title: United States – New Hampshire Payments Regulation Monitor | World Payments Monitor canonical: https://payments.gi/jurisdictions/united-states-new-hampshire/ date_modified: 2026-10-21 publisher: Asymmetric Intelligence # United States – New Hampshire US-NH schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-21 · 14 modules · 63 sourced findings · 136 sources in the cumulative register 14 Modules baseline.modules[] 63 Findings modules[].findings[] 39 Tier-1 sources run_metadata.t1_source_count Confidence mix (sums to 14 rendered modules; click to filter) No modules moved this cycle. ** United States federal law** that applies in United States – New Hampshire is covered once, on the [United States](https://payments.gi/jurisdictions/united-states/) page. This page covers United States – New Hampshire’s own layer: its own law, regulators and enforcement. ## Jurisdiction brief ###### Latest update · 4 October 2026 #### Lead Signal New Hampshire's money-transmitter reporting regime under RSA 399-G changed effective 1 October 2026, through 2026 session law chapter 294. RSA 399-G:15(II)(d), which required reporting of average daily outstanding transmission liability, was repealed, while RSA 399-G:18(III) now requires a licensee or applicant to file a correcting amendment within 30 days of discovering inaccurate or incomplete filed information. Both changes are administrative adjustments to the content and accuracy standard of ongoing regulatory reporting rather than a change to money-transmitter licensure eligibility or the licensing route itself. #### Other Developments **Likely legislative vehicle identified but not confirmed.** HB1207, a 2026-session bill requested by the NH Banking Department, raises licence application and renewal fees for money-transmitter and other consumer-credit licensees and carries further RSA 399-G reporting amendments. It is the probable vehicle for the chapter-294 amendments, but this chapter-to-bill mapping has not been independently confirmed against the enrolled act text, so the fee-increase dimension should be treated as not yet verified. #### Cross-Monitor Connections No cross-monitor signal was identified this period arising from the W1a development. #### Outlook The substantive 2024 HB1241 licensing-modernisation framework remains the governing structure for New Hampshire money-transmitter licensure; the chapter-294 amendments are reporting-content adjustments layered onto that framework rather than a replacement of it. Confirming the enrolled-act chapter-to-bill mapping, and resolving whether HB1207's fee increases were in fact enacted alongside the reporting changes, are the key open items for market participants tracking the practical compliance burden of maintaining an NH money-transmitter licence going forward. _2 earlier updates not shown here._ ###### Standing brief · as of 7 July 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Lead Signal New Hampshire's first full-spectrum baseline under the World Payments Monitor reveals a jurisdiction of contradictions: a modernized, actively-enforced money-transmission licensing regime sits alongside a genuinely unresolved crypto-legislative status. RSA 399-G governs money transmission in NH, administered by the Banking Department (Bank Commissioner) via NMLS, with licensees examined at least every 24 months; HB 1241, signed Aug 23 2024 and effective Oct 22 2024, reenacted the chapter, modernizing control-acquisition, key-individual, and multistate-licensing provisions. That modernization has not translated into laxity: a February 2026 NH Banking Department consent order found RAM Payment, LLC provided third-party account-management and payment-processing services for debt-resolution consumers in NH prior to obtaining its money-transmitter license, violating RSA 399-G:2, I, while a December 2025 consent order against River Financial Inc., an Ohio-based Bitcoin ATM operator, confirms that Bitcoin-cash exchange activity crossing into fiat requires an NH money-transmitter license notwithstanding the crypto-only carve-out. The more consequential story concerns HB 639, the so-called 'Blockchain Basic Law.' Trade press reporting from July 2-4, 2026 describes it as 'published,' 'registered,' or 'enrolled' July 1 2026, but official legislative tracking shows the NH Senate referred the bill to interim study on January 7, 2026, by a 4-2 vote. The bill's enactment status is genuinely unresolved as of this cycle; it should not be treated as current law. New Hampshire's operative crypto-payments framework remains the 2017 RSA 399-G:3, VII exemption: persons selling or issuing payment instruments or stored value solely in convertible virtual currency, or receiving convertible virtual currency for transmission, are exempt from NH money-transmitter licensure but remain subject to RSA 358-A consumer-protection law. #### Other Developments New Hampshire's community-banking sector shows two simultaneous structural shifts. Six NH-headquartered depository institutions -- Claremont Savings Bank, First Seacoast Bank, Meredith Village Savings Bank, Merrimack County Savings Bank, Savings Bank of Walpole, and Service Credit Union -- are FedNow participants, part of 1,400+ national participants two years post-launch. Simultaneously, Metro Credit Union, serving members across five NH counties, announced an April 2026 intent to merge with Massachusetts-based Members Plus Credit Union, illustrating the MA-NH retail-payments corridor amid a national wave of credit-union consolidation: NCUA approved 41 credit-union mergers with combined assets of $34 billion in Q3 2025 alone, exceeding 2022-2024 combined. Portsmouth, NH-headquartered Bottomline Technologies, a Thoma Bravo portfolio company since 2022 serving 1,200+ financial institutions and moving $16T+ payments annually, continued a steady product cadence: it launched Payments Fraud Defense, an AI-driven fraud platform aligned with Nacha's 2026 fraud-monitoring rules, on January 8, 2026, and introduced a Paymode for Digital Banking enhancement on March 31, 2026 to help banks identify check-heavy business customers and migrate them to Premium ACH. On the merchant-payments side, NH is the only New England state allowing unrestricted credit-card surcharging, unlike Massachusetts, Maine and Connecticut which ban surcharging entirely; NH HB1319 (a 1% interchange cap proposal) and HB682 were introduced but did not become law, leaving the national Visa/Mastercard interchange class settlement -- a 0.1pp posted-rate cut and a 1.25% eight-year cap that merchant groups continue to contest as inadequate -- as the operative ceiling for NH merchants. A 2025 ransomware attack on vendor Marquis Software Solutions, exploiting a SonicWall VPN vulnerability, compromised data at 70+ financial institutions and roughly 400,000 consumers nationally, with affected NH credit unions notifying the NH Attorney General under RSA 359-C, which requires notification to the Attorney General if even one NH resident is affected. New Hampshire's consumer-protection architecture layers state and federal authority: the NH Department of Justice's Consumer Protection & Antitrust Bureau enforces state and federal unfair-and-deceptive-practices laws and investigates and prosecutes the most serious cases of elder abuse and financial exploitation, running sustained 2025-2026 scam-prevention and AI-fraud-awareness campaigns, while the Banking Department separately warns that PayPal, Venmo, Cash App and other non-bank payment apps are not protected by federal deposit insurance. RSA 358-A further empowers consumers with private lawsuits for actual or minimum $1,000 damages, treble damages for willful violations, plus attorney's fees, supplementing federal FTC Act enforcement. On settlement infrastructure, NH community banks and credit unions predominantly access Federal Reserve rails, including FedNow, through correspondent relationships with bankers' banks or corporate credit unions rather than