[Federal Register Volume 91, Number 121 (Thursday, June 25, 2026)]
[Proposed Rules]
[Pages 38340-38350]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2026-12794]


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DEPARTMENT OF THE TREASURY

Financial Crimes Enforcement Network

31 CFR Part 1010

RIN 1506-AB75


Definition of Huione Group, a Financial Institution Operating 
Outside the United States of Primary Money Laundering Concern

AGENCY: Financial Crimes Enforcement Network (FinCEN), Treasury.

ACTION: Notice of proposed rulemaking.

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SUMMARY: FinCEN is issuing a notice of proposed rulemaking (NPRM), 
pursuant to section 311 of the USA PATRIOT Act, that proposes amending 
the existing definition of Huione Group to include, within the 
definition of that group, H-Pay Service PLC, and adding and defining 
the term ``successor entity.'' With this NPRM, FinCEN does not alter 
its assessment that Huione Group is a financial institution operating 
outside the United States of primary money laundering concern, and the 
existing special measure codified at 31 CFR 1010.664 with respect to 
Huione Group remains in effect.

DATES: Written comments on the notice of proposed rulemaking must be 
submitted on
    or before July 27, 2026.

ADDRESSES: Comments must be submitted in one of the following two ways 
(please choose only one of the ways listed):
     Federal E-rulemaking Portal: https://www.regulations.gov. 
If you are reading this document on federalregister.gov, you may use 
the green ``SUBMIT A PUBLIC COMMENT'' button beneath this rulemaking's 
title to submit a comment to the regulations.gov docket.
     Mail: Financial Crimes Enforcement Network, P.O. Box 39, 
Vienna, VA 22183. Refer to Docket Number FINCEN-2026-0166 in the 
submission.
    Do not include any personally identifiable information (such as 
name, address, or other contact information) or confidential business 
information that you do not want publicly disclosed. All comments are 
public records; they are publicly displayed exactly as received, and 
will not be deleted, modified, or redacted. Comments may be submitted 
anonymously. Follow the search instructions on https://www.regulations.gov to view public comments.

FOR FURTHER INFORMATION CONTACT: The FinCEN Resource Center at 
www.fincen.gov/contact.

SUPPLEMENTARY INFORMATION:

I. Statutory Provisions

    Section 311 of the USA PATRIOT Act (section 311), codified at 31 
U.S.C. 5318A, grants the Secretary of the Treasury (Secretary) the 
authority to make a finding that ``reasonable grounds exist for 
concluding'' that any of the following ``is of primary money laundering 
concern'':
     A jurisdiction outside of the United States;
     One or more financial institutions operating outside of 
the United States;
     One or more classes of transactions within, or involving, 
a jurisdiction outside of the United States; or
     One or more types of accounts.\1\
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    \1\ 31 U.S.C. 5318A(a)(1).
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    Upon making such a finding, the Secretary is authorized to require 
domestic financial institutions and domestic financial agencies to take 
certain ``special measures.'' \2\ The five special measures set out in 
section 311 are safeguards that may be employed to defend the U.S. 
financial system from money laundering and terrorist financing risks. 
The Secretary may impose one or more of these special measures to 
protect the U.S. financial system from such threats. Through special 
measures one through four, the Secretary may impose additional 
recordkeeping, information collection, and reporting requirements on 
covered domestic financial institutions and domestic financial 
agencies--collectively, ``covered financial

[[Page 38341]]

institutions.'' \3\ Through special measure five, the Secretary may 
``prohibit, or impose conditions upon, the opening or maintaining in 
the United States of a correspondent account or payable-through 
account'' for or on behalf of a foreign banking institution, if such 
correspondent account or payable-through account involves the foreign 
financial institution found to be of primary money laundering 
concern.\4\
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    \2\ On October 26, 2001, the President signed into law the 
Uniting and Strengthening America by Providing Appropriate Tools 
Required to Intercept and Obstruct Terrorism Act of 2001, Public Law 
107-56 (USA PATRIOT Act). Title III of the USA PATRIOT Act amended 
the anti-money laundering (AML) provisions of the Bank Secrecy Act 
(BSA) to promote the prevention, detection, and prosecution of 
international money laundering and the financing of terrorism. The 
BSA, as amended, is the popular name for a collection of statutory 
authorities that FinCEN administers that is codified at 12 U.S.C. 
1829b, 1951-1960 and 31 U.S.C. 5311-5314, 5316-5336, and includes 
other authorities reflected in notes thereto. Regulations 
implementing the BSA appear at 31 CFR Chapter X.
    \3\ 31 U.S.C. 5318A(b)(1)-(4). For purposes of this proposed 
rule, the term ``covered financial institution'' has the same 
meaning as provided at 31 CFR 1010.605(e)(1).
    \4\ 31 U.S.C. 5318A(b)(5).
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    Before making a finding that reasonable grounds exist for 
concluding that a financial institution operating outside of the United 
States (or other jurisdiction, account, or class of transactions) is of 
primary money laundering concern, the Secretary is required to consult 
with both the Secretary of State and the Attorney General.\5\ In 
addition, in the case of a decision to apply one or more of the special 
measures, in making a finding that reasonable grounds exist for 
concluding that a financial institution operating outside of the United 
States is of primary money laundering concern, the Secretary is 
required to consider such information as the Secretary determines to be 
relevant, including the following potentially relevant institutional 
factors:
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    \5\ 31 U.S.C. 5318A(c)(1).
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     The extent to which such a financial institution is used 
to facilitate or promote money laundering in or through a jurisdiction 
outside the United States, including any money laundering activity by 
organized criminal groups, international terrorists, or entities 
involved in the proliferation of weapons of mass destruction (WMD) or 
missiles;
     The extent to which such a financial institution is used 
for legitimate business purposes in the jurisdiction; and
     The extent to which such action is sufficient to ensure, 
with respect to transactions involving the jurisdiction and 
institutions operating in the jurisdiction, that the purposes of 
section 311 continue to be fulfilled, and to guard against 
international money laundering and other financial crimes.\6\
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    \6\ 31 U.S.C. 5318A(c)(2)(B)(i)-(iii). In addition, in the case 
of a finding relating to a particular jurisdiction, section 311 sets 
out certain ``jurisdictional factors'' that the Secretary may 
consider, which are not relevant here. See 31 U.S.C. 
5318A(c)(2)(A)(i)-(vii).
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    In selecting one or more special measures, the Secretary ``shall 
consult with the Chairman of the Board of Governors of the Federal 
Reserve System, any other appropriate Federal banking agency (as 
defined in section 3 of the Federal Deposit Insurance Act), the 
Secretary of State, the Securities and Exchange Commission, the 
Commodity Futures Trading Commission, the National Credit Union 
Administration Board, and in the sole discretion of the Secretary, such 
other agencies and interested parties as the Secretary may find 
appropriate.'' \7\ When imposing special measure five, the Secretary 
must do so ``in consultation with the Secretary of State, the Attorney 
General, and the Chairman of the Board of Governors of the Federal 
Reserve System.'' \8\ In addition, the Secretary is required to 
consider the following factors:
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    \7\ 31 U.S.C. 5318A(a)(4)(A).
    \8\ 31 U.S.C. 5318A(b)(5). Prior to issuing this proposed rule, 
FinCEN consulted with representatives and staff of the Board of 
Governors of the Federal Reserve System, the Office of Comptroller 
of the Currency, the Secretary of State, the staff of the Securities 
and Exchange Commission, staff of the National Credit Union 
Administration, the Federal Deposit Insurance Corporation, and the 
Attorney General. These consultations involved obtaining interagency 
views on all aspects of this proposed rule. Those views are 
reflected in FinCEN's explanation of the reasons for issuing this 
proposed rule.
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     Whether similar action has been or is being taken by other 
nations or multilateral groups;
     Whether the imposition of any particular special measure 
would create a significant competitive disadvantage, including any 
undue cost or burden associated with compliance, for financial 
institutions organized or licensed in the United States;
     The extent to which the action or the timing of the action 
would have a significant adverse systemic impact on the international 
payment, clearance, and settlement system, or on legitimate business 
activities involving the particular jurisdiction, institution, class of 
transactions, or type of account; and
     The effect of the action on United States national 
security and foreign policy.\9\
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    \9\ 31 U.S.C. 5318A(a)(4)(B)(i)-(iv).
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    The authority of the Secretary to administer the Bank Secrecy Act 
(BSA) and its implementing regulations, including the authority under 
section 311 to make such a finding and to impose special measures, has 
been delegated to the Director of FinCEN.\10\
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    \10\ Treasury Order 180-01 (Jan. 14, 2020).
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II. Prior Finding That Huione Group Is of Primary Money Laundering 
Concern and Imposition of Special Measure

