{ "lastUpdated": "2026-10-12", "states": [ { "name": "New York", "slug": "new-york", "status": "live", "statusLabel": "Live Regime", "framework": "NYDFS BitLicense / Limited Purpose Trust Charter; proposed 23 NYCRR Part 202 (Authorized Payment Stablecoin Issuers)", "regulator": "New York Department of Financial Services (NYDFS)", "detail": "Most coins commonly called \u201cstablecoins\u201d count as Virtual Currency under New York\u2019s rules, which means issuing one requires a BitLicense or a New York-chartered trust company (the trust route also lets a company handle money transmission and fiduciary duties without extra licenses, which a BitLicense alone doesn\u2019t allow). Before issuing, a coin also needs DFS sign-off through self-certification, a spot on DFS\u2019s approved \u201cGreenlist,\u201d or individual approval. Coins already on the Greenlist include Gemini Dollar, Ripple USD, and WisdomTree Dollar. In July 2026, DFS proposed a new regulation, 23 NYCRR Part 202 (\u201cAuthorized Payment Stablecoin Issuers\u201d), that reaffirms and aligns New York\u2019s payment-stablecoin regime with the federal GENIUS Act. Part 202 takes effect on the GENIUS Act\u2019s own effective date; it ties reserve, redemption, and attestation duties to the GENIUS Act (segregated per-brand reserves, monthly reserve-composition reports examined by a registered public accounting firm, and an annual attestation), gives issuers already approved by DFS 12 months to reach full compliance, and withdraws the department\u2019s June 8, 2022 stablecoin guidance as of its effective date.", "effective": "In force now under the BitLicense / limited-purpose trust charter and DFS\u2019s June 8, 2022 stablecoin guidance; proposed 23 NYCRR Part 202 takes effect on the GENIUS Act\u2019s effective date (expected January 18, 2027) (replacing the 2022 guidance), with a 12-month compliance transition for existing issuers.", "lastVerified": "2026-08-26", "sourceText": "NY DFS Virtual Currency Businesses; proposed 23 NYCRR Part 202, Authorized Payment Stablecoin Issuers (July 2026)", "sourceUrl": "https://www.dfs.ny.gov/virtual_currency_businesses", "keyPoints": [ "Today: hold a BitLicense or New York trust charter, and follow DFS\u2019s 2022 stablecoin guidance (full 1:1 reserves, redemption at par, monthly CPA attestation)", "Get DFS sign-off on the specific coin (self-certification, the approved Greenlist, or individual approval)", "When Part 202 takes effect: back and segregate reserves per coin, file monthly reserve reports checked by an outside accounting firm, and get a yearly sign-off", "Publish clear rules for how customers can cash out their coins", "Already licensed? You have 12 months to meet the new Part 202 rules once they take effect" ], "summary": "New York already requires state approval to issue a stablecoin, and it already sets reserve, redemption, and attestation rules through existing DFS guidance. It has proposed updated rules (Part 202) that will replace that guidance and match the new federal GENIUS Act once the Act takes effect; firms already licensed then get a year to comply." }, { "name": "California", "slug": "california", "status": "live", "statusLabel": "Live Regime", "framework": "Digital Financial Assets Law (DFAL)", "regulator": "California Department of Financial Protection and Innovation (DFPI)", "detail": "California's Digital Financial Assets Law entered into force on July 1, 2026. Any exchange, custodian, stablecoin issuer, or Bitcoin ATM operator serving California residents must now hold a DFPI license or have filed a complete application, or face civil enforcement of up to $100,000 per day. The law bars licensees from exchanging a stablecoin unless its issuer is licensed, has applied for a license, or is a qualified bank or trust company backing the coin with eligible securities. DFPI expects an initial $100,000 net worth, subject to change, and began accepting applications through NMLS on March 9, 2026.", "effective": "In force since Jul. 1, 2026; DFPI license or complete application now required; enforcement active", "lastVerified": "2026-09-02", "sourceText": "AB 39, Financial Code Div. 1.25", "sourceUrl": "https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202320240AB39", "summary": "California regulates digital-financial-asset (crypto) business activity under the Digital Financial Assets Law, licensed by the DFPI. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "Obtain a DFPI license under the Digital Financial Assets Law (DFAL) before engaging in digital-financial-asset business activity with California residents.", "Meet the licensing law\u2019s prudential requirements (surety bond or net worth, permissible investments or reserve holdings) and comply with AML, reporting, and consumer-disclosure obligations.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Texas", "slug": "texas", "status": "live", "statusLabel": "Live Regime", "framework": "Money Services Modernization Act (Finance Code ch. 152)", "regulator": "Texas Department of Banking", "detail": "Texas treats a qualifying stablecoin as \u201cmoney\u201d or \u201cmonetary value,\u201d so transmitting or issuing it requires a money-transmission license. Under Finance Code \u00a7 152.003(19), \u201cmoney\u201d/\u201cmonetary value\u201d includes a stablecoin that (A) is pegged to a sovereign currency, (B) is fully backed by assets held in reserve, and (C) is redeemable for sovereign currency from the issuer; \u201cmoney transmission\u201d is defined at \u00a7 152.003(22). The Texas Department of Banking set this position in Supervisory Memorandum 1037 (rev. Jan. 28, 2025) under the Money Services Modernization Act (Finance Code ch. 152, enacted by Acts 2023, 88th Leg., R.S., Ch. 277 (S.B. 895)). Non-stablecoin virtual currency (e.g., Bitcoin, Ether) is not \u201cmoney,\u201d so receiving it alone is not money transmission, though a business may still be a \u201cdigital asset service provider\u201d under Finance Code \u00a7 160.001(6). The Department regulates fiat-backed stablecoin issuers as money transmitters and, under \u00a7 152.059, defers to federal law (the GENIUS Act) to the extent of any inconsistency, with the Commissioner to issue interpretive guidance. Texas also prohibits a state CBDC (\u00a7 152.006) and, as amended in 2025 (Acts 2025, 89th Leg., R.S., Ch. 642 (H.B. 3833)), treats stablecoin as a permissible investment only to the extent of outstanding same-kind transmission obligations and subject to custody requirements (\u00a7 152.356(a)(6), (a-1)).", "effective": "In force since Sept. 1, 2023 (Acts 2023, Ch. 277 / S.B. 895); \u00a7 152.356 amended eff. Sept. 1, 2025 (Acts 2025, Ch. 642 / H.B. 3833)", "lastVerified": "2026-10-12", "sourceText": "Tex. Fin. Code \u00a7 152.003(19) (\u201cmoney\u201d/\u201cmonetary value\u201d includes a fiat-pegged, fully reserved, redeemable stablecoin) and \u00a7 152.003(22) (\u201cmoney transmission\u201d); Money Services Modernization Act, ch. 152 (Acts 2023, Ch. 277 / S.B. 895; \u00a7 152.356 amended by Acts 2025, Ch. 642 / H.B. 3833); \u00a7 152.059 (federal/GENIUS deference); \u00a7 152.006 (no state CBDC); \u00a7 160.001(6) (digital asset service provider); Dept. of Banking Supervisory Memorandum 1037 (rev. Jan. 28, 2025). Primary-source verified against the enrolled Finance Code (Oct. 2026).", "sourceUrl": "https://statutes.capitol.texas.gov/Docs/FI/htm/FI.152.htm", "summary": "In Texas, a fiat-pegged, fully reserved, redeemable stablecoin is \u201cmoney\u201d under Finance Code \u00a7 152.003(19), so transmitting or issuing it requires a money-transmission license; other virtual currency is not \u201cmoney.\u201d The Department regulates stablecoin issuers consistent with the federal GENIUS Act (\u00a7 152.059). Primary-source verified Oct. 2026.", "keyPoints": [ "Obtain a Texas money-transmission license from the Department of Banking before transmitting or issuing a fiat-pegged, fully reserved, redeemable stablecoin, which is \u201cmoney\u201d/\u201cmonetary value\u201d under Finance Code \u00a7 152.003(19); \u201cmoney transmission\u201d is defined at \u00a7 152.003(22) (Money Services Modernization Act; Supervisory Memorandum 1037, rev. Jan. 28, 2025).", "Receiving non-stablecoin virtual currency (e.g., Bitcoin, Ether) alone is not money transmission because it is not \u201cmoney,\u201d but the business may still be a \u201cdigital asset service provider\u201d under Finance Code \u00a7 160.001(6).", "The Department regulates fiat-backed stablecoin issuers as money transmitters and defers to federal law under \u00a7 152.059 (consistent with the federal GENIUS Act); a payment stablecoin issuer must also be a permitted issuer under the GENIUS Act.", "Stablecoin is a permissible investment only to the extent of outstanding same-kind transmission obligations and subject to custody requirements (\u00a7 152.356(a)(6), (a-1), as amended by H.B. 3833, 2025); Texas does not authorize a state CBDC (\u00a7 152.006)." ] }, { "name": "Florida", "slug": "florida", "status": "live", "statusLabel": "Live Regime", "framework": "Money services business licensing (Fla. Stat. ch. 560) reaching virtual currency now; Florida Payment Stablecoin Act (HB 175) adds a stablecoin-issuer license from Oct. 1, 2026; SB 1568 pilot; HB 505 kiosks", "regulator": "Florida Office of Financial Regulation (OFR)", "detail": "Florida regulates money services businesses under Chapter 560 of the Florida Statutes, administered by the Office of Financial Regulation (OFR). Virtual currency is treated as \u201cmonetary value,\u201d so transmitting or exchanging it for others generally requires a Chapter 560 license, a view the OFR aligned with after Florida v. Espinoza. A 2022 amendment (CS/HB 273), effective January 1, 2023, added a statutory definition of \u201cvirtual currency\u201d and eased the rules for direct two-party transactions, so a seller selling virtual currency straight to a buyer no longer needs a license, while third-party transmission remains licensable. On top of this, Florida enacted a package of stablecoin laws signed by Governor DeSantis on June 27, 2026. HB 175, the Florida Payment Stablecoin Act, requires a license from the OFR before issuing a payment stablecoin, with reserves backed one-to-one by cash or similarly safe assets and verified monthly by a CPA, aligning the state with the federal GENIUS Act; its licensing provisions take effect October 1, 2026. SB 1568 establishes a Stablecoin Pilot Program letting the Department of Financial Services accept approved payment stablecoins for certain government fees, effective on enactment. HB 505 requires virtual-currency kiosk operators to register with the OFR. Payment-stablecoin issuance also remains federally governed by the GENIUS Act.", "effective": "Chapter 560 money-services licensing (reaching virtual currency; two-party VC sales exempt since Jan. 1, 2023) in force now; stablecoin package signed June 27, 2026, HB 175 issuer licensing effective Oct. 1, 2026; SB 1568 pilot and HB 505 kiosks effective on enactment", "lastVerified": "2026-08-27", "sourceText": "Fla. Stat. ch. 560 (Money Services Businesses; virtual currency as monetary value; CS/HB 273 2022, eff. Jan. 1 2023); HB 175 Florida Payment Stablecoin Act (eff. Oct. 1, 2026); SB 1568 Stablecoin Pilot; HB 505 kiosks; FL Office of Financial Regulation", "sourceUrl": "https://www.flsenate.gov/Session/Bill/2026/175", "keyPoints": [ "Today: hold a Florida money-services (Chapter 560) license to transmit or exchange virtual currency for others, through the Office of Financial Regulation", "Direct two-party sales of virtual currency (seller straight to buyer) have been exempt from licensing since January 1, 2023 (CS/HB 273)", "From October 1, 2026: to *issue* a payment stablecoin, get the new OFR license under HB 175, back reserves 1:1 with cash or safe assets, verified monthly by a CPA (aligned with the GENIUS Act)", "Virtual-currency kiosk operators must register with the OFR (HB 505)", "Florida is piloting acceptance of approved stablecoins for certain state fees (SB 1568)" ], "summary": "Florida already