holding direct master accounts for every rail. #### Cross-Monitor Connections NH's existing convertible-virtual-currency money-transmission exemption and the pending, contested HB639 self-custody and node/mining protections reduce state-level licensing touchpoints for crypto-fiat conversion, with potential illicit-finance and AML oversight-gap implications that sit outside WPM scope but merit a flag to the Financial Integrity Monitor. Separately, this cycle's Sentinel.gi-branded payments-context feed returned no accessible content for US-NH; the only illicit-finance-adjacent context carried forward is the statutory BSA/AML hooks in RSA 399-G itself -- RSA 399-G:19 requires licensees to file written BSA compliance plans, and RSA 399-G:15 sits as a dedicated Money Laundering Reports provision -- carried as context only, not a Sentinel finding. #### Outlook New Hampshire's regulatory direction is best described as fragmenting: enforcement against unlicensed money transmission is intensifying even as the state's crypto-legislative posture remains unresolved. Watch the HB 639 interim-study process into 2026-Q3 for clarity on whether the bill's blockchain-rights provisions ultimately take effect, and watch the Chicago merchant damages trial against Visa and Mastercard, also expected in 2026-Q3, for signals on how the interchange settlement dispute will affect NH merchants downstream. The credit-union consolidation wave and FedNow adoption pattern both point toward continued corridor integration with Massachusetts and the wider New England market through the remainder of 2026. trust tier: ai_unverified ###### Latest update · 4 October 2026 #### Regulatory Status New Hampshire's money-transmitter licensing framework, governed by RSA 399-G as substantively modernised by 2024's HB1241, saw an administrative reporting update effective 1 October 2026 under 2026 session law chapter 294. RSA 399-G:15(II)(d)'s average-daily-outstanding-transmission-liability reporting requirement was repealed, and RSA 399-G:18(III) now requires licensees and applicants to file a correcting amendment within 30 days of discovering inaccurate or incomplete filed information. HB1207, a Banking Department-requested bill also raising licence application and renewal fees, is the probable but not independently confirmed vehicle for these amendments. #### Outlook Confirmation of the HB1207-to-chapter-294 mapping, and whether its fee increases were enacted, are the key items to watch for New Hampshire money-transmitter licensees and applicants. _1 earlier update not shown here._ ###### Standing brief · as of 7 July 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Regulatory Status New Hampshire's payments regulatory architecture centers on RSA 399-G, the money-transmission licensing statute administered by the state Banking Department via NMLS, reenacted through HB 1241 (effective October 22, 2024). The regime draws a clear bank/nonbank line: bank, trust, savings-and-loan, credit-union, thrift and insurance charterees, plus government agencies, are exempt from licensure, while nonbank licensees must maintain net worth, a surety bond (greater of $100,000 or 100% of trailing three-month average daily transmission liability, capped at $500,000), and permissible investments under RSA 399-G:26-29. Enforcement has been active: the Banking Department issued consent orders against RAM Payment, LLC (February 2026, unlicensed debt-resolution payment processing) and River Financial Inc. (December 2025, unlicensed Bitcoin ATM/fiat conversion activity), demonstrating that the state's 2017 convertible-virtual-currency exemption (RSA 399-G:3, VII) does not extend to crypto-fiat conversion. The state's broader crypto-legislative posture is more contested than trade-press reporting initially suggested: HB 639, the 'Blockchain Basic Law,' was reported as enrolled/published as of July 1, 2026, but legislative tracking shows a January 2026 Senate referral to interim study, leaving its enactment status genuinely unresolved this cycle. New Hampshire is the only New England state permitting unrestricted credit-card surcharging, and state-level interchange-cap bills (HB1319, HB682) have failed to become law. Consumer protection runs through the Attorney General's Consumer Protection & Antitrust Bureau (RSA 358-A) and the Banking Department's non-bank-payment-app warnings, while breach notification (RSA 359-C) requires Attorney General notice if even one resident is affected -- a threshold tested by the 2025 Marquis Software Solutions ransomware incident affecting NH credit unions. Instant-payments adoption is advancing via six FedNow-participant NH depository institutions, accessing Federal Reserve settlement predominantly through correspondent relationships rather than direct master accounts. Portsmouth-based Bottomline Technologies (Thoma Bravo-owned) remains the state's dominant commercial payments entity, and the Metro Credit Union/Members Plus Credit Union merger (announced April 2026) illustrates deepening Massachusetts-New Hampshire credit-union consolidation. W11 (AML/CFT) coverage could not be populated from the Sentinel.gi feed this cycle; only statutory BSA/AML hooks in RSA 399-G are carried as context. #### Outlook New Hampshire's regulatory direction is fragmenting: enforcement intensity against unlicensed money transmission is rising in parallel with an unresolved crypto-legislative status. The HB 639 interim-study process and the national Chicago merchant damages trial against Visa/Mastercard, both expected around 2026-Q3, are the key near-term watch points, alongside continued FedNow adoption and credit-union consolidation deepening the Massachusetts-New Hampshire corridor. 14 of 14 modules Signal Density Selections OR within a group, AND across groups. Press / to search. ### W1a Licensing, Authorisation & Market Access Confirmed confirmed 2026-07-05 NH money transmission remains governed by RSA 399-G, administered by the NH Banking Department via NMLS. HB 1207 (signed 2026-07-10) amends RSA 399-G's fee, renewal and authorised-delegate certificate-of-authority provisions, with staggered effective dates of 2027-07-01 and 2027-10-01. Standing sub-brief · as of 7 July 2026 276 words · last cycle 2026-10-11 #### Licensing, Authorisation & Market Access New Hampshire regulates money transmission under RSA 399-G, administered by the state Banking Department (Bank Commissioner) through the Nationwide Multistate Licensing System (NMLS). Licensees are examined at least every 24 months. HB 1241, signed August 23, 2024 and effective October 22, 2024, reenacted the chapter, modernizing provisions governing control acquisitions, key-individual requirements, and multistate licensing -- a wholesale refresh of a licensing framework that predates the current wave of nonbank payments activity. The statute draws a firm bank/nonbank line: charterees of banks, trusts, savings and loan associations, credit unions, thrifts, and insurance companies, together with government agencies, are exempt from NH money-transmitter licensing altogether. Nonbank licensees, by contrast, must post a surety bond equal to the greater of $100,000 or 100% of their average daily transmission liability over the trailing three months, capped at $500,000 -- a graduated, scale-sensitive safeguarding mechanism that rises with a licensee's outstanding-obligation exposure rather than applying a flat requirement. Taken together, the October 2024 reenactment and the bonding structure position New Hampshire as an actively maintained, NMLS-integrated licensing jurisdiction rather than a legacy statute left to atrophy. The bank-charter exemption is unambiguous and does not extend, on its face, to virtual-currency-only activity that converts to fiat (see W2), a distinction the Banking Department has since enforced directly (see W7). #### Outlook Watch for further NMLS-driven procedural updates flowing from the HB 1241 modernization, and for whether the Banking