    Huione Group \11\ is a financial services conglomerate based in 
Phnom Penh, Cambodia.\12\ Huione Group is the parent company of, or 
otherwise controls, several subsidiaries, affiliates, and components--
including, but not limited to: Haowang Guarantee, Huione Pay PLC, and 
Huione Crypto (collectively, Components)--that coordinate to provide 
services that are useful for money laundering and carrying out cyber 
scams. FinCEN assesses that, as discussed below, Huione Group and its 
subsidiaries, affiliates, and components, including the Components, 
operate as a coordinated collective, and for that reason, FinCEN will 
correspondingly refer to Huione Group and its Components as the 
``Huione Group.''
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    \11\ Huione Group is the parent company of several subsidiaries 
and components, including Haowang Guarantee, Huione Pay PLC, and 
Huione Crypto. FinCEN assesses that this grouping of exchange 
services operates as a coordinative collective, and for that reason, 
FinCEN will correspondingly refer to the collective as the ``Huione 
Group.''
    \12\ Cambodia Corporate Registry, ``Huione'' Search, https://www.businessregistration.moc.gov.kh/cambodia-master/service/
create.html?targetAppCode=cambodia-
master&targetRegisterAppCode=cambodia-br-
companies&service=registerItemSearch (last accessed Oct. 7, 2025); 
Huione Pay, Index, formerly available at https://www.huionepay.com.kh/index/help; Huione Group, About, formerly 
available at https://huione.com/html/about.jsp (last accessed Sept. 
24, 2024). Huione Crypto has numerous job announcements with a work 
location in Phnom Penh, Cambodia. See Huione Crypto, Career 
Opportunities, formerly available at https://www.huione.io/en-US/careerOpportunities (last accessed Mar. 27, 2025). Haowang Guarantee 
also lists job announcements with a work location in Phnom Penh, 
Cambodia. See Haowang Guarantee, About, formerly available at 
https://www.hwdb.la/about/ (last accessed Mar. 27, 2025). This 
information was available as of the issuance of the NPRM, however, 
it has since been removed by Haowang Guarantee, resulting in a 
``page not found'' error. FinCEN assesses that this change is more 
likely than not caused by negative public attention following a 
series of reports by blockchain analytic firms on money laundering 
occurring at Huione Group.
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    Although it was originally incorporated in Hong Kong in 2018 as 
Huione Group Limited, Huione Group, the controlling entity of the 
conglomerate, does not appear to be registered as a business in any 
jurisdiction,\13\ and several of Huione Group's Components have been 
registered outside of Cambodia. Nevertheless, Huione Group's website is 
registered \14\ to an individual with a listed location of Phnom Penh, 
Cambodia and Huione Group's operations are principally carried out in 
Cambodia.
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    \13\ Hong Kong Companies Registry, Huione Group Limited, at p. 
54, https://www.cr.gov.hk/docs/wrpt/RNC063_2018.12.17-2018.12.23.pdf.
    \14\ The registration is valid through June 3, 2026. See ICANN, 
Huione.com, https://lookup.icann.org/en/huione.com (last accessed 
Oct. 7, 2025).
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    For years, Huione Group has laundered illicit proceeds from 
cybercrimes--namely, cyber heists

[[Page 38342]]

carried out by the Lazarus Group,\15\ an entity sanctioned by 
Treasury's Office of Foreign Assets Control (OFAC)--and Convertible 
Virtual Currency (CVC) investment scams carried out by transnational 
criminal organizations (TCOs) based in Southeast Asia.\16\
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    \15\ The Lazarus Group is an agency, instrumentality, or 
controlled entity of the government of the Democratic People's 
Republic of Korea, that has stolen large volumes of Convertible 
Virtual Currency in numerous and often widely reported cyber heists. 
On September 13, 2019, the Lazarus Group was sanctioned by OFAC. See 
Department of the Treasury, Press Release, Treasury Sanctions North 
Korean State-Sponsored Malicious Cyber Groups (Sept. 13, 2019), 
https://home.treasury.gov/news/press-releases/sm774.
    \16\ These scams are also referred to as ``pig butchering.'' See 
FinCEN, FIN-2023-Alert005, FinCEN Alert on Prevalent Virtual 
Currency Investment Scam Commonly Known as ``Pig Butchering'' (Sept. 
8, 2023), https://www.fincen.gov/sites/default/files/shared/FinCEN_Alert_Pig_Butchering_FINAL_508c.pdf.
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    On May 5, 2025, FinCEN issued a notice of proposed rulemaking 
(First NPRM) that found that reasonable grounds exist for concluding 
that Huione Group is a financial institution operating outside the 
United States of primary laundering concern.\17\ On October 16, 2025, 
FinCEN issued a final rule (Final Rule) that prohibits covered U.S. 
financial institutions from opening or maintaining a correspondent 
account for, or on behalf of Huione Group, as defined in that Final 
Rule.\18\ The provisions of the Final Rule are codified at 31 CFR 
1010.664.
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    \17\ FinCEN, Special Measure Regarding Huione Group, as a 
Foreign Financial Institution of Primary Money Laundering Concern, 
90 FR 18934 (May 5, 2025).
    \18\ FinCEN, Imposition of Special Measure Regarding Huione 
Group, as a Foreign Financial Institution of Primary Money 
Laundering Concern, 90 FR 48295 (Oct. 16, 2025); see 31 CFR 
1010.664.
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A. Finding That Huione Group Is of Primary Money Laundering Concern

    Huione Group is a parent entity that controls the following 
Components: \19\ Haowang Guarantee; Huione Pay PLC; and Huione Crypto. 
FinCEN found that reasonable grounds exist to conclude that Huione 
Group and each of its Components engages in the business of money 
transmission, and that Huione Group is therefore a financial 
institution under the BSA and its implementing regulations. FinCEN also 
determined that Huione Group and each of its Components, including, but 
not limited to, Huione Pay PLC, are financial institutions operating 
outside of the United States.
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    \19\ As explained further in Section III.B, since the NPRM was 
issued Huione Group has changed its business structure in an effort 
to counter governmental scrutiny, including the special measure 
finalized last year.
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1. Huione Group
    Huione Group is a Cambodia based, Hong Kong-registered,\20\ sole 
proprietorship founded in or around 2014, that appears to be owned and 
controlled by an individual Cambodian national,\21\ and at times holds 
itself out as the parent entity of the Components.\22\ By its own 
account, Huione Group began as a fiat currency exchange service and 
over the past decade, expanded its commercial interests to include 
finance, insurance, real estate entities,\23\ and most recently, CVC 
exchange services.\24\ The Components operate in an interconnected 
fashion to provide an integrated payment service provider, illicit 
online market, and CVC exchanger (a type of virtual asset service 
provider or VASP).
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    \20\ Hong Kong Companies Registry, Huione Group Limited, at p. 
54, https://www.cr.gov.hk/docs/wrpt/RNC063_2018.12.17-2018.12.23.pdf.
    \21\ See The Record, Tether freezes $29 million of 
cryptocurrency connected to Cambodian marketplace accused of fueling 
scams (July 15, 2024), https://therecord.media/tether-freezes-29-million-crypto-connected-to-scam-marketplace.
    \22\ See, e.g., Elliptic, Huione: The Company Behind the Largest 
Ever Illicit Online Marketplace Has Launched a Stablecoin (Jan. 14, 
2025), https://www.elliptic.co/blog/huione-largest-ever-illicit-online-marketplace-stablecoin; Elliptic, Huione Guarantee: The 
multi-billion dollar marketplace used by online scammers (July 9, 
2024, updated Mar. 27, 2025), https://www.elliptic.co/blog/cyber-scam-marketplace; Chainalysis, 2024 Crypto Crime Mid-year Update 
Part 2: China-based CSAM and Cybercrime Networks on the Rise, Pig 
Butchering Scams Remain Lucrative (Aug. 29, 2024), https://www.chainalysis.com/blog/2024-crypto-crime-mid-year-update-part-2/; 
ABC News, Cambodian online marketplace outed as one-stop shop for 
scammers' money laundering and `detention equipment' needs (July 26, 
2024), https://www.abc.net.au/news/2024-07-27/online-marketplace-for-money-laundering-and-scammers/104131624; Huione Crypto, Terms 
and Conditions, formerly available at https://www.huione.io/en-US/termsAndConditions/userAgreement (last accessed Mar. 27, 2025). The 
Huione Group website is no longer accessible, which FinCEN assesses 
is likely a response to negative public attention following a series 
of reports by blockchain analytic firms on money laundering 
occurring at Huione Group.
    \23\ Huione Group, Who We Are, formerly available at https://www.huione.com/html/about.jsp (last accessed Sept. 24, 2024).
    \24\ Huione Crypto, Introduce, formerly available at https://www.huione.io/en-US/introduce (last accessed Mar. 26, 2025).
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    Huione Group, as an individual entity, coordinates its Components' 
activities by operating the customer service and public relations 
functions of the Huione Group. Huione Group has historically done this 
by hosting Telegram channels \25\ to aid customers experiencing 
problems with the services that the Components provide.\26\ One of 
Huione Group's Telegram channels also provides public relations 
commentary on behalf of the whole of the Huione Group network.\27\ 
Through coordination by Huione Group, Huione Group's Components all 
share CVC infrastructure, making it challenging to ascertain the 
specific Component involved in a particular transaction.
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    \25\ Following the issuance of the NPRM, Telegram blocked Huione 
Group's telegram channels, which Haowang Guarantee notified 
customers of on its website. Haowang Guarantee, Announcements, 
formerly available at https://www.hwbd.la/announcement (last 
accessed May 15, 2025).
    \26\ Telegram, Huione Group Customer Service Center, formerly 
available at https://t.me/huionekf/138 (last accessed Mar. 27, 
2025).
    \27\ See, e.g., Telegram, Huione Group Customer Service, Huione 
Statement (Mar. 9, 2025), formerly available at https://t.me/huionekf/346.
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    As reflected in the Final Rule, FinCEN found that reasonable 
grounds exist to conclude that Huione Group is a money transmitter. By 
providing customer service and public relations services on behalf of 
the Components, Huione Group is itself part of a network of people who 
engage as a business in facilitating the transfer of money. 
Furthermore, through Huione Group's apparent control of the Components 
(each of which is itself a money transmitter and responds to Huione 
Group's coordination of the Components' business activities such that 
they form a self-contained ecosystem of exchange, payment, and market 
services), Huione Group is engaged as a business in the transmission of 
value that substitutes for currency. Accordingly, FinCEN found that 
reasonable grounds exist to conclude that Huione Group is a financial 
institution as defined by the BSA and as that term is used in section 
311.
    Furthermore, based on publicly available information, Huione Group 
is operated by a Cambodian person, from Phnom Penh, Cambodia.\28\ The 
Huione Group website is registered to a Cambodian address in Phnom 
Penh, uses a Cambodian Top-Level Domain, and communicates predominately 
in the Chinese language via a Cambodian website and one or more 
Telegram channels operated from Cambodia.\29\ Accordingly, FinCEN found 
that reasonable grounds exist to conclude that Huione Group is operated 
from and

