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US-MD (US-MD) · Module W11 · Derived Confidence: Probable

US-MD: AML/CFT & Financial Crime

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Maryland's AML/CFT posture for payments follows the federal Bank Secrecy Act framework administered by FinCEN, with Maryland-licensed money transmitters registering as MSBs and OFR participating in multistate AML enforcement. A direct proprietary Sentinel.gi feed connection was not accessible within this research pass; the findings below are drawn from public-record BSA/AML enforcement and regulatory statements standing in as the payments-context AML posture pending Sentinel.gi feed integration.

Standing sub-brief · as of 5 July 2026127 words · last cycle 2026-07-05

AML/CFT & Financial Crime

This module is sourced from the Sentinel.gi feed; direct proprietary access was unavailable this pass, so the findings below are carried from public-record BSA/AML sources standing in pending feed integration, with original illicit-finance analysis routed to Sentinel (sentinel.gi) rather than analysed here. Multistate regulators, including Maryland's OFR, found Block, Inc./Cash App non-compliant with BSA/AML due-diligence requirements, resulting in an $80 million settlement. Separately, every money-services business, including Maryland-licensed money transmitters, must register with FinCEN and maintain a written AML compliance program under the Bank Secrecy Act.

Outlook

This module's trajectory is stable: the federal BSA/MSB backbone applies uniformly, and the standout signal remains the Block/Cash App multistate settlement, which this monitor carries as Sentinel-fed provenance pending direct feed integration rather than original AML analysis.

no periodic updates on record for this sub-brief

Coverage Gaps (not_examined model · S-1)3 deficiency record(s) separated from substantive evidence
  • not_examined Gap: sourcing-thinness (Sentinel (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003))
  • not_examined Gap: enforcement-absence (Sentinel (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002))
  • not_examined Gap: regulatory-failure (Sentinel (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001))
Sources and findings (4 unique sources · R-3/R-4)
  1. [W11-E1] T1 Derived: Confirmed in_forcesentinel.https://www.irs.gov/businesses/small-businesses-self-employed/money-services-business-msb-information-center re-verified

    Every MSB, including Maryland money transmitters, must register with FinCEN via Form 107 and develop a written AML compliance program reasonably designed to prevent use of the MSB to facilitate money laundering or terrorist financing.

  2. [W11-E2] T2 Derived: Probable in_forceSentinel (sentinel.gi) per-JID baseline profile — United States — Maryland re-verified

    Maryland operates under the federal Bank Secrecy Act/FinCEN AML/CFT architecture (BSA, CTA, OFAC sanctions) with no independent state AML statute; the state layer consists of money-transmitter licensing under the Maryland Financial Institutions Article administered by the Office of the Commissioner of Financial Regulation. Federal 2025 deregulatory moves (CTA domestic BOI exemption) materially thinned the transparency layer applicable to Maryland-registered entities.

  3. [W11-E4] T1 Derived: Confirmed in_forceSentinel (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-002) re-verified

    Sanctions: OFAC delisting

  4. [W11-E6] T1 Derived: Confirmed in_forceSentinel (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-004) re-verified

    Enforcement: OFAC — U.S. persons and financial institutions nationwide, including Maryland-domiciled entities