US money transmitter enforcement tracker: every state, FinCEN and CFPB action on customer funds, licensing and compliance since 2022

Key takeaways

• Three customer-fund failures define the period: Sigue (unpaid transmission liabilities, net worth and permissible investment breaches, 2024), Prime Trust ($82.8 million fiat shortfall, Nevada receivership, 2023) and Synapse (an estimated $65 million to $96 million shortfall in end-user accounts, still not fully reconciled, 2024 to 2025).
• Net worth breaches now end licenses: CoinZoom surrendered its Washington license in 2026 after holding under a third of the required $3 million, Bittrex surrendered its Texas license in 2023, Fortress Trust was fined in Connecticut in 2024, and Bitcoin Depot's Connecticut license was summarily suspended in 2026.
• Payroll processors are the most frequent unlicensed-transmission target: Paycor ($275,000, Texas 2026), Paylocity ($318,750, Texas 2025), Brotherhood Works, Viventium, PrimePay and Kronos.
• The CFPB's Remittance Rule cases produced $55 million from Block (2025), $1.5 million from Sendwave (2023), $950,000 from Small World (2022) and $700,000 from UniTeller (2022); the CFPB then cut Wise's penalty from $2 million to $44,955 in May 2025 and withdrew from the MoneyGram case.
• Multistate coordination through the Conference of State Bank Supervisors is now the default for large cases: Block (48 jurisdictions), Wise (six regulators, $4.2 million), ACI Payments (44 agencies, $2.39 billion of erroneous debits), Sigue (41 jurisdictions), Coinme (34 states).
• Regulators are ordering segregation directly: Coinme was required to place all Washington customers' assets in segregated accounts within 14 days (December 2025); Hodan Global was ordered to hold transmittal funds in insured, segregated client accounts (Massachusetts, 2024); Bitcoin Depot was ordered to segregate customer funds within seven days (Connecticut, 2026).

What this tracker covers

This page lists public enforcement actions against US money transmitters and money services businesses from January 2022 onward where we have opened the order, consent order, petition or regulator press release and confirmed the date, the firm, the outcome and any figure. It covers state banking and financial regulators (New York, California, Texas, Washington, Connecticut, Massachusetts, New Jersey, Illinois, Nevada and multistate settlements), FinCEN and the CFPB, and the two bankruptcies where customer money was found short, Synapse and Prime Trust.

Each entry gives what happened in plain words, the penalty or order, the law cited and a link to the primary source. Orders that appear on a regulator's index but whose documents could not be opened are left out until they can be read; the Texas Department of Banking lists 62 money services business orders for the period, of which 30 are included here. Limited purpose trust companies (Gemini, Paxos, Genesis Global Trading) and pure cybersecurity cases are outside the scope.

For how the state rules work see the permissible investments guide, the state-by-state permissible investments table and the money transmitter reconciliation guide. The UK equivalent is the FCA safeguarding enforcement tracker.

The customer-fund shortfalls on record

Regulators rarely publish shortfall figures; these come from court petitions, trustee reports and consent orders.

Customer funds, net worth and permissible investments

The cases closest to safeguarding: money owed to customers that was not there, firms below the net worth a license requires, and regulators ordering segregation.