[[Page 38343]]

located in Cambodia and thus operates outside of the United States.\30\
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    \28\ The Record, Tether freezes $29 million of cryptocurrency 
connected to Cambodian marketplace accused of fueling scams (July 
15, 2024), https://therecord.media/tether-freezes-29-million-crypto-connected-to-scam-marketplace; see also ICANN, Huione.com, https://lookup.icann.org/en/huione.com; Elliptic, Huione Guarantee: The 
multi-billion dollar marketplace used by online scammers (July 9, 
2024, updated Mar. 27, 2025), https://www.elliptic.co/blog/cyber-scam-marketplace.
    \29\ On May 13, 2025, Telegram shut down Huione Group's Telegram 
channel, however, there is evidence that Huione Group is creating 
new channels under different names to circumvent the action taken by 
Telegram.
    \30\ FinCEN is not aware of any physical presence by Huione 
Group or the Components in the United States, or any substantial 
business with customers in the United States. Accordingly, FinCEN 
found that there are reasonable grounds to conclude that Huione 
Group, including the Components, are foreign financial institutions 
that operate outside the United States.
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2. Huione Pay PLC
    Of note, Huione Pay PLC is a Component of the Huione Group that, as 
of January 2025, was registered \31\ as a payment services institution 
with the National Bank of Cambodia.\32\ Although as of July 30, 2025, 
the Huione Pay PLC website was inaccessible, Huione Pay PLC offered--as 
explained in the Final Rule--its customers the ability to trade CVC on 
different blockchains, and to convert CVC to or from various fiat 
currencies.\33\ Part of Huione Pay PLC, Huione International Payments, 
acted as a merchant on Haowang Guarantee's platform, exchanging CVC to 
facilitate the transfer of the proceeds of cyber scams.\34\ Huione Pay 
PLC previously held the local equivalent of a money transmitting 
business license issued by the Kingdom of Cambodia and engaged in the 
exchange of CVC in a manner consistent with the definition of a money 
transmitting business.\35\ Accordingly, as reflected in the Final Rule, 
FinCEN found that reasonable grounds exist to conclude that Huione Pay 
PLC is a financial institution as that term is used in the BSA and 
section 311.
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    \31\ National Bank of Cambodia, List of Payment Service 
Institutions (Dec. 31, 2024), https://www.nbc.gov.kh/english/supervision/payment_service.php (last accessed Mar. 21, 2025). The 
National Bank of Cambodia's List of Payment Service available on its 
website only reflects the most recent reporting period. As such, the 
information presented by FinCEN reflects information that was 
available at the time indicated, in this example, the above-
mentioned information indicates that as of March 21, 2025, Huione 
Pay PLC was registered as a payment service institution. Future 
references to this list correspondingly indicate the information as 
it was available on the date indicated.
    \32\ Until December 2023, there was a likely related entity, 
``Huione Pay,'' registered as a money services business in Canada, 
which was incorporated in the country as Huione Pay Inc. Financial 
Transactions and Reports Analysis Centre of Canada (FINTRAC), Money 
Services Business Registry, Huione Pay Inc, https://fintrac-canafe.canada.ca/msb-esm/reg-eng (last accessed Mar. 13, 2025). In 
March 2025, Huione Group advertised its plans to expand Huione Pay 
PLC into new markets, including in North America. Telegram, Huione 
Group Customer Service, Huione Statement (Mar. 9, 2025), formerly 
available at https://t.me/huionekf/346.
    \33\ Huione Pay website, Index, formerly available at https://www.huionepay.com.kh/index/help (last accessed Mar. 27, 2025); 
FinCEN, Imposition of Special Measure Regarding Huione Group, as a 
Foreign Financial Institution of Primary Money Laundering Concern, 
90 FR 48295 (Oct. 16, 2025); see also 31 CFR 1010.664.
    \34\ FinCEN assesses that Huione International Payments is part 
of Huione Pay PLC and that the entity supports Haowang Guarantee's 
facilitation of transactions connected to money laundering 
activities. See Elliptic, Huione Guarantee: The multi-billion dollar 
marketplace used by online scammers (July 9, 2024, updated Mar. 27, 
2025), https://www.elliptic.co/blog/cyber-scam-marketplace; The New 
York Times, How Scammers Launder Money and Get Away With It (Mar. 
23, 2025), https://www.nytimes.com/2025/03/23/world/asia/cambodia-money-laundering-huione.html.
    \35\ National Bank of Cambodia, List of Payment Service 
Institutions (Dec. 31, 2024), https://www.nbc.gov.kh/english/supervision/payment_service.php (last accessed Mar. 21, 2025).
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    Moreover, in the Final Rule, FinCEN found that reasonable grounds 
exist to conclude that Huione Pay PLC operates outside of the United 
States. Huione Pay PLC operates, or has operated, eight Cambodian 
domestic branch locations, located in Battambang, Phnom Penh, Poipet, 
Siem Reap, and Sihanoukville.\36\ Huione Pay PLC has advertised on 
social media that it has, or had, operated a branch in Laukkaing,\37\ 
the capital of the Kokang Self-Administered Zone in northern Burma and 
a known center for criminal CVC investment scams, before a 2023-2024 
crackdown shuttered the majority of these operations.\38\ As noted 
above, Huione Pay PLC held a corporate registration in Cambodia as well 
as a payment services institution license, both of which have been 
revoked as of March 2025.\39\ Based on the foregoing, FinCEN found that 
reasonable grounds exist to conclude that Huione Pay PLC is operated 
from and located in Cambodia, and thus operates outside of the United 
States.
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    \36\ Telegram, Huione Branch, formerly available at https://t.me/huionestoreaddress/7 (last accessed Mar. 27, 2025).
    \37\ Telegram, Huione Group Customer Service Center, formerly 
available at https://t.me/huionekf/138 (last accessed Mar. 27, 
2025).
    \38\ Recorded Future, Myanmar rebels take control of `pig 
butchering' scam city amid China pressure on junta (Jan. 8, 2024), 
https://therecord.media/myanmar-rebels-control-pig-butchering-scam-hub.
    \39\ National Bank of Cambodia, List of Payment Service 
Institutions (Dec. 31, 2024), https://www.nbc.gov.kh/english/supervision/payment_service.php (last accessed Mar. 21, 2025). As of 
March 31, 2025, Huione Pay PLC is no longer listed as having an 
active license for ``other financial services activities.'' National 
Bank of Cambodia, List of Payment Service Institutions (Mar. 31, 
2025), https://www.nbc.gov.kh/english/supervision/payment_service.php (last accessed Oct 7, 2025). As of July 30, 
2025, Huione Pay PLC has also lost its corporate registration. See 
Cambodia Corporate Registry, Huione Search, https://www.businessregistration.moc.gov.kh/cambodia-master/service/
create.html?targetAppCode=cambodia-
master&targetRegisterAppCode=cambodia-br-
companies&service=registerItemSearch (last accessed July 29, 2025).
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3. Huione Group and Its Components Are of Primary Money Laundering 
Concern
    In the Final Rule, FinCEN further found that Huione Group (defined 
to include each of the Components, including, but not limited to, 
Huione Pay PLC) is of primary money laundering concern. As stated in 
the Final Rule, FinCEN assessed that Huione Group is used to facilitate 
and promote money laundering, particularly in support of illicit 
financial activities connected to the Democratic People's Republic of 
Korea (DPRK) and Southeast Asia-based TCOs.\40\ Because Huione Group 
has shared infrastructure with its constituent entities, the structure 
makes it challenging to ascertain the specific Component involved in 
any particular transaction. Nevertheless, FinCEN based this assessment 
on information available through both public and non-public reporting, 
and after thorough consideration of each of the following factors: (1) 
Huione Group provides services that DPRK government entities use to 
launder the proceeds of cyber heists; (2) TCOs based in Southeast Asia 
have used Huione Group to launder illicit proceeds of cyber scams, 
including CVC investment scams; and (3) Huione Group operates an 
illicit online market.\41\
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    \40\ FinCEN, Imposition of Special Measure Regarding Huione 
Group, as a Foreign Financial Institution of Primary Money 
Laundering Concern, 90 FR 48295, 48296 (Oct. 16, 2025).
    \41\ For additional details on FinCEN's assessment with respect 
to Huione Group's facilitation and promotion of money laundering, 
see the discussion in the Final Rule at 90 FR at 48300-48303. 
FinCEN, Imposition of Special Measure Regarding Huione Group, as a 
Foreign Financial Institution of Primary Money Laundering Concern, 
90 FR 48295, 48300-48303 (Oct. 16, 2025).
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    With this notice of proposed rulemaking, FinCEN does not alter its 
assessment that Huione Group is a financial institution operating 
outside the United States of primary money laundering concern.

B. Imposition of Special Measure Prohibiting the Opening or Maintaining 
of Correspondent Accounts For or On Behalf of Huione Group

    Consistent with the finding that Huione Group is a foreign 
financial institution of primary money laundering concern and in 
consideration of additional relevant factors, FinCEN imposed, under 
special measure five, a prohibition on covered financial institutions 
from opening or maintaining a correspondent account for, or on behalf 
of, Huione Group in order to guard against the money laundering risks 
to the U.S. financial system posed by Huione Group, as

[[Page 38344]]

identified in the First NPRM, Final Rule, and this notice of proposed 
rulemaking.\42\ That special measure remains in effect.
---------------------------------------------------------------------------

    \42\ For additional details on FinCEN's imposition of special 
measure five, see the Final Rule published at 90 FR at 48305-48306. 
FinCEN, Imposition of Special Measure Regarding Huione Group, as a 
Foreign Financial Institution of Primary Money Laundering Concern, 
90 FR 48295 (Oct. 16, 2025); see 31 CFR 1010.664.
---------------------------------------------------------------------------

III. Proposed Rule

A. Summary

    FinCEN is issuing this notice of proposed rulemaking to address 
Huione Group's efforts to circumvent the previously imposed special 
measure by continuing to operate as a financial institution outside the 
United States under a different name. This proposed rule is necessary 
to protect the U.S. financial system and the national security of the 
United States. This proposed rule, issued pursuant to section 311, 
would amend the definition of Huione Group \43\ to include ``H-Pay 
Service PLC and any successor entity'' of Huione Group, and would 
further add and define the term ``successor entity.''
---------------------------------------------------------------------------

    \43\ This proposed final rule does not remove any of the named 
Huione Group components as established in 31 CFR 1010.664. See 31 
CFR 1010.664; see also FinCEN, Imposition of Special Measure 
Regarding Huione Group, as a Foreign Financial Institution of 
Primary Money Laundering Concern, 90 FR 48295 (Oct. 16, 2025).
---------------------------------------------------------------------------

