Huione Group Section 311 Money Laundering Designation

Current understanding

FinCEN has designated Huione Group as a foreign financial institution of primary money laundering concern under Section 311 of the USA PATRIOT Act, with an associated special measure restricting U.S. financial institutions from opening or maintaining correspondent accounts involving Huione. A proposed amendment would expand the designation to cover subsidiary H-Pay Service PLC and add a ‘successor entity’ definition to prevent evasion via corporate restructuring, while leaving the underlying special measure unchanged.

Evidence log

• 2026-10-06 — Proposal of Special Measure Regarding Convertible Virtual Currency Mixing, as a Class of Transactions of Primary Money Laundering Concern; Withdrawal: cross-connection with fincen-crypto-mixing-section-311: Both are FinCEN Section 311 actions targeting crypto-adjacent money laundering risks, but the withdrawal of the class-wide mixing rule leaves entity-specific designations like Huione Group as the primary Section 311 tool against crypto-related illicit finance. (novelty: 3)
• 2026-09-01 — Proposal of Special Measure Regarding Banque Misr UAE as a Financial Institution Operating Outside of the United States of Primary Money Laundering Concern: cross-connection with fincen-banque-misr-uae-section-311: Both are Section 311 special measures targeting specific foreign financial institutions as primary money-laundering concerns and cutting them off from U.S. correspondent banking. (novelty: 3)
• 2026-06-24 — Permitted Payment Stablecoin Issuer Anti-Money Laundering/Countering the Financing of Terrorism and Sanctions Compliance Risk Management: cross-connection with payment-stablecoin-issuer-aml-sanctions: Both reflect FinCEN’s expanding AML perimeter over crypto-adjacent payment rails — one via issuer-level BSA obligations, the other via Section 311 special measures against foreign networks. (novelty: 4)

Open questions

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