--- title: "United States – North Dakota Payments Regulation Monitor | World Payments Monitor" canonical: https://payments.gi/jurisdictions/united-states-north-dakota/ source_html: /jurisdictions/united-states-north-dakota/index.html description: "United States – North Dakota payments and e-money regulation: 14 modules, 68 sourced findings, updated 2026-10-26." generated_at: 2026-10-26T19:20:26Z content_sha256: 7750c735582bd33a63986b5e75e978e4b97d6ec27a4c025179ba4231da95d0c4 generator: "fe-fleet/md-twin@1.0" --- # United States – North Dakota US-ND schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-26 · 14 modules · 68 sourced findings · 189 sources in the cumulative register Download report (PDF) Expand all 14 Modules 0 Moved this cycle 1 Key judgments 3 Open gaps 68 Findings 113 Tier-1 sources Confidence mix 8 confirmed 6 unpopulated (sums to 14 rendered modules; click to filter) No modules moved this cycle. United States federal law that applies in United States – North Dakota is covered once, on the [United States](/jurisdictions/united-states/) page. This page covers United States – North Dakota’s own layer: its own law, regulators and enforcement. ## Jurisdiction brief Jurisdiction lead brief 1,355 Full executive summary 575 ###### Latest update · 25 October 2026 #### Lead Signal The Bank of North Dakota has confirmed the live operation of Roughrider Coin, a dollar-backed tokenized asset built for interbank settlement among the state's community banks and credit unions. Issued by VersaBank, integrated on Fiserv's platform, built on Fireblocks tokenisation and custody infrastructure, and settled on the Solana chain, the asset has been operating since October 1, 2026, with adoption reported at roughly ninety participating institutions on a voluntary basis. The product is developed for regulated institutions and positioned as integrating with existing payment operations rather than replacing them. This is a state-level digital-money infrastructure deployment of real scale, built by a public state-owned bank rather than a private-sector issuer, and it sits apart from both the stablecoin products more commonly tracked in this space and from any central-bank digital currency initiative. No bespoke regulatory guidance addressing the product's treatment has been identified, which leaves its exact supervisory positioning an open question even as adoption proceeds. #### Other Developments Personnel-bar orders at the state licensing authority. The North Dakota Department of Financial Institutions issued perpetual prohibition orders against Monica Trevino Trousdale and Brianna Ricks, barring them from employment or participation in any entity the Department licenses. The orders were issued under the Department's general enforcement authority; the underlying conduct was not disclosed in the public notices. Roughrider Coin's commercial architecture. The platform brings together four named participants in distinct roles: the Bank of North Dakota as vendor, VersaBank as issuer, Fiserv as platform partner, and Fireblocks as infrastructure supplier, with settlement occurring on the Solana chain. The commercial terms of the arrangement were not publicly disclosed. The product's stated purpose is to modernize interbank payments for community banks and credit unions, and reporting describes faster settlement as the primary benefit realized by participating lenders. #### Cross-Monitor Connections A multistate settlement involving Coinme Inc., resolving Bank Secrecy Act and anti-money-laundering violations connected to that company's virtual-currency kiosk business, was identified but is carried for substantive analysis in the financial-crime monitor rather than here; the payments-relevant fact is simply that a kiosk-based virtual-currency operator in this state's market was found to have compliance failures serious enough to draw coordinated multistate regulatory action. Separately, the Roughrider Coin launch has a financial-integrity dimension insofar as no anti-money-laundering-specific guidance for the product has surfaced, a gap tracked in that monitor's parallel treatment of the same launch. #### Outlook The trajectory to watch is whether Roughrider Coin's adoption among North Dakota's community banks and credit unions continues to expand beyond the roughly ninety institutions reported, and whether the Department of Financial Institutions or another authority issues any guidance clarifying the product's regulatory treatment. As a bank-issued, blockchain-settled interbank instrument built on third-party infrastructure from a major custody and tokenisation provider, Roughrider Coin represents a notable case of public-sector digital-asset infrastructure deployment that market participants and other state banking authorities may watch closely as a model, or a cautionary example, depending on how its supervisory treatment develops. 7 earlier updates not shown here. ###### Standing brief · as of 5 July 2026 Written before the update above. Where they differ, the update is the more recent position. #### Lead Signal A federal district court sitting in North Dakota has vacated Regulation II, the Federal Reserve's debit-card interchange fee standard, in a ruling with nationwide implications for every US card-issuing bank and merchant acquirer. In Corner Post, Inc. v. Board of Governors of the Federal Reserve System, the US District Court for the District of North Dakota held on August 6, 2025 that the Federal Reserve exceeded its statutory authority in setting the debit-interchange fee cap, and vacated Regulation II in its entirety, with the vacatur stayed pending an anticipated Federal Reserve appeal. Judge Daniel Traynor found that the Fed impermissibly included fixed ACS costs, network processing fees, transaction-monitoring costs and fraud losses in setting the Reg II interchange standard, contravening the Durbin Amendment's plain text, and cited Loper Bright to reject deference to the Fed's rulemaking. Nationwide debit-interchange economics for every US card-issuing bank and merchant acquirer now hinge on the outcome of the Fed's anticipated appeal. Separately, and just as consequentially for the state's own payments landscape, the Bank of North Dakota — the nation's only state-owned bank — has advanced its Roughrider Coin stablecoin pilot: on March 25, 2026 the North Dakota Industrial Commission approved a bank-to-bank use case after a closed-door risk assessment, with ten local banks expressing pilot interest and launch targeted later in 2026. Roughrider Coin, developed with Fiserv on its FIUSD digital-asset platform and first announced October 8, 2025, would be the first US state-affiliated stablecoin, positioning Bank of North Dakota as a first-mover template for other state-owned or community-banking systems. #### Other Developments Beneath these headline developments, North Dakota's payments-regulatory baseline is now fully populated across the methodology's fourteen modules. Money transmission remains governed by the 2023 Money Transmission Modernization Act (NDCC ch. 13-09.1), administered by the state's Department of Financial Institutions via the Nationwide Multistate Licensing System, with banks and credit unions exempt and non-bank licensees required to post a surety bond of $150,000 to $500,000 alongside $100,000 minimum net worth. Safeguarding of customer funds rests on a permissible-investments backing model rather than pure trust segregation, now layered with House Bill 1127's cybersecurity-governance regime, effective August 1, 2025, which requires a written information-security program, a designated qualified individual, and Commissioner notification within 45 days of a breach affecting 500 or more consumers, backed by civil penalties of up to $100,000 per violation. On the crypto side, House Bill 1447 introduced a licensing and consumer-protection regime for virtual-currency kiosk operators, including blockchain-analytics fraud detection, quarterly transaction reporting, a $2,000 daily per-customer transaction limit, and mandated live customer service, following FBI-reported national crypto-fraud losses of $5.6 billion in 2023 and 103 North Dakota digital-currency scam complaints totaling roughly $6.5 million in losses that year. Instant-payments adoption continues to expand, with at least six North Dakota institutions live on the FedNow rail, while the Bank of North Dakota's correspondent-banking role — providing ACH origination, Federal Reserve activity settlement, item processing and letter-of-credit pledging to most in-state institutions — remains structurally distinctive because BND's deposits are state-guaranteed rather than FDIC-insured. Commercially, in-state community-bank consolidation continues, led by First Holding Company of Park River's agreement to acquire First State Bank of Cando, expected to close in the first quarter of 2026, and a Mayo family shareholder group's April 2026 Federal Reserve change-in-bank-control filing over First Holding Company of Cavalier, parent of United Valley Bank; deal values in both transactions were not publicly disclosed. #### Cross-Monitor Connections The AML/CFT surface for North Dakota's money-transmission and crypto-kiosk sectors currently rests on a single statutory hook — NDCC 13-09.1-22's requirement that licensees file all reports mandated by federal currency-reporting, recordkeeping and suspicious-activity-reporting rules under the federal Anti-Money Laundering Act of 2020 — because no live Sentinel.gi feed was accessible for the jurisdiction this cycle. This leaves a coverage gap on original illicit-finance and AML-supervision analysis for North Dakota's non-bank money transmitters and virtual-currency kiosk operators, flagged here for the Financial Intelligence Monitor and to be revisited once Sentinel.gi integration is restored. #### Outlook The Federal Reserve's response to Corner Post is the single most consequential near-term forward marker: an appeal, if successful, would restore Regulation II's interchange cap nationwide, while a failed or abandoned appeal would leave debit-interchange pricing unmoored from the vacated federal standard across every US card-issuing bank and acquirer, not only those doing business in North Dakota. On the state's own initiative, Roughrider Coin's public launch is targeted for the fourth quarter of 2026, a milestone that would make Bank of North Dakota the first US state-affiliated stablecoin issuer and could serve as a template other state-owned or community-banking systems begin to study. Continued layering of conduct and cybersecurity obligations onto non-bank money transmitters and virtual-currency kiosk operators, evident in House Bill 1127 and House Bill 1447, suggests North Dakota's regulatory direction is tightening even as its market structure — anchored by Bank of North Dakota as wholesaler, correspondent and now stablecoin issuer — continues to offset the rural de-risking pressures documented elsewhere in the Federal Reserve's Ninth District. Read full brief · 1355 words ###### Latest update · 25 October 2026 #### Regulatory Status North Dakota's payments-relevant regulatory landscape is defined by two developments operating at different points of the same general framework. The North Dakota Department of Financial Institutions issued perpetual prohibition orders against two individuals, Monica Trevino Trousdale and Brianna Ricks, barring them from employment or participation in any Department-licensed entity; the underlying conduct was not disclosed. This is enforcement activity under the Department's existing general licensing and market-access authority rather than evidence of a change to that authority. Separately, and with substantially more market significance, the Bank of North Dakota confirmed the live operation of Roughrider Coin, a dollar-backed tokenized interbank-settlement asset issued by VersaBank, integrated on Fiserv's platform, and built on Fireblocks tokenisation and custody infrastructure with Solana-chain settlement. Live since October 1, 2026, the product has reached voluntary adoption among roughly ninety of the state's banks and credit unions. North Dakota has no bespoke stablecoin-specific regulatory framework, and no guidance addressing Roughrider Coin's treatment under the state's general banking and money-transmission statutes has been identified. A related item, a multistate settlement involving Coinme Inc. over Bank Secrecy Act and anti-money-laundering violations tied to virtual-currency kiosk operations, touches this jurisdiction's payments and financial-crime landscape but is substantively analysed elsewhere; the payments-relevant takeaway is that the state's kiosk-based virtual-currency sector saw a compliance enforcement outcome, distinct from the bank-led Roughrider Coin initiative. #### Outlook The principal development to track going forward is the pace and scale of Roughrider Coin adoption beyond its initial roughly ninety participating institutions, and whether any state or federal authority issues guidance on the product's regulatory status. The personnel-bar orders, by contrast, appear to be a closed enforcement matter absent further related disclosures. 