B. Huione Group's Efforts To Circumvent the Special Measure, Including 
Huione Pay PLC's Name Change to H-Pay Service PLC

    Based on public and non-public information, FinCEN assesses that H-
Pay Service PLC (H-Pay) is a financial institution operating outside 
the United States that is not only of primary money laundering concern 
as a component of Huione Group, but also that the transition within the 
Huione Group of operations from Huione Pay PLC to H-Pay represents an 
effort, consistent with past practice, of the Huione Group to evade 
public scrutiny and circumvent the special measure imposed through the 
Final Rule.
    H-Pay is a newly operational component of the Huione Group that 
FinCEN assesses has, following the publication of the First NPRM and 
Final Rule, effectively assumed the business role of Huione Pay PLC 
within the Huione Group.
    As an initial matter, H-Pay was licensed in Cambodia as a ``payment 
services institution'' \44\ and advertises offering services such as 
worldwide payments, savings accounts, and mobile banking.\45\ FinCEN 
assesses that H-Pay is engaged as a business in the transmission of 
currency due to these service offerings. Accordingly, FinCEN finds 
reasonable grounds exist to conclude that H-Pay is a money transmitter, 
which is a type of financial institution as that term is used in the 
BSA and section 311.
---------------------------------------------------------------------------

    \44\ National Bank of Cambodia, List of Payment Service 
Institutions (as of Sept. 30, 2025), https://www.nbc.gov.kh/download_files/data/khmer/KH/EN-PSIs.pdf.
    \45\ H-Pay Service PLC's website, www.h-pay.com (last accessed 
Mar. 19, 2026).
---------------------------------------------------------------------------

    Further, based on public and non-public information, FinCEN 
assesses that H-Pay is a component of the Huione Group--closely linked 
to Huione Pay PLC--and operating outside the United States. Although 
FinCEN assesses that Huione Pay PLC remains a financial institution of 
primary money laundering concern,\46\ Huione Pay PLC's ability to 
freely operate has been increasingly constrained. In particular, a 
March 6, 2025 media report indicated that Huione Pay PLC's banking 
license was revoked by the Cambodian government.\47\ According to a 
July 31, 2025 update, the National Bank of Cambodia rescinded this 
license by updating its list of ``Payment Service Institutions.'' \48\ 
Further, as of March 2025, Huione Pay PLC was registered with the 
Cambodian Ministry of Commerce for ``other financial service 
activities;'' however, as of July 29, 2025, it no longer appears in the 
Ministry of Commerce's business registration database, indicating that 
Huione Pay PLC lacks an active corporate registration or payment 
service license.\49\
---------------------------------------------------------------------------

    \46\ Shortly after publication of the NPRM in May 2025, Huione 
Pay began removing signage from its headquarters and other branches. 
When contacted by a journalist about this change, a Huione Pay 
employee claimed that Huione Pay was ``operating as usual,'' despite 
Huione Pay's license being revoked in March 2025. Cambodian 
Journalists Alliance Association, Huione Pay Removes Sign After U.S. 
Blacklist Move (May 7, 2025), www.cambojanews.com/huione-pay-removes-sign-after-u-s-blacklist-move/. At present, FinCEN has no 
information confirming that Huione Pay PLC has wholly ceased 
operations.
    \47\ See Radio Free Asia, Exclusive: World's Largest online 
black market' Loses banking license (Mar. 6, 2025), https://www.rfa.org/english/cambodia/2025/03/06/huione-cambodia-cyberscam-cryptocurrency/. Huione Group responded to the allegations, refuting 
them by noting that Huione Pay PLC does not require a banking 
license for its operations. Telegram, Huione Group Customer Service, 
Huione Statement (Mar. 9, 2025), formerly available at https://t.me/huionekf/346. As of March 31, 2025, Huione Pay PLC is no longer 
listed as having an active license for ``other financial services 
activities.'' National Bank of Cambodia, List of Payment Service 
Institutions (Mar. 31, 2025), https://www.nbc.gov.kh/english/supervision/payment_service.php (last accessed May 14, 2025).
    \48\ National Bank of Cambodia, List of Payment Service 
Institutions (July 31, 2025), https://www.nbc.gov.kh/english/supervision/payment_service.php (last accessed Oct. 7, 2025).
    \49\ Cambodia Corporate Registry, Huione Search, https://www.businessregistration.moc.gov.kh/cambodia-master/service/
create.html?targetAppCode=cambodia-
master&targetRegisterAppCode=cambodia-br-
companies&service=registerItemSearch (last accessed Mar. 27, 2025; 
July 29, 2025).
---------------------------------------------------------------------------

    As Huione Pay PLC's operations have become restricted, FinCEN 
assesses that H-Pay has assumed its place. Despite incorporating in 
2024,\50\ H-Pay was not listed as a licensed payment service 
institution by the National Bank of Cambodia until June 2025, after the 
National Bank of Cambodia revoked Huione Pay PLC's license, the 
Ministry of Commerce apparently delisted Huione Pay PLC, and FinCEN 
issued the First NPRM.\51\ H-Pay originally utilized an address \52\ in 
the same building as the flagship location of Panda Commercial Bank 
PLC, a financial institution in Cambodia that has reportedly been 
linked to Huione Pay PLC and the Huione Group and that has had its 
license revoked (and been forced into liquidation) by the National Bank 
of Cambodia.\53\ After that point, FinCEN assesses that H-Pay assumed 
Huione Pay PLC's physical and operational footprint. Shortly after 
publication of the First NPRM in May 2025, Huione Pay PLC began 
removing signage from its headquarters and other branches,\54\ and by 
November 2025, signs for H-Pay replaced Huione Pay PLC signs at both 
their headquarters location and at

[[Page 38345]]

multiple other branches.\55\ At the same time, a still-active Huione 
Pay hotline even referred a journalist to use H-Pay's app to continue 
accessing Huione Pay's services.\56\ And, as of December 2025--
following a ``bank run'' on H-Pay \57\--H-Pay customers were advised--
through a Chinese-language note on the door of the H-Pay headquarters--
of a ``Huione Deferred Payment Plan'' for their deposits in H-Pay,\58\ 
providing evidence of continued Huione Group--and specifically, Huione 
Pay--operations through H-Pay.
---------------------------------------------------------------------------

    \50\ Kingdom of Cambodia, Business Registration, H-PAY SERVICE 
PLC. (00074959) General Details, https://www.businessregistration.moc.gov (last accessed Dec. 11, 2025).
    \51\ National Bank of Cambodia, List of Payment Service 
Institutions, https://www.nbc.gov.kh/download_files/data/khmer/KH/EN-PSIs.pdf (as of June 30, 2025).
    \52\ National Bank of Cambodia, List of Payment Service 
Institutions (Mar. 31, 2025), https://www.nbc.gov.kh/english/supervision/payment_service.php (last accessed Oct 7, 2025); Kingdom 
of Cambodia Ministry of Commerce Business Registration, H-PAY 
SERVICE PLC. (00074959) Addresses, 
www.businessregistration.moc.gov.kh (last accessed Dec. 30, 2025).
    \53\ Cambodian Journalists Alliance Association, National Bank 
Revokes Panda Bank License, Orders Liquidation (Feb. 24, 2026), 
www.cambojanews.com/national-bank-revokes-panda-bank-license-orders-liquidation/. Huione Group has a history of claiming to be 
affiliated with Panda Bank. For example, a post from @hwdbgs, a now-
deleted Huione Guarantee-affiliated Telegram channel, claimed that 
Panda Bank was a subsidiary of Huione Group. Additionally, now-
deactivated website for Huione Group's insurance arm advertised on 
its website, as recently as 2024, that its shareholders also owned 
Huione Pay and Panda Bank. Telegram, @hwdb Channel (Apr. 5, 2022), 
archived at tgstat.com/channel/@hwdbgs.
    \54\ Cambodian Journalists Alliance Association, Huione Pay 
Removes Sign After U.S. Blacklist Move (May 7, 2025), 
www.cambojanews.com/huione-pay-removes-sign-after-u-s-blacklist-move/.
    \55\ Cambodian Journalists Alliance Association, H-Pay Emerges 
From Sanctioned Huione Pay, Panda Bank Links Noted (Nov. 27, 2025), 
www.cambojanews.com/h-pay-emerges-from-sanctioned-huione-pay-panda-bank-links-noted/.
    \56\ Id.
    \57\ Cambodian Journalists Alliance Association, Huione Pay 
Pulls Rebrand Sign, Freezes Accounts After CamboJA Report (Dec. 3, 
2025), www.cambojanews.com/huione-pay-pulls-rebrand-sign-freezes-accounts-after-camboja-report/.
    \58\ Id.
---------------------------------------------------------------------------

    More evidence of H-Pay's links to Huione Pay can be found in H-
Pay's early branding. A logo visible on H-Pay's website in August 2025 
bears a strong resemblance to Huione Pay's logos advertised on its 
websites, some of which remain active, featuring a red emblem with two 
curved laurel wreaths which form an almost complete circle.\59\ By 
December 2025, H-Pay's logo on its website was altered to remove the 
two curved laurel wreaths,\60\ which FinCEN assesses is an attempt to 
obfuscate its connection to Huione Pay.
---------------------------------------------------------------------------

    \59\ H-Pay's website, formerly available at www.h-pay.com (last 
accessed Aug. 18, 2025); Huione Pay's website, www.dev.huione.com 
(last accessed Aug. 18, 2025).
    \60\ H-Pay's website, formerly available at www.h-pay.com (last 
accessed Dec. 9, 2025).
---------------------------------------------------------------------------

    Additionally, a scam compound called ``#8 Park'' \61\ that hosted a 
physical Huione Pay store and also bore signage for a company allegedly 
linked to the OFAC-sanctioned ``Prince Group'' TCO,\62\ was reportedly 
also known as ``Huione Park.'' \63\ Following the disruption of Huione 
Pay's business, its branch in the compound was replaced with a new 
company, ``H-Pay,'' \64\ which has been publicly characterized as a 
``rebrand'' of Huione Pay.\65\ This H-Pay location was so vital to the 
compound that the #8 Park administrators had declared H-Pay to be the 
mandatory payment platform inside the complex.\66\ As described in the 
Final Rule, Huione Pay lost its license to operate as a payment service 
institution, as of March 31, 2025.\67\
---------------------------------------------------------------------------

