Definition of Huione Group, a Financial Institution Operating Outside the United States of Primary Money Laundering Concern
Key claim: FinCEN proposes to expand the existing Huione Group money laundering designation under Section 311 of the USA PATRIOT Act to include H-Pay Service PLC and introduce a ‘successor entity’ definition, while leaving the existing special measure in place.
Abstract
(Proposed Rule · Treasury Department, Financial Crimes Enforcement Network) 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.
Why this matters
Section 311 designations are a core Treasury tool for cutting foreign financial institutions off from the U.S. financial system on national security grounds, and expansions to cover subsidiaries and successor entities close a well-known evasion pathway. The proposed amendment signals FinCEN’s intent to keep pace with restructuring by designated illicit-finance networks without reopening the underlying primary-concern determination.