6 earlier updates not shown here. ###### Standing brief · as of 5 July 2026 Written before the update above. Where they differ, the update is the more recent position. #### Regulatory Status North Dakota's payments-regulatory posture is elevated and tightening: this cycle establishes a full baseline across all fourteen methodology modules, anchored by two nationally significant developments. First, a North Dakota federal court vacated Regulation II, the Federal Reserve's debit-card interchange fee standard, in Corner Post, Inc. v. Board of Governors of the Federal Reserve System on August 6, 2025, with nationwide implications for US card-issuing banks and merchant acquirers, though the vacatur is stayed pending an anticipated Federal Reserve appeal. Second, Bank of North Dakota - the nation's only state-owned bank - has advanced Roughrider Coin, a USD-value-pegged stablecoin built with Fiserv, toward a targeted 2026 launch after the Industrial Commission approved a bank-to-bank use case on March 25, 2026. Beneath these headline items, licensing and safeguarding rest on the 2023 Money Transmission Modernization Act and a permissible-investments backing model, now layered with House Bill 1127's cybersecurity-governance regime and House Bill 1447's crypto-kiosk consumer protections; correspondent-banking access runs through Bank of North Dakota's state-guaranteed, non-FDIC-insured settlement network, which continues to offset rural de-risking pressure documented in the Federal Reserve's Ninth District. The jurisdiction's AML/CFT module currently rests only on a statutory reporting hook under NDCC 13-09.1-22, since no live Sentinel.gi feed was accessible this cycle. #### Outlook The Federal Reserve's response to the Corner Post appeal and Roughrider Coin's progress toward its targeted fourth-quarter 2026 launch are the two forward markers most likely to shape North Dakota's payments-regulatory trajectory over the coming cycles, against a backdrop of continued in-state community-bank consolidation and layered conduct/cybersecurity obligations on non-bank money transmitters and virtual-currency kiosk operators. Read full brief · 575 words × 14 of 14 modules Signal Moved Judgment Gap Density Comfortable Compact Expand all sources Reset all Selections OR within a group, AND across groups. Press / to search. ### W1aLicensing, Authorisation & Market AccessConfirmedconfirmed 2026-07-05▾# NDDFI issued perpetual participation-prohibition orders against two named individuals (Trevino Trousdale, Ricks) from employment or affairs of any NDDFI-licensed bank, credit union, or financial institution, dated on or about 2026-10-16. Horizon · 2026-Q4 (± a year) DFI designation of 'alternative financing products' under amended ND Money Brokers Act Adopted, not yet in force · Tier 3 source Standing sub-brief · as of 5 July 2026 185 words · last cycle 2026-10-25 #### Licensing, Authorisation & Market Access North Dakota's non-bank payments licensing regime rests on the 2023 Money Transmission Modernization Act (NDCC ch. 13-09.1), enacted March 15, 2023 as SB 2119 and administered by the North Dakota Department of Financial Institutions through the Nationwide Multistate Licensing System, replacing the prior chapter 13-09 framework. No physical presence in the state is required, and banks and credit unions remain exempt from the licensing requirement, consistent with the standard US dual-track model separating bank-PSP activity from non-bank payment-institution/e-money activity. Entry into the non-bank market carries a defined prudential threshold: applicants must demonstrate a minimum net worth of $100,000 and post a surety bond of between $150,000 and $500,000 under NDCC 13-09-05, with the exact bond amount set by the Commissioner according to the applicant's financial condition and transmission volume. #### Outlook With the MTMA baseline now fully established, the near-term licensing story for US-ND runs through implementation rather than new legislation: expect continued NMLS-based licensing of money transmitters and crypto-kiosk operators under the existing statutory bond/net-worth thresholds, with no indication of pending amendments to the core chapter 13-09.1 framework this cycle. Read full sub-brief · 185 words Periodic update · new data 2026-10-25 #### Licensing, Authorisation & Market Access The North Dakota Department of Financial Institutions issued perpetual prohibition orders against two individuals, Monica Trevino Trousdale and Brianna Ricks, barring them from employment or participation in any entity the Department licenses. This is an exercise of the Department's standing personnel-exclusion authority rather than a new rule or licensing-framework change. The orders were made public via the Department's own notices, though the underlying conduct that prompted them was not disclosed in those notices, which limits the ability to characterize the nature or severity of the conduct beyond the fact that it was sufficient to warrant a permanent bar. This development sits within the Department's general market-access gatekeeping function, which covers who may be employed by or participate in licensed financial institutions and money-transmission businesses operating in the state. A perpetual bar is among the most severe sanctions available short of criminal referral, and its issuance signals that the Department continues to actively use its exclusionary powers even where it does not simultaneously publish the factual basis for doing so. No change to the underlying licensing statute or authorisation framework accompanied these orders. The action should be read as enforcement activity under an existing framework rather than as evidence of a shift in the framework itself. #### Outlook Without further disclosure of the underlying conduct, it is difficult to assess whether this action reflects an isolated personnel issue or points to a broader pattern at a particular licensed entity or across the market. Continued monitoring of the Department's enforcement notices is the only available means of tracking whether additional related actions follow. 4 earlier distinct update(s) Periodic update · new data 2026-10-18 #### Licensing, Authorisation & Market Access NDDFI Commissioner Lise Kruse issued orders around 2026-10-16 perpetually prohibiting Monica Trevino Trousdale and Brianna Ricks from employment or participation in the affairs of any NDDFI-licensed bank, credit union, or other financial institution. This is an individual-level market-access enforcement action: the orders bar these two named individuals from holding any role in an NDDFI-licensed entity going forward, applying across the full range of institution types NDDFI licenses, from banks and credit unions to nonbank financial entities under its jurisdiction. The same cycle also carries a licensing-relevant dimension in the Coinme multistate settlement: Coinme's status as an NDDFI-licensed money transmitter and kiosk operator is directly implicated by the settlement terms, with the required wind-down of its North Dakota kiosk operations by 2027-01-01 amounting to a voluntary relinquishment of market access in that line of business, conditioned on the settlement rather than on a separate licence-revocation proceeding. Read together, the two developments show NDDFI exercising its market-access authority on two tracks this cycle, one targeting individual personnel directly, the other operating through a negotiated multistate settlement that results in an operator's withdrawal from a licensed activity. #### Outlook No further licensing or market-access developments beyond these two actions are addressed by the current record for North Dakota this cycle. Whether the participation-prohibition orders against Trevino Trousdale and Ricks are connected to the Coinme matter or arise from an unrelated matter is not established by the available record. Periodic update · new data 2026-09-28 #### Licensing, Authorisation & Market Access North Dakota's money-transmission licensing regime is anchored in the Money Transmission Modernization Act, N.D.C.C. ch. 13-09.1, which replaced the legacy money-transmitters chapter effective with its 2023 enactment. The Act is administered by the North Dakota Department of Financial Institutions and applies to nonbank payment-institution and e-money-institution-type entities, carrying the standard multistate-model licensing conditions applicable to that category. A distinguishing feature of the North Dakota implementation is its dedicated fee schedule for virtual-currency transmitters: the greater of five hundred dollars or 0.25 percent of average USD-equivalent virtual-currency transmission volume calculated over the trailing twelve months, subject to a twenty-five-hundred-dollar cap. This fee-formula distinction confirms that virtual-currency transmission is treated as a licensed activity class within the same statutory perimeter as traditional money transmission, rather than as an unregulated or separately-carved-out activity. The licensing framework itself did not change substantively this cycle; what confirms as material is the consolidation of the post-2023 regime as the settled operative framework, replacing any residual reliance on the repealed chapter 13-09. This is a bank-versus-nonbank distinction worth carrying explicitly: the licensing obligations described here apply to nonbank payment-institution and e-money-institution-type entities specifically, and do not touch depository institutions, which are licensed and supervised through an entirely separate banking framework. #### Outlook The licensing framework is now settled following the 2023 modernization, and the near-term outlook is one of monitoring practical administration rather than anticipating further statutory change. Watch for Department of Financial Institutions guidance clarifying application of the virtual-currency fee formula to novel transmission models, which would sharpen market-access certainty for prospective licensees. Periodic update · new data 2026-09-14 #### Licensing, Authorisation & Market Access North Dakota's licensing perimeter for money transmission and virtual-currency businesses has undergone structural modernization across two legislative cycles. SB2119, enacted in 2023, created N.D.C.C. ch. 13-09.1 by adopting the multistate Money Transmission Modernization Act model law, repealing the prior ch. 13-09 framework entirely. This is a nonbank-PI/EMI-type licensing regime -- North Dakota's money-transmitter statute governs the nonbank payment-institution and e-money-institution-equivalent population rather than bank-chartered entities, which operate under separate prudential frameworks. Under the modernized regime, the licensing renewal fee is capped at $2,500, calculated as the greater of a flat amount or a formula tied to the dollar volume of money or virtual currency transmitted in the state over the trailing twelve months ending June 30. Building on that 2023 foundation, HB1447 in the 2025 session added a dedicated virtual-currency-kiosk sub-regime under new N.D.C.C. §§13-09.1-50 through 13-09.1-54. Kiosk operators must hold a money transmitter license specifically covering kiosk operations, meet physical security standards for kiosk placement, and comply with the fraud-warning disclosure and daily transaction-limit requirements addressed separately under Product Innovation & Market Development. This sub-regime represents a targeted licensing expansion responding to the specific risk profile of unattended virtual-currency kiosks as opposed to online exchange or custody activity. A third and still-developing element is HB1127, effective 1 August 2025, which amended North Dakota's Money Brokers Act to potentially bring DFI-designated 'alternative financing products' within that Act's licensing scope. As of this cycle, DFI has not yet issued the administrative order identifying which specific products would be captured, leaving the practical reach of this amendment undetermined. Firms offering financing products adjacent to traditional money-broker activity should monitor for the forthcoming designation. Taken as a whole, this is a material and structural tightening of North Dakota's licensing perimeter: a base modernization (2023), a targeted sectoral expansion for virtual-currency kiosks (2025), and a pending further expansion into alternative financing products (2025, designation pending) together