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                                            27, 2025). This information was previously                                                                         18 See https://huione.money (website for ‘‘USDH

                                            available as of the issuance of the NPRM, however,          16 These scams are also referred to as ‘‘pig         (Huione USD), Stablecoin that Never be freezed’’
                                            it has since been removed by Haowang Guarantee,           butchering.’’ See FinCEN, FIN–2023–Alert005,           describing USDH as ‘‘[a] stablecoin pegged 1:1 to
                                            resulting in a ‘‘page not found’’ error. FinCEN           FinCEN Alert on Prevalent Virtual Currency             the US Dollar launched by Huione Labs under
                                            assesses that this change is more likely than not         Investment Scam Commonly Known as ‘‘Pig                Huione Group.’’); Huione Crypto, USDH is a stable
                                            caused by negative public attention following a           Butchering’’ (Sept. 8, 2023), https://                 currency in one word!, formerly available at https://
                                            series of reports by blockchain analytic firms on         www.fincen.gov/sites/default/files/shared/FinCEN_      huione.io/en-us/introduce (last accessed Mar. 27,
                                            money laundering occurring at Huione Group.               Alert_Pig_Butchering_FINAL_508c.pdf.                   2025).

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                                                             Federal Register / Vol. 90, No. 198 / Thursday, October 16, 2025 / Rules and Regulations                                                  48297

                                            acknowledgments of its failings,19                         The BSA defines a ‘‘financial                        Guarantee; Huione Pay PLC; and Huione
                                            FinCEN assesses that Huione Group has                   institution’’ to be any of several                      Crypto. FinCEN finds that reasonable
                                            no meaningful AML/KYC program, even                     categories of entities, including money                 grounds exist to conclude that Huione
                                            after FinCEN issued the NPRM on May                     transmitters.23 The BSA defines a                       Group and each of the Components
                                            5, 2025.20                                              money transmitter as including ‘‘a                      engages in the business of money
                                               This Final Rule (1) sets forth                       licensed sender of money or any other                   transmission, and is therefore a
                                            FinCEN’s finding, based on public and                   person who engages as a business in the                 financial institution under the BSA and
                                            non-public information, that Huione                     transmission of currency funds, or value                its implementing regulations.
                                            Group is a financial institution                        that substitutes for currency.’’ 24 A
                                            operating outside of the United States of                                                                       a. Huione Group
                                                                                                    money transmitter does not require a
                                            primary money laundering concern; and                   particular license, corporate structure,                   Huione Group is a Cambodia based,
                                            (2) imposes special measure five, which                 or physical location.                                   Hong Kong-registered,28 sole
                                            prohibits covered financial institutions                   As detailed further below, much of                   proprietorship founded in or around
                                            from opening or maintaining a                           Huione Group’s illicit money                            2014, that appears to be owned and
                                            correspondent account for, or on behalf                 transmitting activity occurs through                    controlled by an individual Cambodian
                                            of, Huione Group.                                       transactions in CVC. This is consistent                 national,29 and at times holds itself out
                                            A. Findings                                             with the money transmitter definition,                  as the parent entity of the
                                                                                                    which includes services in CVC.                         Components.30 By its own account,
                                               Section 311 authorizes FinCEN,                       FinCEN’s 2019 Guidance on CVC                           Huione Group began as a fiat currency
                                            through delegated authority and in                      explains that for the purposes of the                   exchange service and over the past
                                            relevant part, to make a finding ‘‘that                 BSA’s implementing regulations,                         decade, expanded its commercial
                                            reasonable grounds exist for                            persons ‘‘may be a money transmitter                    interests to include finance, insurance,
                                            concluding’’ that ‘‘[one] or more                       . . . regardless of the technology                      real estate entities,31 and most recently,
                                            financial institutions operating outside                employed for the transmittal of value or                CVC exchange services.32 The
                                            of the United States’’ is ‘‘of primary                  the type of asset the person uses as                    Components operate in an
                                            money laundering concern.’’ 21 A                        value that substitutes for currency, or                 interconnected fashion to provide an
                                            prerequisite to such a finding is that the              whether such asset is physical or                       integrated payment service provider,
                                            relevant institution is a ‘‘financial                   virtual.’’ 25 For the reasons explained in              illicit online market, and CVC
                                            institution operating outside of the                    that Guidance, the term ‘‘value that                    exchanger (a type of virtual asset service
                                            United States.’’ 22                                     substitutes for currency’’ includes                     provider or VASP).
                                               19 Following negative public reporting about
                                                                                                    CVC.26                                                     Huione Group, as an individual
                                            Huione Group in July 2024, Huione Group provided                                                                entity, coordinates the Components’
                                                                                                    1. Huione Group and Its Identified
                                            a statement to ABC News, stating that ‘‘. . . because                                                           activities by operating the customer
                                                                                                    Components Are Each a Financial
                                            our [Huione Group’s] services are all public,                                                                   service and public relations functions of
                                            covering Asia, Europe and America, and the privacy      Institution
                                            attributes of [CVC] are superimposed, our KYC
                                            [know your customer] capabilities are now
                                                                                                       Huione Group is a parent entity that                    28 Hong Kong Companies Registry, Huione Group

                                                                                                    controls the following constituent                      Limited, at p. 54, https://www.cr.gov.hk/docs/wrpt/
                                            seriously insufficient.’’ See ABC News, Cambodian
                                                                                                                                                            RNC063_2018.12.17-2018.12.23.pdf.
                                            online marketplace outed as one-stop shop for           entities or Components: 27 Haowang                         29 See The Record, Tether freezes $29 million of
                                            scammers’ money laundering and ‘detention
                                            equipment’ needs (July 26, 2024), https://                                                                      cryptocurrency connected to Cambodian
                                                                                                    authorizes ‘‘Prohibitions or Conditions on Opening      marketplace accused of fueling scams (July 15,
                                            www.abc.net.au/news/2024-07-27/online-
                                                                                                    or Maintaining Certain Correspondent or Payable-        2024), https://therecord.media/tether-freezes-29-
                                            marketplace-for-money-laundering-and-scammers/
                                                                                                    Through Accounts.’’ The statute goes on to define       million-crypto-connected-to-scam-marketplace.
                                            104131624; see also The Record, Tether freezes $29
                                                                                                    the terms correspondent account and payable-               30 See, e.g., Elliptic, Huione: The Company
                                            million of cryptocurrency connected to Cambodian
                                                                                                    through account in reference to payments made on        Behind the Largest Ever Illicit Online Marketplace
                                            marketplace accused of fueling scams (July 15,
                                                                                                    behalf of a ‘‘foreign financial institution’’—a term    Has Launched a Stablecoin (Jan. 14, 2025), https://
                                            2024), https://therecord.media/tether-freezes-29-
                                                                                                    otherwise undefined. For the purposes of this final     www.elliptic.co/blog/huione-largest-ever-illicit-
                                            million-crypto-connected-to-scam-marketplace;
                                            Elliptic, Huione Guarantee: The multi-billion dollar    rule, and under these facts, FinCEN finds that          online-marketplace-stablecoin; Elliptic, Huione
                                            marketplace used by online scammers (July 9, 2024,      Huione Group is both a foreign financial institution    Guarantee: The multi-billion dollar marketplace
                                            updated Mar. 27, 2025), https://www.elliptic.co/        and a financial institution outside of the United       used by online scammers (July 9, 2024, updated
                                            blog/cyber-scam-marketplace; Elliptic, Huione: The      States.                                                 Mar. 27, 2025), https://www.elliptic.co/blog/cyber-
                                                                                                       23 See 31 U.S.C. 5312(a)(2).
                                            Company Behind the Largest Ever Illicit Online                                                                  scam-marketplace; Chainalysis, 2024 Crypto Crime
                                                                                                       24 31 U.S.C. 5312(a)(2)(R) (allowing ‘‘a licensed
                                            Marketplace Has Launched a Stablecoin (Jan. 14,                                                                 Mid-year Update Part 2: China-based CSAM and
                                            2025), https://www.elliptic.co/blog/huione-largest-     sender of money or any other person . . .’’ to          Cybercrime Networks on the Rise, Pig Butchering
                                            ever-illicit-online-marketplace-stablecoin;             constitute money transmitter). FinCEN’s                 Scams Remain Lucrative (Aug. 29, 2024), https://
                                            Chainalysis, 2024 Crypto Crime Mid-year Update          implementing regulations define ‘‘person’’ broadly      www.chainalysis.com/blog/2024-crypto-crime-mid-
                                            Part 2: China-based CSAM and Cybercrime                 as ‘‘an individual, a corporation, a partnership, a     year-update-part-2/; ABC News, Cambodian online
                                            Networks on the Rise, Pig Butchering Scams              trust or estate, a joint stock company, an              marketplace outed as one-stop shop for scammers’
                                            Remain Lucrative (Aug. 29, 2024), https://              association, a syndicate, joint venture, or other       money laundering and ‘detention equipment’ needs
                                            www.chainalysis.com/blog/2024-crypto-crime-mid-         unincorporated organization or group, an Indian         (July 26, 2024), https://www.abc.net.au/news/2024-
                                            year-update-part-2/.                                    Tribe (as that term is defined in the Indian Gaming     07-27/online-marketplace-for-money-laundering-
                                               20 In a June 18, 2025 comment on the NRPM,           Regulatory Act), and all entities cognizable as legal   and-scammers/104131624; Huione Crypto, Terms
                                            outside counsel for Huione Pay PLC claimed that         personalities.’’ 31 CFR 1010.100(mm).                   and Conditions, formerly available at https://
                                            ‘‘Huione Pay PLC is an independent entity and is           25 FinCEN, FIN–2019–G001, Application of             www.huione.io/en-US/termsAndConditions/
                                            undertaking substantial efforts to address and          FinCEN’s Regulations to Certain Business Models         userAgreement (last accessed Mar. 27, 2025). The
                                            remediate compliance issues raised by the [NPRM]’’      Involving Convertible Virtual Currencies (May 9,        Huione Group website is no longer accessible,
                                            For reasons explained in Section II.C.1, FinCEN         2019), at Section 1.2.3, https://www.fincen.gov/        which FinCEN assesses is likely a response to
                                            continues to assess that Huione Pay PLC is a            sites/default/files/2019-05/                            negative public attention following a series of
                                            component of Huione Group. See infra Section            FinCEN%20Guidance%20                                    reports by blockchain analytic firms on money

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                                            II.C.1.                                                 CVC%20FINAL%20508.pdf.                                  laundering occurring at Huione Group.
                                               21 31 U.S.C. 5318A(a)(1).                               26 Id. at Sections 1.2.1, 1.3.                          31 Huione Group, Who We Are, formerly available
                                               22 31 U.S.C. 5318A(a)(1) authorizes the                 27 As explained further in Section II.B, since the   at https://www.huione.com/html/about.jsp (last
                                            imposition of special measures on, among others,        NPRM was issued, Huione Group changed its               accessed Sept. 24, 2024).
                                            ‘‘financial institutions operating outside of the       business structure in an apparent effort to counter        32 Huione Crypto, Introduce, formerly available at

                                            United States.’’ Of the five special measures           governmental scrutiny, including the special            https://www.huione.io/en-US/introduce (last
                                            authorized by the statute, the fifth measure            measure proposed in FinCEN’s May 2025 NPRM.             accessed Mar. 26, 2025).