• 8 Oct 2026. Coinme, Inc. (crypto kiosk operator and money transmitter). A multistate examination from March 2023 to March 2025, led by Washington with 33 other states and territories, found no effective anti-money-laundering program for the kiosks and unremediated prior findings; the Washington release also cites net worth noncompliance and weak accounting. Outcome: $2,200,000 penalty plus $300,000 costs; a further $4,000,000 if kiosks are not shut in all states by 1 January 2027; independent consultant for two years. Bank Secrecy Act; Washington Uniform Money Services Act. Source: Consent order (PDF) and press release.
• 9 Mar 2026. Bitcoin Depot Operating LLC (crypto kiosk operator). Connecticut summarily suspended the license: tangible net worth below $1,000,000 in 2022 and 2023 (admitted), $150,426 of fees above the 15% cap on 1,015 transactions, refund failures and scam losses. The firm was ordered to segregate customer funds within seven days. Outcome: Interim order; hearing set for 13 May 2026; restitution, disgorgement and revocation sought. Conn. Gen. Stat. 36a-597, 36a-600(d), 36a-604(c), 36a-606a, 36a-607, 36a-608, 36a-613. Source: Order (PDF).
• 9 Feb 2026. CoinZoom, Inc. (crypto exchange and money transmitter). Held under one third of the required $3,000,000 tangible net worth from 2022 to 2024, filed inaccurate financials, failed to report a lawsuit and other states' orders, and filed its annual report and call report late. Outcome: $150,000 fine ($50,000 stayed for three years) plus fees; license surrendered within 90 days; 60-day customer withdrawal window; unclaimed funds escheated; three-year industry bar. RCW 19.230.060, .070, .100, .110, .130, .150, .152, .170, .230, .340. Source: Consent order (PDF).
• 23 Dec 2025. Coinme, Inc.. Consent order staying the November temporary order: Coinme had to hold all Washington customers' virtual currency in segregated accounts within 14 days and the cash for outstanding kiosk transactions in a segregated, unencumbered account within 30 days. Outcome: No fine; monthly remediation updates. Washington Uniform Money Services Act. Source: Consent order (PDF).
• 25 Nov 2025. Coinme, Inc. and Neil Bergquist. Statement of charges and temporary cease and desist: unredeemed customer vouchers booked as income ($2,201,254 at end 2023, $6,170,822 at end 2024) without disclosure or escheat; negative tangible net worth at the end of 2022, 2023 and 2024; inconsistent permissible investment records; late and inaccurate annual reports. Outcome: Sought: revocation, 10-year bar, restitution or escheat, $300,000 fine. Temporary order: cease Washington activity and segregate customer assets. RCW 19.230.060, .110, .170, .230, .290, .340; WAC 208-690. Source: Statement of charges (PDF).
• 20 Mar 2025. Sigue Corporation and Guillermo de la Vina (money transmitter). Final multistate order (36 states, the District of Columbia, Kentucky and Massachusetts): failed to pay transmission liabilities when due, failed to maintain net worth and permissible investments, ceased operations in January 2024. Outcome: $1,000,000 penalty ($27,778 per state), stayed for two years and waived on compliance; permanent cease and desist; licenses surrendered; de la Vina barred as a control person; cooperation with surety bond claims. State money transmission laws under the CSBS and MTRA protocol. Source: NYDFS order page and order (PDF).
• 28 Feb 2025. Plutus Financial, Abra entities and William Barhydt. Texas counterpart to the 2024 multistate Abra order: unlicensed transmission, with customer assets held through unlicensed entities including an offshore exchange. Outcome: $250,000 fine stayed for five years; customer assets converted and mailed as cashier's checks within 30 days; Barhydt a passive investor only for five years with a personal guarantee. Tex. Fin. Code 152.101, 152.406. Source: Order 2025-004 (PDF).
• 27 Jan 2025. Sigue Corporation, GroupEx Financial and Guillermo de la Vina. California final consent order: failed to pay transmission liabilities when due, fell below minimum tangible net worth and failed to hold the required eligible securities. Outcome: $300,000 penalty stayed for three years and waived on compliance; licenses surrendered; de la Vina barred; bond information sent to customers; website kept live for two years. Cal. Fin. Code 2040, 2081, 2101, 2120, 2124, 2148. Source: Final consent order (PDF).
• 28 Oct 2024. Hodan Global Money Services, Inc. (money transmitter). A 2022 examination found substantial noncompliance. The order requires customer transmittal funds to be held in federally insured client funds accounts, not commingled, segregated and reconciled, with an AML program, timely reports and complete remittance receipts. Outcome: $5,000 penalty; quarterly progress reports. M.G.L. c.169 ss.10 and 13; 209 CMR 45; 31 CFR 1022.210; 12 CFR 1005.31. Source: Consent order.
• 14 Aug 2024. Fortress Trust LLC (money transmitter). Failed to maintain minimum tangible net worth, gave no advance notice of a change in control or a main office move, and failed to record another state's suspension on NMLS. Outcome: $75,000 penalty; net worth to be met by 30 September 2024; external consultant and independent auditor. Conn. Gen. Stat. 36a-598, 36a-600(d), 36a-604(c), 36a-607. Source: Connecticut bulletin.