Department extends its 24-month examination cadence to newly licensed entrants given the enforcement activity documented elsewhere in this baseline (RAM Payment, River Financial). No further legislative amendments to RSA 399-G's licensing core are currently flagged in the regulatory horizon. Periodic update · new data 2026-10-04 #### Licensing, Authorisation & Market Access New Hampshire's money-transmitter regime under RSA 399-G saw an administrative reporting update effective 1 October 2026, enacted through 2026 session law chapter 294. RSA 399-G:15(II)(d), the provision requiring periodic reporting of average daily outstanding transmission liability, was repealed. At the same time, RSA 399-G:18(III) was tightened to require a licensee or applicant to file a correcting amendment within 30 days of discovering that previously filed information was inaccurate or incomplete. Neither change alters who must be licensed, what activities require licensure, or the licence application process itself; both are adjustments to the content and accuracy standard of ongoing regulatory reporting for existing and prospective licensees. HB1207, a 2026-session bill requested by the New Hampshire Banking Department, is the probable legislative vehicle for these amendments. The bill would also raise licence application and renewal fees for money-transmitter and other consumer-credit licensees. This chapter-to-bill mapping has not been independently confirmed against the enrolled act text this period, so the fee-increase component in particular should be treated as plausible but unverified pending confirmation. The substantive licensing framework established by 2024's HB1241 modernisation remains the governing structure into which this period's reporting amendments and possible fee changes are layered. #### Outlook Confirming the enrolled-act chapter-to-bill mapping — specifically, whether HB1207 is in fact the vehicle for chapter 294, and whether its fee increases were enacted alongside the reporting changes — is the key open item. Market participants maintaining or applying for an NH money-transmitter licence should watch for a revised fee schedule as the practical, bottom-line consequence of this period's legislative activity. **2 earlier distinct update(s)** Periodic update · new data 2026-09-28 #### Licensing, Authorisation & Market Access New Hampshire's money-transmitter licensing regime tightened materially this cycle for mixed fiat/crypto operators. The New Hampshire Banking Department issued an Order to Show Cause on May 27, 2025 against BAM Trading Services Inc. (Binance.US), seeking revocation of its money-transmitter licence. The action is grounded in the federal Bank Secrecy Act guilty plea of the licensee's controlling indirect owner, who holds approximately 80 percent indirect ownership, for willfully causing the broader Binance enterprise to fail to maintain an effective anti-money-laundering program. This is a direct exercise of the state's licensing-authority revocation power against an existing, previously-authorised market participant, not a new-entrant screening decision. The timing of this enforcement action coincides with a separate structural change to the licensing statute itself: a transition provision within RSA 399-G that had shielded existing money-transmitter licensees from newer or conflicting provisions expired on January 1, 2026. With that protection sunset, every existing licensee, including BAM Trading Services, is now fully subject to current revocation standards and compliance expectations without the benefit of grandfathered treatment. The practical effect is that the regulatory bar for maintaining a New Hampshire money-transmitter licence has risen for the state's existing licensee population at precisely the moment one of that population's members faces an active revocation proceeding. For market access purposes, this signals a jurisdiction where the licensing authority is both willing and evidently able to pursue revocation against a licensee with international scale and a federal enforcement history, and where the statutory protections that might have delayed or complicated such action have themselves expired. A prospective mixed fiat/crypto money-transmission business evaluating New Hampshire as an operating jurisdiction should treat the currently pending BAM Trading matter, and its still-unretrieved September 2025 docketed follow-on order, as a live indicator of how the post-sunset standard will be applied in practice, rather than treating RSA 399-G as a static compliance target. #### Outlook The resolution of the BAM Trading Services Order to Show Cause, including the substantive disposition of its September 9, 2025 docketed follow-on order, is the key near-term signal for this module. A full revocation would demonstrate that the post-sunset standard is being applied with maximum severity, while a negotiated consent outcome, comparable to the $60,000 civil-penalty and wind-down arrangement Connecticut's Department of Banking reached with the same corporate family, would suggest a more calibrated enforcement approach. Either outcome will shape how other mixed fiat/crypto money-transmission businesses assess New Hampshire's licensing-authority posture going forward. Periodic update · new data 2026-09-14 #### Licensing, Authorisation & Market Access New Hampshire's money-transmitter licensing perimeter moved in two directions simultaneously this cycle, both changes anchored to RSA 399-G. First, the transition-period shield under RSA 399-G:39, which had allowed previously-licensed money transmitters to continue operating under prior compliance terms during a grace period, expired January 1, 2026. Licensees must now demonstrate full compliance with the current text of RSA 399-G without that grace period, a tightening of the conventional money-transmission licensing environment that applies across the state's existing licensee population. Second, and in the opposite direction, HB639, enacted as Chapter 286 of the 2026 session with main provisions effective September 8, 2026, exempts home and business digital-asset mining, node operation, and staking from RSA 399-G money-transmitter licensing entirely. This is confirmed by a Tier-1 legislative record establishing the enactment and effective date. The carve-out narrows the population of activities requiring a money-transmitter license precisely as the compliance bar for the remaining licensed population rises, producing a bifurcated regulatory posture within a single statute: tightening for conventional non-bank payment institutions and electronic-money issuers, liberalising for blockchain infrastructure participants. Supervisory practice around the licensed population continues under an established cadence: the New Hampshire Banking Department requires money-transmitter licensees to be examined at least every 24 months, a standing baseline confirmed directly by the regulator and unaffected by either this cycle's tightening or liberalising development. The distinction between bank and non-bank market access is material here, since RSA 399-G's licensing perimeter applies to non-bank payment institutions and electronic-money issuers rather than to bank-chartered entities, which access the payments system through separate prudential channels untouched by this cycle's developments. #### Outlook The key event to watch is HB639's September 8, 2026 commencement, at which point the crypto carve-out becomes fully operative alongside the already-tightened conventional-licensee compliance requirement. Whether the New Hampshire Banking Department issues supervisory guidance clarifying the boundary between exempt crypto-infrastructure activity and activity still requiring licensure, particularly for hybrid business models combining node operation with other money-transmission functions, would be the clearest indicator of how administrable the bifurcated regime proves in practice. **Sources and findings (7)** 1. T1 [https://www.banking.nh.gov/consumer-credit-licensees-registrants/money-transmitters](https://www.banking.nh.gov/consumer-credit-licensees-registrants/money-transmitters) 2. T1 [https://www.banking.nh.gov/news-and-media/new-hampshire-banking-department-announcement-regarding-hb-1241-relating-money](https://www.banking.nh.gov/news-and-media/new-hampshire-banking-department-announcement-regarding-hb-1241-relating-money) retrieved 2026-07-05 3. T1 [https://gc.nh.gov/rsa/html/xxxvi/399-g/399-g-mrg.htm](https://gc.nh.gov/rsa/html/xxxvi/399-g/399-g-mrg.htm) retrieved 2026-07-05 4. T1 [https://gc.nh.gov/rsa/html/xxxvi/399-g/399-g-mrg.htm](https://gc.nh.gov/rsa/html/xxxvi/399-g/399-g-mrg.htm) retrieved 2026-07-05 5. T2 [https://legiscan.com/NH/text/HB1241/id/2868262](https://legiscan.com/NH/text/HB1241/id/2868262) retrieved 2026-07-05 6. T3 [https://moneytransmitterlaw.com/cryptocurrency-state-laws/new-hampshire/](https://moneytransmitterlaw.com/cryptocurrency-state-laws/new-hampshire/) retrieved 2026-07-05 7. T1 [https://www.banking.nh.gov/about-us](https://www.banking.nh.gov/about-us) retrieved 2026-07-05 ### W1b Conduct, Safeguarding & Promotions Confirmed confirmed 2026-07-05 Safeguarding under RSA 399-G rests on prudential net-worth and permissible-investment requirements plus the surety bond, with recordkeeping/complaint-handling obligations; the Banking Department retains cease-and-desist, consent-order and revocation powers. Standing sub-brief · as of 7 July 2026 200 words · last cycle 2026-07-05 #### Conduct, Safeguarding & Financial Promotions New Hampshire's prudential and safeguarding regime for money transmitters rests on three linked statutory pillars: net-worth maintenance (RSA 399-G:26), the surety bond (RSA 399-G:27), and permissible-investment maintenance (RSA 399-G:28-29), which together back outstanding transmission obligations. This combined net-worth-plus-bond-plus-permissible-investment structure is the core safeguarding mechanism for the jurisdiction and applies specifically to nonbank money-transmitter licensees rather than bank-chartered institutions, which are exempt from the licensing regime entirely (see W1a). On the conduct and enforcement side, the Banking Commissioner holds a full toolkit: suspension or revocation of licenses (RSA 399-G:30-31), cease-and-desist orders (RSA 399-G:32), consent orders (RSA 399-G:33), and civil penalties (RSA 399-G:34). Licensees must file written BSA/AML compliance plans and periodic call reports, with late-filing penalties reaching up to $625 per report or $2,500 per financial statement -- a recordkeeping and reporting discipline that sits alongside, but is administratively distinct from, the substantive AML statutory hooks tracked separately under W11. #### Outlook The consent-order enforcement documented under W7 (RAM Payment, River Financial) demonstrates the Commissioner's toolkit is being actively used rather than held in reserve. No safeguarding-mechanism changes are currently on the regulatory horizon for New Hampshire; the net-worth/bond/investment structure appears stable pending any future legislative revision. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://law.justia.com/codes/new-hampshire/title-xxxvi/chapter-399-g/](https://law.justia.com/codes/new-hampshire/title-xxxvi/chapter-399-g/) retrieved 2026-07-05 2. T1 [https://law.justia.com/codes/new-hampshire/title-xxxvi/chapter-399-g/](https://law.justia.com/codes/new-hampshire/title-xxxvi/chapter-399-g/) retrieved 2026-07-05 3. T1 [https://www.banking.nh.gov/sites/g/files/ehbemt621/files/inline-documents/sonh/chapter-399-g_effectiveuntil2024october21.pdf](https://www.banking.nh.gov/sites/g/files/ehbemt621/files/inline-documents/sonh/chapter-399-g_effectiveuntil2024october21.pdf) retrieved 2026-07-05 4. T1 [https://www.banking.nh.gov/about-us](https://www.banking.nh.gov/about-us) retrieved 2026-07-05 ### W2 Stablecoins & Digital Money Confirmed confirmed 2026-07-05 New Hampshire has no bespoke stablecoin statute; convertible-virtual-currency activity is exempt from money-transmitter licensure under RSA 399-G:3 (2017, reenacted 2024) but subject to RSA 358-A consumer protection. HB 639 ('Blockchain Basic Law'), which would codify additional protections for self-custody/node/mining/crypto-payments, has NOT been confirmed enacted: trade press describes July 2026 enrollment/registration, but legislative tracking shows a January 2026 Senate referral to interim study. Treat HB639 as pending, not current law, pending further verification. Horizon · 2026-Q3 (±multi_year) HB 639 'Blockchain Basic Law' — enactment status unresolved (Senate interim-study referral vs. reported enrollment)_proposed · TT3_ Standing sub-brief · as of 7 July 2026 323 words · last cycle 2026-07-05 #### Stablecoins & Digital Money New Hampshire has no bespoke stablecoin statute. Instead, since 2017 (and reenacted within the October 2024 HB1241 restructuring of RSA 399-G), the state has exempted persons selling or issuing payment instruments or stored value solely in convertible virtual currency, or receiving convertible virtual currency for transmission, from money-transmitter licensure under RSA 399-G:3, VII -- while leaving such persons subject to the state's general consumer-protection statute, RSA 358-A. That carve-out has clear limits. A December 2025 NH Banking Department consent order against River Financial Inc., an Ohio-based Bitcoin ATM operator, confirms that Bitcoin-cash exchange activity crossing into fiat requires an NH money-transmitter license notwithstanding the crypto-only exemption; the firm operated in New Hampshire from June 2024 before obtaining licensure in October 2024. The order is a direct, primary-source demonstration that the virtual-currency exemption is narrowly drawn around currency-to-currency activity and does not shield fiat off-ramps. The more contested element of this baseline is HB 639, the 'Blockchain Basic Law.' The bill passed the NH House by April 2025, and trade press dated July 2-4, 2026 describes it as 'published,' 'registered,' or 'enrolled' as of July 1, 2026. However, official legislative tracking shows the NH Senate referred the bill to interim study on January 7, 2026, by a 4-2 vote. This composer treats HB639's enactment status as genuinely unresolved this cycle -- it should not be read as current law. New Hampshire's operative crypto-payments framework remains the 2017 RSA 399-G:3 virtual-currency exemption described above; this is a correction to an earlier research-stage assertion that HB639 was already in force. #### Outlook The HB639 interim-study process is expected to reach some resolution point in 2026-Q3, though the uncertainty band on that timing is wide (multi-year, per the regulatory horizon entry). This composer flags the underlying gap: no official NH General Court floor-vote record was retrieved to settle the conflict between trade-press and legislative-tracker accounts, an under-indexing risk for US state-level legislative tracking generally. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T2 [https://www.cryptotimes.io/2026/07/04/new-hampshire-registers-hb639-blockchain-rights-crypto-protections/](https://www.cryptotimes.io/2026/07/04/new-hampshire-registers-hb639-blockchain-rights-crypto-protections/) retrieved 2026-07-05 2. T3 [https://cryptobriefing.com/new-hampshire-hb639-crypto-payments-wallets/](https://cryptobriefing.com/new-hampshire-hb639-crypto-payments-wallets/) retrieved 2026-07-05 3. T3 [https://bills.nhliberty.org/bills/2025/HB639](https://bills.nhliberty.org/bills/2025/HB639) retrieved 2026-07-05 4. T3 [https://stevenscenter.wharton.upenn.edu/publications-50-state-review/](https://stevenscenter.wharton.upenn.edu/publications-50-state-review/) retrieved 2026-07-05 5. T1 [https://www.banking.nh.gov/sites/g/files/ehbemt621/files/enforcement-orders/2025.12.09-river-financial-consent-order-2024-22674_signed_redacted.pdf](https://www.banking.nh.gov/sites/g/files/ehbemt621/files/enforcement-orders/2025.12.09-river-financial-consent-order-2024-22674_signed_redacted.pdf) retrieved 2026-07-05 ### W3 Operational Resilience & Critical Infrastructure Probable confirmed 2026-07-05 NH layers state breach-notification (RSA 359-C) and insurance-sector cybersecurity reporting (RSA 420-P) atop federal operational-resilience expectations; third-party vendor risk materialised via the 2025 Marquis Software Solutions ransomware incident. Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. [Open its jurisdiction pages on Dataprotection.gi →](https://dataprotection.gi/jurisdictions/) Standing sub-brief · as of 7 July 2026 173 words · last cycle 2026-07-05 #### Operational Resilience & Critical Infrastructure New Hampshire's breach-notification law, RSA 359-C, requires notification to the NH Attorney General if even one New Hampshire resident is affected, and obliges entities to promptly determine the likelihood that exposed personal information will be misused. This is a comparatively low notification threshold relative to peer states, and it applies irrespective of institution size. That threshold was tested in 2025 when a ransomware attack on vendor Marquis Software Solutions, exploiting a SonicWall VPN vulnerability, compromised data at more than 70 financial institutions and roughly 400,000 consumers nationally. Affected New Hampshire credit unions notified the NH Attorney General under the state breach regime, illustrating how a national third-party-vendor incident cascades into state-level regulatory obligations even when the vulnerability itself originated outside New Hampshire. #### Outlook Third-party vendor risk, rather than direct institutional compromise, is the operative resilience theme for New Hampshire's smaller depository institutions, which frequently rely on shared core-banking and software vendors. Continued monitoring of vendor-concentration risk in the community-bank and credit-union sector is warranted given the Marquis precedent. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T3 [https://www.constangy.com/data-privacy-us-nh](https://www.constangy.com/data-privacy-us-nh) retrieved 2026-07-05 2. T3 [https://www.constangy.com/data-privacy-us-nh](https://www.constangy.com/data-privacy-us-nh) retrieved 2026-07-05 3. T3 [https://www.americanbanker.com/news/vpn-vulnerability-leads-to-data-breaches-at-70-banks](https://www.americanbanker.com/news/vpn-vulnerability-leads-to-data-breaches-at-70-banks) retrieved 2026-07-05 4. T1 [https://www.banking.nh.gov/consumer-assistance](https://www.banking.nh.gov/consumer-assistance) retrieved 2026-07-05 ### W4 Scheme & Network Compliance Probable confirmed 2026-07-05 NH imposes no state-specific card-scheme rules beyond the federal Durbin framework; the state remains among the most permissive on surcharging, having declined interchange caps (HB1319, HB682), leaving scheme rules and the national interchange settlement as the operative layer. Standing sub-brief · as of 7 July 2026 166 words · last cycle 2026-07-05 #### Scheme & Network Compliance New Hampshire is the only New England state allowing unrestricted credit-card surcharging, with no state cap beyond the federal ceiling -- a marked contrast with Massachusetts, Maine and Connecticut, which ban surcharging entirely. This positions New Hampshire merchants distinctly within a regional patchwork of state-level scheme-adjacent rules. Legislative attempts to alter that landscape have failed: NH HB1319, a proposed 1% interchange-fee cap, and HB682 were both introduced but did not become law. Nationally, merchant groups continue to contest the 2026 Visa/Mastercard interchange class settlement -- a 0.1-percentage-point cut to posted rates and a 1.25% cap running eight years -- as inadequate, a dispute that affects New Hampshire merchants operating under the settlement's terms even though the litigation itself is not NH-specific. #### Outlook Watch the Chicago merchant damages trial against Visa and Mastercard (GrubHub-led interchange litigation), expected in 2026-Q3, for downstream effects on the settlement terms New Hampshire merchants currently operate under. No renewed state-level interchange-cap legislation is currently flagged for New Hampshire. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T3 [https://www.nickel.com/surcharge-laws/new-hampshire](https://www.nickel.com/surcharge-laws/new-hampshire) retrieved 2026-07-05 2. T3 [https://merchantcostconsulting.com/lower-credit-card-processing-fees/new-hampshire-surcharge-laws/](https://merchantcostconsulting.com/lower-credit-card-processing-fees/new-hampshire-surcharge-laws/) retrieved 2026-07-05 3. T3 [https://csnews.com/new-hampshire-legislators-taking-credit-card-fees](https://csnews.com/new-hampshire-legislators-taking-credit-card-fees) retrieved 2026-07-05 4. T3 [https://www.paymentsdive.com/news/merchants-assail-card-fees-pact/807846/](https://www.paymentsdive.com/news/merchants-assail-card-fees-pact/807846/) retrieved 2026-07-05 ### W5 Payment Corridor Dynamics Probable confirmed 2026-07-05 NH's corridor exposure is dominated by federal domestic rails: several NH banks and the state's largest credit union have adopted FedNow; the market is integrated with the MA/New England corridor via cross-border credit-union mergers. Standing sub-brief · as of 7 July 2026 167 words · last cycle 2026-07-05 #### Payment Corridor Dynamics Six New Hampshire-headquartered depository institutions -- Claremont Savings Bank, First Seacoast Bank, Meredith Village Savings Bank, Merrimack County Savings Bank, Savings Bank of Walpole, and Service Credit Union -- are FedNow participants, part of a national base exceeding 1,400 participants two years after the service's launch. This places New Hampshire's community-banking sector squarely within the leading edge of instant-payments adoption relative to peer small-state markets. Corridor integration is deepening on the credit-union side as well: Metro Credit Union, serving members across five New Hampshire counties, announced in April 2026 its intent to merge with Massachusetts-based Members Plus Credit Union. The deal illustrates the Massachusetts-New Hampshire retail-payments corridor and sits within a broader national wave of credit-union consolidation tracked under W6. #### Outlook FedNow adoption among New Hampshire's community banks is likely to continue expanding given the national trajectory, while the Metro/Members Plus merger -- still pending regulatory approval with no disclosed completion timeline -- will be a bellwether for further cross-border New England credit-union consolidation. no periodic updates on record for this sub-brief ** Sources and findings (3)** 1. T3 [https://www.nerdwallet.com/banking/learn/banks-that-use-fednow](https://www.nerdwallet.com/banking/learn/banks-that-use-fednow) retrieved 2026-07-05 2. T1 [https://www.frbservices.org/news/fed360/issues/071625/fednow-service-two-years-growth-innovation](https://www.frbservices.org/news/fed360/issues/071625/fednow-service-two-years-growth-innovation) retrieved 2026-07-05 3. T3 [https://www.prnewswire.com/news-releases/metro-credit-union-and-members-plus-credit-union-announce-intent-to-merge-powered-by-partnership-302732894.html](https://www.prnewswire.com/news-releases/metro-credit-union-and-members-plus-credit-union-announce-intent-to-merge-powered-by-partnership-302732894.html) retrieved 2026-07-05 ### W6 Industry Structure & Commercial Probable confirmed 2026-07-05 NH's payments industry structure is anchored by Bottomline Technologies (Thoma Bravo-owned) alongside Fidelity's Merrimack payments operations and Service Credit Union; the national bank-CU consolidation wave is reshaping the NE community-banking landscape. Standing sub-brief · as of 7 July 2026 160 words · last cycle 2026-07-05 #### Industry Structure & Commercial Dynamics Portsmouth, New Hampshire-headquartered Bottomline Technologies, founded in 1989, has been a Thoma Bravo private-equity portfolio company since 2022. The firm serves more than 1,200 financial institutions and over 10,000 businesses, moving more than $16 trillion in payments annually with approximately 2,933 employees -- New Hampshire's flagship commercial payments entity and a bellwether for private-equity-owned B2B payments consolidation nationally. Bottomline's position sits within a wider structural current: the National Credit Union Administration approved 41 credit-union mergers with combined assets of $34 billion in the third quarter of 2025 alone, exceeding the combined total for 2022-2024, a wave expected to intensify through 2026. The Metro Credit Union/Members Plus Credit Union deal (W5, W13) is New Hampshire's direct exposure to that national consolidation trend. #### Outlook Expect continued PE-driven consolidation pressure in B2B payments infrastructure (Bottomline as the New Hampshire bellwether) alongside accelerating credit-union merger activity nationally, both trends reinforcing each other as smaller institutions seek scale or exit. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T3 [https://www.thomabravo.com/portfolio/bottomline](https://www.thomabravo.com/portfolio/bottomline) retrieved 2026-07-05 2. T3 [https://leadiq.com/c/bottomline-technologies/5a1d8a9c2400002400646a64](https://leadiq.com/c/bottomline-technologies/5a1d8a9c2400002400646a64) retrieved 2026-07-05 3. T3 [https://www.oca.nh.gov/news-and-media/please-dont-help-me-pay-my-next-vacation](https://www.oca.nh.gov/news-and-media/please-dont-help-me-pay-my-next-vacation) retrieved 2026-07-05 4. T3 [https://www.cutoday.info/THE-feature/Why-Healthy-Credit-Unions-Are-Choosing-To-Merge-And-Why-2026-Could-Break-Records](https://www.cutoday.info/THE-feature/Why-Healthy-Credit-Unions-Are-Choosing-To-Merge-And-Why-2026-Could-Break-Records) retrieved 2026-07-05 5. T3 [https://www.indeed.com/q-fintech-l-manchester,-nh-jobs.html](https://www.indeed.com/q-fintech-l-manchester,-nh-jobs.html) retrieved 2026-07-05 ### W7 Legal & Litigation Confirmed confirmed 2026-07-05 The NH Banking Department has issued consent orders against non-bank processors for unlicensed transmission (RAM Payment, Feb 2026) and a Bitcoin-ATM operator (River Financial, Dec 2025); RSA 358-A provides a private right of action with treble damages, layered onto national interchange antitrust litigation. Horizon · 2026-Q3 (±quarter) Chicago merchant damages trial vs. Visa/Mastercard (GrubHub-led interchange litigation)_proposed · TT3_ Standing sub-brief · as of 7 July 2026 193 words · last cycle 2026-07-05 #### Legal & Litigation The NH Banking Department has been an active enforcer against unlicensed payments activity across two 2025-2026 consent orders. In February 2026, the Department found that RAM Payment, LLC, a Delaware-based company, provided third-party account-management and payment-processing services for debt-resolution consumers in New Hampshire prior to obtaining its money-transmitter license, in violation of RSA 399-G:2, I. In December 2025, a parallel consent order against River Financial Inc., a Bitcoin ATM operator, established that crypto-to-fiat conversion activity likewise requires licensure (see W2, W7). Beyond direct regulatory enforcement, RSA 358-A, the state Consumer Protection Act, empowers consumers with private rights of action for actual damages or a minimum of $1,000, trebled for willful violations, plus attorney's fees -- a private-litigation layer that supplements both state regulatory action and federal FTC Act enforcement. #### Outlook Two consent orders within roughly three months of each other suggest sustained Banking Department enforcement attention to unlicensed transmission, a posture likely to continue given the Department's demonstrated willingness to act against both traditional processors and crypto-adjacent operators. Nationally, watch the Chicago merchant damages trial against Visa/Mastercard, expected 2026-Q3, as a parallel litigation track with indirect New Hampshire merchant exposure. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://mm.nh.gov/files/uploads/banking/enforcement-orders/20260205-co-rampaymentllc-fullyexecuted-redacted.pdf](https://mm.nh.gov/files/uploads/banking/enforcement-orders/20260205-co-rampaymentllc-fullyexecuted-redacted.pdf) retrieved 2026-07-05 2. T1 [https://www.banking.nh.gov/sites/g/files/ehbemt621/files/enforcement-orders/2025.12.09-river-financial-consent-order-2024-22674_signed_redacted.pdf](https://www.banking.nh.gov/sites/g/files/ehbemt621/files/enforcement-orders/2025.12.09-river-financial-consent-order-2024-22674_signed_redacted.pdf) retrieved 2026-07-05 3. T3 [https://grokipedia.com/page/New_Hampshire_Consumer_Protection_Act](https://grokipedia.com/page/New_Hampshire_Consumer_Protection_Act) retrieved 2026-07-05 4. T3 [https://www.paymentsdive.com/news/merchants-assail-card-fees-pact/807846/](https://www.paymentsdive.com/news/merchants-assail-card-fees-pact/807846/) retrieved 2026-07-05 ### W8 Merchant Acquiring & Risk Probable confirmed 2026-07-05 NH merchant acquiring operates under federal Durbin rules and unrestricted state-level surcharging, governed by card-network disclosure requirements and RSA 358-A; no NH-specific acquiring or high-risk-merchant regime exists. Standing sub-brief · as of 7 July 2026 126 words · last cycle 2026-07-05 #### Merchant Acquiring & Risk New Hampshire merchants implementing surcharge programs must operate within federal maximums -- a general 4% cap and a 3% Visa network cap -- with proper point-of-sale disclosure; violations expose merchants to card-network fines, FTC exposure, and complaints to the NH Attorney General's Consumer Protection Bureau. No New Hampshire-specific high-risk-merchant or MCC regime was identified this cycle; the state's merchant-acquiring risk framework rests entirely on federal and network-level rules layered onto the state's permissive surcharging posture (see W4). #### Outlook Absent a state-specific acquiring regime, New Hampshire merchant risk exposure will continue to track federal Durbin-framework and card-network rule changes rather than any state-level rulemaking. This is flagged as a research gap (no NH-specific high-risk-merchant regime located) rather than a confirmed absence of risk. no periodic updates on record for this sub-brief ** Sources and findings (3)** 1. T3 [https://www.nickel.com/surcharge-laws/new-hampshire](https://www.nickel.com/surcharge-laws/new-hampshire) retrieved 2026-07-05 2. T3 [https://www.getflexpoint.com/credit-card-surcharging-us-states/new-hampshire](https://www.getflexpoint.com/credit-card-surcharging-us-states/new-hampshire) retrieved 2026-07-05 3. T3 [https://ebizcharge.com/blog/credit-card-surcharging-a-state-by-state-legal-analysis/](https://ebizcharge.com/blog/credit-card-surcharging-a-state-by-state-legal-analysis/) retrieved 2026-07-05 ### W9 Product Innovation & Market Development Probable confirmed 2026-07-05 Product innovation in NH is led by Bottomline's 2025-2026 product releases, community-bank FedNow rollout, and NH's crypto-friendly legislative programme (state Bitcoin allocation; HB639 status contested/unconfirmed). Standing sub-brief · as of 7 July 2026 167 words · last cycle 2026-09-05 #### Product Innovation & Market Development New Hampshire's 2025-2026 legislative programme signals an active, if contested, push to court digital-asset payment innovation: proposals include a state Bitcoin-reserve allocation of up to 5% of public funds, a proposed $100 million Bitcoin-backed bond, and the pending HB 639 'Blockchain Basic Law.' HB639's own enactment status remains unresolved (see W2), which caps confidence in describing New Hampshire's crypto posture as settled policy rather than aspirational legislative activity. On the instant-payments side, 2025 is described industry-wide as 'the year of the send,' with more than 1,300 financial institutions on FedNow relying on third-party providers and APIs for send/receive capability -- the operating model that New Hampshire's FedNow-participant