indicate a state actively extending its nonbank payments-licensing architecture rather than leaving it static. #### Outlook The key event to watch is DFI's anticipated designation order under the amended Money Brokers Act, expected around Q4 2026, which will determine which alternative financing products fall within the expanded licensing scope. Separately, whether DFI issues interpretive guidance on enforcement of the kiosk sub-regime's licensing and physical-security requirements would signal how actively the new virtual-currency-kiosk licensing layer is being supervised. Periodic update · new data 2026-08-25 #### Licensing, Authorisation & Market Access North Dakota's money-transmission licensing framework rests on a 2023 restructuring: Senate Bill 2119 enacted the Money Transmission Modernization Act as NDCC ch. 13-09.1, repealing the prior ch. 13-09 money-transmitter chapter. This is the state's standing licensing architecture — a Tier-1-sourced, High-confidence structural fact drawn directly from the North Dakota Department of Financial Institutions — and it is the chapter within which this cycle's two legislative extensions operate. Two dated developments this cycle extend that chapter's scope. House Bill 1447 (Tier-3 sourced, Elevated impact) requires cryptocurrency-kiosk and ATM operators to obtain a North Dakota money transmitter licence, deploy blockchain-analytics software, appoint a compliance officer, file quarterly reports, post fraud warnings, and cap early transactions at $2,000 per day. This is corroborated across two independent Tier-3 press sources but has not yet been confirmed against a Tier-1 ND.gov bill-status record. House Bill 1127 (Tier-3 sourced, Monitored impact) amends the Money Brokers Act, effective August 1, 2025, to define "loan" to include any Department-of-Financial-Institutions-designated "alternative financing product." Both extensions attach to the existing licence-type structure — a money transmitter license, with no exemptions listed for either — rather than creating a new licence category. Both developments sit in the non-bank PI/EMI lane of the state's licensing architecture: crypto-kiosk operators and alternative-financing providers are captured, where captured at all, through money-transmitter and money-broker licensing rather than banking-charter supervision. No bank-prudential licensing change was identified for North Dakota this cycle; the entirety of this cycle's licensing-perimeter movement runs through the non-bank money-transmission and money-brokerage lanes. A key judgment from this cycle's tracking, assessed at High confidence and Elevated impact, is that North Dakota's licensing perimeter has expanded twice in 2025, signalling a tightening posture toward previously unlicensed or ambiguously-scoped payment-adjacent activity. #### Outlook HB 1127's practical effect depends on whether the Department of Financial Institutions exercises its discretion to designate specific alternative financing products — a step that has not yet occurred. HB 1447's practical effect depends on Tier-1 confirmation of its enacted text and effective date, which was not reached this cycle. Both remain open items for the next tracking cycle. Evidence 6 Sources and findings (6) - T1[https://www.nd.gov/dfi/news/north-dakota-enacts-money-transmission-modernization-act](https://www.nd.gov/dfi/news/north-dakota-enacts-money-transmission-modernization-act)retrieved 2026-07-05 - T1[https://www.nd.gov/dfi/about-dfi/non-depository/frequently-asked-questions-non-depository](https://www.nd.gov/dfi/about-dfi/non-depository/frequently-asked-questions-non-depository)retrieved 2026-07-05 - T1[https://moneytransmitterlaw.com/cryptocurrency-state-laws/north-dakota/](https://moneytransmitterlaw.com/cryptocurrency-state-laws/north-dakota/)retrieved 2026-07-05 - T1[https://www.bondexchange.com/north-dakota-money-transmitter-bond-a-comprehensive-guide/](https://www.bondexchange.com/north-dakota-money-transmitter-bond-a-comprehensive-guide/)retrieved 2026-07-05 - T1[https://www.nd.gov/dfi/crypto-atms](https://www.nd.gov/dfi/crypto-atms)retrieved 2026-07-05 - T1[https://www.nd.gov/faq/financial-institutions-faq](https://www.nd.gov/faq/financial-institutions-faq)retrieved 2026-07-05 ### W1bConduct, Safeguarding & PromotionsConfirmedconfirmed 2026-07-05▾# Federal GENIUS Act implementation racing 18 July 2026 statutory deadline: joint FinCEN/OFAC AML-sanctions proposed rule (8 Apr 2026), FDIC custody rule (comments due 9 Jun 2026), Treasury 'substantially similar' NPRM gating state-qualified issuers including ND. Standing sub-brief · as of 5 July 2026 188 words · last cycle 2026-09-21 #### Conduct, Safeguarding & Financial Promotions Safeguarding of customer funds for North Dakota money-transmitter licensees does not rely on pure trust-account segregation; instead, NDCC 13-09-04 requires licensees to maintain permissible investments with an aggregate market value not less than the aggregate face amount of outstanding payment instruments and stored value, functioning as the statutory backstop for consumer funds. Layered on top of that longstanding model, House Bill 1127, effective August 1, 2025, imposes new conduct-adjacent cybersecurity duties on NDDFI-regulated non-depository financial corporations: a written information-security program, a designated qualified individual responsible for it, documented risk assessments, and a requirement to notify the Commissioner within 45 days of a breach affecting 500 or more consumers. Civil penalties of up to $100,000 per violation attach to non-compliance, positioning HB 1127 as a materially new conduct obligation layered onto the existing safeguarding backbone rather than a replacement for it. #### Outlook HB 1127's infosec/breach-notification regime is now in force and is the live conduct item to track for non-bank licensees; expect NDDFI examination attention to shift toward verifying qualified-individual designations and breach-notification readiness among money transmitters and crypto-kiosk operators over the coming cycles. Read full sub-brief · 188 words Periodic update · new data 2026-09-28 #### Conduct, Safeguarding & Financial Promotions North Dakota's 2025 House Bill 1447 introduced the state's first crypto-adjacent conduct obligation reaching the payments sector: mandatory scam-warning disclosures for virtual-currency kiosk operators. The new provisions require kiosk operators to disclose statutory warnings covering three specific fraud typologies: frozen-account claims, fraudulent bank-transaction claims, and requests for payment purportedly made to government agencies. This is a targeted conduct rule addressing a documented fraud vector in the kiosk channel specifically, rather than a general financial-promotions or advertising-conduct regime applicable across payment products. This conduct obligation is layered directly onto the existing money-transmission licensing base at ch. 13-09.1 rather than existing as a freestanding consumer-protection statute, meaning the disclosure duty is enforceable as a condition of the underlying money-transmitter license held by kiosk operators. The obligation applies to nonbank payment-institution and e-money-institution-type entities operating kiosks; it carries no separate financial-promotions or marketing-restriction dimension beyond the specific scam-warning disclosure content mandated by statute. #### Outlook This is a newly enacted, narrowly scoped conduct obligation that has not yet been tested by enforcement. Watch for Department of Financial Institutions guidance or enforcement activity addressing kiosk-operator compliance with the scam-warning disclosure duty, which would clarify the practical conduct-supervision posture the Department intends to take toward this channel. 1 earlier distinct update(s) Periodic update · new data 2026-08-11 #### Conduct, Safeguarding & Financial Promotions This cycle's federal overlay development is squarely a conduct-and-safeguarding matter for any permitted payment stablecoin issuer, North Dakota's included. Treasury, FinCEN, and OFAC have issued a joint proposed rule applying Bank Secrecy Act-equivalent AML and sanctions-compliance program obligations to permitted payment stablecoin issuers; the proposal reaches both bank-model and non-bank-model issuers, though the compliance-program design each is expected to build differs by model. The FDIC has proposed a distinct, bank-side rule addressing custody safeguarding of stablecoin reserves specifically, published in the Federal Register on 10 April 2026 with a comment period that closed 9 June 2026. Read together, the two proposals separate the AML/sanctions-program obligation, which applies broadly across issuer models, from the reserve-custody-safeguarding obligation, which is scoped specifically to bank issuers holding customer-facing reserves. The item with the most direct bearing on North Dakota is the substantially-similar equivalence test that Treasury's rulemaking is expected to finalize. That test will determine whether a state-level stablecoin regime, such as North Dakota's, qualifies its state-supervised issuers for a sub-ten-billion-dollar state-oversight track, or whether issuers exceeding that threshold must transition to the full federal permitted-payment-stablecoin-issuer regime absent a waiver. The rule as proposed also requires that any state framework relied upon under this test must not itself impede federal compliance, meaning North Dakota's own state-level oversight design is not fully autonomous of the federal standard even where an issuer qualifies for the state track. Until the equivalence test is finalized, this is a live compliance-design uncertainty rather than a settled safeguarding requirement, and it applies to every state-qualified issuer currently operating or planning to operate under a state framework, not to North Dakota's pilot alone. For the safeguarding dimension specifically, the FDIC's proposed custody rule is the more directly applicable instrument to a bank-model issuer such as North Dakota's state-owned bank, since it addresses how stablecoin reserves must be held rather than how transactions must be screened. The AML/sanctions program obligation under the joint Treasury/FinCEN/OFAC proposal is the parallel conduct-side requirement, and both would need to be satisfied concurrently by a bank-model state-qualified issuer once finalized. No financial-promotions-specific rule change was identified in the claims reviewed this cycle bearing on stablecoin marketing or disclosure requirements. #### Outlook Both federal proposals are still in consultation or pre-finalization stages, and the FDIC custody rule's comment period has already closed as of 9 June 2026, putting it closer to finalization than the joint AML-sanctions proposal. Watch for the finalized text of the substantially-similar equivalence test specifically, since its precise calibration will determine whether North Dakota's state-qualified-issuer track remains viable in its currently-contemplated form, and for whether the finalized custody rule imposes reserve-composition or reserve-location requirements beyond what the proposal currently contemplates. Evidence 5 Sources and findings (5) - T1[https://moneytransmitterlaw.com/cryptocurrency-state-laws/north-dakota/](https://moneytransmitterlaw.com/cryptocurrency-state-laws/north-dakota/)retrieved 2026-07-05 - T2[https://www.workplaceprivacyreport.com/2025/07/articles/data-security/hb1127-explained-north-dakotas-new-infosec-requirements-for-financial-corporations/](https://www.workplaceprivacyreport.com/2025/07/articles/data-security/hb1127-explained-north-dakotas-new-infosec-requirements-for-financial-corporations/)retrieved 2026-07-05 - T1[https://www.nd.gov/dfi/crypto-atms](https://www.nd.gov/dfi/crypto-atms)retrieved 2026-07-05 - T1[https://ndlegis.gov/cencode/t13c09-1.pdf](https://ndlegis.gov/cencode/t13c09-1.pdf)retrieved 2026-07-05 - T1[https://attorneygeneral.nd.gov/consumer-resources/](https://attorneygeneral.nd.gov/consumer-resources/)retrieved 2026-07-05 ### W2Stablecoins & Digital Money1 judgmentProbableconfirmed 2026-07-05▾# North Dakota has no dedicated stablecoin-issuer licensing statute; digital-money activity is governed instead through the general money-transmitter chapter (13-09.1) plus the federal GENIUS Act framework. The headline development is Bank of North Dakota's (the nation's only state-owned bank) Roughrider Coin, a USD-backed stablecoin built with Fiserv for bank-to-bank settlement, approved for pilot by the ND Industrial Commission with launch targeted in 2026. Key judgment — Probable · impact ELEVATED The Bank of North Dakota's Roughrider Coin, built on a bank-issued, Solana-settled, Fireblocks-tokenised interbank-settlement stack, represents a notable state-level digital-money