Kingdom Trust, a small South Dakota company, quietly navigated the unexciting realm of individual retirement account custodianship. During the mid-2010s, it began courting a markedly different clientele: obscure firms from notorious offshore havens struggling to secure U.S. accounts. In April 2023, FinCEN announced a $1.5 million civil money penalty on Kingdom Trust for willful violations of the Bank Secrecy Act (BSA). It was FinCEN’s first enforcement action against a trust company.