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                                            48298            Federal Register / Vol. 90, No. 198 / Thursday, October 16, 2025 / Rules and Regulations

                                            the Huione Group. Huione Group                          Guarantee was rebranded as Haowang                      and determined it had processed at least
                                            historically does this by hosting                       Guarantee, announcing the change on                     USD 49 billion worth of CVC since
                                            Telegram channels 33 to aid customers                   September 30, 2024, and offering                        2021. Chainalysis also determined that
                                            experiencing problems with the services                 customer discount following the                         merchants operating on Haowang
                                            that the Components provide.34 One of                   rebrand to thank its long-term                          Guarantee’s marketplace offered various
                                            Huione Group’s Telegram channels also                   customers.37 The reason for the                         illicit services, including the
                                            provides public relations commentary                    Haowang Guarantee rebrand is unclear,                   technology, infrastructure, and
                                            on behalf of the whole of the Huione                    although FinCEN assesses that it could                  resources to conduct cyber scams.43
                                            Group network. On March 9, 2025, that                   be to distance itself from the negative                    In addition, Elliptic reports that
                                            public relations channel responded to                   public reporting about Huione Group.38                  Haowang Guarantee provides money
                                            counter news media reports that the                        Multiple blockchain analytic firms                   laundering services to criminal
                                            Cambodian government revoked Huione                     have analyzed and reported on                           organizations, helping them transfer the
                                            Pay PLC’s banking license.35 Through                    Haowang Guarantee for facilitating the                  proceeds of investment frauds and other
                                            coordination by Huione Group, Huione                    sale of contraband and illicit services.                cyber scams to the legitimate banking
                                            Group’s Components all share CVC                        For example, a public report issued by                  sector undetected.44 Because Haowang
                                            infrastructure, making it challenging to                blockchain analytics company Elliptic                   Guarantee offers ‘‘virtual digital
                                            ascertain the specific Component                        found that Haowang Guarantee appears                    products and transaction services’’ and
                                            involved in a particular transaction.                   to operate in a manner similar to a                     facilitates CVC transactions, FinCEN
                                               FinCEN finds that reasonable grounds                 darknet market.39 This assessment is                    finds that there are reasonable grounds
                                            exist to conclude that Huione Group is                  based on the fact that Haowang                          to conclude that it is engaged as a
                                            a money transmitter. By providing                       Guarantee offers a marketplace where                    business in the transmission of value
                                            customer service and public relations                   third party merchants can sell goods                    that substitutes for currency.
                                            services on behalf of the Components,                   and services, including money                           Accordingly, FinCEN finds that
                                            Huione Group is itself part of a network                laundering services and equipment that                  reasonable grounds exist to conclude
                                            of people who engage as a business in                   can be used to detain people, which                     that Haowang Guarantee is a financial
                                            facilitating the transfer of money.                     could be used for illicit purposes such                 institution as that term is used in the
                                            Furthermore, through Huione Group’s                     as human trafficking.40 While FinCEN                    BSA and section 311.
                                            apparent control of the Components                      does not have evidence that Haowang
                                                                                                                                                            c. Huione Pay PLC
                                            (each of which is itself a money                        Guarantee operates on the darknet,
                                            transmitter and responds to Huione                      FinCEN assesses that Haowang                               As of January 2025, Huione Pay PLC
                                                                                                    Guarantee deals in the sale of illicit                  was registered as a payment services
                                            Group’s coordination of the
                                                                                                    goods and services in a manner similar                  institution with the National Bank of
                                            Components’ business activities such
                                                                                                    to a darknet market but on the open                     Cambodia.45 On March 6, 2025, a media
                                            that they form a self-contained
                                                                                                    internet.41                                             report indicated that Huione Pay PLC’s
                                            ecosystem of exchange, payment, and
                                                                                                       Chainalysis, a separate blockchain                   banking license was revoked by the
                                            market services), Huione Group is
                                                                                                    analytics company, found similar                        Cambodian government.46 According to
                                            engaged as a business in the
                                                                                                    results. In its 2024 Crypto Crime Mid-                  a July 31, 2025 update, the National
                                            transmission of value that substitutes for
                                                                                                    Year Update Report, it determined that                  Bank of Cambodia rescinded this license
                                            currency. Accordingly, FinCEN finds
                                            that reasonable grounds exist to                        Haowang Guarantee operates as a peer-
                                                                                                                                                              43 Id.
                                            conclude that Huione Group is a                         to-peer marketplace that connects
                                                                                                                                                               44 Elliptic, Huione: The Company Behind the
                                            financial institution as defined by the                 buyers and sellers and facilitates
                                                                                                                                                            Largest Ever Illicit Online Marketplace Has
                                            BSA and as that term is used in section                 transactions.42 Chainalysis reviewed                    Launched a Stablecoin (Jan. 14, 2025), https://
                                            311.                                                    blockchain data of Haowang Guarantee                    www.elliptic.co/blog/huione-largest-ever-illicit-
                                                                                                                                                            online-marketplace-stablecoin.
                                            b. Haowang Guarantee (Formerly                             37 Telegram, Haowang Guarantee Customer                 45 National Bank of Cambodia, List of Payment

                                                                                                                                                            Service Institutions (Dec. 31, 2024), https://
                                            Huione Guarantee)                                       Service Channel (Sept. 30, 2024), formerly available
                                                                                                                                                            www.nbc.gov.kh/english/supervision/payment_
                                                                                                    at https://t.me/s/kefu (last accessed Mar. 27, 2025).
                                               Haowang Guarantee described itself                      38 See supra note 30.                                service.php (last accessed Mar. 21, 2025). The
                                            as ‘‘a professional e-commerce platform                    39 Darknet Markets almost exclusively accept CVC
                                                                                                                                                            National Bank of Cambodia’s List of Payment
                                                                                                                                                            Service available on its website only reflects the
                                            that provides users with virtual digital                as payment for a large range of illegal services and    most recent reporting period. As such, the
                                            products and transaction services . . .                 goods, including ransomware-as-a-service (RaaS).        information presented by FinCEN reflects
                                                                                                    CVC is often the payment method of choice on            information that was available at the time indicated,
                                            [that] does not participate in nor                      darknet marketplaces because illicit actors who         in this example, the above mentioned information
                                            understand the specific business of the                 transact on the darknet often incorrectly believe       indicates that as of March 21, 2025, Huione Pay
                                            customer. . . . Huione cannot verify or                 virtual currencies to be an anonymous and               PLC was registered as a payment service institution.
                                            guarantee the process of funds or                       untraceable means of exchange.                          Future references to this list correspondingly
                                                                                                       40 Elliptic, Huione Guarantee: The multi-billion
                                            goods.’’ 36 On October 19, 2024, Huione                                                                         indicate the information as it was available on the
                                                                                                    dollar marketplace used by online scammers (July        date indicated.
                                                                                                    9, 2024, updated Mar. 27, 2025), https://                  46 See Radio Free Asia, Exclusive: World’s Largest
                                              33 Following the issuance of the NPRM, Telegram
                                                                                                    www.elliptic.co/blog/cyber-scam-marketplace.            online black market’ Loses banking license (Mar. 6,
                                            blocked Huione Group’s telegram channels, which            41 For example, Haowang Guarantee has many
                                                                                                                                                            2025), https://www.rfa.org/english/cambodia/2025/
                                            Haowang Guarantee notified customers of on its          similar characteristics to the darknet market           03/06/huione-cambodia-cyberscam-
                                            website. Haowang Guarantee, Announcements,              described here See Department of the Treasury,          cryptocurrency/. Huione Group responded to the
                                            formerly available at https://www.hwbd.la/              Press Release, Treasury Sanctions Russia-Based          allegations, refuting them by noting that Huione Pay
                                            announcement (last accessed May 15, 2025).              Hydra, World’s Largest Darknet Market, and              PLC does not require a banking license for its
                                              34 Telegram, Huione Group Customer Service
                                                                                                    Ransomware-Enabling Virtual Currency Exchange           operations. Telegram, Huione Group Customer
                                            Center, formerly available at https://t.me/huionekf/    Garantex (Apr. 5, 2022), https://home.treasury.gov/

lotter on DSK11XQN23PROD with RULES1
                                                                                                                                                            Service, Huione Statement (Mar. 9, 2025), formerly
                                            138 (last accessed Mar. 27, 2025).                      news/press-releases/jy0701.                             available at https://t.me/huionekf/346. As of March
                                              35 Telegram, Huione Group Customer Service,              42 Chainalysis, 2024 Crypto Crime Mid-year           31, 2025, Huione Pay PLC is no longer listed as
                                            Huione Statement (Mar. 9, 2025), formerly available     Update Part 2: China-based CSAM and Cybercrime          having an active license for ‘‘other financial
                                            at https://t.me/huionekf/346.                           Networks on the Rise, Pig Butchering Scams              services activities.’’ National Bank of Cambodia,
                                              36 Haowang Guarantee, About, formerly available       Remain Lucrative (Aug. 29, 2024), https://              List of Payment Service Institutions (Mar. 31, 2025),
                                            at https://www.hwbd.la/about (last accessed July        www.chainalysis.com/blog/2024-crypto-crime-mid-         https://www.nbc.gov.kh/english/supervision/
                                            28, 2025).                                              year-update-part-2/.                                    payment_service.php (last accessed May 14, 2025).