    \61\ On March 26, 2026, the United Kingdom's Foreign, 
Commonwealth, and Development Office sanctioned a number of scam 
compound associated entities, including Legend Innovation Company, 
the operator of #8 Park. FCDO, UK Crackdown on Vile Scam Centres 
Steps Up with Sanctions on Illicit Crypto Network (Mar. 26, 2026) 
https://www.gov.uk/government/news/uk-crackdown-on-vile-scam-centres-steps-up-with-sanctions-on-illicit-crypto-network.
    \62\ On October 14, 2025, OFAC sanctioned 146 targets within the 
Cambodia-based Prince Group Transnational Criminal Organization 
(Prince Group). Treasury, Press Release, U.S. and U.K. Take Largest 
Action Ever Targeting Cybercriminal Networks in Southeast Asia (Oct. 
14, 2025), https://home.treasury.gov/news/press-releases/sb0278.
    \63\ Elliptic, #8 Park: Prince and Huione's role in a scam 
compound still operating amid crackdowns (Feb. 4, 2026), https://www.elliptic.co/blog/8-park-prince-and-huiones-role-in-a-scam-compound-still-operating-amid-crackdowns.
    \64\ Id.
    \65\ KiriPost, Rebranded H-Pay Freezes Withdrawals Amid Cash 
Crunch Following International Sanctions (Dec. 1, 2025), https://kiripost.com/stories/rebranded-h-pay-freezes-withdrawals-amid-cash-crunch-following-international-sanctions.
    \66\ See supra note 63.
    \67\ National Bank of Cambodia, List of Payment Service 
Institutions (Mar. 31, 2025), https://www.nbc.gov.kh/english/supervision/payment_service.php (last accessed Oct 7, 2025).
---------------------------------------------------------------------------

    Importantly, Huione Group's efforts to replace Huione Pay PLC with 
H-Pay follows the pattern of conduct that Huione Group has used 
following previous instances of negative public attention. 
Specifically, Huione Group has used name changes and creation or co-
option of new or other entities as a method to circumvent public 
scrutiny and the finding and special measure placed upon it by FinCEN. 
For example, on October 19, 2024, following a spate of negative media 
reports detailing Huione Group's indiscretions, ``Huione Guarantee'' 
rebranded as ``Haowang Guarantee.'' \68\ Later, in December 2024, 
Haowang Guarantee announced it was buying a stake in another illicit 
marketplace, Tudou Guarantee.\69\ Shortly after the publication of the 
First NPRM, Haowang Guarantee's illicit marketplace was reportedly 
banned from Telegram,\70\ resulting in Haowang Guarantee announcing it 
would close on its website.\71\ Haowang Guarantee then began directing 
its former customers to the illicit marketplace, Tudou Guarantee, that 
it had invested in earlier.\72\ And, given the rapid transition of 
Huione Pay PLC operations, facilities, and branding to H-Pay, FinCEN 
assesses that Huione Pay PLC changing its name to H-Pay presents 
another example of the Huione Group attempting to circumvent the impact 
of Huione Pay's corporate delisting and loss of license, as well as, 
ultimately, enforcement of the Final Rule.
---------------------------------------------------------------------------

    \68\ Telegram, Haowang Guarantee Customer Service Channel (Sept. 
30, 2024), formerly available at https://t.me/s/kefu (last accessed 
Mar. 27, 2025).
    \69\ In the same post, Tudou Guarantee claimed that Tudou 
Guarantee and Haowang Guarantee are independent organizations. 
FinCEN assesses that this is not credible. The combination of 
overlap in customers, particularly following Haowang Guarantee's ban 
from Telegram, the ownership stake by Haowang Guarantee of Tudou 
Guarantee, and media reporting lead FinCEN to believe Tudou 
Guarantee subsumed Haowang Guarantee. Telegram, @danbl0 Channel 
(Dec. 14, 2024), https://t.me/danbl0/16 (last accessed Jan. 14, 
2026); Telegram, @hwgq Channel (Dec. 10, 2024), tgstat.com/channel/@hwgq/249 (last accessed Jan. 14, 2026).
    \70\ Reuters, 2 massive black market services blocked by 
Telegram, messaging app says (May 15, 2025), https://www.reuters.com/world/china/2-massive-black-market-services-blocked-by-telegram-messaging-app-says-2025-05-15/.
    \71\ Haowang Guarantee website, formerly available at hwdb.la 
(last accessed on Nov. 11, 2025).
    \72\ Elliptic, Telegram dark markets expand to fill the gap left 
by Huione Guarantee (Jun. 23, 2025), www.elliptic.co/blog/telegram-
dark-markets-expand-to-fill-the-gap-left-by-huione-guarantee.
---------------------------------------------------------------------------

    In an announcement on April 10, 2026, the National Bank of Cambodia 
reportedly revoked H-Pay's payment services license. However, given the 
continued operations of Huione Pay and its eventual migration to H-Pay 
after the National Bank of Cambodia revoked Huione Pay's license in 
March 2025, FinCEN has reason to believe the same pattern of activity 
will persist with H-Pay and a future, successor entity.
    Therefore, for the reasons set out above, FinCEN assesses that 
reasonable grounds exist to conclude that H-Pay is a financial 
institution operating outside the United States, a Component of Huione 
Group that, like other Components of Huione Group is of primary money 
laundering concern, and, as such, should be included in the definition 
of Huione Group and subject to the special measure applicable to Huione 
Group.

C. Proposed Amended Definition of Huione Group

    The Final Rule defines ``Huione Group'' to mean ``all subsidiaries, 
branches, and offices of Huione Group operating as a financial 
institution in any jurisdiction outside of the United States, including 
Haowang Guarantee (formerly known as Huione Guarantee), Huione Pay PLC, 
and Huione Crypto Sp[oacute][lstrok]ka Z Ograniczon[aogon] 
Odpowiedzialno[sacute]ci[aogon] (d/b/a Huione Crypto).'' \73\
---------------------------------------------------------------------------

    \73\ 31 CFR 1010.664(a)(1).
---------------------------------------------------------------------------

    This proposed rule would amend the definition of Huione Group set 
forth at 31 CFR 1010.664(a)(1) to add: (1) H-Pay; and (2) the term 
``successor entity.'' In addition, this proposed rule would define 
``successor entity'' for purposes of this rule to mean any person that 
replaces Huione Group by acquiring its assets, in whole or in part, 
and/or carrying out the affairs of Huione Group under a new name.

[[Page 38346]]

IV. Section-by-Section Analysis

A. Definition of Huione Group

    This proposed rule defines the term ``Huione Group'' in 31 CFR 
1010.664(a)(1) means ``all subsidiaries, branches, and offices of 
Huione Group operating as a financial institution in any jurisdiction 
outside of the United States, including Haowang Guarantee (formerly 
known as Huione Guarantee), Huione Pay PLC, Huione Crypto 
Sp[oacute][lstrok]ka Z Ograniczon[aogon] 
Odpowiedzialno[sacute]ci[aogon] (d/b/a Huione Crypto), and H-Pay 
Service PLC, as well as any successor entity.

B. Definition of Successor Entity

    This proposed rule would also add a new definition, set forth at 31 
CFR 1010.664(a)(6), to define the term ``successor entity'' for 
purposes of this rule to mean any person that replaces Huione Group, or 
any Component thereof, by acquiring its assets, in whole or in part, 
and/or carrying out the affairs of Huione Group under a new name. In 
the future, FinCEN may publish notifications of future name changes of 
Huione Group, or any Component thereof, should they occur.

V. Executive Order 14294

    Section 5 of Executive Order 14294 directs that all future NPRMs 
and final rules published in the Federal Register, the violation of 
which may constitute criminal regulatory offenses, should include a 
statement identifying that the rule or proposed rule is a criminal 
regulatory offense and the authorizing statute.\74\
---------------------------------------------------------------------------

    \74\ Executive Order 14294, ``Fighting Overcriminalization in 
Federal Regulations'' 90 FR 20367 (issued May 9, 2025; published May 
14, 2025), https://www.federalregister.gov/executiveorder/14294.
---------------------------------------------------------------------------

    Executive Order 14294 further directs that the regulatory text of 
all NPRMs and final rules with criminal consequences published in the 
Federal Register after May 9, 2025, should explicitly state a mens rea 
requirement for each element of a criminal regulatory offense, 
accompanied by citations to the relevant provisions of the authorizing 
statute.
    Willful violations of the regulations set forth in this proposed 
rule may be subject to criminal penalties pursuant to 31 U.S.C. 5322 
and regulations promulgated in 31 CFR Chapter X. The statutory 
authority for criminal liability requires a mens rea of willfulness as 
an element pursuant to 31 U.S.C. 5322(a) and 31 U.S.C. 5322(b). 
FinCEN's existing regulation, 31 CFR 1010.840, that sets out criminal 
penalties for violations of regulations promulgated in 31 CFR Chapter X 
also includes a mens rea of willfulness. In drafting this statement, 
FinCEN has consulted with the Department of Justice.