infrastructure deployment with no visible bespoke AML guidance yet, distinct from private-sector stablecoin products. claims: wpm-2026-W43-001 Horizon · 2026-Q4 (± six months) Roughrider Coin public launch targeted Adopted, not yet in force · Tier 3 source Horizon · 2026-Q4 (± six months) Roughrider Coin public launch targeted Adopted, not yet in force · Tier 3 source Horizon · 2026-Q4 (± six months) GENIUS Act Treasury NPRM on state/federal 'substantial similarity' finalization Consultation · Tier 3 source Standing sub-brief · as of 5 July 2026 219 words · last cycle 2026-10-25 #### Stablecoins & Digital Money Bank of North Dakota and Fiserv announced the Roughrider Coin partnership on October 8, 2025, building a USD-value-pegged stablecoin on Fiserv's FIUSD digital-asset platform as a non-binding, zero-cost-to-BND pilot for bank-to-bank settlement. The North Dakota Industrial Commission advanced that pilot on March 25, 2026, approving a bank-to-bank use case after a closed-door risk assessment, with ten local banks expressing pilot interest and a launch targeted later in 2026; use of the coin remains voluntary for North Dakota banks and credit unions. No bespoke state stablecoin-issuer statute underpins this activity: the NDDFI has clarified that pure crypto-to-crypto exchange currently falls outside the general money-transmitter statute's scope, but any company that also holds or transmits fiat currency, including via digital wallets, still requires a Money Transmitter License. Roughrider Coin therefore operates through the general MTL framework and a non-binding Industrial Commission approval rather than dedicated stablecoin legislation. #### Outlook Roughrider Coin's public launch is targeted for the fourth quarter of 2026 per the Industrial Commission's timeline, which would make Bank of North Dakota the first US state-affiliated stablecoin issuer; the absence of bespoke stablecoin legislation means the pilot's legal footing continues to rest on the general MTL statute and non-binding regulatory approval rather than a purpose-built framework, a gap likely to draw legislative attention if the launch proceeds. Read full sub-brief · 219 words Periodic update · new data 2026-10-25 #### Stablecoins & Digital Money The Bank of North Dakota has confirmed the live operation of Roughrider Coin, a dollar-backed tokenized digital asset built specifically for interbank settlement. The product has been operating since October 1, 2026, and reporting places voluntary adoption at roughly ninety North Dakota banks and credit unions, described in coverage as modernizing interbank payments for community banks and credit unions and developed for regulated institutions in a manner designed to integrate with existing payment operations rather than disrupt them. The technical and commercial architecture behind the product is distinctive. VersaBank serves as issuer of the dollar-backed token, Fiserv provides platform integration connecting the asset to participating institutions' existing payment operations, and Fireblocks supplies the tokenisation and custody infrastructure underpinning the asset. Settlement occurs on the Solana blockchain. This combination, a state-owned bank partnering with a chartered bank issuer, a major payments-platform provider, and a specialist digital-asset infrastructure firm, represents a notably institutional approach to stablecoin-style interbank settlement, distinct from retail-facing or privately issued stablecoin products more commonly seen in this space. What distinguishes Roughrider Coin from a central bank digital currency is important to state plainly: this is a bank-issued, privately operated settlement instrument rather than a sovereign digital currency, and adoption among participating institutions is voluntary rather than mandated. It is also not, on the information available, subject to any bespoke state regulatory framework specific to stablecoins; North Dakota has no dedicated stablecoin-authorisation regime distinct from its general money-transmission and banking statutes, and no guidance addressing Roughrider Coin's treatment under those general statutes has been identified. The scale of reported adoption, roughly ninety institutions within weeks of a stated launch date, makes this one of the more concrete examples of state-level digital-money infrastructure deployment tracked recently. The involvement of a state-owned bank as the lead vendor, rather than a private fintech or a large money-center bank, is itself a structurally notable feature: it suggests a model in which a state's own banking infrastructure provider builds and operates settlement rails for its community banking sector, rather than community banks individually adopting a third-party commercial product. #### Outlook The key variables to watch are the pace of further adoption beyond the initial roughly ninety institutions, whether other state-owned or regional banking infrastructure providers in other jurisdictions attempt to replicate this model, and whether North Dakota or federal banking regulators issue any guidance addressing the product's status. Given the product's institutional-only distribution model and its positioning as complementary to, rather than a replacement for, existing payment rails, near-term regulatory intervention appears unlikely absent a specific triggering event, but the absence of any stated regulatory position remains a feature worth monitoring as adoption scales. 1 earlier distinct update(s) Periodic update · new data 2026-10-11 #### Stablecoins & Digital Money Bank of North Dakota's Roughrider Coin went live October 1, 2026, making it the first US state-owned bank to bring a stablecoin to live production. The instrument is structured as a wholesale, institution-only, dollar-backed stablecoin: VersaBank USA, N.A., an OCC-chartered bank, serves as the issuing entity, Fireblocks provides the tokenization infrastructure, and settlement runs on Solana. The program operates on Fiserv's digital asset platform, which activated the same day with Roughrider Coin as its first live use case. The legal basis for this structure is the GENIUS Act's state-issuer carve-out, which permits a state-chartered or state-owned issuer to bring a payment stablecoin to market pending finalization of federal and state 'substantial similarity' implementing rules. Those implementing rules, expected to finalize in Q4 2026 as scheduled via a Treasury rulemaking process, have not yet concluded, which means North Dakota's current program design sits inside an active rulemaking window rather than operating under a settled federal framework. This positioning is the defining feature of the stablecoin-regime story this cycle: a live, operational program built on a provisional legal foundation. A four-institution pilot cohort, Gate City Bank, First International Bank & Trust, Capital Credit Union, and North Star Community Credit Union, all North Dakota-domiciled, was announced October 5, 2026, confirming the program moved from a bilateral issuer-sponsor arrangement into an active multi-institution pilot within days of going live. The wholesale, institution-only design confines the current counterparty universe to interbank and institutional relationships rather than retail customers, a scope limitation that shapes both the operational risk profile and the regulatory questions the program raises. Whether VersaBank or Bank of North Dakota requires a North Dakota money-transmitter license for this activity, or whether the program relies entirely on VersaBank's OCC charter combined with the GENIUS Act carve-out, was not resolved this cycle; this is an open licensing question for a novel structure that does not map cleanly onto existing state money-transmission categories. #### Outlook The determinative near-term event is Treasury's finalization of the GENIUS Act 'substantial similarity' implementing rules, expected Q4 2026 as scheduled. That rule will decide whether North Dakota's reliance on the state-issuer carve-out remains viable in its current form or whether further state legislative or regulatory action becomes necessary. Until that rule finalizes, Roughrider Coin's durability as a compliant structure carries a live federalism question: a state program built ahead of, rather than after, the governing federal rule's finalization. Evidence 5 Sources and findings (5) - T1[https://bnd.nd.gov/roughrider/](https://bnd.nd.gov/roughrider/)retrieved 2026-07-05 - T1[https://northdakotamonitor.com/2026/03/26/north-dakota-moves-forward-with-stablecoin-as-local-banks-express-interest-in-pilot-project/](https://northdakotamonitor.com/2026/03/26/north-dakota-moves-forward-with-stablecoin-as-local-banks-express-interest-in-pilot-project/)retrieved 2026-07-05 - T2[https://investors.fiserv.com/news-releases/news-release-details/bank-north-dakota-and-fiserv-partner-launch-roughrider-coin](https://investors.fiserv.com/news-releases/news-release-details/bank-north-dakota-and-fiserv-partner-launch-roughrider-coin)retrieved 2026-07-05 - T1[https://www.nd.gov/faq/financial-institutions-faq](https://www.nd.gov/faq/financial-institutions-faq)retrieved 2026-07-05 - T3[https://www.tokenpost.com/news/regulation/13806](https://www.tokenpost.com/news/regulation/13806)retrieved 2026-07-05 ### W3Operational Resilience & Critical InfrastructureConfirmedconfirmed 2026-07-05▾# 2025 HB 1127 created ch. 13-01.2, a GLBA-Safeguards-Rule-modeled written information-security-program mandate for nonbank 'financial corporations' (explicitly including money transmitters and cryptocurrency kiosks; banks/credit unions excluded), with a 45-day/≥500-consumer DFI breach-notification trigger. Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. [Open its jurisdiction pages on Dataprotection.gi →](https://dataprotection.gi/jurisdictions/) Standing sub-brief · as of 5 July 2026 193 words · last cycle 2026-09-21 #### Operational Resilience & Critical Infrastructure North Dakota's operational-resilience regime runs on two tracks. Depository institutions sit on a supervisory cadence of roughly 24 months for state-chartered banks and 18 to 24 months for credit unions, with information security treated as a major examination focus area across both bank and non-depository reviews. Non-depository money-services licensees now carry a distinct statutory layer: House Bill 1127 requires designation of a qualified individual to oversee the information-security program, oversight protocols for third-party-employed security personnel, and annual written board reporting on program performance. The pilot phase of Roughrider Coin has itself become a live operational-resilience case study: Bank of North Dakota's chief executive characterized the stablecoin's development risk as low to moderate, explicitly flagging reliance on vendor Fiserv and reputational risk tied to the product's novelty as the key considerations presented to the Industrial Commission ahead of its March 2026 approval. #### Outlook Expect NDDFI examination priorities to keep information security as a central focus across both depository and non-depository reviews, with HB 1127's qualified-individual and board-reporting requirements now due for supervisory follow-through, and continued vendor-concentration and reputational-risk monitoring around Roughrider Coin as it approaches a targeted 2026 launch. Read full sub-brief · 193 words Periodic update · new data 2026-09-28 #### Operational Resilience & Critical Infrastructure North Dakota's 2025 House Bill 1127 established the state's first operational-resilience and data-security mandate reaching nonbank payments entities. The bill created a new chapter, 13-01.2, requiring covered nonbank financial corporations, a category including money transmitters and virtual-currency kiosks, to maintain a written information-security program. The mandate carries a defined breach-notification trigger: covered entities must notify the Department of Financial Institutions as soon as possible and no later than forty-five days after discovering a breach affecting five hundred or more consumers. Banks and credit unions are explicitly excluded from this chapter's scope, reflecting that this is a nonbank-specific resilience overlay filling a gap left by existing federal prudential frameworks that already cover depository institutions. This is the first North Dakota-specific resilience mandate of its kind reaching payments nonbanks, and it is worth tracking as a state-level analog to broader operational-resilience frameworks being developed elsewhere, even though it is considerably narrower in scope than a comprehensive resilience regime. The distinction between bank and nonbank coverage here is the module's analytical spine: depository payment-service providers remain under separate federal safeguards regimes, while