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                                                             Federal Register / Vol. 90, No. 198 / Thursday, October 16, 2025 / Rules and Regulations                                                48299

                                            by updating its list of ‘‘Payment Service               FinCEN finds that reasonable grounds                   Huione Group website is registered to a
                                            Institutions.’’ 47 Further, as of March                 exist to conclude that Huione Pay PLC                  Cambodian address in Phnom Penh,
                                            2025, Huione Pay PLC was registered                     is a financial institution as that term is             uses a Cambodian Top-Level Domain,
                                            with the Cambodian Ministry of                          used in the BSA and section 311.                       and communicates predominately in the
                                            Commerce for ‘‘other financial service                                                                         Chinese language via a Cambodian
                                                                                                    d. Huione Crypto
                                            activities,’’ however, as of July 29, 2025,                                                                    website and one or more Telegram
                                            it no longer appears in the Ministry of                    Huione Crypto provides CVC trading                  channels operated from Cambodia.58
                                            Commerce’s business registration                        services through its ‘‘Huione Exchange’’               Accordingly, FinCEN finds that
                                            database, indicating that Huione Pay                    brand, which it owns and operates.                     reasonable grounds exist to conclude
                                            PLC lacks an active corporate                           Huione Exchange provides a platform                    that Huione Group is operated from and
                                            registration or payment service                         for its customers to trade CVC using                   located in Cambodia and thus operates
                                            license.48 Until December 2023, there                   either its ‘‘peer to peer’’ or                         outside of the United States.
                                            was a likely related entity, ‘‘Huione                   ‘‘centrali[z]ed exchange platform.’’ 54 In
                                            Pay,’’ registered as a money services                   other words, Huione Crypto is a VASP                   b. Haowang Guarantee (Formerly
                                            business in Canada, which was                           operating under the Huione Group                       Huione Guarantee)
                                            incorporated in the country as Huione                   umbrella, and other Huione Group
                                                                                                                                                              Haowang Guarantee has operated a
                                            Pay Inc.49 In March 2025, Huione Group                  entities use Huione Crypto’s
                                                                                                                                                           Telegram-based marketplace that allows
                                            advertised its plans to expand Huione                   infrastructure to engage in CVC
                                                                                                                                                           its customers to buy and sell goods and
                                            Pay PLC into new markets, including in                  transactions. Separately, Huione Crypto
                                                                                                                                                           services, relying on other Huione Group
                                            North America.50                                        issues the USDH stablecoin.55 By
                                                                                                                                                           services and infrastructure to execute
                                               Huione Pay PLC offers its customers                  facilitating CVC value exchanges for its
                                                                                                                                                           the exchanges. FinCEN assesses that
                                            the ability to trade CVC on different                   customers through its trading platform,
                                                                                                                                                           Haowang Guarantee deliberately
                                            blockchains, and to convert CVC to or                   and by issuing a stablecoin that
                                                                                                                                                           obfuscates its location to shield its
                                            from various fiat currencies; however, as               facilitates the transfer of money outside
                                                                                                    the conventional financial institution                 enterprise and customers from law
                                            of July 30, 2025, the Huione Pay PLC                                                                           enforcement. However, Haowang
                                            website was inaccessible.51 Part of                     systems, Huione Crypto is engaged in
                                                                                                    money transmission as described at 31                  Guarantee is integrated into Huione
                                            Huione Pay PLC, Huione International                                                                           Group’s operations and is apparently
                                            Payments, acts as a merchant on                         U.S.C. 5312(a)(2)(R). Accordingly,
                                                                                                    FinCEN finds that reasonable grounds                   subject to Huione Group’s control.
                                            Haowang Guarantee’s platform,                                                                                  FinCEN assesses that it is operated from
                                            exchanging CVC to facilitate the transfer               exist to conclude that Huione Crypto is
                                                                                                    a financial institution as that term is                Cambodia and Haowang Guarantee
                                            of the proceeds of cyber scams.52                                                                              advertises job opportunities based in
                                            Huione Pay PLC previously held the                      used in the BSA and section 311.
                                                                                                                                                           Phnom Phen, Cambodia. Accordingly,
                                            local equivalent of a money transmitting                2. Huione Group and Its Identified                     FinCEN finds that reasonable grounds
                                            business license issued by the Kingdom                  Components Operate Outside the                         exist to conclude that Haowang
                                            of Cambodia and engages in the                          United States                                          Guarantee is operated from and located
                                            exchange of CVC in a manner consistent                                                                         in Cambodia and thus operates outside
                                            with the definition of a money                             As in the NPRM, FinCEN finds that
                                                                                                    reasonable grounds exist for concluding                of the United States.
                                            transmitting business.53 Accordingly,
                                                                                                    that Huione Group is a foreign financial               c. Huione Pay PLC
                                              47 National Bank of Cambodia, List of Payment         institution.56 As described in section
                                            Service Institutions (July 31, 2025), https://          II.A.1, Huione Group is a financial                      Huione Pay PLC operates, or has
                                            www.nbc.gov.kh/english/supervision/payment_             services conglomerate based in Phnom                   operated, eight Cambodian domestic
                                            service.php (last accessed Oct. 7, 2025).               Penh, Cambodia, and its network offers                 branch locations, located in Battambang,
                                               48 Cambodia Corporate Registry, Huione Search,

                                            https://www.businessregistration.moc.gov.kh/
                                                                                                    unique services ranging from an online                 Phnom Penh, Poipet, Siem Reap, and
                                            cambodia-master/service/create.html?                    marketplace selling items useful for                   Sihanoukville.59 Huione Pay PLC has
                                            targetAppCode=cambodia-master&                          carrying out cyber scams to money                      advertised on social media that it has,
                                            targetRegisterAppCode=cambodia-br-companies&            laundering services that accept both fiat              or had, operated a branch in
                                            service=registerItemSearch (last accessed Mar. 27,
                                            2025; July 29, 2025).
                                                                                                    currencies and CVC.                                    Laukkaing,60 the capital of the Kokang
                                               49 Financial Transactions and Reports Analysis                                                              Self-Administered Zone in northern
                                                                                                    a. Huione Group
                                            Centre of Canada (FINTRAC), Money Services                                                                     Burma and a known center for criminal
                                            Business Registry, Huione Pay Inc, https://fintrac-        Based on publicly available                         CVC investment scams, before a 2023–
                                            canafe.canada.ca/msb-esm/reg-eng (last accessed         information, Huione Group is operated                  2024 crackdown shuttered the majority
                                            Mar. 13, 2025).                                         by a Cambodian person, from Phnom
                                               50 Telegram, Huione Group Customer Service,                                                                 of these operations.61 As noted above,
                                            Huione Statement (Mar. 9, 2025), formerly available
                                                                                                    Penh, Cambodia.57 Furthermore, the
                                            at https://t.me/huionekf/346.                                                                                  multi-billion dollar marketplace used by online
                                               51 Huione Pay website, Index, formerly available     www.nbc.gov.kh/english/supervision/payment_            scammers (July 9, 2024, updated Mar. 27, 2025),
                                            at https://www.huionepay.com.kh/index/help (last        service.php (last accessed Mar. 21, 2025).             https://www.elliptic.co/blog/cyber-scam-
                                            accessed Mar. 27, 2025).                                  54 Huione Crypto, Legal, formerly available at       marketplace.
                                               52 FinCEN assesses that Huione International         https://www.huione.io/en-US/termsAndConditions/          58 On May 13, 2025, Telegram shut down Huione

                                            Payments is part of Huione Pay PLC and that the         userAgreement (last accessed Mar. 27, 2025).           Group’s Telegram channel, however, there is
                                            entity supports Haowang Guarantee’s facilitation of       55 See Section I.B.                                  evidence that Huione Group is creating new
                                            transactions connected to money laundering                56 FinCEN, Special Measure Regarding Huione          channels under different names to circumvent the
                                            activities. See Elliptic, Huione Guarantee: The         Group, as a Foreign Financial Institution of Primary   action taken by Telegram.
                                                                                                                                                             59 Telegram, Huione Branch, formerly available at
                                            multi-billion dollar marketplace used by online         Money Laundering Concern, 90 FR 18934 (May 5,
                                            scammers (July 9, 2024, updated Mar. 27, 2025),         2025).                                                 https://t.me/huionestoreaddress/7 (last accessed

lotter on DSK11XQN23PROD with RULES1
                                            https://www.elliptic.co/blog/cyber-scam-                  57 The Record, Tether freezes $29 million of         Mar. 27, 2025).
                                            marketplace; The New York Times, How Scammers                                                                    60 Telegram, Huione Group Customer Service
                                                                                                    cryptocurrency connected to Cambodian
                                            Launder Money and Get Away With It (Mar. 23,            marketplace accused of fueling scams (July 15,         Center, formerly available at https://t.me/huionekf/
                                            2025), https://www.nytimes.com/2025/03/23/world/        2024), https://therecord.media/tether-freezes-29-      138 (last accessed Mar. 27, 2025).
                                            asia/cambodia-money-laundering-huione.html.             million-crypto-connected-to-scam-marketplace; see        61 Recorded Future, Myanmar rebels take control
                                               53 National Bank of Cambodia, List of Payment        also ICANN, Huione.com, https://lookup.icann.org/      of ‘pig butchering’ scam city amid China pressure
                                            Service Institutions (Dec. 31, 2024), https://          en/huione.com; Elliptic, Huione Guarantee: The                                                    Continued

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                                            48300            Federal Register / Vol. 90, No. 198 / Thursday, October 16, 2025 / Rules and Regulations