• 26 Jun 2024. Plutus Financial, Abra Trading, Plutus Lending and William Barhydt. Multistate working group (Arkansas, Connecticut, Georgia, Ohio, Oregon, Texas, Washington, Vermont): unlicensed transmission from March 2021 to June 2023, with some customer assets ending up on an offshore exchange through an unlicensed intermediary. Outcome: $250,000 fine stayed for five years; customer assets returned by check by 1 August 2024 (Washington: $116,001 to 706 users); five-year control bar and personal guarantee for Barhydt. RCW 19.230.030, 19.230.340. Source: Washington consent order (PDF).
• 14 Jun 2024. Evolve Bancorp and Evolve Bank and Trust (partner bank to Synapse). The Federal Reserve ordered stronger anti-money-laundering, risk management and oversight of fintech partners, including recordkeeping and consumer compliance; the Board said the order was independent of the Synapse bankruptcy. Outcome: Cease and desist; no penalty. Federal Reserve enforcement authority. Source: Federal Reserve release.
• 13 Jun 2024. Synapse Financial Technologies (Chapter 11 trustee). The trustee's second status report put about $219 million of end-user funds frozen and estimated the shortfall in the for-benefit-of accounts at $65 million to $96 million, believed to predate the petition. By the fifteenth report (6 February 2025) one partner bank had paid about $109.99 million of $110.29 million and another about $59.11 million of $62.09 million; the exact amounts and sources of the shortfall had not been established. Outcome: No regulator penalty; funds returned bank by bank; reconciliation incomplete. Chapter 11, US Bankruptcy Court, Central District of California, case 1:24-bk-10646. Source: Second status report (PDF) and fifteenth status report (PDF).
• 23 May 2024. BlockFi Trading LLC. Connecticut found that suspending customer withdrawals on 10 November 2022 was a failure to transmit money for Connecticut wallet holders, an unsafe or unsound practice, and that the surety bond had lapsed. Outcome: $150,000 penalty treated as an allowed unsecured claim in the BlockFi bankruptcy. Conn. Gen. Stat. 36a-602, 36a-608. Source: Consent order (PDF).
• 18 Apr 2024. Sigue Corporation. Illinois joined the multistate order: Sigue to stop Illinois transmission and regulators to file bond claims for 233 money orders ($45,151) and 202 transfers ($63,123) outstanding. Outcome: Cease order; records preserved. 205 ILCS 657/80. Source: IDFPR release.
• 10 Apr 2024. Texas G and S Investments, trading as Texas Money Exchange. Inaccurate general ledger, late records, miscalculated average outstanding transmission liabilities, late 2020 to 2022 annual and quarterly reports, AML gaps and breach of a 2022 order. Outcome: $250,000 in four quarterly installments; audit reporting to 2027. Tex. Fin. Code 151.202, 151.207, 151.601 to 151.603, 152.057, 152.201, 152.207, 152.403, 152.405 to 152.407; 31 CFR 1022.210. Source: Order 2024-010 (PDF).
• 15 to 22 Mar 2024. Sigue Corporation. Interim multistate consent order (41 jurisdictions) plus Washington, California and Massachusetts orders: Sigue ceased operations at the end of January 2024 with about $4.9 million of unpaid transmission liabilities in the participating states plus New York, and admitted failing to maintain net worth and permissible investments. California counted 8,232 unpaid transactions worth over $1.7 million. Outcome: Cease all transmission except to pay liabilities; license surrenders; bond-claim declarations within 10 days. State money transmission laws; Cal. Fin. Code 2037. Source: Interim consent order (PDF) and DFPI release (PDF).
• 16 and 17 Oct 2023. ACI Payments, Inc. and ACI Worldwide (payment processor and money transmitter). A test of the Speedpay platform using live mortgage servicing data sent 1,432,821 erroneous ACH entries totaling $2,389,173,559 against 478,568 borrowers' bank accounts on 23 April 2021. Outcome: $9,509,999.84 split equally across 44 state agencies (Texas: $216,136 plus $100,000 costs) plus $10 million to 50 state attorneys general; synthetic test data required for five years; monitoring committee for two years. Source: CSBS announcement, Texas order 2023-032 (PDF) and DFPI release (PDF).
• 21 and 26 Jun 2023. Prime Trust, LLC (Nevada trust company, crypto custodian). Nevada's receivership petition alleged Prime owed clients $85,670,000 in dollars and held $2,904,000, and owed $69,509,000 in crypto and held $68,648,000; from December 2021 to March 2022 it bought crypto with customer omnibus funds to cover withdrawals from inaccessible legacy wallets; the March 2023 call report showed negative $12,071,508 equity. The company stipulated to receivership and later filed for Chapter 11 in Delaware. Outcome: Receivership, then Chapter 11 (case 23-11161, District of Delaware). NRS 669.100, 669.2825, 669.2846. Source: Receivership petition (PDF).
• 5 Apr 2023. Bittrex, Inc. (crypto exchange and money transmitter). Net worth fell below the Texas minimum; the license was surrendered in lieu of revocation, accounts set to withdrawal only and abandoned assets sent to the Comptroller. Outcome: No fine; license surrendered by 7 April 2023; all Texas transmission to stop after 30 April 2023. Tex. Fin. Code 151.207, 151.208, 151.307, 151.703, 151.706. Source: Order 2023-010 (PDF).
• 16 Dec 2022. BlockFi Trading, LLC. Washington's final order after BlockFi suspended withdrawals on 10 November 2022, with about $391,968,000 of Washington residents' assets in interest accounts at the end of 2021 and a cancelled surety bond. Outcome: Final cease and desist: no new Washington business; all retail digital assets to be held in a segregated trust arrangement; bond to be maintained. No fine. RCW 19.230.050, 19.230.260, 19.230.340. Source: Final order (PDF).