nonbank payment institutions and e-money-institution-type entities in North Dakota now face a state-specific, GLBA-Safeguards-modeled written-program obligation for the first time. #### Outlook The mandate is confirmed and in force as of August 1, 2025, but its practical enforcement posture remains untested. Watch for Department of Financial Institutions guidance or enforcement activity clarifying how the written-risk-assessment and breach-notification requirements will be supervised in practice for nonbank payments entities. Evidence 5 Sources and findings (5) - T2[https://www.privacyanddatasecurityinsight.com/2025/05/north-dakota-governor-signs-cybersecurity-governance-law-for-financial-institutions/](https://www.privacyanddatasecurityinsight.com/2025/05/north-dakota-governor-signs-cybersecurity-governance-law-for-financial-institutions/)retrieved 2026-07-05 - T1[https://www.bankinfosecurity.com/interviews/state-spotlight-north-dakota-information-security-top-priority-i-295](https://www.bankinfosecurity.com/interviews/state-spotlight-north-dakota-information-security-top-priority-i-295)retrieved 2026-07-05 - T1[https://ndlegis.gov/cencode/t06c01.pdf](https://ndlegis.gov/cencode/t06c01.pdf)retrieved 2026-07-05 - T1[https://www.nd.gov/dfi/about-dfi/non-depository/frequently-asked-questions-non-depository](https://www.nd.gov/dfi/about-dfi/non-depository/frequently-asked-questions-non-depository)retrieved 2026-07-05 - T1[https://northdakotamonitor.com/2026/03/26/north-dakota-moves-forward-with-stablecoin-as-local-banks-express-interest-in-pilot-project/](https://northdakotamonitor.com/2026/03/26/north-dakota-moves-forward-with-stablecoin-as-local-banks-express-interest-in-pilot-project/)retrieved 2026-07-05 ### W4Scheme & Network ComplianceConfirmedconfirmed 2026-07-05▾# North Dakota is the unlikely epicenter of the single most consequential US card-scheme compliance event of the period: a federal district court in Bismarck vacated the Federal Reserve's Regulation II debit-interchange fee standard (stayed pending appeal). Separately, state-level legislative attempts to regulate interchange-on-sales-tax have failed, and North Dakota otherwise defaults to federal/network surcharging rules with no bespoke state scheme-compliance statute. Standing sub-brief · as of 5 July 2026 231 words · last cycle 2026-07-05 #### Scheme & Network Compliance The most consequential US card-scheme compliance event of the cycle originated in North Dakota's federal court: in Corner Post, Inc. v. Board of Governors of the Federal Reserve System, the US District Court for the District of North Dakota vacated Regulation II, the Federal Reserve's debit-card interchange fee standard, in its entirety on August 6, 2025, finding the Fed exceeded its statutory authority; the vacatur is stayed pending an anticipated Federal Reserve appeal. Nationwide debit-interchange economics for every US card-issuing bank and merchant acquirer now depend on that appeal's outcome. At the state level, an earlier legislative attempt to regulate interchange failed: SB 2217, which sought to ban interchange fees on the sales-tax portion of card transactions, was rejected 29-64 in the North Dakota House in 2023 after opposition from the ND Bankers Association and more than a dozen trade associations, leaving North Dakota reliant on federal and network defaults for interchange policy absent the Corner Post ruling's effects. #### Outlook The Federal Reserve's anticipated appeal of the Corner Post vacatur is the defining forward marker for US debit-interchange economics; its outcome will determine whether Regulation II's fee cap is restored nationwide or whether card-issuing banks and acquirers operate for a period without a federal interchange ceiling, with North Dakota's failed SB 2217 confirming that state-level intervention on interchange remains politically difficult independent of the federal litigation's outcome. Read full sub-brief · 231 words no periodic updates on record for this sub-brief Evidence 4 Sources and findings (4) - T1[https://www.cooley.com/news/insight/2025/2025-08-15-district-court-vacates-regulation-iis-debit-card-interchange-fee-standard](https://www.cooley.com/news/insight/2025/2025-08-15-district-court-vacates-regulation-iis-debit-card-interchange-fee-standard)retrieved 2026-07-05 - T1[https://northdakotamonitor.com/2025/08/07/north-dakota-truck-stop-paves-way-for-reducing-debit-card-fees-nationwide/](https://northdakotamonitor.com/2025/08/07/north-dakota-truck-stop-paves-way-for-reducing-debit-card-fees-nationwide/)retrieved 2026-07-05 - T2[https://www.consumerfinancemonitor.com/2023/02/22/north-dakota-legislation-seeks-to-ban-interchange-on-sales-tax/](https://www.consumerfinancemonitor.com/2023/02/22/north-dakota-legislation-seeks-to-ban-interchange-on-sales-tax/)retrieved 2026-07-05 - T3[https://merchantcostconsulting.com/lower-credit-card-processing-fees/north-dakota-surcharge-laws/](https://merchantcostconsulting.com/lower-credit-card-processing-fees/north-dakota-surcharge-laws/)retrieved 2026-07-05 ### W5Payment Corridor Dynamics1 gapProbableconfirmed 2026-07-05▾# ND's payment corridors run through two channels: (i) the FedNow instant-payments rail, on which Bank of North Dakota and at least five other ND institutions are live; and (ii) BND's own correspondent/wholesale network, which channels ND's roughly 100+ community banks and credit unions into national ACH, Fedwire and Fed-funds settlement. The planned Roughrider Coin stablecoin is explicitly positioned as a new cross-border/bank-to-bank settlement corridor layered atop this existing infrastructure. Open gap — wpm-int-1 No ND-specific instant/emerging-market-rail development found this cycle. US state-level divergence under-indexed by scope, not by choice. Standing sub-brief · as of 5 July 2026 174 words · last cycle 2026-07-05 #### Payment Corridor Dynamics At least six North Dakota institutions - Bank of North Dakota, Farmers & Merchants Bank of ND, First State Bank, First Western Bank & Trust, VISIONBank, and Western Cooperative Credit Union - are live participants on the FedNow instant-payments rail. Bank of North Dakota itself functions as the correspondent bank for most of the state's financial institutions, providing ACH origination, Federal Reserve activity settlement, item processing and check clearing, government-security purchases, and letter-of-credit pledging. Layered atop these established rails, Bank of North Dakota and Fiserv position the Roughrider Coin stablecoin as an instant, interoperable, borderless bank-to-bank settlement corridor intended to increase bank-to-bank transactions and global money movement, with eventual merchant adoption floated as a longer-term goal. #### Outlook Expect FedNow participation among North Dakota institutions to continue expanding alongside Bank of North Dakota's established correspondent network, while Roughrider Coin's approved bank-to-bank use case, if it proceeds to its targeted 2026 launch, would add a genuinely new settlement corridor layered on top of existing ACH, Fedwire and FedNow infrastructure rather than displacing it. Read full sub-brief · 174 words no periodic updates on record for this sub-brief Evidence 4 Sources and findings (4) - T3[https://www.nerdwallet.com/banking/learn/banks-that-use-fednow](https://www.nerdwallet.com/banking/learn/banks-that-use-fednow)retrieved 2026-07-05 - T1[https://www.businesswire.com/news/home/20251008696630/en/Bank-of-North-Dakota-and-Fiserv-Partner-to-Launch-Roughrider-Coin-North-Dakotas-first-Stablecoin](https://www.businesswire.com/news/home/20251008696630/en/Bank-of-North-Dakota-and-Fiserv-Partner-to-Launch-Roughrider-Coin-North-Dakotas-first-Stablecoin)retrieved 2026-07-05 - T1[https://bnd.nd.gov/fi/](https://bnd.nd.gov/fi/)retrieved 2026-07-05 - T1[https://www.library.nd.gov/statedocs/BND/BankofND20101101.pdf](https://www.library.nd.gov/statedocs/BND/BankofND20101101.pdf)retrieved 2026-07-05 ### W6Industry Structure & Commercial1 gapConfirmedconfirmed 2026-07-05▾# North Dakota's payments-adjacent banking sector is uniquely structured around Bank of North Dakota, the only state-owned general-service bank in the US, which acts as wholesaler, correspondent and technology-adoption leader for a fragmented, community-bank-dominated market with the highest per-capita density of financial institutions of any state. In-state community-bank consolidation continues via family-holding-company M&A alongside BND's Roughrider Coin fintech push. Open gap — wpm-int-3 No ND private-company PSP/fintech funding event other than the BND/Fiserv/VersaBank partnership found this cycle. Private-company signals vector under-indexed this cycle for US-ND. Horizon · 2027 (± a year) ND DFI 'alternative financing products' designation under Money Brokers Act Consultation · Tier 3 source Standing sub-brief · as of 5 July 2026 186 words · last cycle 2026-09-21 #### Industry Structure & Commercial Dynamics Bank of North Dakota holds roughly 15% of in-state bank deposits and was credited in a 2011 Boston Federal Reserve study with enhancing the viability of small banks; roughly half of BND's loan book consists of participations and purchases from community banks, cementing its role as wholesaler to a fragmented, community-bank-dominated market. That community-bank sector continues to consolidate through family-holding-company transactions, exemplified by First Holding Company of Park River's agreement to acquire First State Bank of Cando, expected to close in the first quarter of 2026. Underpinning much of this activity is a concentrated technology-vendor base: Fiserv, with roughly 10,000 financial-institution clients globally, serves as Bank of North Dakota's core banking-services vendor and strategic technology partner for Roughrider Coin, illustrating how reliant North Dakota's community banks are on a small number of large national processors. #### Outlook Expect Bank of North Dakota's wholesaler and correspondent role, alongside continued in-state family-holding-company consolidation, to remain the defining structural features of North Dakota's banking market, with Fiserv's vendor concentration - now extending into stablecoin infrastructure via Roughrider Coin - an increasingly load-bearing dependency to watch. Read full sub-brief · 186 words Periodic update · new data 2026-09-28 #### Industry Structure & Commercial Dynamics A possible future expansion of North Dakota's licensing perimeter is on watch this cycle, arising from HB 1127's broadening of the Money Brokers Act's definitions. Secondary legal commentary indicates the Department of Financial Institutions could, at some future point, designate certain 'alternative financing products,' specifically merchant cash advances and earned-wage-access products, as covered loans subject to money-broker licensing. As of this cycle, the Department has not issued any such designation, and this remains a discretionary, not-yet-exercised authority rather than a realized change to the industry-structure landscape for these product categories in North Dakota. This is a genuinely forward-looking industry-structure signal rather than an observed commercial-dynamics shift: no merchant-cash-advance or earned-wage-access provider has yet been brought within the money-broker licensing perimeter as a result of this statutory change. The commercial significance, if the designation is eventually exercised, would be to bring a currently uncovered product category (alternative financing) within the state's existing money-broker licensing and disclosure framework, materially changing the competitive and compliance landscape for providers of those products operating in or serving North Dakota consumers. #### Outlook The key industry-structure development to watch is whether the Department of Financial Institutions actually exercises its discretion to designate alternative financing products as covered loans. Until such a designation issues, no change to the competitive landscape for merchant-cash-advance or earned-wage-access providers has actually occurred in North Dakota. Evidence 5 Sources and findings (5) - T1[https://en.wikipedia.org/wiki/Bank_of_North_Dakota](https://en.wikipedia.org/wiki/Bank_of_North_Dakota)retrieved 2026-07-05 - T2[https://bankingjournal.aba.com/2026/01/bank-acquisitions-announced-in-four-states-4/](https://bankingjournal.aba.com/2026/01/bank-acquisitions-announced-in-four-states-4/)retrieved 2026-07-05 - T1[https://www.federalregister.gov/documents/2026/04/08/2026-06771/change-in-bank-control-notices-acquisitions-of-shares-of-a-bank-or-bank-holding-company](https://www.federalregister.gov/documents/2026/04/08/2026-06771/change-in-bank-control-notices-acquisitions-of-shares-of-a-bank-or-bank-holding-company)retrieved 2026-07-05 - T1[https://investors.fiserv.com/news-releases/news-release-details/bank-north-dakota-and-fiserv-partner-launch-roughrider-coin](https://investors.fiserv.com/news-releases/news-release-details/bank-north-dakota-and-fiserv-partner-launch-roughrider-coin)retrieved 2026-07-05 - T1[https://bnd.nd.gov/government/](https://bnd.nd.gov/government/)retrieved 2026-07-05 ### W7Legal & LitigationConfirmedconfirmed 2026-07-05▾# The dominant payments-legal event centered on North Dakota is Corner Post, Inc. v. Board of Governors of the Federal Reserve System, in which a Bismarck federal judge vacated Regulation II's debit-interchange framework nationwide (stayed on appeal) after a multi-year procedural odyssey including a Supreme Court ruling on timeliness. Separately, the ND Attorney General's Consumer Protection Division continues active enforcement against payment-adjacent deceptive billing practices, and HB 1127 gives NDDFI new civil-penalty enforcement powers over non-bank financial corporations. Standing sub-brief · as of 5 July 2026 208 words · last cycle 2026-07-05 #### Legal & Litigation Corner Post v. Board of Governors of the Federal Reserve System dominates North Dakota's payments-litigation docket: Judge Daniel Traynor held that the Fed impermissibly included fixed ACS costs, network processing fees, transaction-monitoring costs and fraud losses in setting the Regulation II interchange standard, contravening the Durbin Amendment's plain text, and cited Loper Bright to reject deference to the Fed's rulemaking. Separately, House Bill 1127 gives the NDDFI new enforcement powers, authorizing penalties of up to $100,000 per violation plus $1,000-per-day continuing penalties, along with cease-and-desist authority, against covered financial corporations for infosec violations. On the consumer-enforcement side, the North Dakota Attorney General's Office settled in February 2026 with Lake Holdings over deceptive invoice solicitations mimicking legitimate billing sent to North Dakota churches, nonprofits and small businesses since 2022, with the settlement requiring full refunds and changes to the company's mailer practices. #### Outlook The Federal Reserve's appeal of the Corner Post vacatur will remain the dominant North Dakota payments-litigation story going forward, with its Loper Bright-grounded reasoning likely to be tested at the appellate level; meanwhile HB 1127's new penalty and cease-and-desist authority gives NDDFI a enforcement toolkit that has not yet been exercised against a payments licensee, making its first application a marker worth tracking. Read full sub-brief · 208 words no periodic updates on record for this sub-brief Evidence 4 Sources and findings (4) - T1[https://www.cooley.com/news/insight/2025/2025-08-15-district-court-vacates-regulation-iis-debit-card-interchange-fee-standard](https://www.cooley.com/news/insight/2025/2025-08-15-district-court-vacates-regulation-iis-debit-card-interchange-fee-standard)retrieved 2026-07-05 - T1[https://northdakotamonitor.com/2025/08/07/north-dakota-truck-stop-paves-way-for-reducing-debit-card-fees-nationwide/](https://northdakotamonitor.com/2025/08/07/north-dakota-truck-stop-paves-way-for-reducing-debit-card-fees-nationwide/)retrieved 2026-07-05 - T1[https://www.valleynewslive.com/2026/02/16/north-dakota-ag-secures-settlement-over-fake-invoice-scam-targeting-businesses-nonprofits/](https://www.valleynewslive.com/2026/02/16/north-dakota-ag-secures-settlement-over-fake-invoice-scam-targeting-businesses-nonprofits/)retrieved 2026-07-05 - T2[https://www.privacyanddatasecurityinsight.com/2025/05/north-dakota-governor-signs-cybersecurity-governance-law-for-financial-institutions/](https://www.privacyanddatasecurityinsight.com/2025/05/north-dakota-governor-signs-cybersecurity-governance-law-for-financial-institutions/)retrieved 2026-07-05 ### W8Merchant Acquiring & Risk1 gapProbableconfirmed 2026-07-05▾# North Dakota imposes no bespoke merchant-acquiring statute: credit-card surcharging is permitted by default (subject to federal/network disclosure rules) while debit surcharging remains nationally prohibited under the Durbin Amendment and network rules. The state's own public-sector merchant acquiring runs exclusively through BND, and the newly regulated crypto-ATM channel (HB 1447) introduces bespoke high-risk-merchant fraud-control obligations (blockchain analytics, compliance officers). Open gap — wpm-int-2 No ND merchant-acquiring/high-risk-MCC development found this cycle. AML/CFT supervision-gap analysis for non-bank money transmitters and crypto kiosks remains under-indexed pending Sentinel.gi integration. Standing sub-brief · as of 5 July 2026 166 words · last cycle 2026-07-05 #### Merchant Acquiring & Risk North Dakota imposes no unique state restriction on credit-card surcharging: merchants may surcharge provided they post point-of-sale and checkout disclosures and itemize the surcharge as a separate receipt line, defaulting to federal and network rules. Debit-card surcharging, by contrast, remains prohibited nationwide, including in North Dakota, through the combination of card-network rules and the Durbin Amendment, independent of state credit-surcharge policy and unaffected by the Corner Post vacatur of Regulation II. A new high-risk-merchant channel has emerged in virtual-currency kiosks: House Bill 1447 requires crypto-ATM operators to obtain Money Transmitter Licenses, deploy blockchain analytics for fraud detection, submit quarterly transaction reports, and appoint a dedicated compliance officer. #### Outlook Expect North Dakota's baseline surcharge posture to remain stable regardless of the Corner Post appeal's outcome, since debit surcharging is governed by network rules and the Durbin Amendment rather than Regulation II itself, while HB 1447's crypto-kiosk licensing and compliance-officer requirements move into an implementation and enforcement phase for the state's virtual-currency kiosk operators. Read full sub-brief · 166 words no periodic updates on record for this sub-brief Evidence 5 Sources and findings (5) - T3[https://merchantcostconsulting.com/lower-credit-card-processing-fees/credit-card-surcharge-laws-by-state/](https://merchantcostconsulting.com/lower-credit-card-processing-fees/credit-card-surcharge-laws-by-state/)retrieved 2026-07-05 - T3[https://ebizcharge.com/blog/credit-card-surcharging-a-state-by-state-legal-analysis/](https://ebizcharge.com/blog/credit-card-surcharging-a-state-by-state-legal-analysis/)retrieved 2026-07-05 - T2[https://www.consumerfinancemonitor.com/2023/02/22/north-dakota-legislation-seeks-to-ban-interchange-on-sales-tax/](https://www.consumerfinancemonitor.com/2023/02/22/north-dakota-legislation-seeks-to-ban-interchange-on-sales-tax/)retrieved 2026-07-05 - T1[https://bnd.nd.gov/government/](https://bnd.nd.gov/government/)retrieved 2026-07-05 - T2[https://www.coindesk.com/policy/2025/03/19/north-dakota-senate-passes-crypto-atm-bill-to-create-licensing-regime](https://www.coindesk.com/policy/2025/03/19/north-dakota-senate-passes-crypto-atm-bill-to-create-licensing-regime)retrieved 2026-07-05 ### W9Product Innovation & Market DevelopmentProbableconfirmed 2026-07-05▾# ND's flagship product-innovation story is the Roughrider Coin, a state-owned-bank-affiliated stablecoin built with Fiserv, positioned as a bank-to-bank instant-settlement product with potential future merchant use. This sits alongside FedNow adoption, a new statutory response (HB 1447) to organic crypto-ATM market growth, and exploratory legislative interest (Resolution 3001, HB 1082) in digital-asset investment and UCC modernization. Standing sub-brief · as of 5 July 2026 176 words · last cycle 2026-09-14 #### Product Innovation & Market Development Roughrider Coin is the flagship product-innovation story in North Dakota's payments landscape: Bank of North Dakota's Fintech program frames the stablecoin as helping the state's local banking partners figure out fintech, and BND has continually developed resources tied to the pilot since its October 8, 2025 announcement. Officials have indicated that Roughrider Coin, initially built for bank-to-bank use, could eventually be accepted by merchants as payment, a horizon extension beyond the pilot's current scope though not yet confirmed. Separately, House Bill 1082 proposed Uniform Commercial Code amendments affecting how digital assets, including central bank digital currency, are defined relative to money under North Dakota commercial law, drawing opposition from crypto-advocacy groups concerned about the treatment of non-CBDC digital currencies. #### Outlook Roughrider Coin's evolution from a bank-to-bank pilot toward a possible merchant-facing instrument is the product-innovation item most worth tracking, alongside how HB 1082's UCC definitional debate over digital assets and CBDC treatment resolves, since either development could reshape how North Dakota law characterizes stablecoins and other digital-asset instruments relative to money. Read full sub-brief · 176 words Periodic update · new data 2026-09-14 #### Product Innovation & Market Development The defining product-development event this cycle in North Dakota is the consumer-facing fraud-disclosure requirement embedded in HB1447's virtual-currency-kiosk sub-regime. Kiosk operators must now provide fraud warnings referencing specific, named scam patterns -- frozen-account claims, identity-theft claims, and government-payment-request claims -- to consumers before a kiosk transaction may proceed. This is a binding, in-force product-design requirement rather than voluntary industry guidance: it directly shapes the transactional user experience at the point of sale for a specific product category (unattended virtual-currency kiosks) that has drawn increasing regulatory attention nationally as a vector for elder-fraud and romance-scam typologies. This development is properly classified here rather than under W6 (structural market analysis) because it is not a broad market-structure trend but a specific, discrete regulatory requirement attached to a defined product category. It is distinct from W10 (Consumer Protection & APP Fraud) in that its primary classification addresses the product-design and market-access conditions attached to kiosk deployment -- what a kiosk operator must build into the product to remain licensed -- though it carries clear consumer-protection relevance as a secondary dimension. The disclosure requirement operates alongside the daily-transaction-limit provision under the same HB1447 sub-regime, together forming a two-part control: a point-of-transaction warning intended to interrupt in-progress scams, and a value cap intended to limit the maximum loss if the warning is not heeded. Both provisions apply specifically to virtual-currency kiosks as a discrete nonbank product category (bank-or-nonbank classification: nonbank_pi_emi) rather than to money-transmission activity generally. #### Outlook The signal to watch is whether North Dakota's Department of Financial Institutions issues any bulletin or interpretive guidance addressing how the daily-transaction-limit and fraud-disclosure requirements are being enforced in practice since HB1447 took effect; no such guidance has been located as of this cycle. Continued national attention to crypto-kiosk fraud typologies makes it plausible other states will look to North Dakota's disclosure-plus-limit model as a template. Evidence 5 Sources and findings (5) - T1[https://bnd.nd.gov/fintech/](https://bnd.nd.gov/fintech/)retrieved 2026-07-05 - T2[https://www.ksjbam.com/2025/10/09/bank-of-north-dakota-to-launch-roughrider-coin-stablecoin-cryptocurrency/](https://www.ksjbam.com/2025/10/09/bank-of-north-dakota-to-launch-roughrider-coin-stablecoin-cryptocurrency/)retrieved 2026-07-05 - T2[https://www.coindesk.com/policy/2025/03/19/north-dakota-senate-passes-crypto-atm-bill-to-create-licensing-regime](https://www.coindesk.com/policy/2025/03/19/north-dakota-senate-passes-crypto-atm-bill-to-create-licensing-regime)retrieved 2026-07-05 - T3[https://decrypt.co/300499/north-dakota-considers-state-bitcoin-treasury](https://decrypt.co/300499/north-dakota-considers-state-bitcoin-treasury)retrieved 2026-07-05 - T3[https://ndcan.org/house-bill-1082](https://ndcan.org/house-bill-1082)retrieved 2026-07-05 ### W10Consumer Protection & APP FraudConfirmedconfirmed 2026-07-05▾# No change to ND's underlying consumer-protection/dispute-resolution standing state this cycle. This is a bounded D-tier enforcement event: Block, Inc. (Cash App) entered a new multistate settlement (distinct from the Jan-2025 $255M CFPB/48-state BSA-AML-adjacent action) addressing fraud-protection and complaint-handling failures; North Dakota is not among the four states explicitly excluded from the settlement, indicating probable ND participation, though no ND-specific primary-source (AG