                                            Huione Pay PLC held a corporate                         Huione Pay PLC and Haowang                            identified any actual physical location
                                            registration in Cambodia as well as a                   Guarantee, and collectively comprise a                or other information suggesting Huione
                                            payment services institution license,                   single organization.                                  Group or the Components are operating
                                            both of which have been revoked as of                      Huione Crypto advertises jobs in                   in the United States.
                                            March 2025.62 Based on the foregoing,                   Phnom Penh, Cambodia indicating it is                    Based on the foregoing, FinCEN
                                            FinCEN finds that reasonable grounds                    likely operated out of Cambodia, instead              assesses that Huione Group, including
                                            exist to conclude that Huione Pay PLC                   of Poland. Additionally, the Standard                 the Components, are predominately
                                            is operated from and located in                         Terms and Conditions of Huione Crypto                 operated from and located in Cambodia,
                                            Cambodia, and thus operates outside of                  stated that the ‘‘Group provides the                  with a limited connection to Poland
                                            the United States.                                      Services through www.7572.com, the                    where Huione Crypto holds a corporate
                                                                                                    Group’s mobile application or any                     registration. While the three MSB
                                            d. Huione Crypto                                        Huione application programming                        registrations by Huione Crypto, Huione
                                              Huione Crypto is registered in Poland                 interface.’’ The listed web page                      Pay Inc., and Huione LTD suggest that
                                            under the name Huione Crypto Spó5ka                    (www.7572.com) formerly, but no                       Huione Group may intend to expand its
                                            Z Ograniczona˛ Odpowiedzialnościa˛ 63                  longer, redirects to the website of                   business to the United States in the
                                            and is also registered as a Money                       Huione Pay PLC                                        future, as of the date of this final rule,
                                            Services Business (MSB) 64 with                         (www.huionepay.com.kh), however, as                   FinCEN is not aware of any physical
                                            FinCEN. However, despite its                            of August 19, 2025, it appears to be a                presence by Huione Group or the
                                            registration in Poland and the United                   website used exclusively by Huione Pay                Components in the United States, or any
                                            States, FinCEN assesses that Huione                     PLC. Indeed, Huione Crypto’s user                     substantial business with customers in
                                            Crypto actually operates in and from                    agreement expressly disclaims that                    the United States. Accordingly, FinCEN
                                            Cambodia,65 and FinCEN has found no                     persons inside the United States may                  finds that there are reasonable grounds
                                            evidence consistent with activity in the                not avail themselves of Huione Group’s                to conclude that Huione Group,
                                            United States.66 FinCEN assesses that                   services.68 Accordingly, FinCEN finds                 including the Components, are foreign
                                            the ‘‘Group’’ referenced in Huione                      that reasonable grounds exist to                      financial institutions that operate
                                            Crypto’s previously used Standard                       conclude that Huione Crypto is operated               outside the United States.
                                            Terms and Conditions, which does not                    from and located in Cambodia and thus
                                            appear on its new website                                                                                     3. Huione Group and Its Identified
                                                                                                    operates outside of the United States.
                                            (www.huione.me),67 refers to Huione                                                                           Components Are of Primary Money
                                            Group, and that Huione Crypto’s CVC                     e. Huione Group’s Connections to the                  Laundering Concern
                                            services share infrastructure with                      United States                                            FinCEN assesses that Huione Group is
                                                                                                       The most evidence of activity in the               used to facilitate and promote money
                                            on junta (Jan. 8, 2024), https://therecord.media/       United States by Huione Group or its                  laundering, particularly in support of
                                            myanmar-rebels-control-pig-butchering-scam-hub.         individual Components are three MSB                   illicit financial activities connected to
                                              62 National Bank of Cambodia, List of Payment
                                                                                                    registrations 69 with FinCEN and an                   the Democratic People’s Republic of
                                            Service Institutions (Dec. 31, 2024), https://
                                            www.nbc.gov.kh/english/supervision/payment_             address reported on two registrations.70              Korea (DPRK) and Southeast Asia-based
                                            service.php (last accessed Mar. 21, 2025); As of        In April 2023, Huione Crypto registered               TCOs. Because Huione Group has
                                            March 31, 2025, Huione Pay PLC is no longer listed      as a dealer in foreign exchange, and                  shared infrastructure with its
                                            as having an active license for ‘‘other financial       provided a business address in Phnom                  constituent entities, the structure makes
                                            services activities.’’ National Bank of Cambodia,
                                            List of Payment Service Institutions (Mar. 31, 2025),   Penh, Cambodia, while noting no                       it challenging to ascertain the specific
                                            https://www.nbc.gov.kh/english/supervision/             branches in the United States. In August              Component involved in any particular
                                            payment_service.php (last accessed Oct 7, 2025); As     2024, Huione Pay Inc. registered to                   transaction. Nevertheless, FinCEN bases
                                            of July 30, 2025, Huione Pay PLC has also lost its      conduct multiple MSB activities,                      this assessment on information available
                                            corporate registration. See Cambodia Corporate
                                            Registry, Huione Search, https://
                                                                                                    including check cashing, dealing in                   through both public and non-public
                                            www.businessregistration.moc.gov.kh/cambodia-           foreign exchange, and money                           reporting, and after thorough
                                            master/service/create.html?targetAppCode=               transmission. Huione Pay Inc. provided                consideration of each of the following
                                            cambodia-master&targetRegisterAppCode=                  an address in Denver, Colorado                        factors: (1) Huione Group provides
                                            cambodia-br-companies&
                                            service=registerItemSearch (last accessed July 29,
                                                                                                    associated with a virtual mail                        services that DPRK government entities
                                            2025).                                                  forwarding service, and it also noted no              use to launder the proceeds of cyber
                                              63 Polish corporate registration database, Huione     branches in the United States. Finally,               heists; (2) TCOs based in Southeast Asia
                                            Crypto SPÓ4KA Z OGRANICZONA            ˛               in February 2025, Huione LTD                          have used Huione Group to launder
                                            ODPOWIEDZIALNOŚCIA        ˛ , https://                 registered as a dealer in foreign
                                            www.biznes.gov.pl/en/wyszukiwarka-firm/wpis/krs/
                                                                                                                                                          illicit proceeds of cyber scams,
                                            0001043802 (last accessed Oct. 6, 2025).                exchange, money transmitter, and seller               including CVC investment scams; and
                                              64 For more information on what type of business      of money orders, and noted no branches                (3) Huione Group operates an illicit
                                            or activity requires registration as a money service    in the United States. Huione LTD                      online market.
                                            business, see FinCEN, Money Services Business           appears to use the same Denver,
                                            Definition, https://www.fincen.gov/money-services-
                                                                                                    Colorado mail forwarding service as                   a. Huione Group Facilitates
                                            business-definition. See also 31 CFR 1010.100(ff).                                                            Transactions for DPRK Actors To
                                              65 Huione Crypto, Career Opportunities, formerly      Huione Pay Inc. FinCEN has not
                                                                                                                                                          Launder Funds From Sanctions Evasion
                                            available at https://Huione.io/en-US/
                                            careerOpportunities (last accessed Mar. 27, 2025);        68 Huione Crypto, Legal, formerly available at      and Cyber Heists
                                            Huione Crypto, Legal, formerly available at https://    https://www.huione.io/en-US/termsAndConditions/          DPRK-affiliated actors have
                                            www.huione.io/en-US/termsAndConditions/                 userAgreement (last accessed Mar. 27, 2025).
                                            userAgreement (last accessed Mar. 27, 2025);              69 FinCEN’s MSB Registrant Search web page
                                                                                                                                                          extensively used the Huione Group to
                                            Huione Pay PLC, formerly available at                   reflects only what the registrant has provided to     launder stolen CVC for the benefit of the

lotter on DSK11XQN23PROD with RULES1
                                            www.huionepay.com.kh (last accessed Mar. 27,            FinCEN, and FinCEN does not approve or endorse        DPRK government and in support of
                                            2025).                                                  any business that has registered as an MSB.           DPRK’s WMD and ballistic missile
                                              66 See FinCEN, MSB Registrant Search, Huione,           70 An examiner attempted to contact Huione Pay
                                                                                                                                                          programs, in violation of U.S. and
                                            https://www.fincen.gov/msb-state-selector.              Inc. at the Denver, Colorado location in November
                                              67 Huione Crypto website, www.huione.me/              2024, but the examiner did not identify a Huione
                                                                                                                                                          multilateral sanctions programs,
                                            home?ts=1755613352122 (last accessed Aug. 19,           Pay Inc. representative, nor any other evidence of    including United Nation Security
                                            2025).                                                  a physical presence by Huione Pay Inc.                Council Resolutions (UNSCRs). The

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                                                             Federal Register / Vol. 90, No. 198 / Thursday, October 16, 2025 / Rules and Regulations                                                   48301