Unlicensed money transmission

Payroll processors, escrow providers, crypto platforms and overseas remitters found to be transmitting money without the state license. Most settled for five-figure penalties and an application.

• 6 Oct 2026. Paycor, Inc. (payroll processor). Payroll processing in Texas since 2014 treated as unlicensed money transmission; now an authorized delegate of a licensed firm. Outcome: $275,000 penalty. Tex. Fin. Code 152.003, 152.004, 152.101, 152.406, 152.407. Source: Order 2026-020 (PDF).
• 5 Oct 2026. Set Forth, LLC (debt-relief payment processor). Payment processing for debt-relief plans found to be licensable money transmission; the model was changed to fit an exemption. Outcome: $77,729 penalty. Tex. Fin. Code 151.301, 151.302, 152.003, 152.004, 152.101, 152.406, 152.407. Source: Order 2026-019 (PDF).
• 23 Sep 2026. Triple A Technologies Pte Ltd (Singapore payment processor). Received and transmitted value for merchants without a Texas license. Outcome: $20,000 penalty; must stop unless licensed. Tex. Fin. Code 152.003, 152.101, 152.406, 152.407. Source: Order 2026-016 (PDF).
• Jul 2026. Envios de Valores La Nacional Corp. (money transmitter). Admitted violations of the New Jersey Money Transmitters Act, including record-keeping and delegate-contract rules; license surrendered 26 February 2026. Outcome: $75,000 civil penalty. N.J.S.A. 17:15C-17; N.J.A.C. 3:27-6.1. Source: Consent order (PDF).
• 11 May 2026. SeedTrust, LLC (surrogacy escrow). Surrogacy escrow found to be unlicensed money transmission. Outcome: $90,000 penalty plus $50,000 of pro bono services; license or exemption within 90 days, otherwise customer funds returned within 60 days. Tex. Fin. Code 151.301, 151.302, 152.002, 152.003, 152.101, 152.104, 152.106, 152.406, 152.407. Source: Order 2026-009 (PDF).
• 8 May 2026. Brotherhood Works, LLC (payroll processor). Transmitting payroll money since 2012 without a license; application pending. Outcome: $75,000; if the license fails, Texas customer funds returned within 60 days. Tex. Fin. Code 152.003, 152.101, 152.106, 152.401, 152.406, 152.407. Source: Order 2026-008 (PDF).
• 2 Apr 2026. M and M Tech Solutions Corp.. Massachusetts cease directive for unlicensed money transmission. Outcome: Cease directive; no penalty stated. M.G.L. c.169. Source: Division of Banks bulletin (PDF).
• 30 Mar 2026. INX Digital, Inc. (licensed money transmitter). Closed an acquisition of control on 10 November 2025 without the Commissioner's approval and ignored information requests. Outcome: $25,000. Tex. Fin. Code 152.151, 152.406, 152.407. Source: Order 2026-004 (PDF).
• 24 Feb 2026. GPD Holdings LLC, trading as CoinFlip (crypto kiosk operator). Sold stablecoin to Texans through an unlicensed affiliate from February 2024 to October 2025, repeating conduct covered by a 2023 order. Outcome: $40,840; license required. Tex. Fin. Code 152.003, 152.101, 152.406, 152.407. Source: Order 2026-001 (PDF).
• 10 Dec 2025. Paylocity Corporation (payroll processor). Payroll funds received and distributed without a license. Outcome: $318,750; application within 60 days, otherwise Texas customer funds returned within 60 days. Tex. Fin. Code 151.301, 151.302, 151.702, 151.706, 151.707, 152.003, 152.101, 152.406, 152.407. Source: Order 2025-026 (PDF).
• 22 Oct 2025. TranZlanta Financial Services, LLC (remitter). A Washington-licensed remitter sent California consumers' money to The Gambia from 2019 to 2022 without a California license. Outcome: Cease and desist; no fine. Cal. Fin. Code 567, 2003, 2030. Source: Order (PDF).
• 25 Jul 2025. Coinbase Custody Trust Company, LLC. Operated in Connecticut without a money transmission license since at least 2019. Outcome: $30,000 penalty plus $5,250 back license fees. Conn. Gen. Stat. 36a-597(a). Source: Connecticut bulletin.
• 4 Apr 2025. EzyRemit Worldwide Inc. (remitter). Advertised and offered remittances to Vietnam to a California resident without a license. Outcome: Cease and desist; no fine. Cal. Fin. Code 567, 2003, 2030. Source: Order (PDF).