or DFI) release confirming ND's individual signature has yet been located. Standing sub-brief · as of 5 July 2026 204 words · last cycle 2026-09-21 #### Consumer Protection & APP Fraud House Bill 1447 is North Dakota's most concrete recent consumer-protection action in payments, requiring virtual currency kiosk operators to cap daily transactions at $2,000 per customer, provide risk, fee and transaction disclosures and receipts, deploy fraud-detection measures, and staff live customer service from 8am to 10pm Central Time. The statute responds directly to documented harm: NDDFI Commissioner Lisa Kruse testified that the FBI reported $5.6 billion in nationwide crypto fraud losses in 2023, while North Dakotans filed 103 digital-currency scam complaints that year involving roughly $6.5 million in losses. Outside the crypto-kiosk-specific regime, general consumer redress in North Dakota runs through the Attorney General's Consumer Protection Division, which mediates complaints from state residents or non-residents with disputes involving a North Dakota business and can refer unresolved matters to private attorneys; no dedicated state statutory mandate for authorized-push-payment fraud reimbursement on bank transfers was identified. #### Outlook HB 1447's consumer protections for crypto-kiosk users are now the state's most concrete payments-fraud safeguard and should be watched for enforcement activity as the law beds in, while the continued absence of a dedicated APP-fraud bank-transfer reimbursement mandate leaves a gap in North Dakota's consumer-protection framework relative to jurisdictions that have adopted such rules. Read full sub-brief · 204 words Periodic update · new data 2026-09-28 #### Consumer Protection & APP Fraud North Dakota's 2025 House Bill 1447 directly addresses APP-fraud-adjacent abuse patterns in the virtual-currency-kiosk channel. The new statutory scam-warning disclosure duty requires kiosk operators to warn consumers about three specific fraud typologies: claims that a consumer's bank account has been frozen, claims of a fraudulent bank transaction requiring urgent remediation, and demands for payment purportedly owed to government agencies. These three typologies map directly onto well-documented authorized-push-payment and social-engineering fraud patterns that have driven kiosk-based consumer losses nationally, and the North Dakota statute represents a targeted legislative response to that specific fraud vector rather than a general consumer-protection expansion. The disclosure duty is paired with a fraud-prevention program requirement for kiosk operators, meaning the obligation extends beyond a point-of-transaction warning to an ongoing internal control expectation. This is a confirmed statutory development, though its practical enforcement and consumer-outcome effects remain untested, since no enforcement or compliance data has yet been located addressing operator adherence to the new duties. #### Outlook The consumer-protection trajectory here is escalating in scope but not yet tested in practice. Watch for any consumer-complaint data, Department of Financial Institutions enforcement activity, or reported kiosk-fraud incident data that would indicate whether the new scam-warning disclosure and fraud-prevention program requirements are having a measurable effect on kiosk-channel APP-fraud losses in North Dakota. 1 earlier distinct update(s) Periodic update · new data 2026-09-08 #### Consumer Protection & APP Fraud Block, Inc. agreed to a $45 million multistate settlement with 46 states resolving allegations that Cash App misled consumers about fraud protections and failed to provide adequate complaint-resolution support, with remedial terms that include live phone and chat support, marketing changes, and reimbursement-obligation commitments. The claim is entered under the nonbank_pi_emi bank-or-nonbank designation, keeping the module's standing bank-PSP versus non-bank-PI/EMI distinction intact: Cash App operates as a non-bank payment product rather than a chartered bank, and this settlement's conduct obligations attach at that non-bank layer. North Dakota is not listed among the four states excluded from the settlement, indicating probable ND participation, though no ND-specific primary source has yet confirmed the state's individual signature. The finding is distinct from the Jan-2025 $255M CFPB/48-state BSA-AML-adjacent action, a separate and earlier enforcement track; this settlement addresses fraud-protection marketing claims and complaint-handling process failures rather than anti-money-laundering program deficiencies. The module's baseline trajectory remains stable: this is a bounded, D-tier enforcement event layered onto an otherwise unchanged consumer-protection and dispute-resolution framework for North Dakota. #### Outlook The item to watch is confirmation-grade: an ND-specific Attorney General or Department of Financial Institutions release naming North Dakota among the settling states would convert this from a probable to a confirmed finding, while continued silence leaves the state's participation resting on exclusion-list inference alone. No other W10 activity -- financial-promotion, merchant-acquiring-adjacent, or otherwise -- surfaced for North Dakota this cycle. Evidence 5 Sources and findings (5) - T1[https://www.nd.gov/dfi/crypto-atms](https://www.nd.gov/dfi/crypto-atms)retrieved 2026-07-05 - T1[https://northdakotamonitor.com/2025/01/22/north-dakota-bill-takes-aim-at-crypto-fraud-with-new-consumer-protections/](https://northdakotamonitor.com/2025/01/22/north-dakota-bill-takes-aim-at-crypto-fraud-with-new-consumer-protections/)retrieved 2026-07-05 - T1[https://attorneygeneral.nd.gov/consumer-resources/consumer-complaints/](https://attorneygeneral.nd.gov/consumer-resources/consumer-complaints/)retrieved 2026-07-05 - T3[https://states.aarp.org/north-dakota/2025-cryptoatm](https://states.aarp.org/north-dakota/2025-cryptoatm)retrieved 2026-07-05 - T1[https://www.nd.gov/dfi/](https://www.nd.gov/dfi/)retrieved 2026-07-05 ### W11AML/CFT & Financial Crime (Sentinel.gi-fed)Sourced from Sentinel.gi ↗Probableconfirmed 2026-07-05▾# W11 is designated Sentinel.gi-fed per methodology; no live Sentinel.gi payments-context feed was accessible during this collection pass, so no original illicit-finance analysis has been performed. The only fact captured is the statutory BSA/AML reporting linkage embedded in ND's money-transmitter chapter, included as regime context rather than AML analysis. Standing sub-brief · as of 5 July 2026 134 words · last cycle 2026-08-21 #### AML/CFT & Financial Crime North Dakota's AML/CFT surface for payments rests on a statutory hook rather than original Sentinel.gi analysis this cycle: under NDCC 13-09.1-22, money transmitter licensees and their authorized delegates must file all reports required by federal currency-reporting, recordkeeping, and suspicious-activity-reporting requirements under the federal Anti-Money Laundering Act of 2020. No live Sentinel.gi payments-context feed was accessible for North Dakota this cycle, so this module carries only that statutory regime context rather than independent illicit-finance or AML-supervision analysis of the state's money transmitters and virtual-currency kiosk operators, a coverage gap flagged for the Financial Intelligence Monitor. #### Outlook W11 for North Dakota remains pending live Sentinel.gi integration; once a feed is accessible, expect the module to develop original AML-supervision analysis for money transmitters and crypto-kiosk operators rather than the current statutory-hook baseline alone. Read full sub-brief · 134 words Periodic update · new data 2026-08-25 #### AML/CFT & Financial Crime This finding is carried through the Sentinel.gi feed: NDCC ch. 13-09.1-22 requires North Dakota money-transmitter licensees to file all federally-required currency, recordkeeping, and Suspicious Activity Reports under the Anti-Money Laundering Act of 2020, and ties the licence renewal fee to virtual-currency-transmission volume, capped at $2,500. This is a Tier-1-sourced, High-confidence structural fact drawn from the North Dakota Legislative Council's codified statute text. Consistent with this monitor's practice for Sentinel-fed AML material, this brief attributes the underlying illicit-finance intelligence to the Sentinel feed and links out to it rather than re-analysing the underlying financial-crime dynamics, which are covered in depth by the financial-integrity monitor's D7 and D1 domains. The cycle's relevant development is one of scope rather than substance: House Bill 1447 brings crypto-kiosk operators within the money-transmitter licence category, and because the AML/CFT reporting duty in 13-09.1-22 attaches to licensees generically, crypto-kiosk operators become subject to the same federally-required reporting obligations as any other North Dakota money transmitter once licensed. The reporting duty itself has not changed; the population of entities bound by it has grown. #### Outlook Watch for how the Department of Financial Institutions supervises the newly-licensed crypto-kiosk population's compliance with the existing currency-recordkeeping-SAR duty in practice, and for Tier-1 confirmation of HB 1447's enactment status, which was not reached this cycle. Evidence 6 Sources and findings (6) - T1[https://ndlegis.gov/cencode/t13c09-1.pdf](https://ndlegis.gov/cencode/t13c09-1.pdf)retrieved 2026-07-05 - T?FIM (sentinel.gi) per-JID baseline profile — United States — North Dakota — North Dakota has no standalone state AML statute; entities and MSBs operating in-state are governed by the federal Bank Secrecy Act/AML Act framework (FinCEN, OFAC) with state money-transmitter licensing and examination performed by the North Dakota Department of Financial Institutions (DFI). No ND-specific AML/CFT statutory deficiency has been separately assessed by FATF, which evaluates the US as a single jurisdiction. - T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: sourcing-thinness - T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: legal-gap - T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-004) — Gap: absent-field-provenance - T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: regulatory-failure ### W12Correspondent Banking, Settlement & AccessConfirmedconfirmed 2026-07-05▾# Correspondent banking and settlement access in North Dakota is structurally centered on Bank of North Dakota, which acts as the correspondent bank for most in-state institutions, holds its own Federal Reserve account through the Minneapolis Fed, and is uniquely state-guaranteed rather than FDIC-insured. This model was explicitly designed to offset de-risking/access pressure on small rural institutions of the kind documented elsewhere in the Ninth Federal Reserve District. Standing sub-brief · as of 5 July 2026 212 words · last cycle 2026-07-05 #### Correspondent Banking, Settlement & Access Bank of North Dakota provides correspondent banking services - ACH origination, Federal Reserve activity settlement, item processing, government-security purchases, and letter-of-credit pledging - to most of the state's financial institutions, making it the structural hub through which North Dakota's community banks reach national payment rails. Unlike virtually all other US banks, BND's own deposits are not FDIC-insured; under NDCC 6-09-10 they are instead guaranteed by the full faith and credit of the State of North Dakota, a structural counterparty-risk feature unique to BND's correspondent role. That model operates against a backdrop of documented access pressure elsewhere in the Ninth Federal Reserve District: the Federal Reserve Bank of Minneapolis has cited declining bank-branch density in the Upper Midwest, pointing to Benson County, North Dakota - roughly 7,000 residents spread across 1,430 square miles - as an example of the physical-access and de-risking pressure that BND's correspondent model helps offset for rural institutions. #### Outlook BND's state-guaranteed correspondent model is likely to remain the structural backbone connecting North Dakota's community banks to national settlement rails regardless of the Roughrider Coin pilot's outcome, and its role in offsetting rural de-risking pressure documented by the Minneapolis Fed is likely to draw continued attention as branch density in the Upper Midwest keeps declining. Read full sub-brief · 212 words no periodic updates on record for this sub-brief Evidence 5 Sources and findings (5) - T1[https://bnd.nd.gov/fi/](https://bnd.nd.gov/fi/)retrieved 2026-07-05 - T1[https://www.usccr.gov/files/pubs/uncsam/agency/fedres.htm](https://www.usccr.gov/files/pubs/uncsam/agency/fedres.htm)retrieved 2026-07-05 - T1[https://en.wikipedia.org/wiki/Bank_of_North_Dakota](https://en.wikipedia.org/wiki/Bank_of_North_Dakota)retrieved 