                                            United States has consistently taken                     (FBI), the Cybersecurity and                           used by the Lazarus Group sent CVC
                                            measures to counter DPRK’s abuse of                      Infrastructure Security Agency (CISA),                 valued at over USD 150,000 to Huione
                                            CVC and protect the United States from                   and Treasury issued a joint                            Group.81
                                            DPRK’s illicit financial activity.71                     Cybersecurity Advisory to highlight the                   FinCEN conducted blockchain
                                            However, as outlined in Treasury’s 2024                  cyber threat associated with                           analysis, using commercially available
                                            National Proliferation Financing Risk                    cryptocurrency thefts and tactics used                 blockchain analytic software, of flows of
                                            Assessment, DPRK has continued to                        by the DPRK state-sponsored advanced                   CVC associated with several heists
                                            advance its illicit exploitation of new                  persistent threat group, since at least                carried out by DPRK. This analysis
                                            financial technology, including the theft                2020.77 The U.S. government has                        identified that Huione Group received a
                                            and laundering of CVC, to raise and                      observed DPRK cyber actors targeting a                 combined total of approximately USD
                                            move money to fund its illicit weapons                   variety of organizations in the                        2.6 million worth of CVC from the June
                                            programs.72 Indeed, the UNSCR 1718                       blockchain technology and                              2, 2023 Atomic Wallet heist and the
                                            Committee’s Panel of Experts (UNSCR                      cryptocurrency industry, including                     June 22, 2023 Coinspaid 82 and Alphapo
                                            1718 POE) found that the malicious                       cryptocurrency exchanges,                              heists.83 In July 2024, Huione Group
                                            cyber activities of the DPRK generates                   decentralized finance protocols, play-to-              received USD 35 million worth of stolen
                                            approximately 50 percent of its foreign                  earn CVC video games, CVC trading                      CVC, later attributed to the Lazarus
                                            currency income. In its March 2024                       companies, venture capital funds                       Group by the FBI, from the May 2024
                                            annual report, the UNSCR 1718 POE                        investing in CVC, and individual                       heist targeting DMM, a Japanese
                                            indicated that it was investigating 17                   holders of large amounts of                            VASP.84 While the DMM heist was not
                                            CVC heists in 2023 for which the DPRK                    cryptocurrency or valuable non-fungible                initially attributed to the Lazarus Group
                                            may be responsible, valued at more than                  tokens.78 FinCEN assesses that, over                   (or any other prohibited entity or
                                            USD 750 million.73                                       time, the DPRK’s money laundering                      jurisdiction), the heist itself was widely
                                                                                                     processes have become more complex in                  reported by the time Huione Group
                                            i. Background on DPRK CVC Heists                                                                                received the CVC, and FinCEN would
                                                                                                     order to evade OFAC sanctions, law
                                               In the same March 2024 report, the                    enforcement, and BSA reporting                         expect covered financial institutions to
                                            UNSCR 1718 POE noted it was                              obligations from hacked entities or CVC                have an effective AML/KYC program to
                                            investigating 58 suspected cyberattacks                  entities used in the laundering process.               appropriately monitor transactions for
                                            by DPRK’s Reconnaissance General                         DPRK is leveraging sophisticated CVC                   red flags indicating connections to a
                                            Bureau (RGB),74 to which the Lazarus                     methods and a range of intermediary                    high profile heist such as this. In total,
                                            Group 75 is related, on CVC companies                    entities, often operating across multiple              based on publicly and non-publicly
                                            between 2017 and 2023, valued at                         jurisdictions in East Asia, to further                 available information available to
                                            approximately USD 3 billion. FinCEN                      obfuscate its laundering. In fact, in                  FinCEN, FinCEN’s analysis has
                                            assesses that these funds likely                         August 2023, the FBI alerted the public                identified that Huione Group has
                                            bolstered DPRK’s WMD development.76                      to several thefts from CVC companies                   received at least USD 37.6 million worth
                                            The Federal Bureau of Investigation                      that it attributed to the Lazarus Group                of CVC from DPRK cyber actors
                                                                                                     and warned that there could be another                 stemming from DPRK-attributed heists.
                                               71 See FinCEN, READOUT: FinCEN Hosts Public-
                                                                                                     USD 40 million worth of CVC being                         On multiple occasions between 2022
                                            Private Dialogue on Countering the DPRK’s Illicit        prepared for laundering through                        and 2024, a DPRK national with deep
                                            Cyber Activities (Aug. 31, 2023), https://
                                            www.fincen.gov/news/news-releases/readout-               VASPs.79                                               ties to the RGB, DPRK’s primary foreign
                                            fincen-hosts-public-private-dialogue-countering-                                                                intelligence organization, worked with
                                            dprks-illicit-cyber.
                                                                                                     ii. Huione Group Launders the Proceeds                 Huione Pay PLC officials to transfer
                                               72 Department of the Treasury, National               of DPRK Cyber Heists
                                                                                                                                                            CVC and fiat currency. FinCEN assesses
                                            Proliferation Financing Risk Assessment (Feb. 7,            Despite the 2023 FBI alert and other
                                            2024), at pp. 2, 18, https://home.treasury.gov/
                                                                                                                                                            that senior Huione Pay PLC leadership
                                            system/files/136/2024-National-Proliferation-
                                                                                                     public reporting, Huione Group has                     was aware of the individual’s affiliation
                                            Financing-Risk-Assessment.pdf.                           continued to receive and process these                 with DPRK. This DPRK national
                                               73 United Nations, S/2024/215, UN Panel of            illicit proceeds. There is wide reporting              maintained personal relationships with
                                            Experts Letter (Mar. 7, 2024), at p. 60, https://        that Huione Group has received stolen                  multiple Huione Pay PLC officials and
                                            documents.un.org/doc/undoc/gen/n24/032/68/pdf/           CVC from multiple heists linked to
                                            n2403268.pdf.                                                                                                   regularly met in person with at least one
                                               74 On January 2, 2015, OFAC sanctioned DPRK’s
                                                                                                     DPRK actors, namely the Lazarus                        of these officials. In late 2023, the DPRK
                                            RGB for being a controlled entity of the Government      Group.80 For example, between June                     national worked with Huione Pay PLC
                                            of North Korea. See Department of the Treasury,          2023 and February 2024, a CVC wallet                   officials to convert CVC into fiat
                                            Press Release, Treasury Imposes Sanctions Against
                                            the Government of The Democratic People’s
                                                                                                                                                            currency and subsequently transfer fiat
                                                                                                       77 Department of the Treasury, Press Release,
                                            Republic Of Korea (Jan. 2, 2015), https://               Treasury Sanctions North Korean State-Sponsored           81 Reuters, Exclusive: North Korean hackers sent
                                            home.treasury.gov/news/press-releases/jl9733. RGB        Malicious Cyber Groups (Sept. 13, 2019), https://
                                            was also previously listed in the annex to E.O.          home.treasury.gov/news/press-releases/sm774.           stolen crypto to wallet used by Asian payment firm
                                            13551 on August 30, 2010. Executive Order 13551,           78 CISA, AA22–108A, TraderTraitor: North             (July 15, 2024), https://www.reuters.com/
                                            ‘‘Blocking Property of Certain Persons With Respect                                                             technology/cybersecurity/north-korean-hackers-
                                                                                                     Korean State-Sponsored APT Targets Blockchain
                                            to North Korea,’’ 75 FR 53837 (Aug. 30, 2010).                                                                  sent-stolen-crypto-wallet-used-by-asian-payment-
                                                                                                     Companies (Apr. 20, 2022), https://www.cisa.gov/
                                               75 This group is commonly referred to by the
                                                                                                     news-events/cybersecurity-advisories/aa22-108a.        firm-2024-07-15/.
                                                                                                                                                               82 FBI, FBI Identifies Cryptocurrency Funds
                                            cybersecurity industry as Lazarus Group, APT38,            79 FBI, FBI Identifies Cryptocurrency Funds
                                            BlueNoroff, and Stardust Chollima. For the               Stolen by DPRK (Aug. 22, 2023), https://               Stolen by DPRK (Aug. 22, 2023), https://
                                            purposes of this final rule, FinCEN will refer to this   www.fbi.gov/news/press-releases/fbi-identifies-        www.fbi.gov/news/press-releases/fbi-identifies-
                                            group as Lazarus Group. See Department of the            cryptocurrency-funds-stolen-by-dprk.                   cryptocurrency-funds-stolen-by-dprk.
                                            Treasury, Press Release, Treasury Sanctions North                                                                  83 Id.
                                                                                                       80 The U.S. Government has previously issued
                                            Korean State-Sponsored Malicious Cyber Group

lotter on DSK11XQN23PROD with RULES1
                                                                                                                                                               84 FBI, FBI, DC3, and NPA Identification of North
                                                                                                     advisories to publicly highlight the Lazarus Group’s
                                            (Sept. 13, 2019), https://home.treasury.gov/news/        threat and tactics associated with CVC theft           Korean Cyber Actors, Tracked as TraderTraitor,
                                            press-releases/sm774.                                    targeting organizations in the blockchain and CVC      Responsible for Theft of $308 Million USD from
                                               76 Department of the Treasury, Press Release,                                                                Bitcoin.DMM.com (Dec. 23, 2024), https://
                                                                                                     industry. See CISA, AA22–108A, TraderTraitor:
                                            Treasury Imposes Sanctions Against the                   North Korean State-Sponsored APT Targets               www.fbi.gov/news/press-releases/fbi-dc3-and-npa-
                                            Government of The Democratic People’s Republic           Blockchain Companies (Apr. 20, 2022), https://         identification-of-north-korean-cyber-actors-tracked-
                                            Of Korea (Jan. 2, 2015), https://home.treasury.gov/      www.cisa.gov/news-events/cybersecurity-advisories/     as-tradertraitor-responsible-for-theft-of-308-million-
                                            news/press-releases/jl9733.                              aa22-108a.                                             from-bitcoindmmcom.

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                                            48302            Federal Register / Vol. 90, No. 198 / Thursday, October 16, 2025 / Rules and Regulations

                                            currency to an associate. In total, the                    Once trust or a relationship has been                Group was the subject of reporting by
                                            DPRK national transferred CVC valued                    established, the scammer will introduce                 several blockchain analytic firms
                                            at tens of thousands USD to the Huione                  the victim to a supposedly lucrative                    describing the use of its various services
                                            Pay PLC official. Furthermore, based on                 investment opportunity in CVC and                       by TCOs for scam activity, including
                                            publicly and non-publicly available                     direct them to use CVC investment                       those offered by Haowang Guarantee.88
                                            information available to FinCEN, in                     websites or applications designed to                    Elliptic reported that Haowang
                                            mid-2023, the DPRK national also                        appear legitimate, but are instead                      Guarantee offered scam-enabling
                                            planned to remit USD internationally to                 fraudulent and ultimately controlled or                 products and services used by scam
                                            Hong Kong and sought Huione Pay PLC                     manipulated by the scammer. When a                      compound operators to imprison and
                                            officials help to do so.                                victim’s pace of investment slows or                    torture their workers. The products
                                               Given the opacity of Huione Group                    stops, the scammer will use even more                   included tear gas, electric batons, and
                                            and the inherent limitation of                          aggressive tactics to extract any final                 electronic shackles, among other related
                                            blockchain analytics, FinCEN is largely                 payments. The scammer may present                       devices. The same month, in a post to
                                            unable to determine what DPRK-                          the victim with supposed losses on the                  its website in response to the adverse
                                            affiliated actors do with the CVC after                 investment and encourage them to make                   media reporting, Haowang Guarantee
                                            they send it to Huione Group. However,                  up the difference through additional                    confirmed that ‘‘detention equipment’’
                                            given the close connection between                      deposits. If the victim attempts to                     is not necessarily human trafficking.’’ 89
                                            Huione Pay PLC officials and DPRK                       withdraw their investment, the scammer                  Subsequently, Huione Pay PLC removed
                                            nationals with close ties to DPRK’s RGB,                may demand that the victim pay                          all references to Haowang Guarantee
                                            FinCEN assesses DPRK most likely uses                   purported taxes or early withdrawal                     from its websites.90
                                            Huione Group to convert CVC to fiat                     fees. Once the victim is unable or                         Neither Huione Pay PLC nor Haowang
                                            currencies.                                             unwilling to pay more into the scam, the                Guarantee have published AML/KYC
                                                                                                    scammer will abruptly cease                             policies.91 Huione Crypto does not have
                                            b. Huione Group Launders the Proceeds                   communication with the victim, taking                   a published AML/KYC policy either.
                                            of Organized Criminal Groups’ Cyber                     the victim’s entire investment with                     Rather, it maintains a ‘‘standard terms
                                            Scams                                                   them.87                                                 and conditions’’ on its website
                                               Huione Group also has significant                                                                            governing the use of its services. In
                                                                                                    ii. Huione Group’s Laundering of                        relevant part, the agreement prohibits
                                            exposure to, and has facilitated                        Proceeds of Cyber Scams, Including
                                            transactions associated with suspected                                                                          the use of Huione Crypto’s platform by
                                                                                                    CVC Investment Scams                                    citizens, nationals or residents of
                                            fraud activity, including CVC
                                            investment scams, also referred to as                      Based on FinCEN analysis of non-                     particular countries, including the
                                            ‘‘pig-butchering.’’ FinCEN assesses that                public information, Huione Group                        United States, Iran or North Korea, as
                                            Huione Group’s extensive CVC services                   received at least USD 36 million worth                  well as individuals sanctioned under
                                            and its online marketplace, Haowang                     of CVC investment scam proceeds, since                  various national regimes, including
                                            Guarantee, has made Huione Group, a                     at least August 2021. More broadly, the                 those of the United States and United
                                            ‘‘one stop shop’’ for criminals to launder              analysis identified that in the aggregate,              Nations. The agreement also states that
                                            CVC obtained through illicit activities,                inclusive of the cyber scam proceeds,                   ‘‘the [u]ser may not use the interface or
                                            and ultimately convert it to fiat                       Huione Group received approximately                     services to disguise the origin or nature
                                            currency.                                               USD 300 million worth of CVC relating                   of illicit proceeds.’’ 92 However, the
                                                                                                    to other cyber scams. Despite the
                                            i. Background on CVC Investment                         limitations noted above, and based on                      88 See Chainalysis, 2024 Crypto Crime Mid-year

