What the records show
State order Executive Committee → Mandated independent AML consultant
receives reports and may inspect workpapers
Order effective 15 January 2025; conditional clocks and written changes. Performance, payment and extensions unverified.
Reports go contemporaneously to Block and committee; committee may request workpapers/work product and ask specified questions. It also receives CAP/company reporting and can request Board Reports. Receipt/inspection rights do not establish state appointment of consultant or formal CAP approval.
Participating state money-transmission regulators → State order Executive Committee
act through specified Executive Committee
Order effective 15 January 2025; conditional clocks and written changes. Performance, payment and extensions unverified.
Initial committee comprises Arkansas, California, Massachusetts, Texas and Washington representatives. It is not the eight examining states, seven enforcement leads or every participating regulator; representation may be replaced under the order.
State order Executive Committee → Required AML Corrective Action Plan
may extend reporting deadlines on good cause
Order effective 15 January 2025; conditional clocks and written changes. Performance, payment and extensions unverified.
II.D.9 allows reporting extensions on reasonable-ground request/good cause. CAP-duration extension instead has consultant review/documentation under II.D.2(c). No actual extension or unconditional state veto over every plan established.
Read the original source 1
What the connections say
3 relationships1Participating state money-transmission regulators → act through specified Executive Committee → State order Executive Committee
Order effective 15 January 2025; conditional clocks and written changes. Performance, payment and extensions unverified.
Initial committee comprises Arkansas, California, Massachusetts, Texas and Washington representatives. It is not the eight examining states, seven enforcement leads or every participating regulator; representation may be replaced under the order.
Read the original source 1
State order Executive Committee → receives reports and may inspect workpapers → Mandated independent AML consultant
Order effective 15 January 2025; conditional clocks and written changes. Performance, payment and extensions unverified.
Reports go contemporaneously to Block and committee; committee may request workpapers/work product and ask specified questions. It also receives CAP/company reporting and can request Board Reports. Receipt/inspection rights do not establish state appointment of consultant or formal CAP approval.
Read the original source 1
State order Executive Committee → may extend reporting deadlines on good cause → Required AML Corrective Action Plan
Order effective 15 January 2025; conditional clocks and written changes. Performance, payment and extensions unverified.
II.D.9 allows reporting extensions on reasonable-ground request/good cause. CAP-duration extension instead has consultant review/documentation under II.D.2(c). No actual extension or unconditional state veto over every plan established.
Read the original source 1