requires a state license to transmit or exchange virtual currency for others, though since 2023 a direct two-party sale (seller straight to buyer) is exempt. From October 1, 2026, a new law adds a dedicated license to *issue* a payment stablecoin, backed one-to-one by reserves checked monthly. Florida is also piloting acceptance of approved stablecoins for some state fees." }, { "name": "Wyoming", "slug": "wyoming", "status": "excluded", "statusLabel": "VC Exempt + State Issuer", "framework": "Money-transmitter exemption for virtual currency (W.S. 40-22-104); Special Purpose Depository Institution charter (W.S. 13-12-101 et seq.); Wyoming Stable Token Act (W.S. 40-31-101 through 40-31-109; SF0127 / Enrolled Act No. 85, 2023), under which the state issues its own stablecoin", "regulator": "Wyoming Division of Banking", "detail": "Wyoming is the most distinctive state regime, and it works in three layers. First, private activity is exempt: the Wyoming Money Transmitters Act exempts virtual currency from licensing, so buying, selling, issuing, or taking custody of payment instruments in the form of virtual currency, or receiving virtual currency for transmission, does not require a money-transmitter license (W.S. 40-22-104). Wyoming defines these categories precisely: under W.S. 34-29-101, digital assets fall into three mutually exclusive classes, digital consumer assets, digital securities, and virtual currency, and a payment stablecoin (a medium of exchange that is not legal tender) generally sits in the \u201cvirtual currency\u201d class the exemption covers. Second, a chartered-bank route exists: Wyoming created the Special Purpose Depository Institution (SPDI), a state bank charter designed to custody and handle digital assets (W.S. 13-12-101 et seq.), used by digital-asset banks such as Kraken Bank and Custodia. Third, and uniquely in the United States, the state issues its own stablecoin. Under the Wyoming Stable Token Act (W.S. 40-31-101 et seq.), the Wyoming Stable Token Commission issues the Frontier Stable Token (FRNT, launched as WYST in August 2025 and later rebranded), a virtual currency redeemable for one US dollar held in trust by the state (W.S. 40-31-104, 40-31-106). Under the Act\u2019s reserve requirements as amended and the Commission\u2019s rules, the token is backed only by cash, US Treasuries maturing within a year, or short-term Treasury repurchase agreements; a trust account holds 100% of the token\u2019s notional value, plus a separate liquidity fund targeting a further 2% buffer, with surplus earnings directed quarterly to a state school foundation program. FRNT reached mainnet on August 18, 2025 and opened to public purchase on January 7, 2026 across eight blockchains. Private payment-stablecoin issuance also remains federally governed by the GENIUS Act.", "effective": "Virtual currency exempt from money-transmitter licensing (W.S. 40-22-104); SPDI charter available (W.S. 13-12-101 et seq.); state-issued FRNT on mainnet since Aug. 18, 2025 and open to public purchase since Jan. 7, 2026", "lastVerified": "2026-08-27", "sourceText": "W.S. 34-29-101 (digital-asset definitions: consumer asset / security / virtual currency); W.S. 40-22-104 (Money Transmitters Act virtual-currency exemption); W.S. 13-12-101 et seq. (SPDI charter); Wyoming Stable Token Act, W.S. 40-31-101 through 40-31-109 (SF0127 / Enrolled Act No. 85, 2023); Wyoming Stable Token Commission", "sourceUrl": "https://stabletoken.wyo.gov", "keyPoints": [ "No money-transmitter license is required to buy, sell, custody, or transmit virtual currency (including stablecoins) in Wyoming (W.S. 40-22-104)", "Digital-asset banks can instead charter as a Special Purpose Depository Institution (SPDI) (W.S. 13-12-101 et seq.), the route used by Kraken Bank and Custodia", "Wyoming itself issues a stablecoin, the Frontier Stable Token (FRNT), redeemable at $1.00 and fully reserved in cash and short US Treasuries", "FRNT has been open to public purchase since January 7, 2026, live across eight blockchains", "Private payment-stablecoin issuance remains federally governed by the GENIUS Act" ], "summary": "Wyoming is deliberately crypto-friendly and distinctive. It does not require a money-transmitter license to buy, sell, custody, or transmit virtual currency, including stablecoins. Instead it built bespoke structures: a special digital-asset bank charter (SPDI) and, uniquely, its own state-issued stablecoin, the Frontier Stable Token (FRNT)." }, { "name": "Illinois", "slug": "illinois", "status": "pending", "statusLabel": "Phasing In", "framework": "Digital assets: Digital Assets and Consumer Protection Act (DACPA, 205 ILCS 731/) and Digital Asset Kiosks Act (DAKA, 205 ILCS 732/), plus the Digital Asset Tax Act (DATA, 35 ILCS 195/, enacted by SB 3019 / Public Act 104-0468). Money transmission: Uniform Money Transmission Modernization Act (SB 3412), which repealed the Transmitters of Money Act effective Jan. 1, 2026.", "regulator": "Illinois Department of Financial and Professional Regulation (IDFPR)", "detail": "Illinois has built a comprehensive digital-asset framework through four instruments, most of which phase in over 2026\u20132027. Money transmission was overhauled first: SB 3412 enacted the Uniform Money Transmission Modernization Act and expressly repealed the Transmitters of Money Act effective January 1, 2026 (\u00a7 900-30), moving Illinois to NMLS-based multistate licensing. Illinois did not adopt the model act\u2019s optional virtual-currency provisions, so the money-transmission statute does not expressly reach virtual-currency or stablecoin transmission. Digital assets are instead addressed by two laws signed August 18, 2025. The Digital Assets and Consumer Protection Act (DACPA, 205 ILCS 731/, Public Act 104-0428) requires any person engaged in \u201cdigital asset business activity\u201d, exchanging, transferring, or storing digital assets for Illinois residents, or digital-asset administration, to register with the Department of Financial and Professional Regulation (IDFPR). Its \u201cdigital asset\u201d definition is drawn to capture stablecoins: assets not marketed for investment are generally excluded, except where the instrument is marketed to hold a nominal value \u201cso stable as to render the nominal value effectively fixed.\u201d DACPA\u2019s prohibitions are not enforced until January 1, 2027, and registration is not required until July 1, 2027 (implementing rules may not take effect before January 1, 2026). The Digital Asset Kiosks Act (DAKA, 205 ILCS 732/, Public Act 104-0429) requires crypto-kiosk operators to register with IDFPR, caps daily kiosk transactions at $2,500 for new customers and $10,500 for existing customers, limits per-transaction fees to the greater of $5 or 18%, and mandates disclosures; existing operators must register by July 1, 2027. Finally, the Digital Asset Tax Act (DATA, 35 ILCS 195/), enacted as Article 3 of the FY2027 revenue bill (SB 3019, Public Act 104-0468), imposes, beginning January 1, 2027, a 0.2% tax on the privilege of receiving digital-asset business activity (exchanging, transferring, or storing digital assets) by an Illinois customer, collected by \u201cdigital asset brokers\u201d (defined by reference to IRC \u00a7 6045(c)(1)(D)) and reaching out-of-state brokers whose gross receipts from Illinois customers reach $100,000 or more, tested quarterly. Returns and payment are due monthly, on or before the 20th, and the tax is administered by the Illinois Department of Revenue (the Act adopts DACPA\u2019s definition of \u201cdigital asset,\u201d so its stablecoin coverage carries into the tax). Illinois is therefore classified as phasing in: the dedicated regime is enacted but its core registration, kiosk, and tax obligations are not enforced until 2027.", "effective": "DACPA/DAKA core obligations enforced Jan. 1, 2027 and registration required by Jul. 1, 2027 (agency rules no earlier than Jan. 1, 2026); DATA (0.2% tax) effective Jan. 1, 2027 with broker registration before then; MTMA (SB 3412) effective Jan. 1, 2026 (Transmitters of Money Act repealed).", "lastVerified": "2026-09-02", "sourceText": "\u201c\u2018Digital asset\u2019 \u2026 does not include \u2026 (4) A digital representation of value that is not marketed, used, promoted, offered, or sold for investment or speculation, except that this exclusion shall not apply to any digital representation of value that \u2026 (B) is marketed \u2026 in a manner that intends to establish a reasonable expectation or belief among the general public that the instrument will retain a nominal value that is so stable as to render the nominal value effectively fixed.\u201d (DACPA, 205 ILCS 731/)", "sourceUrl": "https://www.ilga.gov/legislation/ILCS/details?MajorTopic=REGULATION&Chapter=FINANCIAL+REGULATION&ActName=Digital+Assets+and+Consumer+Protection+Act.&ActID=4632&ChapterID=20&SeqStart=&ChapAct=FullText", "keyPoints": [ "Today: money transmission is governed by the new Uniform Money Transmission Modernization Act (SB 3412), which repealed the Transmitters of Money Act effective Jan. 1, 2026; Illinois did not adopt the model act\u2019s optional virtual-currency provisions, so the money-transmission law does not expressly license virtual-currency or stablecoin transmission", "From Jan. 1, 2027, DACPA (205 ILCS 731/): businesses that exchange, transfer, store, or administer digital assets for Illinois residents must register with IDFPR; the \u201cdigital asset\u201d definition expressly captures stablecoins (instruments marketed to hold a nominal value \u201cso stable as to render the nominal value effectively fixed\u201d). Prohibitions enforced Jan. 1, 2027; registration required by Jul. 1, 2027", "DAKA (205 ILCS 732/): crypto-kiosk operators must register with IDFPR; daily caps of $2,500 (new customers) and $10,500 (existing); per-transaction fees capped at the greater of $5 or 18%; existing operators register by Jul. 1, 2027", "Digital Asset Tax Act (DATA, 35 ILCS 195/; SB 3019 / Public Act 104-0468, Art. 3): a 0.2% tax on the privilege of receiving digital-asset business activity (exchange, transfer, storage/custody) by a customer in Illinois, collected by \u201cdigital asset brokers,\u201d reaching remote brokers with at least $100,000 in annual Illinois receipts (tested quarterly); returns and payment due monthly by the 20th; effective Jan. 1, 2027 (administered by the Illinois Department of Revenue)" ], "summary": "Illinois has enacted a comprehensive digital-asset framework, a consumer-protection registration law (DACPA), a crypto-kiosk law (DAKA), and the nation's first state digital-asset transaction tax (DATA), but the core obligations are not yet enforced and phase in over 2026\u20132027. Today, Illinois money-transmission law (the new Uniform Money Transmission Modernization Act, which repealed the Transmitters of Money Act on Jan. 1, 2026) does not expressly reach virtual-currency transmission. From 2027, digital-asset businesses, stablecoin activity included, must register with IDFPR, and the transaction tax takes effect." }, { "name": "Colorado", "slug": "colorado", "status": "live", "statusLabel": "Live Regime", "framework": "Colorado Money Transmission Modernization Act (HB 25-1201). The Division of Banking treats crypto exchanges that handle fiat or issue stablecoins as money transmitters. Colorado also regulates virtual-currency kiosks (Vending of Digital Assets Act, C.R.S. art. 112 of title 11) and exempts consumptive-purpose digital tokens from securities registration (Colorado Digital Token Act, C.R.S. \u00a7 11-51-308.7).", "regulator": "Colorado Division of Banking", "detail": "Colorado repealed and reenacted its money-transmission law as the Money Transmission Modernization Act through HB 25-1201 (effective August 6, 2025), administered by the Colorado Banking Board and Division of Banking. The statute contains no express virtual-currency language; its coverage of crypto turns on Division guidance. Under the Division\u2019s longstanding position (2018 interim guidance, updated by the December 18, 2025 Interim Guidance on Cryptocurrency and the MTMA), transmitting only cryptocurrency with no fiat involved does not require a license, but exchanges that transmit funds for users, facilitate fiat-to-crypto conversion, or issue stablecoins do need a Colorado money-transmitter license. Separately, the Colorado Vending of Digital Assets Act (C.R.S. art. 112 of title 11) regulates virtual-currency kiosks, requiring on-screen disclosures and receipts and capping daily kiosk transactions at $2,000 for new customers and $10,500 for existing customers, with cancellation and refund rights (C.R.S. \u00a7 11-112-103). The Colorado Digital Token Act (C.R.S. \u00a7 11-51-308.7) exempts a digital token from state securities registration where the token has a primarily consumptive purpose and is not marketed as an investment.", "effective": "Signed Apr. 18, 2025; effective Aug. 6, 2025", "lastVerified": "2026-09-02", "sourceText": "Colorado General Assembly, HB 25-1201", "sourceUrl": "https://leg.colorado.gov/bills/hb25-1201", "summary": "Colorado\u2019s Division of Banking treats crypto exchanges that handle fiat or issue stablecoins as money transmitters requiring a license, while pure crypto-to-crypto transmission is exempt. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "Obtain a Colorado money-transmitter license from the Division of Banking before operating a crypto exchange that transmits funds for users, facilitates fiat-to-crypto conversion, or issues stablecoins (Money Transmission Modernization Act, HB 25-1201; Division Interim Guidance, Dec. 18, 2025).", "Transmitting only cryptocurrency, with no fiat currency involved, does not require a Colorado license.", "Virtual-currency kiosk operators must give on-screen disclosures and receipts and observe daily caps of $2,000 (new customers) and $10,500 (existing) (Vending of Digital Assets Act, C.R.S. \u00a7 11-112-103).", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Washington", "slug": "washington", "status": "live", "statusLabel": "Live Regime", "framework": "Washington Uniform Money Services Act (RCW ch. 19.230). The definition of \u201cmoney transmission\u201d includes virtual currency as \u201cequivalent value\u201d (RCW 19.230.010), so virtual-currency transmission requires a money-transmitter license.", "regulator": "Washington State Department of Financial Institutions", "detail": "Washington writes virtual currency directly into its money-transmission framework rather than creating a separate crypto license. Under the Uniform Money Services Act (RCW ch. 19.230), \u201cmoney transmission\u201d means receiving money or its equivalent value, where equivalent value includes virtual currency, to transmit or deliver to another location (RCW 19.230.010), and \u201cvirtual currency\u201d is defined as a digital representation of value used as a medium of exchange, unit of account, or store of value lacking legal-tender status. Businesses transmitting virtual currency for Washington customers must be licensed by the Department of Financial Institutions, and virtual-currency licensees face additional requirements such as like-kind reserve holdings and security controls.", "effective": "In force", "lastVerified": "2026-09-02", "sourceText": "Washington Uniform Money Services Act, RCW 19.230.010: \u201cmoney transmission\u201d includes virtual currency as equivalent value, so virtual-currency transmission requires a money-transmitter license.", "sourceUrl": "https://app.leg.wa.gov/rcw/default.aspx?cite=19.230.010", "summary": "Washington writes virtual currency into its money-transmission definition, so virtual-currency transmission requires a money-transmitter license. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "Obtain a Washington money-transmitter license from the Department of Financial Institutions before transmitting virtual currency for Washington customers (Uniform Money Services Act, RCW 19.230.010, where \u201cmoney transmission\u201d includes virtual currency).", "Virtual-currency licensees face additional requirements such as like-kind reserve holdings and security controls.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Arizona", "slug": "arizona", "status": "live", "statusLabel": "Live Regime", "framework": "CSBS Money Transmission Modernization Act (SB 1580, 2022)", "regulator": "Arizona Department of Insurance and Financial Institutions", "detail": "Arizona replaced its prior money-transmitter statute with the CSBS Money Transmission Modernization Act in 2022 (SB 1580, Ch. 236), codified at A.R.S. \u00a7\u00a7 6-1201 et seq., administered by the Department of Insurance and Financial Institutions (DIFI). The Act does not separately address virtual currency, but its definition of \u201cmoney transmission\u201d reaches the transmission of \u201cmonetary value\u201d (a medium of exchange, whether or not redeemable in money), which DIFI applies to virtual-currency activity in practice; major exchanges (Coinbase, Binance, Gemini) hold Arizona money-transmitter licenses. Pure crypto-to-crypto transmission with no fiat involved is a closer question, but virtual-currency businesses serving Arizona customers generally license.", "effective": "Signed May 20, 2022", "lastVerified": "2026-09-02", "sourceText": "A.R.S. Title 6, Chapter 12 (SB 1580, Ch. 236, 2022)", "sourceUrl": "https://www.azleg.gov/viewdocument/?docName=https://www.azleg.gov/ars/6/01201.htm", "summary": "In Arizona, virtual-currency money transmission is licensed in practice under the Money Transmission Modernization Act: the Act has no express virtual-currency provision, but its broad \u201cmonetary value\u201d definition is applied to crypto, and major exchanges hold Arizona licenses. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "Obtain an Arizona money-transmitter license from the Department of Insurance and Financial Institutions (via NMLS) before transmitting virtual currency for Arizona residents; the Act has no express virtual-currency provision, but DIFI applies the broad \u201cmonetary value\u201d definition to crypto in practice (A.R.S. \u00a7\u00a7 6-1201, 6-1202; SB 1580 (2022)).", "Pure crypto-to-crypto transmission with no fiat involved is a closer question; exemptions are at A.R.S. \u00a7\u00a7 6-1202 and 6-1203.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Georgia", "slug": "georgia", "status": "live", "statusLabel": "Live Regime", "framework": "Georgia Payment Stablecoin Act (HB 1272)", "regulator": "Georgia Department of Banking and Finance", "detail": "Georgia enacted the Georgia Payment Stablecoin Act (HB 1272) in 2026, a dedicated licensing regime for payment stablecoin issuers, but it is not yet in force. Under Section 4, and subject to appropriations by the General Assembly, it becomes effective on the earlier of January 18, 2027 or 120 days after the issuance of final federal GENIUS Act implementing regulations. The Act carves payment stablecoin issuance out of Georgia's existing money transmission laws and authorizes the Department of Banking and Finance to license issuers, on a framework the statute requires to be substantially similar to the GENIUS Act. Licensed issuers must back outstanding stablecoins one-to-one with liquid reserves held in trust for consumers and maintain redemption policies. Beginning July 18, 2028, it becomes unlawful to offer or sell a payment stablecoin in Georgia unless the issuer is a permitted, licensed, or federally qualified issuer. Separately, some virtual-currency money transmission already requires a license under O.C.G.A. Sec. 7-1-680 et seq.", "effective": "Enacted 2026; effective (subject to state appropriations) the earlier of Jan. 18, 2027 or 120 days after federal GENIUS Act final rules; issuer requirement from Jul. 18, 2028", "lastVerified": "2026-09-02", "sourceText": "\u201cIssuance of payment stablecoin shall not be considered to be money transmission as defined by Code Section 7-1-680.\u2026 Subject to appropriations by the General Assembly, this Act shall become effective upon the earlier of: (1) January 18, 2027; or (2) 120 days after the issuance of final implementing regulations for the GENIUS Act.\u201d (HB 1272)", "sourceUrl": "https://www.legis.ga.gov/api/legislation/document/20252026/249038", "keyPoints": [ "Today: transmitting or issuing a stablecoin requires a Georgia money transmitter license, \u201cvirtual currency\u201d falls within the money-transmission definition (O.C.G.A. \u00a7 7-1-680), administered by the Department of Banking and Finance (recent enforcement: a Jan. 2026 cease-and-desist against a crypto-kiosk operator)", "When the Georgia Payment Stablecoin Act takes effect (the earlier of Jan. 18, 2027 or 120 days after final GENIUS Act rules, subject to state appropriations): only a permitted payment stablecoin issuer may issue a payment stablecoin, licensed by the Department on a framework the statute requires to be \u201csubstantially similar to the GENIUS Act\u201d", "Once effective: issuing a payment stablecoin is no longer \u201cmoney transmission\u201d under \u00a7 7-1-680, a permitted issuer needs no separate money-transmission license to issue, sell, or redeem (but still needs one for other money-transmission activity)", "From July 18, 2028: it is unlawful to offer or sell a payment stablecoin in Georgia unless it is issued by a licensed, permitted, or state qualified payment stablecoin issuer" ], "summary": "Georgia has enacted a dedicated stablecoin-issuer licensing law, the Georgia Payment Stablecoin Act (HB 1272), but it is not yet in force. Until it takes effect, issuing or transmitting a stablecoin in Georgia falls under the state's existing money-transmitter licensing. Once effective, stablecoin issuance moves to the new regime and is no longer treated as money transmission." }, { "name": "North Carolina", "slug": "north-carolina", "status": "live", "statusLabel": "Live Regime", "framework": "Money Transmitters Act (N.C. Gen. Stat. Ch. 53, Art. 16B)", "regulator": "North Carolina Office of the Commissioner of Banks", "detail": "North Carolina regulates stablecoin and virtual-currency activity through its Money Transmitters Act (Chapter 53, Article 16B), administered by the Office of the Commissioner of Banks (NCCOB). The statute expressly defines virtual currency and brings money transmission conducted in whole or in part in virtual currency, including maintaining control of virtual currency on behalf of others, within its licensing requirement. A person engaging in money transmission must obtain a license through NMLS; the license is perpetual but requires an annual NMLS renewal filing. North Carolina does not yet have a dedicated stablecoin-issuer statute. A separate bill, the Virtual Currency Kiosk Consumer Protection Act (HB 920), would place crypto-ATM operators under NCCOB supervision, with implementing rules due by December 1, 2026.", "effective": "Money Transmitters Act in force; virtual currency covered; kiosk bill (HB 920) pending, rules due Dec. 1, 2026", "lastVerified": "2026-09-02", "sourceText": "N.C. Gen. Stat. Ch. 53, Art. 16B (Money Transmitters Act); NC Office of the Commissioner of Banks", "sourceUrl": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/ByArticle/Chapter_53/Article_16B.html", "summary": "North Carolina licenses virtual-currency transmission under its Money Transmitters Act. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "Obtain a North Carolina money-transmitter license from the Office of the Commissioner of Banks before transmitting virtual currency for North Carolina residents (Money Transmitters Act, N.C. Gen. Stat. ch. 53, art. 16B).", "Meet the licensing law\u2019s prudential requirements (surety bond or net worth, permissible investments or reserve holdings) and comply with AML, reporting, and consumer-disclosure obligations.