                                            Scams                                                   publicly and non-publicly available                     Update Part 2: China-based CSAM and Cybercrime
                                                                                                                                                            Networks on the Rise, Pig Butchering Scams
                                               In 2023, FinCEN published an alert on                information, FinCEN assesses that, after                Remain Lucrative (Aug. 29, 2024), https://
                                            the ‘‘Pig Butchering’’ CVC investment                   illicit actors send CVC to Huione Group,                www.chainalysis.com/blog/2024-crypto-crime-mid-
                                                                                                    CVC is then converted to fiat currency                  year-update-part-2/; Elliptic, Huione: The Company
                                            scams.85 These scams are largely                                                                                Behind the Largest Ever Illicit Online Marketplace
                                            perpetrated by criminal organizations                   or different CVC, or withdrawn at a later               Has Launched a Stablecoin (Jan. 14, 2025), https://
                                            based in Southeast Asia, who use                        point to move to a different VASP, as                   www.elliptic.co/blog/huione-largest-ever-illicit-
                                            victims of human trafficking to conduct                 part of the money laundering process.                   online-marketplace-stablecoin; Elliptic, Huione
                                                                                                                                                            Guarantee: the Multi-billion dollar marketplace
                                            outreach to millions of unsuspecting                    c. Huione Group’s Lax Anti-Money                        used by online scammers (July 9, 2024), https://
                                            individuals around the world. The                       Laundering Policies and Procedures                      www.elliptic.co/blog/cyber-scam-marketplace.
                                            frontline scammers in these schemes are                                                                            89 Haowang Guarantee, To all public friends on
                                                                                                       The risks presented by Huione
                                            themselves often victims of trafficking,                                                                        social media (July 17, 2024), formerly available at
                                                                                                    Group’s association with illicit actors                 https://www.yu444.com/gonggao/detail/2237.
                                            including forced labor, and are
                                                                                                    and transactions linked to illicit activity                90 Elliptic, Huione Guarantee: the Multi-billion
                                            subjected to physical and mental abuse.                                                                         dollar marketplace used by online scammers (July
                                                                                                    are compounded by either an absence
                                            The traffickers also force victims to                                                                           9, 2024), https://www.elliptic.co/blog/cyber-scam-
                                                                                                    of, or ineffective, AML/KYC policies
                                            work up to 15 hours a day and, in some                                                                          marketplace.
                                                                                                    and procedures among Huione Group’s
                                            cases, ‘‘resell’’ victims to other scam                                                                            91 Repeated searches of their respective websites,
                                                                                                    components, as well as recent changes                   including most recently on July 28, 2025, failed to
                                            operations or subject them to sex
                                                                                                    that have served to obfuscate Huione                    yield any evidence of a policy. Haowang
                                            trafficking.86                                                                                                  Guarantee’s website did previously contain cursory
                                                                                                    Group’s involvement in illicit activity.
                                                                                                                                                            fraud indicators available to customers, which has
                                              85 FinCEN, FIN–2023–Alert005, FinCEN Alert on         For example, in July 2024, Huione                       since been taken down, likely in response to the
                                            Prevalent Virtual Currency Investment Scam                                                                      NPRM. Regardless, in FinCEN’s assessment, this
                                            Commonly Known as ‘‘Pig Butchering’’ (Sept. 8,          Currency Scams (Sept. 12, 2024), https://               falls short of reasonable policies and procedures

lotter on DSK11XQN23PROD with RULES1
                                            2023), https://www.fincen.gov/sites/default/files/      home.treasury.gov/news/press-releases/jy2576.           aimed at combatting money laundering. See
                                            shared/FinCEN_Alert_Pig_Butchering_FINAL_                  87 FinCEN, FIN–2023–Alert005, FinCEN Alert on        Haowang Guarantee, Fangpian, formerly available
                                            508c.pdf.                                               Prevalent Virtual Currency Investment Scam              at https://hwdb.la/fangpian (last accessed Mar. 27,
                                              86 Department of the Treasury, Press Release,         Commonly Known as ‘‘Pig Butchering’’ (Sept. 8,          2025).
                                            Treasury Sanctions Cambodian Tycoon and                 2023), at p. 4, https://www.fincen.gov/sites/default/      92 Huione Crypto, Legal, formerly available at

                                            Businesses Linked to Human Trafficking and              files/shared/FinCEN_Alert_Pig_Butchering_FINAL_         https://www.huione.io/en-US/termsAndConditions/
                                            Forced Labor in Furtherance of Cyber and Virtual        508c.pdf.                                               userAgreement (last accessed Mar. 27, 2025).

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                                                             Federal Register / Vol. 90, No. 198 / Thursday, October 16, 2025 / Rules and Regulations                                                 48303

                                            extent of the criminal and money                        d. Huione Group Continues Its CVC-                    ineffective AML policies, procedures,
                                            laundering activity on Huione Crypto’s                  Related Operations Despite Regulatory                 and controls, provision of services that
                                            platforms that violate its terms and                    Prohibition                                           offer anonymity and an ability to evade
                                            conditions agreement reflects that its                     Further illustrating the money                     sanctions, and development of a
                                            AML/KYC program is either ineffective                   laundering risk posed by Huione Group                 stablecoin designed to hinder the ability
                                            or unenforced.                                          is the fact that a significant portion of             of law enforcement to recover the
                                               Despite this, and as described in                    its assessed illicit transactional activity           proceeds of crime—is being used
                                            greater detail in section II.A.3 since at               involves CVC, which the National Bank                 extensively to facilitate or promote
                                            least August 2021, FinCEN identified—                   of Cambodia, Huione Group’s primary                   money laundering, in particular by
                                                                                                    regulator, expressly prohibits. In a 2024             organized criminal groups and entities
                                            through analysis of non-public
                                                                                                    public statement, the National Bank of                involved in the proliferation of WMD or
                                            information—that Huione Group
                                                                                                    Cambodia stated that payment firms are                missiles.
                                            received at least USD 37 million worth
                                                                                                    ‘‘not allowed to deal or trade any
                                            of illicit proceeds from sanctioned                     cryptocurrencies and digital assets.                  B. Post-NPRM Developments
                                            entities—including DPRK entities—and                    According to that same reporting, this
                                            at least USD 300 million worth of CVC                                                                            In the wake of the NPRM, Huione
                                                                                                    ban has been in effect since 2018, ‘‘to               Group has continued to facilitate money
                                            from various cyber and CVC scam                         avoid investment losses due to crypto’s
                                            activity. FinCEN’s analysis identified                                                                        laundering. For example, a June 16,
                                                                                                    volatility, cybercrime and the                        2025 media report indicates that
                                            that, in the aggregate, Huione Group has                anonymity of the technology ‘‘which
                                            received at least USD 4 billion worth of                                                                      approximately USD 6.9 million worth of
                                                                                                    may cause risks of money laundering
                                            illicit proceeds, between August 2021                                                                         CVC stolen from a compromised device
                                                                                                    and financing of terrorism.’’ ’’ 96 Despite
                                            and January 2025.93 This large-scale,                                                                         was quickly funneled through one of
                                                                                                    this prohibition, Huione Group has
                                                                                                                                                          Huione Group’s Components following
                                            persistent use of Huione Group by                       continued to develop its CVC services
                                                                                                    and has even expanded its CVC                         the theft.99 Analysis by blockchain
                                            DPRK actors and TCO-driven CVC
                                                                                                    offerings in recent months. In                        analytic firm, Global Ledger found that
                                            investment scams to launder their illicit
                                                                                                    September 2024, Huione Group                          between May 1 and June 17, 2025,
                                            proceeds belies the adequacy or
                                                                                                    launched USDH, a stablecoin it                        transactions involving Huione Group
                                            effectiveness of Huione Group’s AML/
                                                                                                    explicitly advertised as ‘‘unfreezable’’              wallets amounted to more than USD 10
                                            KYC procedures.
                                                                                                    and ‘‘not restricted by traditional                   billion worth of the CVC Tether on
                                               Huione Group itself has conceded the                 regulatory agencies.’’ 97 FinCEN assesses             Tron,100 and USD 219 million worth of
                                            deficiencies in its AML regime. In a July               that Huione Group is likely taking this               the CVC Ethereum.101 Global Ledger’s
                                            2024 media statement, for example,                      step and marketing itself as outside                  analysis also found that Huione Crypto
                                            Huione Group stated ‘‘our [Know Your                    regulatory agency reach to increase its               and Huione Pay continue to operate
                                            Customer] capabilities are now seriously                appeal to illicit actors and hamper                   under the wider Huione Group
                                            insufficient.’’ 94 This statement was                   compliance with applicable AML laws.                  operational structure.102 Huione
                                            made after previously claiming earlier                  Notably, Huione Group’s intentional                   Group’s continued operations point to
                                            that month—in response to public                        launching of this ‘‘unfreezable’’                     the challenges of shuttering
                                            identification of one heist, the proceeds               stablecoin differs from other stablecoin              decentralized, opaque illicit
                                            of which were transmitted to Huione                     issuers that generally respond to law                 marketplaces.103
                                            Pay PLC—that it had not known that                      enforcement requests to freeze CVC tied
                                                                                                    to illicit activity. One particular                   C. Consideration of Comments
                                            Huione Pay PLC ‘‘received funds
                                            indirectly’’ from the heist, due to the                 example of this contrast occurred in July               FinCEN published the NPRM, with a
                                            layers of transactions between the                      2024, when one stablecoin issuer froze                30-day comment period. In response,
                                            source of the heist and the Huione                      CVC valued at over USD 29 million that
                                            Group-owned wallets that ultimately                     was located in a Huione Group CVC                        99 Cointelegraph, Crypto user loses $6.9 million to