VI. Regulatory Impact Analysis

    FinCEN has analyzed this proposed rule as required under Executive 
Order 12866,\75\ Executive Order 13563,\76\ the Regulatory Flexibility 
Act (RFA),\77\ the Unfunded Mandates Reform Act (UMRA),\78\ and the 
Paperwork Reduction Act (PRA).\79\
---------------------------------------------------------------------------

    \75\ Executive Order 12866, Regulatory Planning and Review, 58 
FR 51735 (issued Sept. 30,1993; published Oct. 4, 1993).
    \76\ Executive Order 13563, Improving Regulation and Regulatory 
Review, 76 FR 3821 (issued Jan. 18, 2011; published Jan. 21, 2011).
    \77\ 5 U.S.C. 601 et seq.
    \78\ 2 U.S.C. 1532.
    \79\ 44 U.S.C. 3507(a)(1)(D).
---------------------------------------------------------------------------

    The proposed amendments to the definition of Huione Group are 
expected to better ensure that the imposition of special measure five 
can achieve the intended effects as described in the First NPRM and 
Final Rule.\80\ The analysis below presents an analysis of the expected 
incremental economic effects that FinCEN anticipates would accompany 
adoption of the amendments to the Final Rule as proposed and assesses 
such expectations in more granular detail. This discussion includes an 
explanation of how the assumptions in FinCEN's cost model and 
methodological choices have influenced the conclusions of the agency's 
analysis. The public is invited to comment on all aspects of FinCEN's 
practice.
---------------------------------------------------------------------------

    \80\ See FinCEN, Special Measure Regarding Huione Group, as a 
Foreign Financial Institution of Primary Money Laundering Concern, 
90 FR 18934 (May 5, 2025); FinCEN, Imposition of Special Measure 
Regarding Huione Group, as a Foreign Financial Institution of 
Primary Money Laundering Concern, 90 FR 48295 (Oct. 16, 2025). As 
set out in the First NPRM and Final Rule, the rule is intended to: 
(1) combat and deter money laundering in facilitation of 
proliferation financing associate with Huione Group; and (2) prevent 
Huione Group from using the U.S. financial system to enable its 
illicit finance behavior.
---------------------------------------------------------------------------

A. Executive Orders

    Executive Orders 12866 and 13563 direct agencies to assess costs 
and benefits of available regulatory alternatives and, if regulation is 
necessary, to select regulatory approaches that maximize net benefits 
(including potential economic, environmental, public health and safety 
effects; distributive impacts; and equity). Executive Order 13563 
emphasizes the importance of quantifying both costs and benefits, 
reducing costs, harmonizing rules, and promoting flexibility.
    It has been determined that this proposed rule is not a significant 
regulatory action under section 3(f) of Executive Order 12866. 
Accordingly, a regulatory impact analysis is not required.

B. Regulatory Flexibility Act

    When an agency issues a rulemaking proposal, the Regulatory 
Flexibility Act (RFA) requires the agency to ``prepare and make 
available for public comment an initial regulatory flexibility 
analysis'' (IRFA) that will ``describe the impact of the proposed rule 
on small entities.'' \81\ However, section 605 of the RFA allows an 
agency to certify a rule, in lieu of preparing an analysis, if the 
proposed rulemaking is not expected to have a significant economic 
impact on a substantial number of small entities.
---------------------------------------------------------------------------

    \81\ 5 U.S.C. 603(a).
---------------------------------------------------------------------------

    In the First NPRM, FinCEN considered that the rule would apply to 
all covered financial institutions and could thus potentially affect a 
substantial number of small entities. FinCEN then provided the reasons 
that led it to assesses that the imposition of special measure five on 
Huione Group would be unlikely to have a significant economic impact on 
such entities, and hence that certification was appropriate.\82\ FinCEN 
then continued its analysis of the potential economic impact of the 
impositions of special measure five, generally,\83\ and in the Final 
Rule further concluded that it did not expect the rule to affect a 
substantial number of entities in practice, and that few if any of 
these entities would meet the criteria necessary to be considered small 
entities for the purposes of the RFA.\84\ On this basis, FinCEN 
maintained that certification of the rule continued to be appropriate.
---------------------------------------------------------------------------

    \82\ See FinCEN, Special Measure Regarding Huione Group, as a 
Foreign Financial Institution of Primary Money Laundering Concern, 
90 FR 18934, 18946 (Section VIII.B) (May 5, 2025).
    \83\ See, e.g., FinCEN, Agency Information Collection 
Activities; Proposed Renewal; Comment Request: Renewal Without 
Change of Information Collection Requirements in Connection With the 
Imposition of Special Measures, 90 FR 57279, 57280-57283 (Section 
II) (Dec. 10, 2025).
    \84\ 5 U.S.C. 601(3)-(5).
---------------------------------------------------------------------------

    Since this proposed rule would amend a certified rule, FinCEN 
considered the likelihood that the incremental economic effects of the 
proposed amendments would, independently, significantly impact a 
substantial number of small entities. Under the proposed amendments 
covered financial institutions would be required to take reasonable 
measures to detect use of their correspondent accounts to process 
transactions involving Huione Group as it would be newly defined by the 
proposed amendments to 1010.664(a). As

[[Page 38347]]

previously taken into consideration, because all U.S. persons, 
including U.S. financial institutions, currently must comply with OFAC 
sanctions, and U.S. financial institutions generally have suspicious 
activity reporting requirements and systems in place to screen 
transactions to comply with OFAC sanctions and section 311 special 
measures administered by FinCEN, it is not foreseeable that adding H-
Pay Services PLC to the definition of Huione Group would have a 
substantial impact. The systems that U.S. financial institutions have 
in place to comply with economic sanctions and BSA requirements can 
easily be modified to adapt to this addition.
    However, it is less clear that the special due diligence that would 
be required under the proposed rule--i.e., preventing the processing of 
transactions involving Huione Group and the transmittal of notification 
to certain correspondent account holders--would not impose a 
significant additional economic burden upon U.S. financial institutions 
because the proposed rule would also amend the definition of Huione 
Group to include any successor entity and both (1) the number of future 
successors and (2) the frequency with which such successor entities may 
arise and be identified are unknown.\85\ FinCEN is therefore, as a 
conservative precaution, not taking the position that the proposed rule 
could not have a significant economic impact on a small covered 
financial institution. Instead, FinCEN is certifying that the proposed 
amendments to the Final Rule contained in this rulemaking would not 
have a significant impact on a substantial number of small businesses 
because it continues to expect, as in the Final Rule, that few, if any, 
covered financial institutions that maintain foreign correspondent 
accounts meet the applicable definitional criteria to be deemed a 
``small entity'' under the RFA.
---------------------------------------------------------------------------

    \85\ FinCEN is requesting comment on the likelihood of 
additional successor entities and the expected burden associated 
with naming additional successor entities. See infra Section VI.D, 
Additional Requests for Comments, Question #3.
---------------------------------------------------------------------------

    FinCEN invites comments from members of the public who believe 
there would be a significant economic impact on small entities from the 
imposition of a prohibition under the fifth special measure regarding 
Huione Group.

C. Unfunded Mandates Reform Act

    Section 202 of the UMRA \86\ requires that an agency prepare a 
budgetary impact statement before promulgating a rule that may result 
in expenditure by the State, local, and Tribal governments, in the 
aggregate, or by the private sector, of $193 million or more in any one 
year ($100 million in 1995, adjusted for inflation).87 88 If 
a budgetary impact statement is required, section 202 of the UMRA also 
requires an agency to identify and consider a reasonable number of 
regulatory alternatives before promulgating a rule.
---------------------------------------------------------------------------

    \86\ 2 U.S.C. 1532.
    \87\ Id.
    \88\ The U.S. Bureau of Economic Analysis reports the annual 
value of the gross domestic product implicit price deflator for 
calendar year 1995 (the year UMRA was enacted) as 66.939, and as 
128.974 for calendar year 2025 (the most recent available). Thus, 
the inflation-adjusted estimate for $100 million is 128.974 / 66.939 
x $100 million, or $192.7 million. U.S. Bureau of Economic Analysis, 
Table 1.1.9. Implicit Price Deflators for Gross Domestic Product.
---------------------------------------------------------------------------

    FinCEN has determined that this proposed rule will not result in 
expenditures by State, local, and Tribal governments in the aggregate, 
or by the private sector, of $193 million or more in any one year. 
Accordingly, FinCEN has not prepared a budgetary impact statement or 
specifically addressed the regulatory alternatives considered.

D. Paperwork Reduction Act

    The recordkeeping and disclosure requirements in this proposed 
rule, which qualify as ``collections of information'' under the PRA, 
will be submitted to the Office of Management and Budget (OMB) for 
review in accordance with the PRA.\89\ Under the PRA, an agency may not 
conduct or sponsor, and a person is not required to respond to, a 
collection of information unless it displays a valid control number 
assigned by the OMB.\90\ Written comments and recommendations for the 
amended prohibition can be submitted by visiting www.reginfo.gov/public/do/PRAMain. Find this particular document by selecting 
``Currently under Review--Open for Public Comments'' or by using the 
search function. Comments are welcome and must be received by [30 DAYS 
AFTER DATE OF PUBLICATION IN THE FEDERAL REGISTER]. In accordance with 
requirements of the PRA, 44 U.S.C. 3506(c)(2)(A), and its implementing 
regulations, 5 CFR part 1320, the following information concerning the 
collection of information as required by 31 CFR 1010.664 is presented 
to assist those persons wishing to comment on the information 
collections.
---------------------------------------------------------------------------

    \89\ 44 U.S.C. 3507(a)(1)(D).
    \90\ 44 U.S.C. 3507(a)(3).
---------------------------------------------------------------------------

    The provisions in this proposed rule would extend the scope of the 
required collection of information found in sections 
1010.664(b)(3)(i)(A) and 1010.664(b)(4) by including the additional 
parties defined in 1010.664(a)(1), as amended, and 1010.664(a)(6). As 
described in the Final Rule, the notification requirement in section 
1010.664(b)(3)(i)(A) is intended to aid cooperation from foreign 
correspondent account holders in preventing transactions involving 
Huione Group from being processed by the U.S. financial system.\91\ The 
information required to be maintained by section 1010.664(b)(4) will 
continue to be used by federal agencies and certain self-regulatory 
organizations to verify compliance by covered financial institutions 
with the notification requirement in section 1010.664(b)(3)(i)(A). The 
additional collection of information resulting from the proposed 
amendment to the definition of Huione Group would be mandatory. The 
proposed rule does not modify the intended purpose of the Final Rule or 
the nature of the information required to be collected or disclosed. It 
would exclusively modify the scope of the parties included within the 
definition of ``Huione Group.'' FinCEN is revising the related PRA 
estimates covered by OMB control number 1506-0083 accordingly to 
account for the revised definition introduced by this proposed rule.
---------------------------------------------------------------------------

    \91\ See FinCEN, Imposition of Special Measure Regarding Huione 
Group, as a Foreign Financial Institution of Primary Money 
Laundering Concern, 90 FR 48295 (Oct. 16, 2025).
---------------------------------------------------------------------------

    Frequency: As required.
    Description of Affected Financial Institutions: Only those covered 
financial institutions defined in section 1010.664(a)(3) that are 
engaged in correspondent banking with, or processing transactions 
potentially involving Huione Group, as defined in section 
1010.664(b)(1) and (2) are expected to be affected.
    Estimated Number of Potential Respondents: Approximately 14,575.

