Imposition of Special Measure Regarding Huione Group, as a Foreign Financial Institution of Primary Money Laundering Concern

<RULE> DEPARTMENT OF THE TREASURY <SUBAGY>Financial Crimes Enforcement Network</SUBAGY> <CFR>31 CFR Part 1010</CFR> <RIN>RIN 1506-AB68</RIN> <SUBJECT>Imposition of Special Measure Regarding Huione Group, as a Foreign Financial Institution of Primary Money Laundering Concern</SUBJECT> <HD SOURCE="HED">AGENCY:</HD> Financial Crimes Enforcement Network (FinCEN), Treasury. <HD SOURCE="HED">ACTION:</HD> Final rule. <SUM> <HD SOURCE="HED">SUMMARY:</HD> FinCEN is issuing this final rule to prohibit covered U.S. financial institutions from opening or maintaining a correspondent account for, or on behalf of Huione Group, a foreign financial institution based in Cambodia found to be of primary money laundering concern pursuant to section 311 of the USA PATRIOT Act. The rule further requires covered financial institutions to apply special due diligence to their foreign correspondent accounts that is reasonably designed to guard against the use of such accounts to process transactions involving Huione Group. </SUM> <EFFDATE> <HD SOURCE="HED">DATES:</HD> This final rule is effective November 17, 2025. </EFFDATE> <FURINF> <HD SOURCE="HED">FOR FURTHER INFORMATION CONTACT:</HD> FinCEN's Regulatory Support Section at <E T="03">www.fincen.gov/contact.</E> </FURINF> <SUPLINF> <HD SOURCE="HED">SUPPLEMENTARY INFORMATION:</HD> <HD SOURCE="HD1">I. Background</HD> <HD SOURCE="HD2">A. Statutory Provisions</HD> 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.”  <SU>1</SU> <FTREF/> <FTNT> <SU>1</SU>  31 U.S.C. 5318A(a)(1). </FTNT> Upon making such a finding, the Secretary is authorized to require domestic financial institutions and domestic financial agencies to take certain “special measures.”  <SU>2</SU> <FTREF/> 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 institutions.”  <SU>3</SU> <FTREF/> 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. <SU>4</SU> <FTREF/> <FTNT> <SU>2</SU>  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. </FTNT> <FTNT> <SU>3</SU>  31 U.S.C. 5318A(b)(1)-(4). The term “covered financial institution” has the same meaning as provided at 31 CFR 1010.605(e)(1); <E T="03">see infra</E> section IV.A.3. </FTNT> <FTNT> <SU>4</SU>  31 U.S.C. 5318A(b)(5). </FTNT> Before making a finding that reasonable grounds exist for concluding that a financial institution 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. <SU>5</SU> <FTREF/> 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 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: <FTNT> <SU>5</SU>  31 U.S.C. 5318A(c)(1). </FTNT> • 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. <SU>6</SU> <FTREF/> <FTNT> <SU>6</SU>  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. <E T="03">See</E> 31 U.S.C. 5318A(c)(2)(A)(i)-(vii). </FTNT> 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.”  <SU>7</SU> <FTREF/> 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.”  <SU>8</SU> <FTREF/> In addition, the Secretary is required to consider the following factors: <FTNT> <SU>7</SU>  31 U.S.C. 5318A(a)(4)(A). </FTNT> <FTNT> <SU>8</SU>  31 U.S.C. 5318A(b)(5). </FTNT> • 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. <SU>9</SU> <FTREF/> <FTNT> <SU>9</SU>  31 U.S.C. 5318A(a)(4)(B)(i)-(iv). </FTNT> 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. <SU>10</SU> <FTREF/> <FTNT> <SU>10</SU>   <E T="03">See</E> Treasury Order 180-01 (Jan. 14, 2020). </FTNT> <HD SOURCE="HD2">B. Huione Group</HD> Huione Group  <SU>11</SU> <FTREF/> is a financial services conglomerate based in Phnom Penh, Cambodia. <SU>12</SU> <FTREF/> 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 (the “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 Components operate as a coordinated collective, and for that reason, FinCEN will correspondingly refer to Huione Group and its Components as the “Huione Group.” <FTNT> <SU>11</SU>  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.” </FTNT> <FTNT> <SU>12</SU>  Cambodia Corporate Registry, “ <E T="03">Huione” Search,</E> <E T="03">https://www.businessregistration.moc.gov.kh/cambodia-master/service/create.html?targetAppCode=cambodia-master&targetRegisterAppCode=cambodia-br-companies&service=registerItemSearch</E> (last accessed Oct. 7, 2025); Huione Pay, <E T="03">Index, formerly available at</E> <E T="03">https://www.huionepay.com.kh/index/help;</E> Huione Gro ━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━ Preview showing 10k of 143k characters. Full document text is stored and available for version comparison. ━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━