                                            received the funds.95                                   wallet because it was ‘‘associated with               a cold wallet from China’s TikTok (June 16, 2025),
                                                                                                    activities allegedly linked to fraudulent             https://cointelegraph.com/news/crypto-investor-
                                               93 By illicit category, Huione Group has received
                                                                                                    and transnational criminal                            loses-6m-douyin-cold-wallet-scam.
                                                                                                                                                             100 Tether, a stablecoin with a 1:1 peg to the USD,
                                            the following proceeds in CVC, denominated in           operations.’’ 98 By trumpeting that its
                                                                                                    stablecoin is ‘‘not restricted by                     does not operate its own blockchain, instead, it is
                                            equivalent USD value: USD 1,363 from child sexual                                                             issued on the blockchains of other CVCs, in this
                                            abuse material; USD 618,861 from Darknet Markets/       traditional regulatory agencies’’ and                 case, it is deployed to the Tron blockchain. For the
                                            Illicit Cyber Vendors; USD 3,246 from FinCEN            offering USDH, which is ‘‘unfreezable,’’              purposes of this final rule, FinCEN considers Tether
                                            Primary Money Laundering Concerns; USD                  even upon a lawful request from law                   on Tron to be one type of CVC. See Cointelegraph,
                                            3,248,510,440 from Identified Illicit Cyber actors;                                                           What Is Tether USDT and How Does it Work (Feb.
                                            USD 47,393,602 from VASPs without KYC policies;         enforcement, Huione Group facilitates
                                                                                                                                                          9, 2025) https://cointelegraph.com/explained/what-
                                            USD 407,129,792 from OFAC Specially Designated          and profits from money laundering,                    is-tether-usdt-and-how-does-it-work.
                                            Nationals (U.S. sanctioned entities); USD               benefiting TCOs and DPRK actors                          101 Cointelegraph, Huione wallets moved $1B to
                                            347,549,705 from Scams; USD 22,133,556 from             exfiltrating the proceeds of their crimes.            crypto exchanges since FinCEN action (July 8,
                                            seized and/or stolen funds; and 2,627,009 from             Given the various aggravating factors              2025), https://cointelegraph.com/news/huione-
                                            terrorist financing.                                                                                          wallets-moved-crypto-exchanges-fincen.
                                               94 See ABC News, Cambodian online marketplace
                                                                                                    described above, FinCEN finds that the                   102 Id.
                                            outed as one-stop shop for scammers’ money              Huione Group—with its weak and                           103 Bloomberg, World’s Biggest Illicit Marketplace
                                            laundering and ‘detention equipment’ needs (July                                                              Becomes an ‘Amazon for Criminals,’ (Aug. 1, 2025)
                                            26, 2024), https://www.abc.net.au/news/2024-07-           96 Id.
                                                                                                                                                          https://www.bloomberg.com/news/features/2025-
                                            27/online-marketplace-for-money-laundering-and-

lotter on DSK11XQN23PROD with RULES1
                                                                                                      97 Huione Crypto, USDH is a stable currency in
                                                                                                                                                          08-01/huione-s-24-billion-hub-for-cybercrime-is-an-
                                            scammers/104131624.                                     one word!, formerly available at https://huione.io/   amazon-for-criminals (last accessed Aug. 18, 2025);
                                               95 Reuters, Exclusive: North Korean hackers sent     en-us/introduce (last accessed Mar. 27, 2025).        CoinDesk, Telegram Bans $35B scam Marketplace.
                                            stolen crypto to wallet used by Asian payment firm        98 The Record, Tether freezes $29 million of        Only to see Illicit Crypto Trades Surge Elsewhere,
                                            (July 15, 2024), https://www.reuters.com/               cryptocurrency connected to Cambodian                 (July 30, 2025), https://www.coindesk.com/
                                            technology/cybersecurity/north-korean-hackers-          marketplace accused of fueling scams (July 15,        business/2025/07/30/illicit-crypto-trade-quickly-
                                            sent-stolen-crypto-wallet-used-by-asian-payment-        2024), https://therecord.media/tether-freezes-29-     rebounds-despite-telegram-s-shutdown-of-usd35b-
                                            firm-2024-07-15/.                                       million-crypto-connected-to-scam-marketplace.         huione-marketplace.

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                                            48304            Federal Register / Vol. 90, No. 198 / Thursday, October 16, 2025 / Rules and Regulations

                                            FinCEN received eight comments.104                      procedures, practices, trainings, and                 of Huione Group. FinCEN weighed the
                                            Those comments are summarized                           user base; and                                        benefit of a more expansive definition of
                                            below, along with FinCEN’s responses.                      • Examine the company’s information                Huione Group with the benefit of
                                            One Huione Group component, Huione                      technology infrastructure, databases,                 regulatory certainty. FinCEN considered
                                            Pay PLC, commented on the NPRM                          controls, and records, and confirm the                the benefit of a more flexible and
                                            through counsel.                                        technical configurations of the Content               expansive definition of Huione Group in
                                                                                                    Distribution Network (CDN) used by                    countering its opaque and evolving
                                            1. Huione Pay PLC’s Comment and                         Huione Pay PLC to enforce the blocking
                                            Request for Extension                                                                                         organizational structure. However,
                                                                                                    of IP addresses originating from
                                               On May 27, 2025, a law firm (‘‘outside                                                                     FinCEN assessed that the burden on
                                                                                                    sanctioned jurisdictions.
                                            counsel’’) representing Huione Pay PLC                     In light of the firm’s work, the                   covered financial institutions of a
                                            emailed FinCEN requesting an                            comment sought an additional                          flexible ‘‘direct or indirect control’’
                                            extension of the public comment period                  unspecified extension of time to submit               definition would be considerable and
                                            so that Huione Pay PLC might provide                    a late comment in order to allow for the              that the probability of misidentification
                                            a fulsome comment addressing                            firm’s work to generate additional                    would be significant. Accordingly,
                                            FinCEN’s concerns, as outlined in the                   information, which would be                           FinCEN determined that final rule
                                            NPRM. FinCEN granted that initial                       transmitted to FinCEN. FinCEN                         should implement the definition of
                                            request for an extension, providing an                  considered granting a longer extension                Huione Group that was proposed in the
                                            additional 14 days for Huione Pay PLC                   and the benefit of greater insight into               NPRM.
                                            and any other similarly situated party to               Huione Pay PLC’s claims of AML/KYC                       The same commenter also suggests
                                            submit a late comment, and outside                      compliance. However, having already                   FinCEN establish a standalone
                                            counsel submitted a comment on June                     provided Huione Pay PLC an additional                 definition for ‘‘Correspondent Account’’
                                            18, 2025, which FinCEN posted to                        14 days to submit a comment—resulting
                                                                                                                                                          as part of the final rule. FinCEN assesses
                                            regulations.gov.                                        in a total of 44 calendar days to provide
                                               In that comment, Huione Pay PLC                                                                            that altering such a definition would be
                                                                                                    substantive comments on the NPRM—
                                            claims, without evidence or further                     FinCEN declined to grant a further                    beyond the scope of this rulemaking.
                                            explanation, that Huione Pay PLC is an                  extension of time, taking into account                The same comment also suggests that
                                            ‘‘independent entity,’’ distinct from                   public and nonpublic information about                FinCEN include a provision that would
                                            Huione Group, presumably seeking to                     Huione Pay PLC’s deep integration and                 cover any successor entity noting that it
                                            have Huione Pay PLC excluded from the                   essential role in Huione Group’s money                should include, ‘‘any attempt to
                                            definition of Huione Group in the                       laundering activities, Huione Group’s                 rebrand, restructure, or create shell
                                            proposed rule. However, Huione Pay                      consistent pattern of obfuscation in the              companies with the intent to avoid
                                            PLC had adequate time to identify and                   face of government action, the volume                 regulatory oversight shall be considered
                                            produce information about its own                       of money laundering occurring through                 a violation, subject to immediate
                                            structure and organization—information                  Huione Group, the danger of the                       enforcement action.’’ FinCEN assesses
                                            that a legitimate enterprise should be                  schemes perpetrated by Huione Group’s                 this final rule sufficiently covers entities
                                            willing to produce and have readily at                  criminal customers, FinCEN’s past                     that covered financial institutions know
                                            hand. Having no factual support for the                 practices relating to public comment                  or have reason to believe are a
                                            proposition that Huione Pay PLC is                      periods,106 and the inadequate basis that             component, branch, or office of Huione
                                            independent of Huione Group, and                        had been presented to further delay a                 Group operating as a financial
                                            considering contradictory public and                    final rule in light of the attendant                  institution in any jurisdiction outside of
                                            nonpublic information, FinCEN finds                     risks.107                                             the United States and, as such, more
                                            this claim unpersuasive and continues
                                            to assess that Huione Pay PLC is a                      2. Comment Suggesting That FinCEN                     explicit provisions are unnecessary.
                                            component of Huione Group.105                           Modify Certain Definitions and Include                   The same commenter also suggests
                                               In its comment, Huione Pay PLC also                  Provisions To Improve Enforceability                  that FinCEN use less subjective
                                            claims that it is ‘‘undertaking                            In response to the NPRM, FinCEN                    language, including more concise
                                            substantial efforts to address and                      received one comment that was                         definitions of ‘‘reasonable steps,’’ and
                                            remediate compliance issues raised by                   generally supportive of the rule but                  suggesting that the phrase ‘‘knows or
                                            the Proposed Rulemaking,’’ and that it                  suggesting that FinCEN modify certain                 has reason to believe’’ leaves too much
                                            had retained ‘‘an independent,                          definitions. That comment suggests that               room for subjective interpretation.
                                            reputable, U.S.-based, global consulting                FinCEN adopt a more comprehensive                     FinCEN assesses that covered financial
                                            firm’’ in order ‘‘to assist Huione Pay                  definition of Huione Group that                       institutions are best suited to make the
                                            PLC in identifying and remediating                      encompasses any entity under                          determination of whether they have
                                            potential compliance deficiencies.’’                    demonstrable direct or indirect control
                                                                                                                                                          obligations to implement the special
                                            Huione Pay PLC represented that the
                                                                                                                                                          measure. Similarly, the commenter
                                            firm would, or had begun to:                              106 The Al-Huda Bank NPRM was published on

                                               • Speak with Huione Pay PLC staff                    January 31, 2024, and the final rule was published    suggested that ‘‘[t]he proposed measure
                                            responsible for various business                        on July 3, 2024. See FinCEN, Proposal of Special      does not explicitly detail the
                                                                                                    Measure Regarding Al-Huda Bank, as a Foreign          consequences for noncompliance,’’ and
                                            functions . . . to understand the                       Financial Institution of Primary Money Laundering
                                            company’s operations, management                        Concern, 89 FR 6074 (Jan. 31, 2024); FinCEN,          that ‘‘FinCEN should incorporate
                                            structure, products, and services;                      Imposition of Special Measure Regarding Al-Huda       language specifying that violations will
                                               • Gather information related to the                  Bank as a Financial Institution of Primary Money      trigger enforcement actions, including
                                                                                                    Laundering Concern, 89 FR 55051 (July 3, 2024).

lotter on DSK11XQN23PROD with RULES1
                                            company’s compliance policies,                            107 Since Huione Pay PLC lodged its request,
                                                                                                                                                          fines, account restrictions, or other
                                                                                                    FinCEN has looked for evidence of action by any       sanctions as detailed in this section.’’
                                               104 Published comments are available online at
                                                                                                    Huione Group entity towards AML/KYC                   Willful violations of this final rule are
                                            https://www.regulations.gov/document/FINCEN-            compliance. Except for some superficial
                                            2025-0004-0003.
                                                                                                                                                          subject to civil and criminal penalties
                                                                                                    restructuring apparently intended to evade further
                                               105 See supra Sections II.A.1.c, II.A.2.c, and       scrutiny, Huione Group’s money laundering             set forth at 31 CFR 1010.821 and
                                            II.A.3.a.ii.                                            enterprise appears to operate just as before.         1010.840, and 31 U.S.C. 5321 and 5322.