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Connecticut", "slug": "connecticut", "status": "live", "statusLabel": "Live Regime", "framework": "Money Transmission Act (virtual currency revisions, PA 25-66 / HB 7082)", "regulator": "Connecticut Department of Banking", "detail": "Connecticut revised its money transmission law to regulate virtual currency, effective October 1, 2025, administered by the Department of Banking. A person engaged in virtual currency business in Connecticut, by receiving, transmitting, storing, or maintaining custody or control of virtual currency, must hold virtual currency of the same type and amount owed or obligated to each customer. Licensees may not lend, hypothecate, pledge, or otherwise use or encumber customer virtual currency without authorization, and the act extends risk-disclosure and receipt requirements to virtual currency transmitters and kiosk operators. Custody may be delegated only to parties qualified to hold it.", "effective": "In force since Oct. 1, 2025", "lastVerified": "2026-09-02", "sourceText": "Conn. Public Act 25-66 (HB 7082); CT Dept. of Banking", "sourceUrl": "https://www.cga.ct.gov/2025/SUM/PDF/2025SUM00066-R03HB-07082-SUM.PDF", "summary": "Connecticut\u2019s Money Transmission Act covers virtual currency, as revised by PA 25-66 (HB 7082), so virtual-currency transmission requires a license. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "Obtain a Connecticut money-transmitter license from the Department of Banking before transmitting virtual currency for Connecticut residents (Money Transmission Act, virtual-currency revisions in PA 25-66 / HB 7082).", "Meet the licensing law\u2019s prudential requirements (surety bond or net worth, permissible investments or reserve holdings) and comply with AML, reporting, and consumer-disclosure obligations.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Nevada", "slug": "nevada", "status": "guidance", "statusLabel": "Guidance-Based", "framework": "CSBS Money Transmission Modernization Act (NRS Ch. 671, enacted by A.B. 21, 2023); virtual currency covered by FID guidance", "regulator": "Nevada Financial Institutions Division", "detail": "Nevada enacted the CSBS Model Money Transmission Modernization Act through A.B. 21 (2023), modernizing its money transmission law at NRS Chapter 671, but it did not adopt the model's optional virtual-currency title (Article XIII). NRS Chapter 671 therefore does not expressly mention virtual or digital currency. Instead, the Financial Institutions Division (FID), through published guidance, applies the money-transmission licensing requirement to entities that transmit or hold digital currency, by kiosk, mobile, internet, or other means. Under that guidance, Bitcoin ATM operators must hold a money transmitter license and bond, and licensees holding virtual currency are expected to keep enough of each type to cover outstanding customer obligations. Entities acting purely as digital-asset custodians may instead be regulated as trust companies under NRS Chapter 669. Nevada thus regulates digital assets case by case under its MTMA-based money transmission law rather than a bespoke virtual-currency framework.", "effective": "MTMA enacted via A.B. 21 (2023) at NRS Ch. 671; digital currency covered by FID guidance, not the optional Article XIII virtual-currency title", "lastVerified": "2026-09-02", "sourceText": "NRS Ch. 671, enacted by A.B. 21 (2023) adopting the CSBS Model MTMA without the optional virtual-currency title; digital currency covered by Nevada FID guidance", "sourceUrl": "https://www.leg.state.nv.us/nrs/nrs-671.html", "summary": "Nevada adopted the Money Transmission Modernization Act, and the Financial Institutions Division\u2019s guidance treats virtual-currency activity as covered. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "Obtain a Nevada money-transmitter license under NRS ch. 671 (Money Transmission Modernization Act, A.B. 21 (2023)) before engaging in covered virtual-currency activity; the Financial Institutions Division applies the Act to virtual currency by guidance.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Maine", "slug": "maine", "status": "live", "statusLabel": "Live Regime", "framework": "Maine Money Transmission Modernization Act (32 M.R.S. ch. 80; LD 2112, effective Aug. 9, 2024). Maine adopted the model act\u2019s virtual-currency provisions, so virtual-currency business activity is licensed.", "regulator": "Maine Bureau of Consumer Credit Protection", "detail": "Maine enacted the Maine Money Transmission Modernization Act through LD 2112 (signed April 22, 2024, effective August 9, 2024), codified in 32 M.R.S. ch. 80 and administered by the Bureau of Consumer Credit Protection. Maine is one of only three states (with Minnesota and North Dakota) to adopt the model act\u2019s virtual-currency provisions: it defines virtual currency as a digital representation of value used as a medium of exchange, unit of account, or store of value that is not money, and requires a license for virtual-currency business activity, including exchanging, transferring, storing, or administering virtual currency (virtual-currency administration meaning issuing virtual currency with authority to redeem it for money, bank credit, or other virtual currency). The Bureau has begun issuing advisory rulings under the new statute.", "effective": "Maine Money Transmission Modernization Act (LD 2112) in force since Aug. 9, 2024; virtual currency business activity covered", "lastVerified": "2026-09-02", "sourceText": "Maine Money Transmission Modernization Act, 32 M.R.S. ch. 80 (LD 2112, eff. Aug. 9, 2024); Maine adopted the virtual-currency business-activity provisions.", "sourceUrl": "https://www.mainelegislature.org/legis/statutes/32/title32ch80.pdf", "summary": "Maine licenses virtual-currency business activity under its Money Transmission Modernization Act, which adopted the model act\u2019s virtual-currency provisions. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "Obtain a Maine license from the Bureau of Consumer Credit Protection before engaging in virtual-currency business activity, including exchanging, transferring, storing, or administering virtual currency (32 M.R.S. ch. 80; LD 2112).", "Meet the licensing law\u2019s prudential requirements (surety bond or net worth, permissible investments or reserve holdings) and comply with AML, reporting, and consumer-disclosure obligations.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "New Hampshire", "slug": "new-hampshire", "status": "excluded", "statusLabel": "VC Excluded", "framework": "New Hampshire money-transmitter licensing law (RSA 399-G). HB 436 (2017) added an exemption in RSA 399-G:3 for persons dealing solely in convertible virtual currency, so virtual-currency transmission is not licensed.", "regulator": "New Hampshire Banking Department", "detail": "New Hampshire requires a money-transmitter license under RSA 399-G, administered by the Banking Department, but HB 436 (2017), effective August 1, 2017, added an exemption in RSA 399-G:3 for persons who sell or issue payment instruments or stored value solely in the form of convertible virtual currency, or who receive convertible virtual currency for transmission. As a result, a virtual-currency-only business is exempt from money-transmitter licensing in New Hampshire, though it remains subject to certain state consumer-protection laws. \u201cConvertible virtual currency\u201d is defined in RSA 399-G:1.", "effective": "RSA 399-G:3, VII exempts persons dealing solely in convertible virtual currency from licensing (fiat-touching activity still licensed; RSA 358-A Consumer Protection Act still applies)", "lastVerified": "2026-09-02", "sourceText": "New Hampshire RSA 399-G:3 exempts persons dealing solely in convertible virtual currency from money-transmitter licensing (added by HB 436 (2017)); \u201cconvertible virtual currency\u201d defined at RSA 399-G:1.", "sourceUrl": "https://gc.nh.gov/rsa/html/XXXVI/399-G/399-G-mrg.htm", "summary": "New Hampshire exempts persons dealing solely in convertible virtual currency from money-transmitter licensing. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "No New Hampshire money-transmitter license is required for a business dealing solely in convertible virtual currency (RSA 399-G:3 exemption, added by HB 436 (2017)); such persons remain subject to certain state consumer-protection laws.", "Federal FinCEN money-services-business registration and a Bank Secrecy Act / AML program still apply to virtual-currency businesses regardless of state licensing.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Rhode Island", "slug": "rhode-island", "status": "live", "statusLabel": "Live Regime", "framework": "Rhode Island Currency Transmissions law (R.I. Gen. Laws ch. 19-14.3), administered by the Department of Business Regulation; its currency-transmitter licensing applies to virtual currency. HB 7282 (2024) added Money Transmission Modernization Act net-worth and permissible-investment provisions.", "regulator": "Rhode Island Department of Business Regulation", "detail": "Rhode Island regulates currency transmission under its Currency Transmissions law (R.I. Gen. Laws ch. 19-14.3), administered by the Department of Business Regulation, and its currency-transmitter licensing applies to virtual-currency services. HB 7282 (2024) amended the statute to add Money Transmission Modernization Act provisions, including minimum tangible net worth and permissible-investment requirements, extending consumer protections to currency (including cryptocurrency) transmitters. A person engaged in currency transmission, including transmitting virtual currency, for Rhode Island customers must be licensed.", "effective": "Currency Transmissions law (R.I. Gen. Laws Ch. 19-14) in force; applies to virtual currency; MTMA provisions added by H.B. 7282 (2024)", "lastVerified": "2026-09-02", "sourceText": "Rhode Island Currency Transmissions law, R.I. Gen. Laws ch. 19-14.3 (Department of Business Regulation); currency-transmitter licensing applies to virtual currency, with net-worth and permissible-investment provisions added by HB 7282 (2024).", "sourceUrl": "https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.3/INDEX.htm", "summary": "Rhode Island\u2019s Currency Transmissions law covers virtual currency, so virtual-currency transmission requires a license. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "Obtain a Rhode Island currency-transmission license from the Department of Business Regulation before transmitting money or virtual currency for Rhode Island customers (Currency Transmissions law, R.I. Gen. Laws ch. 19-14.3).", "Meet the licensing law\u2019s prudential requirements (surety bond or net worth, permissible investments or reserve holdings) and comply with AML, reporting, and consumer-disclosure obligations.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "New Jersey", "slug": "new-jersey", "status": "excluded", "statusLabel": "VC Unsettled", "framework": "New Jersey Money Transmitters Act (N.J.S.A. 17:15C-1 et seq.; definitions at 17:15C-2). Virtual-currency treatment is unsettled: there is no enacted virtual-currency statute, and the Digital Asset and Blockchain Technology Act (A3454) remains pending.", "regulator": "New Jersey Department of Banking and Insurance", "detail": "New Jersey\u2019s treatment of virtual currency is unsettled. Money transmission is licensed under the New Jersey Money Transmitters Act (N.J.S.A. 17:15C-1 et seq.), administered by the Department of Banking and Insurance, and the Department has historically treated some crypto firms as money transmitters, but New Jersey has not enacted an express virtual-currency licensing statute. The proposed Digital Asset and Blockchain Technology Act (A3454), which would create a dedicated digital-asset business licensing regime under the Bureau of Securities, remains pending in the Legislature and is not law. Until a dedicated regime is enacted, virtual-currency activity is governed, if at all, through the existing money-transmission framework.", "effective": "Money Transmitters Act (N.J.S.A. 17:15C) in force but virtual-currency fit is awkward and unsettled; dedicated Digital Asset Business Act (A3454) pending, not enacted", "lastVerified": "2026-09-02", "sourceText": "New Jersey Money Transmitters Act, N.J.S.A. 17:15C-1 et seq.; New Jersey has not enacted an express virtual-currency statute, and the Digital Asset and Blockchain Technology Act (A3454) remains pending.", "sourceUrl": "https://www.nj.gov/dobi/banklicensing/formontrans.html", "summary": "New Jersey\u2019s virtual-currency treatment is unsettled: there is no enacted virtual-currency statute, and the proposed Digital Asset and Blockchain Technology Act remains pending. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "New Jersey has no enacted virtual-currency licensing statute; money transmission is licensed under the Money Transmitters Act (N.J.S.A. 17:15C-1 et seq.), and the Department of Banking and Insurance has historically treated some crypto firms as money transmitters.", "The dedicated Digital Asset and Blockchain Technology Act (A3454) remains pending and is not law; treatment of pure virtual-currency activity is unsettled.", "Federal FinCEN money-services-business registration and a Bank Secrecy Act / AML program still apply to virtual-currency businesses regardless of state licensing.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Delaware", "slug": "delaware", "status": "live", "statusLabel": "Live Regime", "framework": "Sale of Checks and Transmission of Money Act (5 Del. C. Ch. 23); Money Transmission and Virtual Currency Modernization Act (SB 18, enacted 2026)", "regulator": "Delaware Office of the State Bank Commissioner", "detail": "Delaware modernized its money-transmission law through SB 18, the Delaware Money Transmission and Virtual Currency Modernization Act, signed July 7, 2026, which repealed the former Chapter 23 of Title 5 and replaced it with a framework that expressly covers virtual currency, administered by the Office of the State Bank Commissioner. The Act creates a licensing framework for companies that exchange, transfer, or store virtual currency for customers (with licensing, net worth, surety bond, permissible-investment, and disclosure requirements, and NMLS participation), while leaving peer-to-peer activity, software development, and noncustodial technology outside its scope. Virtual currency held by a licensee is a proportional property interest protected from creditor claims. Some provisions await implementing regulations.", "effective": "Sale of Checks Act (Ch. 23) in force and applied to virtual currency; SB 18 signed July 2026, effective the earlier of 1 year after enactment (~July 2027) or upon final regulations", "lastVerified": "2026-09-02", "sourceText": "5 Del. C. Ch. 23; Del. SB 18 (Money Transmission and Virtual Currency Modernization Act, enacted 2026); Office of the State Bank Commissioner", "sourceUrl": "https://legis.delaware.gov/BillDetail/143117", "summary": "Delaware licenses virtual-currency business activity under its Money Transmission and Virtual Currency Modernization Act (SB 18, 2026), which expressly covers exchanging, transferring, or storing virtual currency for customers. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "Obtain a Delaware license from the Office of the State Bank Commissioner before exchanging, transferring, or storing virtual currency for customers (Money Transmission and Virtual Currency Modernization Act, SB 18 (2026), replacing 5 Del. C. ch. 23).", "Peer-to-peer activity, software development, and noncustodial technology are outside the Act\u2019s scope.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Maryland", "slug": "maryland", "status": "live", "statusLabel": "Live Regime", "framework": "Maryland Money Transmission Act (Md. Code, Fin. Inst. \u00a7 12-401 et seq.; license required at \u00a7 12-405). The Office of the Commissioner of Financial Regulation treats virtual-currency transmission as licensable money transmission.", "regulator": "Maryland Office of the Commissioner of Financial Regulation", "detail": "Maryland regulates money transmission under the Maryland Money Transmission Act (Md. Code, Fin. Inst. \u00a7 12-401 et seq.; a license is required under \u00a7 12-405), administered by the Office of the Commissioner of Financial Regulation (OFR). OFR\u2019s position is that money transmission includes the transmission of virtual currency: receiving cryptocurrency from a customer and transferring it is regulated money transmission, so virtual-currency transmission for Maryland customers is licensable. Proposed legislation (SB 759, 2026) would codify the virtual-currency licensing requirement explicitly.", "effective": "Money Transmission Act in force (OFR: crypto transmission licensed); digital-asset authority via SB 759 (eff. June 1, 2026); VC kiosk registration rule eff. Mar. 30, 2026", "lastVerified": "2026-09-02", "sourceText": "Maryland Money Transmission Act, Md. Code, Fin. Inst. \u00a7 12-405 (license required); the Office of the Commissioner of Financial Regulation treats transmission of virtual currency as regulated money transmission.", "sourceUrl": "https://www.dllr.state.md.us/finance/industry/moneytran.shtml", "summary": "Maryland\u2019s Office of the Commissioner of Financial Regulation treats virtual-currency transmission as licensable money transmission under the Maryland Money Transmission Act. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "Obtain a Maryland money-transmitter license from the Office of the Commissioner of Financial Regulation before transmitting virtual currency for Maryland customers (Maryland Money Transmission Act, Md. Code, Fin. Inst. \u00a7 12-405; OFR treats receiving and transferring cryptocurrency as money transmission).", "Meet the licensing law\u2019s prudential requirements (surety bond or net worth, permissible investments or reserve holdings) and comply with AML, reporting, and consumer-disclosure obligations.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Virginia", "slug": "virginia", "status": "excluded", "statusLabel": "VC Excluded", "framework": "Money Transmission Modernization Act (HB 1942, Ch. 19.1)", "regulator": "Virginia State Corporation Commission, Bureau of Financial Institutions", "detail": "Virginia\u2019s Money Transmission Modernization Act (HB 1942, 2025 Acts of Assembly ch. 214) repealed the former Chapter 19 of Title 6.2 and replaced it with Chapter 19.1 (Va. Code \u00a7\u00a7 6.2-1922 to 6.2-1957), effective July 1, 2026, administered by the State Corporation Commission\u2019s Bureau of Financial Institutions. The Act expressly keeps virtual currency outside money transmission: \u201cmoney\u201d is defined as a government-authorized medium of exchange and does not include virtual currency (Va. Code \u00a7 6.2-1922), and a business engaged solely in transmitting virtual currency, without also transmitting money, payment instruments, or stored value, falls outside Chapter 19.1. A business that also handles fiat (for example, a fiat on/off-ramp) may still need a license for that activity.", "effective": "MTMA (HB 1942, Acts ch. 214) effective July 1, 2026; virtual currency expressly excluded from 'money' (Sec. 6.2-1922, Ch. 19.1)", "lastVerified": "2026-09-02", "sourceText": "Va. Code Sec. 6.2-1922 (Ch. 19.1, eff. Jul. 1, 2026; HB 1942 / Acts ch. 214); SCC Bureau of Financial Institutions", "sourceUrl": "https://law.lis.virginia.gov/vacode/title6.2/chapter19.1/section6.2-1922/", "summary": "Virginia expressly excludes virtual currency from money transmission: its Money Transmission Modernization Act defines \u201cmoney\u201d to exclude virtual currency, so transmitting only virtual currency is outside the licensing regime. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "No Virginia money-transmitter license is required for a business that transmits only virtual currency (Money Transmission Modernization Act, Va. Code \u00a7 6.2-1922; \u201cmoney\u201d does not include virtual currency, and solely-virtual-currency transmission falls outside Chapter 19.1, effective July 1, 2026).", "A business that also transmits fiat currency, payment instruments, or stored value may still need a license for that activity.", "Federal FinCEN money-services-business registration and a Bank Secrecy Act / AML program still apply to virtual-currency businesses regardless of state licensing.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "South Carolina", "slug": "south-carolina", "status": "excluded", "statusLabel": "VC Excluded", "framework": "South Carolina Uniform Money Services Act (Title 35, Ch. 11; adopts the CSBS MTMA); S163 (2026) digital-asset exemptions", "regulator": "South Carolina Office of the Attorney General", "detail": "South Carolina regulates money transmission under the South Carolina Uniform Money Services Act (Title 35, Chapter 11, Article 2), administered by the Attorney General\u2019s office (the chapter, originally the Anti-Money Laundering Act, was renamed by 2024 Act No. 218). S163 (the digital-asset / cryptocurrency law), signed May 20, 2026, provides express exemptions from money-transmitter licensing for a range of crypto activities, including digital-asset mining, node operation, crypto-to-crypto trading, and staking-as-a-service, and bars state and local agencies from accepting a central bank digital currency. Virtual-currency activity of these kinds is therefore not licensed; a business that also handles fiat may still need a money-transmitter license for that activity.", "effective": "Uniform Money Services Act in force (Division: VC not 'monetary value'); S163 (2026) statutorily exempts crypto-to-crypto without legal tender, mining, nodes, and blockchain development from money-transmitter licensing", "lastVerified": "2026-09-02", "sourceText": "S.C. Code Title 35, Ch. 11 (Uniform Money Services Act); S.C. S163 (2026); Money Services Division", "sourceUrl": "https://www.scstatehouse.gov/sess126_2025-2026/bills/163.htm", "summary": "South Carolina exempts core crypto activities (mining, node operation, crypto-to-crypto trading, staking) from money-transmitter licensing under S163 (2026), so virtual-currency-only activity is largely outside state licensing. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "No South Carolina money-transmitter license is required for digital-asset mining, node operation, crypto-to-crypto trading, or staking-as-a-service (S163 (2026) exemptions to the Uniform Money Services Act, Title 35, ch. 11, art. 2, administered by the Attorney General).", "A business that also transmits fiat currency may still need a money-transmitter license for that activity.", "Federal FinCEN money-services-business registration and a Bank Secrecy Act / AML program still apply to virtual-currency businesses regardless of state licensing.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Massachusetts", "slug": "massachusetts", "status": "live", "statusLabel": "Live Regime", "framework": "Money Transmission Law (Ch. 312 of the Acts of 2024; MGL c. 169B)", "regulator": "Massachusetts Division of Banks", "detail": "Massachusetts overhauled its money transmission regime with Chapter 312 of the Acts of 2024, codified as MGL c. 169B ('Regulation of Money Transmission') and administered by the Division of Banks. The Division began licensing and regulating money transmitters under c. 169B effective January 1, 2026 (NMLS applications opened around July 1, 2025). The Division has stated that most common transactional virtual currencies, expressly including stablecoins such as USDC, are a form of 'monetary value' under c. 169B, Sec. 1, so virtual-currency transmission requires a license. Non-convertible or closed-loop currencies (for example, in-game currency) are not 'monetary value.' The law is consumer-protection focused, covering money transmission for personal, family, or household purposes.", "effective": "MGL c. 169B (Ch. 312, Acts of 2024); licensing effective Jan. 1, 2026; Division treats transactional virtual currency including USDC as 'monetary value' (licensed)", "lastVerified": "2026-09-02", "sourceText": "Mass. Ch. 312, Acts of 2024 (MGL c. 169B, Sec. 1); Massachusetts Division of Banks FAQs", "sourceUrl": "https://www.mass.gov/info-details/chapter-312-of-the-acts-of-2024-money-transmission-law", "summary": "Massachusetts licenses money transmission under its money-transmission law (Chapter 312 of the Acts of 2024, MGL c. 169B), which the Division of Banks applies to virtual currency. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "Obtain a Massachusetts money-transmitter license from the Division of Banks before transmitting money or virtual currency for Massachusetts customers (MGL c. 169B, Chapter 312 of the Acts of 2024).", "Meet the licensing law\u2019s prudential requirements (surety bond or net worth, permissible investments or reserve holdings) and comply with AML, reporting, and consumer-disclosure obligations.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Pennsylvania", "slug": "pennsylvania", "status": "live", "statusLabel": "Live Regime", "framework": "Pennsylvania Money Transmission and Virtual Currency Transmission Business Licensing Law (7 Pa.C.S.), as amended by Act 7 of 2025 (effective Aug. 26, 2025), which brought virtual-currency transmission for a fee within licensing.", "regulator": "Pennsylvania Department of Banking and Securities", "detail": "Pennsylvania regulates money transmission under what is now the Money Transmission and Virtual Currency Transmission Business Licensing Law (7 Pa.C.S.), administered by the Department of Banking and Securities. Act 7 of 2025 (effective August 26, 2025) amended the law to require any business that transmits virtual currency for a fee, or facilitates the transfer of virtual currency for a fee, to obtain a license on the same terms as other money transmitters, and added virtual-currency transmission to the Act\u2019s short title. This replaced the Department\u2019s earlier statement-of-policy approach to virtual currency.", "effective": "Money Transmission Business Licensing Law as amended by Act 7 of 2025; effective 60 days after enactment (Aug. 26, 2025); virtual-currency transmission for a fee licensed by statute", "lastVerified": "2026-09-02", "sourceText": "Pennsylvania Money Transmission and Virtual Currency Transmission Business Licensing Law (7 Pa.C.S.), as amended by Act 7 of 2025 (eff. Aug. 26, 2025), requiring a license to transmit virtual currency for a fee.", "sourceUrl": "https://www.palegis.us/statutes/unconsolidated/law-information?sessYr=2025&sessInd=0&actNum=0007.", "summary": "Pennsylvania now licenses virtual-currency transmission for a fee under Act 7 of 2025, on the same terms as other money transmitters. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "Obtain a Pennsylvania license from the Department of Banking and Securities before transmitting virtual currency for a fee, or facilitating virtual-currency transfers for a fee, for Pennsylvania customers (Money Transmission and Virtual Currency Transmission Business Licensing Law, 7 Pa.C.S., as amended by Act 7 of 2025).", "Meet the licensing law\u2019s prudential requirements (surety bond or net worth, permissible investments or reserve holdings) and comply with AML, reporting, and consumer-disclosure obligations.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "District of Columbia", "slug": "district-of-columbia", "status": "live", "statusLabel": "Live Regime", "framework": "Money Transmissions Act (D.C. Code Title 26, Ch. 10, Sec. 26-1001)", "regulator": "DC Department of Insurance, Securities and Banking (DISB)", "detail": "The District of Columbia requires a money transmitter license under its Money Transmissions Act (D.C. Code Title 26, Chapter 10; Sec. 26-1001), administered by the Department of Insurance, Securities and Banking (DISB). By DISB bulletin, and relying on United States v. Harmon (in which the court treated Bitcoin as functioning like money under the District's money-transmission definition), DISB considers Bitcoin and other virtual currency used as a medium of exchange, method of payment, or store of value to be money, so receiving for transmission, storing, or taking custody of virtual currency requires a license. Operating a virtual-currency kiosk or transmitting virtual currency without a license violates Sec. 26-1002 and can carry civil and criminal penalties.", "effective": "Money Transmissions Act (D.C. Code Sec. 26-1001 et seq.) in force; DISB treats virtual currency as money (per bulletin and U.S. v. Harmon); VC transmission/custody licensed", "lastVerified": "2026-09-02", "sourceText": "D.C. Code Title 26, Ch. 10 (Sec. 26-1001 et seq.); DISB cryptocurrency & money transmission bulletin", "sourceUrl": "https://code.dccouncil.gov/us/dc/council/code/titles/26/chapters/10", "summary": "The District of Columbia licenses money transmission, which its regulator applies to virtual-currency activity. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "Obtain a DC money-transmitter license from the Department of Insurance, Securities and Banking before transmitting money or virtual currency for DC customers (Money Transmissions Act, D.C. Code \u00a7 26-1001 et seq.).", "Meet the licensing law\u2019s prudential requirements (surety bond or net worth, permissible investments or reserve holdings) and comply with AML, reporting, and consumer-disclosure obligations.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Ohio", "slug": "ohio", "status": "guidance", "statusLabel": "Guidance-Based", "framework": "Ohio Money Transmitters Act (R.C. ch. 1315; definitions at R.C. 1315.01) and Division of Financial Institutions Interpretive Guidance 2022-01 (effective Aug. 31, 2022), under which cryptocurrency businesses must be licensed.", "regulator": "Ohio Division of Financial Institutions", "detail": "Ohio regulates money transmission under the Ohio Money Transmitters Act (R.C. ch. 1315), with core definitions at R.C. 1315.01. In Interpretive Guidance 2022-01 (effective August 31, 2022), the Division of Financial Institutions treats cryptocurrency such as Bitcoin as money or its equivalent and takes the position that, in general, businesses that buy, sell, or transmit cryptocurrency, including Bitcoin ATMs and kiosks, qualify as money transmitters and must be licensed before serving Ohio customers. Operators of Bitcoin ATMs in Ohio as of August 31, 2022 were required to apply through NMLS by October 31, 2022; new entrants must be licensed or obtain a written determination first.", "effective": "Interpretive Guidance 2022-01, effective Aug. 31, 2022", "lastVerified": "2026-09-02", "sourceText": "Ohio Money Transmitters Act, R.C. ch. 1315 (R.C. 1315.01); Division of Financial Institutions Interpretive Guidance 2022-01 (eff. Aug. 31, 2022) treats cryptocurrency businesses, including kiosks, as money transmitters that must be licensed.", "sourceUrl": "https://codes.ohio.gov/ohio-revised-code/section-1315.01", "summary": "Ohio\u2019s Division of Financial Institutions treats cryptocurrency businesses, including kiosks, as money transmitters that must be licensed. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "Obtain an Ohio money-transmitter license (R.C. ch. 1315) before buying, selling, or transmitting cryptocurrency for Ohio customers; the Division treats crypto as money or its equivalent (Interpretive Guidance 2022-01).", "Bitcoin ATM / kiosk operators are covered and must be licensed.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Michigan", "slug": "michigan", "status": "excluded", "statusLabel": "VC Unsettled", "framework": "Michigan Money Transmission Services Act (Act 250 of 2006, MCL 487.1001 et seq.). \u201cMoney\u201d is defined as government-issued currency (MCL 487.1003), so virtual currency is not \u201cmoney\u201d and standalone crypto transmission is outside the Act.", "regulator": "Michigan Department of Insurance and Financial Services (DIFS)", "detail": "Michigan\u2019s Money Transmission Services Act (Act 250 of 2006, MCL 487.1001 et seq.) predates crypto and was not updated for it. \u201cMoney\u201d is defined as a government-authorized medium of exchange (MCL 487.1003), so virtual currency is not \u201cmoney\u201d and pure virtual-currency transmission falls outside the Act; Michigan has no separate virtual-currency license or statutory definition. In practice, the Department of Insurance and Financial Services (DIFS) treats businesses that hold customer fiat funds in connection with crypto, including e-wallet balances, as money transmission requiring a license, and major exchanges hold Michigan money-transmitter licenses. DIFS administers the Act.", "effective": "Act 250 of 2006 (no crypto-specific amendment)", "lastVerified": "2026-09-02", "sourceText": "Michigan Money Transmission Services Act, MCL 487.1003: \u201cmoney\u201d is a government-authorized medium of exchange, so virtual currency is not \u201cmoney\u201d and standalone virtual-currency transmission is outside the Act.", "sourceUrl": "https://www.legislature.mi.gov/Laws/MCL?objectName=MCL-487-1003", "summary": "Michigan\u2019s Money Transmission Services Act does not treat virtual currency as \u201cmoney,\u201d so standalone crypto transmission is outside the Act, though businesses holding customer fiat funds may still need a license. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "No Michigan money-transmitter license is required for pure virtual-currency transmission, because \u201cmoney\u201d means government-issued currency (MCL 487.1003) and virtual currency is not \u201cmoney.\u201d", "DIFS treats businesses that hold customer fiat funds in connection with crypto (including e-wallet balances) as money transmission requiring a license, and major exchanges hold Michigan licenses.", "Federal FinCEN money-services-business registration and a Bank Secrecy Act / AML program still apply to virtual-currency businesses regardless of state licensing.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Tennessee", "slug": "tennessee", "status": "guidance", "statusLabel": "Guidance-Based", "framework": "Tennessee Money Transmitter Act (Tenn. Code Ann. title 45, ch. 7) and TDFI Virtual Currency Guidance. Pure virtual-currency transmission is not money transmission; exchanging virtual currency for sovereign currency may require licensing.", "regulator": "Tennessee Department of Financial Institutions", "detail": "Tennessee regulates money transmission under the Tennessee Money Transmitter Act (Tenn. Code Ann. title 45, ch. 7). In its Virtual Currency Guidance, the Department of Financial Institutions takes the position that cryptocurrency is not \u201cmoney\u201d under the Act, so holding or transmitting pure virtual currency is not money transmission and the money-transmitter license does not cover it. Absent a sovereign currency in the transaction, no money transmission occurs. However, a company that exchanges, administers, or maintains virtual currency for sovereign currency may be subject to state licensing (and to federal regulation), because that activity involves the transmission of sovereign currency.", "effective": "TDFI Virtual Currency Guidance", "lastVerified": "2026-09-02", "sourceText": "Tennessee Money Transmitter Act, Tenn. Code Ann. title 45, ch. 7; TDFI Virtual Currency Guidance: pure virtual-currency transmission is not money transmission, but exchanging virtual currency for sovereign currency may require licensing.", "sourceUrl": "https://www.tn.gov/tdfi/mortgage-consumer-lending/money-transmitter/virtual-currency-guidance-.html", "summary": "In Tennessee, holding or transmitting pure virtual currency is not money transmission, but exchanging virtual currency for sovereign currency may require a license. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "No Tennessee money-transmitter license is required to hold or transmit pure virtual currency (TDFI guidance; crypto is not \u201cmoney\u201d under the Tennessee Money Transmitter Act, Tenn. Code Ann. title 45, ch. 7).", "A company that exchanges, administers, or maintains virtual currency for sovereign currency may need a license, because that involves transmitting sovereign currency.