community banks (see W5) generally follow rather than building proprietary infrastructure. #### Outlook Product innovation in New Hampshire is currently a story of two speeds: steady, incremental commercial product cadence (Bottomline, see W13) against a slower-moving and contested legislative crypto-innovation track (HB639) whose ultimate resolution will materially affect how 'innovation-friendly' New Hampshire's digital-asset posture actually is. Periodic update · new data 2026-09-14 #### Product Innovation & Market Development The New Hampshire Lottery Commission exercised the first of two available two-year extension options on its exclusive sports-wagering contract with DraftKings, formalised as Amendment No. 1 dated December 12, 2025 and reflected in the Governor and Executive Council's February 2026 agenda record. The amendment's substantive payments-relevant change is a restructuring of the promotional-payment mechanics: the retail promotional-deduction cap rises from 10 percent to 40 percent of retail gross gaming revenue, a material change to how promotional spend is netted against revenue before the state's share is calculated on New Hampshire's only regulated online-wagering payment rail. This is confirmed via a Tier-1 government-record source. A second, lower-confidence development touches the same statutory vehicle that reshaped New Hampshire's licensing perimeter this cycle: HB639 is reported, on Tier-3 corroboration, to bar New Hampshire state and local authorities from imposing taxes, fees, or licensing conditions specifically because a payment is made using a digital asset, and to protect self-custody wallet use. For product and market-development purposes, this functions as a market-access-relevant constraint on future state rulemaking that might otherwise touch crypto-payment products, effectively pre-empting a category of state-level friction before it could be introduced, though the precise scope of this provision rests on secondary-source corroboration rather than direct statutory-text confirmation this cycle. #### Outlook Whether the DraftKings promotional-deduction change produces observable shifts in retail promotional-offer structuring, and whether HB639's digital-asset-payment-neutrality provision is tested against any future NH rulemaking attempt, are the two developments to watch. No other product-innovation or market-development signal specific to New Hampshire payments was identified this cycle. **Sources and findings (5)** 1. T3 [https://www.bottomline.com/newsroom/press-releases/bottomline-strengthens-business-payments-fraud-defense-integrated-multi-layered-protection](https://www.bottomline.com/newsroom/press-releases/bottomline-strengthens-business-payments-fraud-defense-integrated-multi-layered-protection) retrieved 2026-07-05 2. T3 [https://www.bottomline.com/newsroom/press-releases/bottomline-enhances-paymode-digital-banking-help-banks-reduce-check-fraud](https://www.bottomline.com/newsroom/press-releases/bottomline-enhances-paymode-digital-banking-help-banks-reduce-check-fraud) retrieved 2026-07-05 3. T3 [https://bitcoinworld.co.in/new-hampshire-blockchain-basics-act-takes-effect/](https://bitcoinworld.co.in/new-hampshire-blockchain-basics-act-takes-effect/) retrieved 2026-07-05 4. T3 [https://www.cryptotimes.io/2026/07/04/new-hampshire-registers-hb639-blockchain-rights-crypto-protections/](https://www.cryptotimes.io/2026/07/04/new-hampshire-registers-hb639-blockchain-rights-crypto-protections/) retrieved 2026-07-05 5. T3 [https://www.independentbanker.org/article/2025/07/01/instant-payments-insights-every-community-bank-needs](https://www.independentbanker.org/article/2025/07/01/instant-payments-insights-every-community-bank-needs) retrieved 2026-07-05 ### W10 Consumer Protection & APP Fraud Confirmed confirmed 2026-07-05 SB 482 creates a new NH chapter regulating digital-asset transaction kiosks (crypto ATMs) to curb elder-fraud losses: a $2,000/day/customer limit, a 48-hour hold with full refund on a flagged first-time transaction, mandatory ID verification and fraud-screening prompts. Signed by Gov. Ayotte; takes effect 2026-12-16. Standing sub-brief · as of 7 July 2026 120 words · last cycle 2026-07-05 #### Consumer Protection & APP Fraud The NH Department of Justice's Consumer Protection & Antitrust Bureau enforces state and federal unfair-and-deceptive-practices laws and investigates and prosecutes the most serious cases of elder abuse and financial exploitation, running sustained 2025-2026 scam-prevention and AI-fraud-awareness campaigns. Separately, the NH Banking Department explicitly warns consumers that PayPal, Venmo, Cash App and other non-bank payment apps are not protected by federal deposit insurance, directing consumers to CFPB guidance on payment-app risk. #### Outlook The combination of an active DOJ scam-awareness campaign and Banking Department non-bank-app warnings suggests New Hampshire's consumer-protection posture is oriented toward public-education tools ahead of any prescriptive APP-fraud liability regime; no such liability-shift legislation is currently flagged on the regulatory horizon for New Hampshire. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T1 [https://www.doj.nh.gov/citizens/consumer-protection-antitrust-bureau](https://www.doj.nh.gov/citizens/consumer-protection-antitrust-bureau) retrieved 2026-07-05 2. T1 [https://www.doj.nh.gov/news-and-media/new-hampshire-department-justice-warns-ai-technology-bringing-new-financial-scams](https://www.doj.nh.gov/news-and-media/new-hampshire-department-justice-warns-ai-technology-bringing-new-financial-scams) retrieved 2026-07-05 3. T1 [https://www.doj.nh.gov/news-and-media/attorney-generals-office-expanding-free-scam-prevention-training](https://www.doj.nh.gov/news-and-media/attorney-generals-office-expanding-free-scam-prevention-training) retrieved 2026-07-05 4. T1 [https://www.banking.nh.gov/consumer-assistance](https://www.banking.nh.gov/consumer-assistance) retrieved 2026-07-05 5. T1 [https://www.doj.nh.gov/news-and-media/consumer-alert-scam-text-messages-falsely-claim-be-nh-dmv-threaten-license](https://www.doj.nh.gov/news-and-media/consumer-alert-scam-text-messages-falsely-claim-be-nh-dmv-threaten-license) retrieved 2026-07-05 ### W11 AML/CFT & Financial Crime [Sourced from Sentinel.gi ↗](https://sentinel.gi/jurisdictions/united-states-new-hampshire/#sec-dom-D7) Uncertain confirmed 2026-07-05 W11 baseline for US-NH is Sentinel.gi-fed by design; no accessible Sentinel content was found this cycle, so the module carries only statutory BSA/AML hooks in RSA 399-G as context, per the no-original-analysis constraint. Standing sub-brief · as of 7 July 2026 138 words · last cycle 2026-07-05 #### AML/CFT & Financial Crime This module is Sentinel.gi-sourced by design, and no Sentinel.gi-branded payments-context feed was accessible for US-NH this cycle. In its absence, the only content carried forward is statutory context embedded in RSA 399-G: RSA 399-G:19 requires licensees to file written BSA compliance plans, and RSA 399-G:15 (Money Laundering Reports) sits as a dedicated statutory provision alongside the federal Bank Secrecy Act filing requirement. This is carried as statutory context only, not as original illicit-finance analysis, which remains out of World Payments Monitor scope; readers seeking AML/CFT analysis for New Hampshire should consult the Sentinel.gi feed directly when available. #### Outlook Coverage of this module for US-NH is expected to improve once the Sentinel.gi feed becomes accessible; until then, this composer will continue to carry only the statutory BSA/AML hooks as context rather than attempt original analysis. no periodic updates on record for this sub-brief ** Sources and findings (6)** 1. T1 [https://law.justia.com/codes/new-hampshire/2015/title-xxxvi/chapter-399-g](https://law.justia.com/codes/new-hampshire/2015/title-xxxvi/chapter-399-g) retrieved 2026-07-05 2. T? FIM (sentinel.gi) per-JID baseline profile — United States — New Hampshire — NH regulates money transmission under RSA 399-G, supervised by the NH Banking Department, which operates an OFAC information-sharing MOU covering state-chartered banking organizations. Federal BSA/AML enforcement (FinCEN, USAO-NH) has been aggressive historically (Ian Freeman case) but NH's legislature has simultaneously embraced crypto via the first-in-nation Strategic Bitcoin Reserve (HB 302, 2025), creating tension between permissive digital-asset policy and AML supervisory capacity. 3. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: sourcing-thinness 4. T2 FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-003) — Enforcement: Cumulative state and municipal crypto-ATM regulation (multiple states) — Bitcoin Depot (crypto ATM operator with nationwide kiosk footprint including New Hampshire-area retail partners) 5. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: capacity-deficit 6. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: regulatory-failure ### W12 Correspondent Banking, Settlement & Access Probable confirmed 2026-07-05 NH community banks/credit unions access Fed settlement infrastructure, including FedNow, predominantly through correspondent relationships rather than holding direct master accounts for every rail. Standing sub-brief · as of 7 July 2026 174 words · last cycle 2026-07-05 #### Correspondent Banking, Settlement & Access The analytical spine of this module is the bank-versus-nonbank access asymmetry in settlement infrastructure. New Hampshire's community banks and credit unions predominantly access Federal Reserve settlement infrastructure, including FedNow, through correspondent or respondent relationships with bankers' banks or corporate credit unions, rather than holding direct master accounts for every rail. FedNow itself requires financial institutions to maintain sufficient funds in their own Federal Reserve master account, or that of a designated correspondent, to cover outgoing payments, ensuring immediate and final settlement without credit risk. This structure means New Hampshire's smaller depository institutions carry an intermediation layer -- and an associated dependency -- that larger, directly-connected institutions do not, a distinction with direct relevance to nonbank payment-institution and EMI access more broadly, which typically has no comparable correspondent pathway into Federal Reserve settlement rails at all. #### Outlook As FedNow adoption expands among New Hampshire's community banks (see W5), correspondent-access arrangements are likely to remain the dominant settlement-access model for smaller institutions rather than a transitional stage toward direct master-account holding. no periodic updates on record for this sub-brief ** Sources and findings (3)** 1. T1 [https://www.federalregister.gov/documents/2020/08/11/2020-17539/service-details-on-federal-reserve-actions-to-support-interbank-settlement-of-instant-payments](https://www.federalregister.gov/documents/2020/08/11/2020-17539/service-details-on-federal-reserve-actions-to-support-interbank-settlement-of-instant-payments) retrieved 2026-07-05 2. T3 [https://bankingjournal.aba.com/2025/02/4-things-to-know-about-the-fednow-service/](https://bankingjournal.aba.com/2025/02/4-things-to-know-about-the-fednow-service/) retrieved 2026-07-05 3. T3 [https://www.aciworldwide.com/fednow](https://www.aciworldwide.com/fednow) retrieved 2026-07-05 ### W13 Commercial Intelligence (M&A, Investment & Product) Probable confirmed 2026-07-05 Trailing-12-month commercial activity centers on Portsmouth-headquartered Bottomline's steady cadence of product releases under Thoma Bravo ownership and the April 2026 Metro Credit Union/Members Plus Credit Union merger announcement with direct NH-county exposure, set against a broader accelerating 2025-2026 US credit-union consolidation wave. Standing sub-brief · as of 7 July 2026 189 words · last cycle 2026-07-05 #### Commercial Intelligence (M&A, Investment & Product) Three discrete commercial events anchor this cycle's New Hampshire commercial-intelligence baseline. Bottomline Technologies launched Payments Fraud Defense on January 8, 2026, an AI-driven fraud platform aligned with Nacha's 2026 fraud-monitoring rules that integrates behavioral analytics and session replay; deal/product value was not publicly disclosed. On March 31, 2026, Bottomline introduced a Paymode for Digital Banking enhancement to help banks identify check-heavy business customers and migrate them to Premium ACH; again, value was not publicly disclosed. On the M&A side, Metro Credit Union announced its intent to merge with Members Plus Credit Union on April 2, 2026. Metro serves members across five New Hampshire counties; the deal's rationale is to expand the combined membership base across the New Hampshire/Massachusetts corridor. Deal value was not publicly disclosed, and the transaction remains pending regulatory approval with no disclosed completion timeline. #### Outlook Bottomline's product cadence (two releases within a single quarter) suggests continued PE-backed investment in fraud and payments-migration tooling, while the Metro/Members Plus merger sits within an accelerating national credit-union consolidation wave (see W6) that is likely to produce further New Hampshire-exposed deal activity through 2026. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T3 [https://www.bottomline.com/newsroom/press-releases/bottomline-strengthens-business-payments-fraud-defense-integrated-multi-layered-protection](https://www.bottomline.com/newsroom/press-releases/bottomline-strengthens-business-payments-fraud-defense-integrated-multi-layered-protection) retrieved 2026-07-05 2. T3 [https://www.bottomline.com/newsroom/press-releases/bottomline-enhances-paymode-digital-banking-help-banks-reduce-check-fraud](https://www.bottomline.com/newsroom/press-releases/bottomline-enhances-paymode-digital-banking-help-banks-reduce-check-fraud) retrieved 2026-07-05 3. T3 [https://www.bottomline.com/newsroom/press-releases/bottomline-breaks-new-ground-paymode-digital-banking](https://www.bottomline.com/newsroom/press-releases/bottomline-breaks-new-ground-paymode-digital-banking) retrieved 2026-07-05 4. T3 [https://www.prnewswire.com/news-releases/metro-credit-union-and-members-plus-credit-union-announce-intent-to-merge-powered-by-partnership-302732894.html](https://www.prnewswire.com/news-releases/metro-credit-union-and-members-plus-credit-union-announce-intent-to-merge-powered-by-partnership-302732894.html) retrieved 2026-07-05 5. T3 [https://www.cutoday.info/THE-feature/Why-Healthy-Credit-Unions-Are-Choosing-To-Merge-And-Why-2026-Could-Break-Records](https://www.cutoday.info/THE-feature/Why-Healthy-Credit-Unions-Are-Choosing-To-Merge-And-Why-2026-Could-Break-Records) retrieved 2026-07-05 ** No modules match.** Filters combine as OR inside a group and AND across groups. ## Editorial metadata Provenance only. Nothing below gates publication or affects the render. Editorial metadata for United States – New Hampshire| Field | Value | |---|---| | `trust.lawyer_review.status` | never_reviewed | | `trust.lawyer_review.reviewer` | no reviewer on record | | ` trust.content_source` | ai_generated | ## Provenance and declared absence **Disclosure model:** module cards load OPEN; standing positions render in full; sub-briefs and jurisdiction briefs load as a clamped teaser with an explicit “read full” control carrying the true word count; earlier updates stay collapsed behind a counted summary. 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A year-precision row is never promoted into a tighter band. **Orphan deltas:** 2 cycle_delta row(s) target non-module objects and are listed in the rail rather than attached to a card. **Envelope:** baseline resolved at `jurisdiction_json.baseline`; 14 module(s), 63 finding(s), 136 source(s) in the cumulative register. Think something on this page is wrong? [Report an error](https://payments.gi/legal/#contact).