• 18 Sep 2024. Afriex Inc. and Wallets Africa, Inc. (remitters). Unlicensed money transmission from California to Nigeria. Outcome: Cease and desist orders; no fines. Cal. Fin. Code 567, 2003, 2030. Source: Afriex order (PDF) and Wallets Africa order (PDF).
• 7 Aug 2024. Binance Holdings Ltd and Changpeng Zhao. Unlicensed money transmission for Washington residents from July 2017 to July 2023. Outcome: $220,770 fine plus fees; five-year industry and licensing bar. RCW 19.230.030, .130, .250, .290, .340. Source: Consent order (PDF).
• 10 Jul 2024. Kalbas, Inc., trading as Unbank (crypto kiosk operator). Transmitted a consumer's funds to third parties without a license since 2019. Outcome: $50,000 penalty plus $6,375 back fees and restitution. Conn. Gen. Stat. 36a-597(a), 36a-608(c). Source: Consent order (PDF).
• 21 Jun 2024. ATM Ops Inc, trading as Bitstop (crypto kiosk operator). Unlicensed kiosk transmission from May to September 2023. Outcome: $10,000 penalty. Conn. Gen. Stat. 36a-597(a). Source: Consent order (PDF).
• 17 Apr 2024. Treasury Vault, LLC and Roger and Angela Dorman. Unlicensed money transmission or currency exchange from October 2019 despite a 2016 order. Outcome: $30,000 fine plus fees. RCW 19.230.030, 19.230.080. Source: Consent order (PDF).
• 3 Oct 2023. LSGT Services LLC, trading as Coinhub (crypto kiosk operator). Unlicensed kiosk transmission from September 2022; two consumers' funds sent to third parties. Outcome: $50,000 penalty plus $3,000 back fees, restitution and a $50,000 consumer scam fund. Conn. Gen. Stat. 36a-597(a), 36a-608(c). Source: Consent order (PDF).
• 26 Aug 2023. Genesis Global Capital, LLC (crypto lender). Borrowed and lent dollars and stablecoin for Texans without a license until 16 November 2022; in Chapter 11. Outcome: Cease and desist; customer notice within seven days; restitution and penalties reserved. Tex. Fin. Code 151.301, 151.302, 151.701, 151.706, 151.707. Source: Order 2023-024 (PDF).
• 4 May 2023. SandP Solutions LLC, trading as Bitcoin of America (crypto kiosk operator). Unlicensed kiosk transmission since 2021; four consumers' funds sent to third parties. Outcome: Restitution to the listed consumers; no penalty because of the wind-down; uncashed checks convert to a penalty. Conn. Gen. Stat. 36a-597(a), 36a-608. Source: Consent order (PDF).
• 29 Mar 2023. Nexo Capital, Inc., Kosta Kantchev and Antoni Trenchev. Unlicensed wallets, exchange and loans to Washington residents from April 2018 to June 2022 (about $306 million of deposits) and misleading licensing claims. Outcome: Cease and desist; five-year industry bar; monetary claims resolved through the NASAA term sheet. RCW 19.230.030, 19.230.340. Source: Consent order (PDF).
• 23 Jan 2023. Viventium HCM, LLC (payroll processor). Unlicensed payroll money transmission since 2019. Outcome: $10,000 plus $3,375 back fees. Conn. Gen. Stat. 36a-597(a). Source: Consent order (PDF).
• 14 Jan 2023. Paxful USA, Inc. (crypto marketplace). Held and transmitted customers' stablecoin in 2020 and 2021 without a license; stablecoin treated as monetary value. Outcome: $16,350; Texas accounts set to withdrawal only; customer letters. Tex. Fin. Code 151.301, 151.302, 151.702, 151.706, 151.707. Source: Order 2023-002 (PDF).
• 1 Dec 2022. West Realm Shires Services, trading as FTX US. Custodial and transmission services for dollars and stablecoin without a license since 2020; in Chapter 11 in Delaware. Outcome: Cease and desist; order posted on the bankruptcy site; penalty reserved. Tex. Fin. Code 151.301, 151.302, 151.701, 151.702, 151.706, 151.707. Source: Order 2022-034 (PDF).
• 14 Oct 2022, 12 Sep 2022, 31 Aug 2022 and 25 Apr 2022. Blockchain.com, PrimePay, Payward Ventures (Kraken) and Kronos SaaShr. Each operated in Connecticut without a money transmission license (since 2020, 2020, 2019 and 2018 respectively). Outcome: $10,000 penalty plus $3,375 back fees in each case. Conn. Gen. Stat. 36a-597(a). Source: Blockchain.com (PDF), PrimePay (PDF), Kraken (PDF) and Kronos (PDF).