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                                                             Federal Register / Vol. 90, No. 198 / Thursday, October 16, 2025 / Rules and Regulations                                           48305

                                            4. Comments Expressing Support for the                     After reviewing the comments and                    United States. These accounts may be
                                            NPRM, and Suggesting Additional Steps                   considering all potential special                      used for commercial payments, as well
                                            To Combat CVC Investment Scams                          measures, FinCEN concludes that a                      as foreign exchange and money markets.
                                               In response to the NPRM, FinCEN                      prohibition under special measure five                 Covered financial institutions and
                                            received one comment expressing                         is warranted. Consistent with the                      transaction partners have ample
                                            support for FinCEN’s identification of                  finding that Huione Group is a foreign                 opportunity to arrange for alternative
                                            Huione Group as a primary money                         financial institution of primary money                 payment mechanisms in the absence of
                                            laundering concern. The commenter                       laundering concern, and in                             correspondent banking relationships
                                            suggests that targeting Huione Group                    consideration of additional relevant                   with Huione Group.
                                                                                                    factors, this final rule imposes a                        As such, a prohibition on
                                            alone is insufficient to effectively
                                                                                                    prohibition on covered financial                       correspondent banking with Huione
                                            safeguard the U.S. financial system, and
                                                                                                    institutions from opening or                           Group will impose minimal additional
                                            that FinCEN should work with other
                                                                                                    maintaining a correspondent account                    compliance costs for covered financial
                                            government agencies to take additional
                                                                                                    for, or on behalf of, Huione Group. This               institutions, which would most
                                            steps, including punitive measures
                                                                                                    prohibition will help guard against the                commonly involve adding Huione
                                            against other large facilitators of money
                                                                                                    money laundering risks to the U.S.                     Group to existing sanctions and money
                                            laundering. FinCEN assesses that this
                                                                                                    financial system posed by Huione                       laundering screening tools. FinCEN
                                            final rule is an important step in
                                                                                                    Group, as identified in the NPRM and                   assesses that given the risks posed by
                                            safeguarding the U.S. financial system                                                                         Huione Group’s facilitation of money
                                            and will continue to take steps to                      this final rule.
                                                                                                                                                           laundering, the additional burden on
                                            safeguard the U.S. financial system.                    A. Whether Similar Action Has Been or                  covered financial institutions in
                                            5. Non-Responsive Comments                              Is Being Taken by Other Nations or                     preventing the opening of
                                                                                                    Multilateral Groups Regarding Huione                   correspondent accounts with Huione
                                               FinCEN received five other comments                  Group
                                            that were not responsive to the NPRM,                                                                          Group, as well as conducting due
                                            including suggestions to investigate                       In March 2025, National Bank of                     diligence on foreign correspondent
                                            other, unrelated alleged financial                      Cambodia stripped Huione Pay PLC of                    account holders and notifying them of
                                            crimes, and separate comments entirely                  its banking license.109 Nevertheless, as               the prohibition, will be minimal.
                                            unrelated to this rulemaking process.                   established above, Huione Group has
                                                                                                                                                           C. The Extent to Which the Action or the
                                                                                                    continued to operate CVC services
                                            D. Summary of FinCEN’s Ongoing                                                                                 Timing of the Action Would Have a
                                                                                                    which are expressly prohibited in
                                                                                                                                                           Significant Adverse Systemic Impact on
                                            Concerns Regarding Huione Group                         Cambodia.110 Thus, FinCEN assesses
                                                                                                                                                           the International Payment, Clearance,
                                               After considering comments received                  that this special measure is appropriate
                                                                                                                                                           and Settlement System, or on Legitimate
                                            from the public, as well as other                       given Huione Group’s ongoing and                       Business Activities of Huione Group
                                            information available to the agency,                    egregious conduct, continuing even after
                                                                                                    one component lost its license to                         FinCEN assesses that imposing the
                                            including both public and non-public
                                                                                                    operate.                                               final rule would have minimal impact
                                            information, and Huione Group’s
                                                                                                                                                           upon the international payment,
                                            ongoing efforts to engage in money                      B. Whether the Imposition of Any                       clearance, and settlement system. As a
                                            laundering activities and evade scrutiny                Particular Special Measure Would                       comparatively small financial
                                            and accountability, FinCEN continues to                 Create a Significant Competitive                       institution responsible for a nominal
                                            find that reasonable grounds exist to                   Disadvantage, Including Any Undue                      amount of transaction volume in the
                                            conclude that Huione Group remains a                    Cost or Burden Associated With                         region, Huione Group is not a
                                            financial institution operating outside                 Compliance, for Financial Institutions                 systemically important financial
                                            the United States that is of primary                    Organized or Licensed in the United                    institution in Cambodia, regionally, or
                                            money laundering concern.                               States                                                 globally. FinCEN views that prohibiting
                                            III. Imposition of a Special Measure                      While FinCEN assesses that the final                 Huione Group’s access to U.S.
                                            Regarding Huione Group as a Foreign                     rule would place some cost and burden                  correspondent banking channels would
                                            Financial Institution of Primary Money                  on covered financial institutions, these               not substantially affect the volume of
                                            Laundering Concern                                      burdens are neither undue nor                          legitimate cross-border transactions.
                                               Based upon this finding, FinCEN is                   inappropriate in view of the threat                    Further, a prohibition under special
                                            authorized to impose one or more                        posed by the illicit activity facilitated by           measure five will not prevent Huione
                                            special measures. Following the                         Huione Group. As described in the                      Group from conducting legitimate
                                            required consultations and the                          NPRM, Huione Group has no direct                       business activities in other foreign
                                            consideration of all relevant factors                   USD correspondent relationships with                   currencies.
                                            discussed in the NPRM, FinCEN                           U.S. financial institutions and instead,               D. The Effect of the Proposed Action on
                                            proposed a prohibition under the fifth                  accesses USD through nested                            United States National Security and
                                            special measure.108                                     corresponding relationships, outside the               Foreign Policy
                                              108 Prior to issuing the NPRM and this final rule,    international financial systems. Those views are         As described above, evidence
                                            FinCEN consulted with representatives and staff of      reflected in FinCEN’s explanation of the reasons for   available to FinCEN demonstrates that
                                            the Board of Governors of the Federal Reserve           issuing this final rule.                               Huione Group serves as a significant
                                                                                                       109 National Bank of Cambodia, List of Payment
                                            System, the Office of the Comptroller of the                                                                   conduit for money laundering by TCOs
                                            Currency, the Secretary of State, the staff of the      Service Institutions (Mar. 31, 2025), https://
                                                                                                    www.nbc.gov.kh/english/supervision/payment_            engaged in CVC investment scams and

lotter on DSK11XQN23PROD with RULES1
                                            Securities and Exchange Commission, the
                                            Commodity Futures Trading Commission, staff of          service.php (last accessed July 28, 2025).             DPRK-related actors engaging in CVC
                                            the National Credit Union Administration, the              110 Reuters, Exclusive: North Korean hackers sent   heists. Imposing special measure five
                                            Federal Deposit Insurance Corporation, and the          stolen crypto to wallet used by Asian payment firm     will: (1) close Huione Group’s access to
                                            Attorney General. These consultations involved          (July 15, 2024), https://www.reuters.com/
                                            obtaining interagency views on the imposition of        technology/cybersecurity/north-korean-hackers-
                                                                                                                                                           USD; (2) inhibit Huione Group’s ability
                                            special measure five and the effects that such a        sent-stolen-crypto-wallet-used-by-asian-payment-       to act as an illicit finance facilitator for
                                            prohibition would have on the U.S. domestic and         firm-2024-07-15/.                                      DPRK and TCOs engaged in CVC

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                                            48306            Federal Register / Vol. 90, No. 198 / Thursday, October 16, 2025 / Rules and Regulations

                                            investment scams; and (3) raise                         beneficial owner or originator.111 This               institutions to Huione Group’s illicit
                                            awareness of the way illicit actors                     would be ineffective in preventing illicit            activity, outweigh the value in
                                            exploit weaknesses in vulnerable                        transactions. Huione Group’s record of                providing conditioned access to the U.S.
                                            jurisdictions to circumvent sanctions                   such circumvention suggests that                      financial system for any purportedly
                                            and finance WMD and ballistic missile                   special measure one would not                         legitimate business activity. Conditions
                                            proliferation.                                          adequately protect the U.S. financial                 on the opening or maintaining of
                                                                                                    system from the threats posed by the                  correspondent accounts would likely be
                                            E. Consideration of Alternative Special
                                                                                                    financial institution.                                insufficient to prevent illicit financial
                                            Measures                                                   Further, the requirements under                    flows through the U.S. financial system,
                                               In assessing the appropriate special                 special measures three and four, that                 given Huione Group’s inadequate AML/
                                            measure to impose, FinCEN considered                    domestic financial institutions obtain
                                            alternatives to a prohibition on the                                                                          KYC program.
                                                                                                    ‘‘with respect to each customer (and
                                            opening or maintaining in the United                    each such representative), information                   In sum, FinCEN assesses that any
                                            States of correspondent accounts or                     that is substantially comparable to that              condition or additional recordkeeping
                                            payable-through accounts, including the                 which the depository institution obtains              or reporting requirement would be an
                                            imposition of one or more of the first                  in the ordinary course of business with               ineffective measure to safeguard the
                                            four special measures, or imposing                      respect to its customers residing in the              U.S. financial system from the illicit
                                            conditions on the opening or                            United States,’’ are also likely to be                behavior facilitated by Huione Group.
                                            maintaining of correspondent accounts                   ineffective.112 Huione Group’s use of                 Such measures would not prevent
                                            under special measure five. Having                      nested correspondent account access                   Huione Group from accessing the
                                            considered these alternatives and for the               through layers of payment systems                     correspondent accounts of U.S. financial
                                            reasons set out below, FinCEN assesses                  would render these alternative measures               institutions, thus leaving the U.S.
                                            that none of the other special measures                 ineffective. Only significant effort and              financial system vulnerable to
                                            available under section 311 would                       expense by U.S. institutions could fill               processing illicit transfers that are likely
                                            appropriately address the risks posed by                this gap, which would impose a                        to finance DPRK’s nuclear proliferation,
                                            Huione Group and the urgent need to                     disproportionate compliance burden,                   or CVC investment scams, resulting in
                                            prevent it from accessing USD through                   with no guarantee that the money                      significant national security and money
                                            correspondent banking.                                  laundering threat would be addressed
                                               With public acknowledgements of its                                                                        laundering risk. In addition, no
                                                                                                    through customer due diligence
                                            failure to address significant AML/KYC                                                                        recordkeeping or reporting requirements
                                                                                                    research. FinCEN also considered
                                            deficiencies, Huione Group continues to                                                                       or conditions would be sufficient to
                                                                                                    special measure two, which may require
                                            present a significant money laundering                                                                        guard against the risks posed by a