[[Page 38348]]



      Table 1--Estimates of Covered Financial Institutions by Type
------------------------------------------------------------------------
           Financial institution type               Number of entities
------------------------------------------------------------------------
Banks with a Federal Functional Regulator (FFR)                \b\ 8,623
 \a\...........................................
Banks without an FFR \c\.......................                  \d\ 365
Broker-dealers in securities (Broker-dealers)                  \f\ 3,278
 \e\...........................................
Futures commission merchants (FCMs) and                          \h\ 954
 Introducing brokers in commodities (IBCs) \g\.
Mutual funds \i\...............................                \j\ 1,355
------------------------------------------------------------------------
\a\ See 31 CFR 1010.100(t)(1); see also 31 CFR 1010.100(d) and 31 CFR
  1020.210(a).
\b\ This includes 4,336 Federal Deposit Insurance Corporation- (FDIC-)
  insured depository institutions (i.e., federally regulated banks)
  according to the FDIC's Quarterly Bank Profile for Q4 2025, p. 2
  (https://www.fdic.gov/quarterly-banking-profile/past-quarterly-banking-profiles profiles). It also includes 4,287 National Credit Union Administration-
   (NCUA-) chartered credit unions (i.e., federally regulated credit
  unions) as of December 31, 2025, according to NCUA's Quarterly Credit
  Union Data Summary: 2025 Q4, p. i (https://ncua.gov/analysis/credit-union-corporate-call-report-data/quarterly-data-summary-reports).
\c\ 31 CFR 1020.210(b).
\d\ The Board of Governors of the Federal Reserve System Master Account
  and Services Database (https://www.federalreserve.gov/paymentsystems/master-account-and-services-database-existing-access.htm) contains
  data as of November 30, 2025, on financial institutions that use
  Federal Reserve Bank financial services, including those with no
  additional Federal regulator. FinCEN used this data to identify 365
  banks and credit unions with no additional Federal regulator using
  Federal Reserve Bank financial services.
\e\ 31 CFR 1010.100(t)(2).
\f\ This estimate is based on U.S. Securities and Exchange Commission
  (SEC) data on active broker-dealers available at ``Company Information
  About Active Broker-Dealers'' (https://www.sec.gov/foia-services/frequently-requested-documents/company-information-about-active-broker-dealers dealers), which listed 3,278 active broker-dealers registered with the
  SEC as of December 31, 2025.
\g\ 31 CFR 1010.100(t)(8) and (9).
\h\ According to the Commodity Futures Trading Commission data on FCMs
  available at ``Financial Data for FCMs'' (https://www.cftc.gov/MarketReports/financialfcmdata/index.htm), there were 66 registered
  FCMs as of December 31, 2025. The number of IBCs as of December 31,
  2025 (888) was obtained from the National Futures Association, ``NFA
  Membership Totals'' website (https://www.nfa.futures.org/registration-membership/membership-and-directories.html). Because deduplication of
  entities registered as both FCMs and IBCs was not feasible, this
  estimate may double-count some entities registered in both categories.
  FinCEN, however, believes this subpopulation may be small.
\i\  See 31 CFR 1010.100(t)(10); see also 31 CFR 1010.100(gg).
\j\ This estimate is based on the number of registered investment
  companies filing Form N-1A in SEC's Annual Registered Investment
  Company Update: Form N-CEN Data, Period Ending December 2024, April
  2025, table 1.3, p. 4 (https://www.sec.gov/files/annual-registered-investment-company-update-20250404.pdf).

    Estimated Number of Expected Respondents: Approximately 129.\92\
---------------------------------------------------------------------------

    \92\ While this regulation applies to all covered institutions 
described in Table 1, in practice the burden would only be imposed 
on select institutions that maintain correspondent accounts for 
foreign banks. Table 2 presents an estimate of this subpopulation of 
banks, brokers or dealers in securities, FCMs and IBCs, and mutual 
funds.

      Table 2--Estimates of Affected Financial Institutions by Type
------------------------------------------------------------------------
           Financial institution type               Number of entities
------------------------------------------------------------------------
Banks with an FFR..............................                   \a\ 66
Banks without an FFR...........................                   \b\ 12
Broker-dealers.................................                   \c\ 30
FCMs and IBCs..................................                    \d\ 9
Mutual funds...................................                   \e\ 12
------------------------------------------------------------------------
\a\ Data is from the Federal Financial Institution Examination Council
  Central Data Repository for Reports of Condition and Income (Call
  Reports) and Uniform Bank Performance Reports, available for most FDIC-
  insured institutions. Using this source of data, FinCEN determines
  that as of Q4 2025, approximately 66 banks (as defined by FinCEN
  regulations, see 31 CFR 1010.100(d)) would be affected by this
  proposed rule in any given year. Specifically, as of Q4 2025, there
  were approximately 66 banks that reported non-zero values for deposit
  liabilities of banks in foreign countries. Deposit liabilities in a
  foreign country is an indication that a bank maintains correspondent
  accounts with a foreign financial institution.
\b\ The Board of Governors of the Federal Reserve System Master Account
  and Services Database contains data on financial institutions that use
  Reserve Bank financial services, including those with no additional
  Federal regulator. FinCEN used this data to identify an additional 12
  international banking entities with no additional Federal regulator
  and that do not file Call Reports, but that are also likely to
  maintain correspondent accounts with a foreign financial institution.
\c\ Broker-dealers, unless they are publicly traded, are not required to
  make reports indicating whether they have foreign correspondent
  accounts or hold foreign deposits. FinCEN reviewed financial statement
  data from 10-Q and 6-K filings with the SEC and identified nine
  publicly traded broker-dealers with U.S. operations that reported
  foreign deposits. FinCEN also examined Suspicious Activity Reports
  filed by broker-dealers in 2024 to identify another two non-publicly
  traded broker-dealers who appeared likely to be maintaining foreign
  deposits. However, because many broker-dealers are not publicly
  traded--so there may be less information about their business publicly
  available--and because many did not file Suspicious Activity Reports,
  FinCEN conservatively estimates that the proportion of broker-dealers
  with foreign correspondent accounts is similar to the proportion for
  banks (approximately 0.9 percent). 0.9 percent of 3,278 active broker-
  dealers is approximately 30 broker-dealers assumed to have foreign
  correspondent accounts.
\d\ FCMs, IBCs, and mutual funds generally use intermediary U.S. banks
  to move and maintain client deposits and funds for investment.
  Therefore, it is unlikely that many of these institutions maintain
  direct correspondent accounts with foreign financial institutions
  outside of their existing upstream banking relationships. However,
  because these institutions may in some cases receive deposits from,
  make payments or other disbursements, or otherwise transact directly
  with foreign financial institutions, FinCEN conservatively estimates
  that the proportion of FCMs, IBCs, and mutual funds with foreign
  correspondent accounts is similar to the proportion for banks
  (approximately 0.9 percent). 0.9 percent of 954 active FCMs and IBCs
  is approximately nine FCMs and IBCs assumed to have foreign
  correspondent accounts.
\e\ 0.9 percent of 1,355 active mutual funds is approximately 12 mutual
  funds assumed to have foreign correspondent accounts.


[[Page 38349]]

    Estimated Average Annual Burden in Hours per Affected Financial 
Institution:
    Imposing special measure five requirements as described in the 
Final Rule was originally expected to result in new, incremental 
recordkeeping burdens on certain covered financial institutions as 
outlined below.
Original Burden Estimates
    An affected covered financial institution is expected to incur 
recordkeeping and disclosure burdens associated with preparing and 
retaining the materials necessary to demonstrate compliance with the 
imposition of special measure five, which includes records related to:
    A. Documenting the reasonable steps the financial institution 
undertakes to ensure no transactions involving Huione Group are 
processed for a foreign correspondent account.\93\
---------------------------------------------------------------------------

    \93\ See FinCEN, Imposition of Special Measure Regarding Huione 
Group, as a Foreign Financial Institution of Primary Money 
Laundering Concern, 90 FR 48295, 48309-48311 (Section VI.D) (Oct. 
16, 2025).
---------------------------------------------------------------------------

    B. Notifying, and documenting that the financial institution has 
provided notice to, foreign correspondent account holders that the 
financial institution knows or has reason to believe provide services 
to Huione Group, informing such correspondents that they may not 
provide Huione Group with access to the correspondent account 
maintained at the financial institution.
    C. Documenting the reasonable steps it took with respect to special 
due diligence requirements, including but not limited to, the reasoning 
that informed decisions to adopt (or not adopt) new measures adding to 
its existing risk-based approach, and those new measures, if adopted.
Revised Burden Estimates
    For purposes of modeling the anticipated changes in PRA burden 
introduced by the proposed rule, FinCEN considered the amendments to 
the definition of Huione Group in 31 CFR 1010.664(a) to include (1) H-
Pay Service PLC and (2) any successor entity separately. Because the 
Final Rule already required affected financial institutions to 
undertake activities A-C in 2025, FinCEN assumes that financial 
institutions may leverage the existing work already undertaken when 
newly applying special measure five to H-Pay Service PLC. As such, 
FinCEN is assigning a burden of four hours, or half the typical year-
one burden, to integrate this newly named entity into an existing 
section 311 finding.
    FinCEN similarly expects that, in the future, should the agency 
identify and provide notice to affected financial institutions of 
additional successor entities upon which the special measure five 
prohibitions would be imposed, the same ability to leverage existing 
work would attenuate the burden associated with imposing special 
measures on a new entity. At this time, FinCEN does not have the 
additional data or information necessary to estimate the likelihood of 
issuing such a determination, or otherwise notifying covered financial 
institutions of their new obligations, in a given year with more 
precision than a general binary random probability (i.e., p = 0.5).
    Thus, in year two, the expected incremental PRA burden of two hours 
associated with newly defining Huione Group to include any successor 
entity, as defined and operationalized, reflects the 50 percent chance 
of an additional four-hour burden and the 50 percent chance of no 
additional burden. In year three, the expected incremental PRA burden 
of 2.125 hours similarly reflects the equally weighted probabilities of 
successors being identified in sequential periods.\94\
---------------------------------------------------------------------------