Consumer remittance and payment rules (CFPB)

The Remittance Transfer Rule (Regulation E, subpart B) governs disclosures, timing, error resolution and refunds for consumer transfers abroad. The CFPB's enforcement of it peaked in January 2025 and has since narrowed.

• 15 May 2025. Wise US, Inc.. Amended consent order superseding the January 2025 order. Outcome: Penalty reduced to $44,955; about $450,000 of redress retained. EFTA; 12 CFR 1005 subpart B; 12 CFR 1005.18. Source: CFPB action page.
• 8 Apr 2025. MoneyGram International and MoneyGram Payment Systems. The CFPB withdrew as plaintiff from the 2022 suit (with the New York Attorney General) alleging delayed availability of funds, failed error investigations and record-keeping failures under the Remittance Rule. Outcome: CFPB withdrawal; the New York Attorney General continued the case alone. EFTA; 12 CFR 1005 subpart B. Source: CFPB case page.
• 30 Jan 2025. Wise US, Inc.. Deceptive ATM fee marketing, prepaid account disclosure failures, Remittance Rule disclosure errors and late fee refunds. Outcome: $2,025,000 penalty plus about $450,000 of redress (later amended, above). CFPA; 12 CFR 1005.18; 12 CFR 1005 subpart B. Source: Consent order (PDF).
• 16 Jan 2025. Block, Inc. (Cash App). No live phone support from 2016 to February 2021; unauthorized-transfer investigations refused or delayed; consumers pushed to bank chargebacks. Outcome: $55,000,000 penalty; $75,000,000 to $120,000,000 of redress; 24-hour live support. 12 CFR 1005.6, 1005.7, 1005.11, 1005.13, 1005.18; 15 USC 1693f; 12 USC 5531, 5536. Source: Consent order (PDF).
• 17 Oct 2023. Chime Inc., trading as Sendwave. Advertised instant, no-fee transfers that were neither; waived consumers' rights in its agreements; late receipts and error-resolution and disclosure failures. Outcome: $1,500,000 penalty plus about $1,500,000 of redress. CFPA; EFTA; 12 CFR 1005 subpart B. Source: CFPB action page.
• 22 Dec 2022. Servicio UniTeller, Inc.. No written error-resolution procedures, no compliance records, inadequate disclosures and refused fee refunds. Outcome: $700,000 penalty plus about $30,000 of redress. EFTA; 12 CFR 1005 subpart B; CFPA. Source: CFPB action page.
• 4 Oct 2022. Choice Money Transfer, Inc., trading as Small World. Inaccurate and mislabeled disclosures in type smaller than the rule allows, no fee refunds on late delivery, English-only failures and no error-resolution policies. Outcome: $950,000 penalty. 12 CFR 1005.30 to 1005.36; EFTA; CFPA. Source: CFPB action page.

Anti-money-laundering and sanctions penalties

The largest figures in US money transmitter enforcement. They are not customer-fund cases, but the orders set the compliance standard every licensee is examined against.