2026-07-05 - T1[https://ndlegis.gov/cencode/t06c01.pdf](https://ndlegis.gov/cencode/t06c01.pdf)retrieved 2026-07-05 - T1[https://www.minneapolisfed.org/article/2018/27-how-bank-closures-affect-rural-communities](https://www.minneapolisfed.org/article/2018/27-how-bank-closures-affect-rural-communities)retrieved 2026-07-05 ### W13Commercial Intelligence (M&A, Investment & Product)Probableconfirmed 2026-07-05▾# ND DFI joined a 34-state $2.5M BSA/AML settlement with crypto-kiosk operator Coinme (announced 2026-10-08), requiring Coinme to exit the virtual-currency-kiosk business (66 ND locations) by 2027-01-01 -- a market-exit event for a nonbank payments/digital-asset participant licensed in ND. Standing sub-brief · as of 5 July 2026 239 words · last cycle 2026-10-25 #### Commercial Intelligence (M&A, Investment & Product) Bank of North Dakota and Fiserv announced the Roughrider Coin partnership on October 8, 2025 to build North Dakota's first stablecoin on Fiserv's digital-asset platform, a partnership-restructuring event whose cost and investment terms were not publicly disclosed. On March 25, 2026 the North Dakota Industrial Commission approved a product milestone for that partnership, clearing Roughrider Coin's bank-to-bank use case with ten local banks expressing pilot interest, though cost and investment figures reviewed in the closed session were not publicly disclosed. On the M&A side, First Holding Company of Park River, parent of First United Bank, agreed to acquire First State Bank of Cando, North Dakota, with the deal expected to close in the first quarter of 2026 and its purchase price not publicly disclosed. Separately, a Mayo family shareholder group filed an April 2026 Federal Reserve Change in Bank Control notice covering retention or acquisition of voting shares in First Holding Company of Cavalier, parent of United Valley Bank; the value of that transaction was also not publicly disclosed. #### Outlook Roughrider Coin's product trajectory toward a targeted 2026 launch remains the central commercial-intelligence item to track, alongside whether further in-state community-bank M&A and change-in-control filings follow the Park River/Cando and Mayo/Cavalier transactions; the persistent non-disclosure of deal and investment values across all four tracked events limits quantitative trend analysis and reflects the generally thin financial disclosure typical of North Dakota's closely-held community banks. Read full sub-brief · 239 words Periodic update · new data 2026-10-25 #### Commercial Intelligence & Fintech The discrete commercial event is the completed launch of Roughrider Coin, announced as having gone live on October 1, 2026. The event brings together four named commercial parties in clearly defined roles: the Bank of North Dakota acting as vendor and lead operator of the initiative, VersaBank acting as issuer of the dollar-backed token, Fiserv acting as platform partner providing integration with participating institutions' existing payment operations, and Fireblocks acting as infrastructure supplier providing tokenisation and custody services. The transaction amount was not publicly disclosed, so no commercial value figure attaches to this event. The launch is positioned by participants as a product aimed at the state's own community banking sector, with reported voluntary adoption by approximately ninety banks and credit unions. Coverage frames the central commercial benefit as faster settlement for lending institutions, a framing consistent with the product's stated purpose of modernizing interbank payments. The announced date for the launch was reported as October 5, 2026, several days after the completion date, consistent with a typical pattern of operational go-live preceding public commercial announcement. This event is distinct from a structural industry-wide trend; it is a single, specific, named product launch involving identifiable commercial counterparties, and should be read as such rather than folded into broader market-structure analysis. It is likewise distinct from a regulatory product-access theme: no regulatory framework specific to this category of product was changed or proposed in connection with the launch, which instead represents commercial product deployment occurring within the existing general banking and money-transmission framework. #### Outlook As a specific, named commercial event rather than a structural trend, the main forward-looking question is whether the same commercial consortium, the Bank of North Dakota, VersaBank, Fiserv, and Fireblocks, pursues further product expansion, additional state-bank partnerships, or expanded participant onboarding beyond the roughly ninety institutions currently reported. Any follow-on commercial announcement involving these same named parties would be the clearest signal of the initiative's continued commercial trajectory. 3 earlier distinct update(s) Periodic update · new data 2026-10-18 #### Commercial Intelligence & Fintech Coinme Inc., a Seattle-based nonbank money transmitter and kiosk operator licensed to operate in North Dakota, has entered a multistate consent settlement, signed 2026-10-08, following a 34-state examination into its Bank Secrecy Act and anti-money-laundering compliance program. The settlement amount is $2.5M across the coalition, not publicly disclosed at the individual-state level except for North Dakota's own allocated share of $10,000. As a condition of the settlement, Coinme must terminate its virtual-currency kiosk operations, including its North Dakota locations, by 2027-01-01, or incur a further $4M penalty; the agreement also requires an independent BSA/AML compliance review of Coinme's program going forward. Rendered as a commercial event, this is a market-exit: a licensed nonbank payment-institution operator is withdrawing from the North Dakota kiosk segment on a defined timetable, with the departure driven directly by regulatory findings rather than ordinary commercial repositioning. North Dakota's regulatory review of the matter is recorded as cleared with conditions, reflecting the state's acceptance of the multistate settlement terms rather than an independent North Dakota-specific enforcement track. For commercial-intelligence purposes, the event marks the removal of one nonbank crypto-kiosk operator from the North Dakota market, with the scale of that removal, an estimated 66 locations, substantially larger than the modest $10,000 state-level settlement allocation might suggest on its own. #### Outlook The operative date remains 2027-01-01, as scheduled, the deadline by which Coinme's North Dakota kiosk exit must be complete to avoid the additional $4M penalty specified in the settlement. No signal in the current record addresses whether a successor nonbank operator will enter the vacated North Dakota kiosk market. Periodic update · new data 2026-10-11 #### Commercial Intelligence & Fintech The Roughrider Coin program is this cycle's clearest discrete commercial event for North Dakota: Fiserv's digital asset platform activated October 1, 2026 with Roughrider Coin as its first live use case, following an October 2025 announcement of the partnership. The commercial structure names four parties in distinct roles: Bank of North Dakota as program sponsor, Fiserv, Inc. as the supplying technology platform, VersaBank USA, N.A. as the OCC-chartered issuing bank, and Fireblocks as the supplying tokenization infrastructure provider. No transaction value or amount was disclosed for any aspect of this arrangement. A four-institution pilot cohort was announced October 5, 2026, expanding the commercial relationship beyond the founding four parties to include Gate City Bank, First International Bank & Trust, Capital Credit Union, and North Star Community Credit Union as pilot participants, each domiciled in North Dakota. This is a dated, discrete commercial milestone, the pilot's formal commencement, distinct from the underlying stablecoin-regime regulatory story, though the two are obviously related facts about the same underlying program. The roughly one-year gap between the October 2025 partnership announcement and the October 1, 2026 live activation reflects the build-out period for a novel, first-of-its-kind commercial arrangement combining a state-owned bank sponsor, a nationally-chartered issuing bank, and third-party fintech infrastructure providers. This sponsor-issuer-technology-supplier template, now operational, is a specific commercial structure rather than a general industry trend, and its replication by other state-level banking entities, if any, would itself constitute a future discrete commercial event rather than evidence of an existing structural shift. #### Outlook The near-term commercial development to track is whether the pilot cohort expands beyond the four named North Dakota institutions, and whether Fiserv's digital asset platform onboards additional bank-sponsor clients using a similar structure. Any such expansion would itself be a discrete, dateable commercial event rather than a continuation of the current one, and would be captured separately as it occurs. Periodic update · new data 2026-08-11 #### Commercial Intelligence & Fintech North Dakota's principal commercial-intelligence development this cycle is the Bank of North Dakota's Roughrider Coin, a proposed bank-to-bank settlement stablecoin built on Fiserv's FIUSD platform. This is a product-release event: the North Dakota Industrial Commission approved the bank-to-bank use case in a closed-door session in March 2026, following a review that included a risk assessment and cost projections, and a September 2026 launch is currently targeted. The event status is pending-regulatory rather than launched, reflecting that the approved use case still sits ahead of its targeted go-live date. The commercial terms of the Fiserv vendor arrangement, including whether specific financial terms attach to the partnership, were not publicly disclosed as part of this development, and the amount is accordingly recorded as not publicly disclosed. As a fintech development specifically, Roughrider Coin is notable for its scope discipline: the approved use case is bank-to-bank settlement, not a retail-facing or merchant-facing stablecoin product, which distinguishes it from a broader consumer stablecoin launch. This positions the Bank of North Dakota, a state-owned institution, as an early mover among state-qualified issuers exploring the GENIUS Act's state-oversight track, using a narrowly-scoped institutional use case as the initial deployment rather than a wider product rollout. The Fiserv partnership itself is the vendor relationship underlying the technical platform, with Fiserv's FIUSD infrastructure providing the stablecoin rails for the pilot. No merger, acquisition, or investment/funding-round event was identified for North Dakota-domiciled payments or fintech entities this cycle; the sole commercial-intelligence development in the claims reviewed is the Roughrider Coin product release and its associated regulatory approval step. #### Outlook The September 2026 targeted launch is the marker to track for this development converting from a pending-regulatory product release into an operating one. Because the underlying use case still requires alignment with the federal GENIUS Act rulemaking track, the practical launch timeline is not fully within North Dakota's own control; a delay in the federal rulemaking's finalization could plausibly affect whether the September 2026 target holds. Evidence 4 Sources and findings (4) - T1[https://www.businesswire.com/news/home/20251008696630/en/Bank-of-North-Dakota-and-Fiserv-Partner-to-Launch-Roughrider-Coin-North-Dakotas-first-Stablecoin](https://www.businesswire.com/news/home/20251008696630/en/Bank-of-North-Dakota-and-Fiserv-Partner-to-Launch-Roughrider-Coin-North-Dakotas-first-Stablecoin)retrieved 2026-07-05 - T1[https://northdakotamonitor.com/2026/03/26/north-dakota-moves-forward-with-stablecoin-as-local-banks-express-interest-in-pilot-project/](https://northdakotamonitor.com/2026/03/26/north-dakota-moves-forward-with-stablecoin-as-local-banks-express-interest-in-pilot-project/)retrieved 2026-07-05 - T2[https://bankingjournal.aba.com/2026/01/bank-acquisitions-announced-in-four-states-4/](https://bankingjournal.aba.com/2026/01/bank-acquisitions-announced-in-four-states-4/)retrieved 2026-07-05 - T1[https://www.federalregister.gov/documents/2026/04/08/2026-06771/change-in-bank-control-notices-acquisitions-of-shares-of-a-bank-or-bank-holding-company](https://www.federalregister.gov/documents/2026/04/08/2026-06771/change-in-bank-control-notices-acquisitions-of-shares-of-a-bank-or-bank-holding-company)retrieved 2026-07-05 No modules match. 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