    \94\ The annual outcomes are modeled as a Bernoulli process, 
with a general formula of expected burden (1/2n-1) x 
{s1, . . .,s2n-1{time}  in year n. 
When n = 3, (1/2 \2\) x {0, 0.25, 4, 4.25{time}  = ((1/4) x (0)) + 
((1/4) x (0.25)) + ((1/4) x (4)) + ((1/4) x (4.25)) = 2.125. This 
reflects a 25 percent of no additional burden in s1 
(there are no successor entities in year two or three), a 25 percent 
chance of an additional 0.25-hour burden in s2 (there is 
a successor entity in year two but no new successor entity in year 
three), a 25 percent chance of an additional four-hour burden in 
s3 (there is no new successor entity in year two but a 
new successor entity in year three), and a 25 percent chance of an 
additional 4.25-hour burden in s4 (there is a new 
successor entity in both years two and three).
---------------------------------------------------------------------------

    Each newly identified entity is then subsequently expected to be 
integrated into the existing section 311 special measures practices of 
affected financial institutions as modeled elsewhere in FinCEN PRA 
analyses.\95\
---------------------------------------------------------------------------

    \95\ See, e.g., FinCEN, Imposition of Special Measure Regarding 
Huione Group, as a Foreign Financial Institution of Primary Money 
Laundering Concern, 90 FR 48295 (Oct. 16, 2025); FinCEN, Proposal of 
Special Measure Regarding Transactions Involving Ten Mexican 
Gambling Establishments as a Class of Transactions of Primary Money 
Laundering Concern, 90 FR 51234 (Nov. 17, 2025); FinCEN, Agency 
Information Collection Activities; Proposed Renewal; Comment 
Request: Renewal Without Change of Information Collection 
Requirements in Connection With the Imposition of Special Measures, 
90 FR 57279 (Dec. 10, 2025); FinCEN, Proposal of Special Measure 
Regarding MBaer Merchant Bank AG as a Financial Institution 
Operating Outside of the United States of Primary Money Laundering 
Concern, 91 FR 10034 (Mar. 2, 2026).
---------------------------------------------------------------------------

    Tables 3 through 5 reflect these revisions to the PRA analysis in 
the Final Rule, including the estimated average annual burden per 
affected financial institution assigned to the additional collection of 
information in this proposed rule: four hours in year one, 2.25 hours 
in year two,\96\ and 2.375 hours in year three.\97\
---------------------------------------------------------------------------

    \96\ 2.25 hours = 0.25 hours associated with including H-Pay 
Service PLC + 2 hours associated with the potential additional 
successor entity in year two.
    \97\ 2.375 hours = 0.25 hours associated with including H-Pay 
Service PLC + 2.125 hours associated with the potential additional 
successor entities in years two and three.

                       Table 3--Expected PRA Burden Hours per Respondent by Effective Year
----------------------------------------------------------------------------------------------------------------
                                                                                      Including
                                                Huione group    Including H-Pay       potential
                     Year                       as defined in     service PLC         additional        Total
                                                 final rule                          successor(s)
----------------------------------------------------------------------------------------------------------------
1............................................            0.25                  4                n/a         4.25
2............................................            0.25               0.25                  2         2.50
3............................................            0.05               0.25              2.125        2.425
                                              ------------------------------------------------------------------
    Total Burden.............................            0.55                4.5              4.125        9.175
----------------------------------------------------------------------------------------------------------------


[[Page 38350]]


              Table 4--Summary of the Incremental Increase in PRA Burden Relative to the Final Rule
----------------------------------------------------------------------------------------------------------------
                                                             Incremental         Total
                                              Number of      increase in      incremental     Total incremental
                   Year                      respondents  burden hours per    increase in   increase in cost \a\
                                                             respondent      burden hours
----------------------------------------------------------------------------------------------------------------
1.........................................           129                 4           516.0               $64,283
2.........................................           129              2.25           290.3                36,159
3.........................................           129             2.375           306.4                38,168
                                           ---------------------------------------------------------------------
3-Year average............................           129              2.88           370.9                46,204
----------------------------------------------------------------------------------------------------------------
\a\ The wage rate applied here is a general composite hourly wage ($87.61) scaled by a private sector benefits
  factor of 1.42 ($124.58 = $87.61 x 1.42). This incorporates Bureau of Labor Statistics mean wage data
  associated with six occupational codes (11-1010: Chief Executives; 11-3021: Computer and Information Systems
  Managers; 11-3031: Financial Managers; 13-1041: Compliance Officers; 23-1010: Lawyers and Judicial Law Clerks;
  43-3099: Financial Clerks, All Other) for each of the nine groupings of North American Industry Classification
  System industry codes that FinCEN determined are most directly comparable to its 11 categories of potentially
  affected financial institutions as delineated in 31 CFR parts 1020 to 1030. See Bureau of Labor Statistics,
  May 2024--National industry-specific and by ownership, https://www.bls.gov/oes/tables.htm. Given that many
  occupations provide benefits beyond wages (e.g., insurance and paid leave), FinCEN applies the private sector
  benefit factor to the unloaded wage rate to reflect the total cost to the employer. The benefit factor is the
  ratio of total compensation (which includes wages and benefits) to wages. Total compensation = $43.94 and
  Wages and salaries = $30.90 (1.42 = $43.94 / $30.90) as of June 2024, based on the private industry workers
  series data downloaded from the Bureau of Labor Statistics, Employer Costs for Employee Compensation data,
  https://www.bls.gov/news.release/archives/ecec_09102024.pdf.


                                Table 5--Annual Time Burden: Three-Year Averages
----------------------------------------------------------------------------------------------------------------
                                                                     Original
                           Total hours                             (final rule)     Incremental        Total
                                                                        \a\           (NPRM)
----------------------------------------------------------------------------------------------------------------
Per Respondent..................................................            0.18            2.88            3.06
On Aggregate....................................................       \b\ 23.65          370.88          394.53
----------------------------------------------------------------------------------------------------------------
\a\ The per-respondent burden for the Final Rule reflects the average annual burden for years two through four
  to ensure comparability with the annual averages for years one through three of this proposed rule.
\b\ The burden was calculated by applying the per-respondent burden from the Final Rule (0.18 hours) to the
  updated number of expected respondents (129) rather than the number of expected respondents under the Final
  Rule (127).

    FinCEN invites comments on: (1) whether the collection of 
information found in section 1010.664(b)(4) is necessary for the proper 
performance of the mission of FinCEN, including whether the information 
will have practical utility; (2) the accuracy of FinCEN's estimate of 
the burden of the collection of information; (3) ways to enhance the 
quality, utility, and clarity of the information required to be 
maintained; (4) ways to minimize the burden of the required collection 
of information, including through the use of automated collection 
techniques or other forms of information technology; and (5) estimates 
of capital or start-up costs and costs of operation, maintenance, and 
purchase of services to report the information.
Additional Requests for Comment
    1. Do FinCEN's expectations for how additional entities would be 
integrated into ongoing compliance activities with the existing Final 
Rule comport with industry practices? If not, how substantively does 
this affect the conclusions of FinCEN's analysis?
    2. Are FinCEN's estimates of burden and cost generally consistent 
with the experience of affected financial institutions? If not, please 
provide data, studies, reports, or anecdotal information that would 
allow FinCEN to improve the accuracy of its burden and cost estimates.
    3. Do FinCEN's expectations about the likelihood of additional 
successor entities being identified comport with market expectations? 
Are FinCEN's expectations about the burden associated with naming 
additional successor entities reasonable?
    4. Is FinCEN's characterization of a diminishing cost profile over 
time in connection with the imposition of section 311 special measures 
a reasonably accurate representation of market practices? If not, 
please provide data, studies, reports, or anecdotal information that 
would allow FinCEN to improve the accuracy of its burden and cost 
estimates.

VII. Regulatory Text

List of Subjects in 31 CFR Part 1010

    Administrative practice and procedure, Banks, Banking, Brokers, 
Crime, Foreign banking, Terrorism.

Authority and Issuance

    For the reasons set forth in the preamble, FinCEN proposes amending 
31 CFR part 1010 to read as follows:

PART 1010--GENERAL PROVISIONS

0
1. The authority citation for part 1010 continues to read as follows:

    Authority: 12 U.S.C. 1829b and 1951-1959; 31 U.S.C. 5311-5314, 
5316-5336; title III, sec. 314, Pub. L. 107-56, 115 Stat. 307; sec. 
2006, Pub. L. 114-41, 129 Stat. 458-459; sec. 701 Pub. L. 114-74, 
129 Stat. 599; sec. 6403, Pub. L. 116-283, 134 Stat. 3388.

0
2. Amend 1010.664 to read as follows:


1010.664  Special measures regarding Huione Group.

    (a) * * * * *
    (1) Huione Group. The term ``Huione Group'' means all subsidiaries, 
branches, offices of Huione Group operating as a financial institution 
in any jurisdiction outside of the United States, including Haowang 
Guarantee (formerly known as Huione Guarantee), Huione Pay PLC, Huione 
Crypto Sp[oacute][lstrok]ka Z Ograniczon[aogon] 
Odpowiedzialno[sacute]ci[aogon] (d/b/a Huione Crypto), and H-Pay 
Service PLC, as well as any successor entity.
* * * * *
    (6) Successor Entity. The term ``successor entity'' means any 
person that replaces Huione Group by acquiring its assets, in whole or 
in part, and/or carrying out the affairs of Huione Group under a new 
name.
* * * * *

Jimmy L. Kirby,
Deputy Director, Financial Crimes Enforcement Network.
[FR Doc. 2026-12794 Filed 6-24-26; 8:45 am]
BILLING CODE 4810-02-P