• 7 Aug 2025. Paxos Trust Company, LLC (New York limited purpose trust company). Failed to vet its stablecoin partner, weak know-your-customer checks and retrospective transaction monitoring; about $1.6 billion of partner flows linked to illicit actors. Outcome: $26,500,000 penalty plus a minimum $22,000,000 compliance spend from 2025 to 2027. 3 NYCRR 116.2; 23 NYCRR 504.3; Banking Law 39, 44. Source: NYDFS consent order.
• 9 Jul 2025. Wise US, Inc.. A multistate examination (July 2022 to September 2023) found no independent AML review, late suspicious activity reports, transaction-monitoring data failures, unremediated prior findings and Remittance Transfer Rule violations. Outcome: $4,200,000 split across California, Massachusetts, Minnesota, Nebraska, New York and Texas; closed-account SAR look-back; quarterly reports for two years. 31 CFR 1022.210, 1022.320; CFPB Remittance Rule; state laws. Source: NYDFS consent order and DFPI consent order (PDF).
• 10 Apr 2025. Block, Inc. (Cash App). The alert backlog grew from about 18,000 in 2018 to over 169,000 in 2020; suspicious activity reports were filed an average of 129 days after the alert; weak sanctions thresholds; 8,359 accounts tied to a Russian criminal network; receipts lacked refund and liability statements. Outcome: $40,000,000; independent monitor for 12 months. Banking Law 39, 44; 3 NYCRR 417.2, 406.3; 23 NYCRR 200 and 500; 31 CFR 1022.210. Source: NYDFS consent order.
• 15 Jan 2025. Block, Inc. (Cash App). Multistate settlement by 47 states and the District of Columbia through the CSBS for Bank Secrecy Act and AML program failures (customer due diligence, identity verification, suspicious activity reporting, high-risk account controls). Outcome: $79,075,000 penalty plus $925,000 costs; independent consultant; report within nine months; fixes within 12 months. Source: CSBS announcement, DFPI release and Washington order (PDF).
• 9 Dec 2025. Paxful, Inc. and Paxful USA, Inc.. Operated as an unregistered money services business for 974 days, had no effective AML program and filed late reports on ransomware, child exploitation and sanctioned-actor activity between 2015 and 2023. Outcome: $3,500,000 civil money penalty, $1,750,000 credited to a Department of Justice resolution. 31 CFR 1022.210, 1022.320, 1022.380; 31 USC 5318, 5330. Source: FinCEN consent order (PDF).
• 31 Jan 2024. Gyanendra Kumar Asre (DDH Group LLC). Ran an unregistered money services business moving bulk cash and checks from Mexican banks through a credit union, with no AML program and no suspicious activity reports on about $940 million. Outcome: $100,000 penalty; five-year bar from US financial institutions. 31 CFR 1020.210, 1020.320, 1022.380; 31 USC 5318, 5330. Source: FinCEN consent order (PDF).
• 21 Nov 2023. Binance Holdings Ltd and affiliates. An unregistered money services business serving US customers from July 2017 to July 2023, with no effective AML program and no suspicious activity reports; the largest settlement in US Treasury history. Outcome: $3.4 billion civil money penalty and a five-year monitorship. 31 CFR 1022.210, 1022.320, 1022.380. Source: FinCEN release and consent order (PDF).
• 2 Nov 2023. Payoneer, Inc.. 2,220 payments totaling $793,951 between 2013 and 2018 to sanctioned jurisdictions and sanctions-list matches; weak screening and automatic release of flagged payments. Outcome: $1,250,000. Banking Law 44; 3 NYCRR 417.2. Source: NYDFS consent order.
• 4 Jan 2023. Coinbase, Inc. (New York money transmitter and BitLicense holder). Over 100,000 unreviewed monitoring alerts and a 14,000-case due diligence backlog by the end of 2021; late suspicious activity reports; a $150 million corporate fraud undetected for six days; a cyber incident reported five months late. Outcome: $50,000,000 penalty plus $50,000,000 of compliance investment; monitor extended by 12 months. Banking Law 44; 3 NYCRR 417.2; 23 NYCRR 200.15, 504.3, 500.17. Source: NYDFS consent order.
• 11 Oct 2022. Bittrex, Inc.. No effective AML program from 2014 to 2018, manual review of tens of thousands of daily trades, transactions tied to sanctioned countries and darknet markets, late suspicious activity reports. Outcome: $29,280,829 penalty, of which $24,280,829 credited against the OFAC settlement. 31 CFR 1022.210, 1022.320. Source: FinCEN consent order (PDF).
• 1 Aug 2022. Robinhood Crypto, LLC (New York money transmitter and BitLicense holder). Manual transaction monitoring with a 4,378-alert backlog in October 2020; improper 2019 certifications; cybersecurity and business continuity gaps; no complaint phone number. Outcome: $30,000,000; independent consultant for 18 months. 3 NYCRR 417.2; 23 NYCRR 200, 504, 500; Banking Law 39, 44. Source: NYDFS consent order.

Charges pending

Statements of charges are allegations; the outcome is decided at hearing or by consent order and will be moved into the sections above when final.

• 3 Sep 2026. GPD Holdings LLC, trading as CoinFlip, and Benjamin Weiss. Washington alleges AML failures, a six to nine month alert backlog, late currency transaction reports, missing disclosures and refunds, with over half of Washington business from seniors. Outcome: Sought: license revocation, industry bar, refunds and a $1,029,600 fine. Washington Uniform Money Services Act. Source: DFI release.
• 11 Jun 2026. Bitcoin Depot Operating, LLC and Brandon Mintz. Washington alleges no suspicious activity monitoring, know-your-customer failures and missing fee disclosures in over 30,000 transactions, with markups up to 42%. Outcome: Sought: revocation, industry bar and a $1,500,000 fine against Mintz. Washington Uniform Money Services Act. Source: DFI release.

What the pattern shows

Two systems of enforcement run side by side. The anti-money-laundering system produces the headline numbers and the monitors. The customer-funds system produces the failures: a transmitter that stops paying out (Sigue), a custodian that spends omnibus money to cover a wallet it cannot open (Prime Trust), a middleware company whose records cannot say which bank holds whose money (Synapse), a kiosk operator that counts unredeemed vouchers as revenue (Coinme). In each case the regulator found out when customers stopped being paid, and the remedy was a bond claim, a receivership or a bankruptcy court.

The response since 2024 has been direct orders to segregate and reconcile: Hodan (insured, segregated, reconciled client accounts), Coinme (segregation within 14 days), Bitcoin Depot (within seven days), BlockFi (a segregated trust arrangement), and the net worth and permissible investment tests enforced to the point of license surrender. For a licensee operating in several states, the practical requirement is now a daily reconciliation of outstanding transmission liabilities against permissible investments, by state, with the evidence ready for the examiner. See the permissible investments guide and the FBO account reconciliation guide.

Safeheld reconciles customer money every business day for regulated firms, works every difference to its cause and keeps the record examiners ask for, including outstanding transmission liabilities against permissible investments for US money transmitters. If your firm is licensed in one state or forty, talk to us about money transmitter reconciliation.

Frequently asked questions

What is the largest penalty against a US money transmitter?

FinCEN's $3.4 billion civil money penalty against Binance in November 2023, with a five-year monitorship, for operating as an unregistered money services business without an effective anti-money-laundering program. The largest state-led penalty is the $80 million multistate settlement with Block (Cash App) in January 2025.

Which money transmitter failures left customers short?

Sigue Corporation stopped operating in January 2024 owing about $4.9 million of unpaid transfers; Prime Trust was found in June 2023 to owe clients $85.7 million in dollars while holding $2.9 million; the Synapse bankruptcy left an estimated $65 million to $96 million shortfall in end-user accounts, which the trustee has not been able to fully reconcile.

What happens when a money transmitter falls below the required net worth?

Recent orders show license surrender or suspension: Bittrex surrendered its Texas license in 2023, CoinZoom its Washington license in 2026, Fortress Trust was fined $75,000 in Connecticut in 2024 and ordered to meet the requirement, and Bitcoin Depot's Connecticut license was summarily suspended in March 2026.

Are payroll companies money transmitters?

Several states say yes when the payroll company receives and holds the employer's funds before paying employees. Texas fined Paycor $275,000 and Paylocity $318,750; Connecticut fined Viventium, PrimePay and Kronos; Brotherhood Works was given 60 days to return Texas customer funds if its application failed.

What is the CFPB Remittance Rule and who has been fined under it?

Regulation E subpart B sets the disclosures, timing, error resolution and refund rules for consumer transfers abroad. Fines since 2022: Block $55 million (2025), Sendwave $1.5 million (2023), Small World $950,000 (2022), UniTeller $700,000 (2022) and Wise, whose $2 million penalty was cut to $44,955 in May 2025.

How do multistate money transmitter settlements work?

State regulators coordinate through the Conference of State Bank Supervisors and the Money Transmitter Regulators Association: one examination, one consent order signed by each participating state, and a penalty split between them. Block (48 jurisdictions), Wise (six), ACI Payments (44), Sigue (41) and Coinme (34) were handled this way.

How often is this tracker updated?

It is reviewed whenever a state regulator, FinCEN or the CFPB publishes an order against a money transmitter or money services business, and the review date at the top of the page is updated each time.

References

• NYDFS, consent order: Sigue Corporation, 20 March 2025
• Nevada Financial Institutions Division, petition to place Prime Trust in receivership, June 2023
• Chapter 11 trustee, Synapse Financial Technologies, second status report, 13 June 2024
• Washington DFI, statement of charges: Coinme, 25 November 2025
• CSBS, Block multistate settlement, 15 January 2025
• FinCEN, Binance settlement release, 21 November 2023
• Texas Department of Banking, enforcement orders index

About Safeheld

Safeheld reconciles client money every day, resolves every difference and prepares every regulatory return for sign-off, for regulated firms in the United States, the United Kingdom, the European Union, Canada, Australia, Singapore and Hong Kong. To discuss your operations, contact us at safeheld.com/contact.

This tracker is compiled from public primary sources for general information and does not constitute legal or regulatory advice. Figures are as stated in the source documents and may be revised by the courts, the administrators or the FCA.