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Minnesota", "slug": "minnesota", "status": "live", "statusLabel": "Live Regime", "framework": "Minnesota Money Transmission Modernization Act (Minn. Stat. ch. 53B), enacted 2023 (SF 2744) and expanded 2024 (SF 4097). Minnesota adopted the model act\u2019s virtual-currency provisions (Minn. Stat. \u00a7\u00a7 53B.69 to 53B.75), so virtual-currency business activity is licensed.", "regulator": "Minnesota Department of Commerce", "detail": "Minnesota adopted the Money Transmission Modernization Act in 2023 (Session Laws 2023, ch. 57, SF 2744, signed May 24, 2023), codified at Minn. Stat. ch. 53B, and is one of only three states (with Maine and North Dakota) to also adopt the model act\u2019s virtual-currency business-activity provisions (Minn. Stat. \u00a7\u00a7 53B.69 to 53B.75). Persons engaged in virtual-currency business activity for Minnesota residents must be licensed by the Department of Commerce, and major exchanges hold Minnesota licenses. Session Laws 2024, ch. 114 (SF 4097), effective August 1, 2024, added requirements for virtual-currency kiosks. The Department of Commerce administers the Act.", "effective": "Under existing Money Transmission Act (no separate VC statute confirmed)", "lastVerified": "2026-09-02", "sourceText": "Minnesota Money Transmission Modernization Act, Minn. Stat. ch. 53B (SF 2744, 2023; SF 4097, 2024); Minnesota adopted the virtual-currency business-activity provisions (\u00a7\u00a7 53B.69 to 53B.75).", "sourceUrl": "https://www.revisor.mn.gov/statutes/cite/53B", "mtma": "One of only two states to adopt the MTMA\u2019s optional virtual-currency provisions (Title XIII), which expressly bring virtual-currency business under money-transmitter licensing (eff. Aug. 1, 2023)", "summary": "Minnesota licenses virtual-currency business activity under its Money Transmission Modernization Act, one of only three states to adopt the model act\u2019s virtual-currency provisions. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "Obtain a Minnesota license from the Department of Commerce before engaging in virtual-currency business activity for Minnesota residents (Minn. Stat. ch. 53B, \u00a7\u00a7 53B.69 to 53B.75).", "Virtual-currency kiosk operators face additional requirements added in 2024 (SF 4097).", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Missouri", "slug": "missouri", "status": "excluded", "statusLabel": "VC Unsettled", "framework": "Missouri Money Transmission Modernization Act of 2024 (Mo. Rev. Stat. \u00a7\u00a7 361.900 to 361.1035), enacted by SB 1359 (2024), which repealed the former Sale of Checks Law. General virtual-currency transmission is not licensed; virtual-currency kiosk operators are licensed as money transmitters.", "regulator": "Missouri Division of Finance", "detail": "Missouri replaced its former Sale of Checks Law (Mo. Rev. Stat. \u00a7\u00a7 361.700 to 361.727, repealed by SB 1359 (2024)) with the Money Transmission Modernization Act of 2024 (Mo. Rev. Stat. \u00a7\u00a7 361.900 to 361.1035). Missouri did not adopt the model act\u2019s general virtual-currency provisions, so transmitting virtual currency by itself generally does not require a Missouri money-transmitter license, though a business handling fiat currency may need one for the fiat leg. The Act does treat virtual-currency kiosk operators as engaged in money transmission requiring licensure under \u00a7\u00a7 361.900 to 361.1035, and unlicensed kiosk operators were required to apply within 60 days after August 28, 2025. The Division of Finance administers the Act.", "effective": "No VC-specific guidance issued", "lastVerified": "2026-09-02", "sourceText": "Missouri Money Transmission Modernization Act of 2024, Mo. Rev. Stat. \u00a7\u00a7 361.900 to 361.1035 (SB 1359 (2024), repealing the Sale of Checks Law); virtual-currency kiosk operators are licensed as money transmitters, general virtual-currency transmission is not.", "sourceUrl": "https://revisor.mo.gov/main/OneSection.aspx?section=361.900", "summary": "Missouri does not license general virtual-currency transmission, but virtual-currency kiosk operators must be licensed as money transmitters under its 2024 Money Transmission Modernization Act. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "No Missouri money-transmitter license is required for general virtual-currency transmission (Money Transmission Modernization Act of 2024, Mo. Rev. Stat. \u00a7\u00a7 361.900 to 361.1035; Missouri did not adopt the general virtual-currency provisions).", "Virtual-currency kiosk operators must be licensed as money transmitters under \u00a7\u00a7 361.900 to 361.1035; a business handling fiat currency may also need a license for the fiat leg.", "Federal FinCEN money-services-business registration and a Bank Secrecy Act / AML program still apply to virtual-currency businesses regardless of state licensing.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Oregon", "slug": "oregon", "status": "live", "statusLabel": "Live Regime", "framework": "Oregon money transmission law (ORS ch. 717; definitions at ORS 717.200, license required at ORS 717.205). \u201cMoney\u201d is defined to include value that substitutes for currency, which the Division of Financial Regulation applies to virtual currency.", "regulator": "Oregon Division of Financial Regulation", "detail": "Oregon requires a license to conduct a money-transmission business (ORS 717.205), administered by the Division of Financial Regulation within the Department of Consumer and Business Services. \u201cMoney\u201d is defined broadly to include a medium of exchange that represents value that substitutes for currency (ORS 717.200), and the Division applies this to virtual currency: businesses selling or issuing virtual currency, or operating a virtual-currency exchange transmitting value for Oregon customers, must obtain a money-transmitter license, subject to the exemptions in ORS 717.210.", "effective": "Under ORS 717 (money transmission license required)", "lastVerified": "2026-09-02", "sourceText": "Oregon money transmission law, ORS 717.200 (\u201cmoney\u201d includes value that substitutes for currency) and ORS 717.205 (license required); the Division of Financial Regulation applies this to virtual-currency transmission.", "sourceUrl": "https://www.oregonlegislature.gov/bills_laws/ors/ors717.html", "summary": "Oregon\u2019s money-transmission law defines \u201cmoney\u201d to include value that substitutes for currency, which the Division of Financial Regulation applies to virtual currency. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "Obtain an Oregon money-transmitter license from the Division of Financial Regulation before selling, issuing, or transmitting virtual currency for Oregon customers (ORS 717.205; \u201cmoney\u201d includes value that substitutes for currency, ORS 717.200).", "Meet the licensing law\u2019s prudential requirements (surety bond or net worth, permissible investments or reserve holdings) and comply with AML, reporting, and consumer-disclosure obligations.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Indiana", "slug": "indiana", "status": "excluded", "statusLabel": "VC Excluded", "framework": "Indiana Money Transmission Modernization Act (Ind. Code \u00a7 28-8-4.1; license required at \u00a7 28-8-4.1-501). Indiana did not adopt the model act\u2019s virtual-currency provisions, so virtual-currency transmission is not licensed.", "regulator": "Indiana Department of Financial Institutions", "detail": "Indiana adopted the Money Transmission Modernization Act, codified at Ind. Code \u00a7 28-8-4.1, which requires a license to engage in the business of money transmission (\u00a7 28-8-4.1-501). Indiana did not adopt the model act\u2019s virtual-currency provisions and does not include virtual-currency transmission within its money-transmission regulation. Consistent with that, the Department of Financial Institutions has stated that a fiat or virtual-currency exchange, where the consumer is strictly buying or selling currency and cannot send fiat to another consumer, does not require a license. The Department of Financial Institutions administers the Act.", "effective": "Per DFI money transmitter licensing FAQ (NMLS)", "lastVerified": "2026-09-02", "sourceText": "Indiana Money Transmission Modernization Act, Ind. Code \u00a7 28-8-4.1 (license required, \u00a7 28-8-4.1-501); Indiana did not adopt the virtual-currency provisions, and the Department of Financial Institutions treats a strict buy/sell currency exchange as not requiring a license.", "sourceUrl": "https://www.in.gov/dfi/files/MTMA-Licensing-Guidance.pdf", "summary": "Indiana does not license virtual-currency transmission: it adopted the Money Transmission Modernization Act without the model act\u2019s virtual-currency provisions. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "No Indiana money-transmitter license is required for virtual-currency transmission (Ind. Code \u00a7 28-8-4.1; Indiana did not adopt the virtual-currency provisions); the Department of Financial Institutions treats a strict buy/sell currency exchange as not requiring a license.", "A business that also transmits fiat currency may still need a money-transmitter license for that activity.", "Federal FinCEN money-services-business registration and a Bank Secrecy Act / AML program still apply to virtual-currency businesses regardless of state licensing.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Iowa", "slug": "iowa", "status": "guidance", "statusLabel": "Guidance-Based", "framework": "Iowa Uniform Money Services Act (Iowa Code ch. 533C; definitions at \u00a7 533C.102, license required at \u00a7 533C.301). The Division of Banking treats virtual currency as \u201cmonetary value,\u201d so receiving it for transmission requires a license.", "regulator": "Iowa Division of Banking", "detail": "Iowa\u2019s Uniform Money Services Act (Iowa Code ch. 533C) defines \u201cmoney transmission\u201d to include receiving money or monetary value for transmission (Iowa Code \u00a7 533C.102), and \u201cmonetary value\u201d as a medium of exchange whether or not redeemable in money. The Division of Banking has long held that virtual currency qualifies as \u201cmonetary value\u201d for purposes of chapter 533C, so receiving virtual currency for transmission in Iowa requires a money-transmitter license (Iowa Code \u00a7 533C.301). Its October 2024 kiosk guidance restated that position and provided that, unless a virtual-currency kiosk operator can independently verify the identity and wallet ownership of the customer for every transaction, the operator is engaged in money transmission and must be licensed.", "effective": "Per Division of Banking guidance (VC = monetary value)", "lastVerified": "2026-09-02", "sourceText": "Iowa Uniform Money Services Act, Iowa Code \u00a7 533C.102 (money transmission includes receiving \u201cmonetary value\u201d); the Division of Banking treats virtual currency as monetary value, so receiving it for transmission requires a license (\u00a7 533C.301; October 2024 kiosk guidance).", "sourceUrl": "https://www.legis.iowa.gov/docs/code/533C.102.pdf", "summary": "Iowa\u2019s Division of Banking treats virtual currency as \u201cmonetary value,\u201d so receiving it for transmission requires a money-transmitter license. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "Obtain an Iowa money-transmitter license (Iowa Code \u00a7 533C.301) before receiving virtual currency for transmission; the Division of Banking treats virtual currency as \u201cmonetary value\u201d (\u00a7 533C.102).", "Virtual-currency kiosk operators are money transmitters unless they can independently verify customer identity and wallet ownership for every transaction (October 2024 guidance).", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Kansas", "slug": "kansas", "status": "guidance", "statusLabel": "Guidance-Based", "framework": "Kansas Money Transmitter Act (K.S.A. 9-508 et seq.) and OSBC Guidance MT 2014-01 (updated Jan. 2, 2025). Decentralized cryptocurrency is not \u201cmoney\u201d or \u201cmonetary value,\u201d so crypto-only transmission is not licensed; crypto-to-sovereign-currency exchange through a third party is.", "regulator": "Kansas Office of the State Bank Commissioner", "detail": "Kansas regulates money transmission under the Kansas Money Transmitter Act (K.S.A. 9-508 et seq.), where \u201cmoney transmission\u201d means selling or issuing payment instruments or receiving money or monetary value for transmission (K.S.A. 9-508). In Guidance Document MT 2014-01 (issued June 6, 2014, updated January 2, 2025), the Office of the State Bank Commissioner concluded that decentralized cryptocurrencies such as Bitcoin are not \u201cmoney\u201d or \u201cmonetary value\u201d under the Act, so an entity engaged solely in transmitting cryptocurrency, exchanging one cryptocurrency for another, or transferring cryptocurrency between accounts is not licensed. Exchanging cryptocurrency for sovereign currency through a third-party exchanger is generally money transmission and requires a license.", "effective": "OSBC Cryptocurrency Guidance MT 2014-01", "lastVerified": "2026-09-02", "sourceText": "Kansas Money Transmitter Act, K.S.A. 9-508; OSBC Guidance MT 2014-01 (updated Jan. 2, 2025): decentralized cryptocurrency is not \u201cmoney\u201d or \u201cmonetary value,\u201d so crypto-only transmission is not licensed, but crypto-to-sovereign-currency exchange through a third party is.", "sourceUrl": "https://www.osbckansas.gov/cml/mt_2014_01.pdf", "summary": "Kansas does not license crypto-only transmission, but exchanging cryptocurrency for sovereign currency through a third party is money transmission requiring a license. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "No Kansas license is required to transmit cryptocurrency only, to exchange one cryptocurrency for another, or to transfer crypto between accounts (OSBC Guidance MT 2014-01; crypto is not \u201cmoney\u201d or \u201cmonetary value\u201d under K.S.A. 9-508).", "Exchanging cryptocurrency for sovereign currency through a third-party exchanger is money transmission and requires a license from the Office of the State Bank Commissioner.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Kentucky", "slug": "kentucky", "status": "live", "statusLabel": "Live Regime", "framework": "Kentucky Money Transmitters Act (KRS ch. 286.11; license required at KRS 286.11-005). The Department of Financial Institutions applies the Act to virtual-currency transmission (2022 guidance); HB 701 (2025) exempts blockchain software development, crypto-to-crypto exchange, and node operation from money transmission (KRS 286.11-007(8)).", "regulator": "Kentucky Department of Financial Institutions", "detail": "Kentucky requires a license to engage in money transmission under the Kentucky Money Transmitters Act (KRS ch. 286.11; KRS 286.11-005), administered by the Department of Financial Institutions. In September 2022 the Department issued guidance applying the Act to virtual currency: a transaction involving virtual currency is covered where monetary value is transmitted, delivered, or instructed to be delivered by any means, so businesses transmitting virtual-currency value for Kentucky customers (for example, fiat on/off-ramp exchange) must be licensed. In 2025, HB 701 (An Act relating to blockchain digital assets, enacted March 2025) created a statutory framework for digital assets in new sections of KRS ch. 369, protecting self-custody, home and business digital-asset mining, node operation, and staking, and amended the money-transmitter exemptions at KRS 286.11-007 to provide that the subtitle does not apply to any individual or business that develops or deploys software on a blockchain protocol (even if it effectuates a crypto-to-crypto exchange), exchanges digital assets for other digital assets, or operates a node (KRS 286.11-007(8)). HB 701 also confirmed, through KRS 292.340, that staking is not the offer or sale of a security. Licensing runs through NMLS.", "effective": "Under Kentucky money transmission statute", "lastVerified": "2026-09-02", "sourceText": "Kentucky Money Transmitters Act, KRS 286.11-005; the Department applies the Act to virtual-currency transmission (2022 guidance). HB 701 (2025) added KRS 286.11-007(8), exempting blockchain software development, crypto-to-crypto exchange, and node operation from money transmission, and created a digital-asset framework in KRS ch. 369.", "sourceUrl": "https://apps.legislature.ky.gov/recorddocuments/bill/25RS/hb701/bill.pdf", "summary": "Kentucky licenses virtual-currency transmission under its Money Transmitters Act, while HB 701 (2025) exempts self-custody, mining, crypto-to-crypto exchange, and node operation. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "Obtain a Kentucky money-transmitter license from the Department of Financial Institutions (via NMLS) before transmitting virtual-currency value for Kentucky customers, such as fiat on/off-ramp exchange (KRS 286.11; 2022 guidance).", "No license is required for blockchain software development, crypto-to-crypto exchange, or node operation (KRS 286.11-007(8), added by HB 701 (2025)); self-custody, mining, and staking are protected.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Hawaii", "slug": "hawaii", "status": "excluded", "statusLabel": "VC Excluded", "framework": "Hawaii Money Transmitters Modernization Act (Haw. Rev. Stat. ch. 489D); digital-currency activity no longer requires a state money-transmitter license (effective July 1, 2024)", "regulator": "Hawaii Division of Financial Institutions", "detail": "Hawaii does not require a state money-transmitter license for digital-currency activity. After running the Digital Currency Innovation Lab (DCIL) as a pilot, the Department of Commerce and Consumer Affairs, Division of Financial Institutions concluded the DCIL on June 30, 2024 and determined that, effective July 1, 2024, its Money Transmitters Modernization Act no longer applies to cryptocurrency activity, so digital-currency companies may operate in Hawaii without a state money-transmitter license. Federal registration and licensing still apply, and a company that also transmits U.S. dollars still needs a money-transmitter license for that fiat activity. Payment-stablecoin issuance remains federally governed by the GENIUS Act.", "effective": "DCIL concluded June 30, 2024; no state money-transmitter license required for digital-currency activity as of July 1, 2024", "lastVerified": "2026-09-02", "sourceText": "Hawaii DCCA/DFI release concluding the Digital Currency Innovation Lab (effective July 1, 2024); Haw. Rev. Stat. ch. 489D", "sourceUrl": "https://cca.hawaii.gov/dfi/news-releases/release-hawaii-digital-currency-innovation-lab-to-conclude/", "summary": "Hawaii no longer requires a state money-transmitter license for digital-currency activity: under its Money Transmitters Modernization Act (effective July 1, 2024), virtual-currency business is outside state money-transmission licensing. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "No Hawaii money-transmitter license is required for digital-currency or virtual-currency activity (Money Transmitters Modernization Act, Haw. Rev. Stat. ch. 489D, effective July 1, 2024, which ended the prior Digital Currency Innovation Lab approach).", "Federal FinCEN money-services-business registration and a Bank Secrecy Act / AML program still apply to virtual-currency businesses regardless of state licensing.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Alabama", "slug": "alabama", "status": "live", "statusLabel": "Live Regime", "framework": "Alabama Monetary Transmission Act (Ala. Code \u00a7 8-7A-2, \u00a7 8-7A-5). The definition of \u201cmonetary value\u201d in \u00a7 8-7A-2 expressly includes virtual currency.", "regulator": "Alabama Securities Commission", "detail": "Alabama requires a license to sell or issue payment instruments or stored value, or to receive money or monetary value for transmission (Ala. Code \u00a7 8-7A-5). The Alabama Monetary Transmission Act defines \u201cmonetary value\u201d as \u201ca medium of exchange, including virtual or fiat currencies, whether or not redeemable in money\u201d (Ala. Code \u00a7 8-7A-2), so transmitting or exchanging virtual currency for others requires a money-transmitter license. The Act is administered by the Alabama Securities Commission.", "effective": "Money-transmitter license required; \u201cmonetary value\u201d expressly covers virtual currency", "lastVerified": "2026-09-02", "sourceText": "\u201cMONETARY VALUE. A medium of exchange, including virtual or fiat currencies, whether or not redeemable in money.\u201d (Ala. Code \u00a7 8-7A-2)", "sourceUrl": "https://asc.alabama.gov/statute/alabama-securities-act-title-8-section-7a/", "summary": "In Alabama, transmitting or exchanging virtual currency for others requires a state money-transmitter license, because \u201cmonetary value\u201d expressly includes virtual currency. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "Obtain an Alabama money-transmitter license from the Alabama Securities Commission (via NMLS) before transmitting or exchanging virtual currency for Alabama residents; \u201cmonetary value\u201d includes virtual currency (Ala. Code \u00a7 8-7A-2) and a license is required under \u00a7 8-7A-5.", "Meet the licensing law\u2019s prudential requirements (surety bond or net worth, permissible investments or reserve holdings) and comply with AML, reporting, and consumer-disclosure obligations.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Alaska", "slug": "alaska", "status": "live", "statusLabel": "Live Regime", "framework": "Alaska Uniform Money Services Act (AS 06.55; definitions at AS 06.55.990, license required at AS 06.55.101). Virtual-currency business activity requires a money-transmitter license; the earlier Limited Licensing Agreement approach was discontinued as of January 2023.", "regulator": "Alaska Division of Banking and Securities", "detail": "Alaska requires virtual-currency business activity to be licensed as money transmission under the Alaska Uniform Money Services Act (AS 06.55). \u201cMoney services\u201d and \u201cmonetary value\u201d are defined in AS 06.55.990, and a license is required under AS 06.55.101. Previously the Division of Banking and Securities handled virtual-currency firms through a separate Limited Licensing Agreement, but that approach ended in January 2023: virtual-currency business activity now requires full money-transmitter licensure under AS 06.55 unless exempt. The Division of Banking and Securities administers the Act.", "effective": "Money-transmitter license plus Limited Licensing Agreement required for virtual-currency business", "lastVerified": "2026-09-02", "sourceText": "Alaska Uniform Money Services Act, AS 06.55 (definitions, AS 06.55.990; license required, AS 06.55.101).", "sourceUrl": "https://www.akleg.gov/basis/statutes.asp#06.55", "summary": "In Alaska, virtual-currency business activity requires a money-transmitter license under the Uniform Money Services Act; the earlier Limited Licensing Agreement approach ended in January 2023. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "Obtain an Alaska money-transmitter license from the Division of Banking and Securities before engaging in virtual-currency business activity (AS 06.55; license required at AS 06.55.101).", "Meet the licensing law\u2019s prudential requirements (surety bond or net worth, permissible investments or reserve holdings) and comply with AML, reporting, and consumer-disclosure obligations.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Arkansas", "slug": "arkansas", "status": "live", "statusLabel": "Live Regime", "framework": "Arkansas Uniform Money Services Act (A.C.A. \u00a7 23-55-102). \u201cMoney transmission\u201d expressly includes receiving virtual currency for transmission; Act 557 of 2025 added virtual-currency kiosk provisions.", "regulator": "Arkansas Securities Department", "detail": "Arkansas\u2019s Uniform Money Services Act defines \u201cmoney transmission\u201d to include \u201creceiving money, virtual currency, or monetary value for transmission\u201d (A.C.A. \u00a7 23-55-102), so transmitting virtual currency for others generally requires a money-transmitter license from the Arkansas Securities Department, which administers the Act. Act 557 of 2025 amended the statute to add definitions and consumer-protection requirements for virtual-currency kiosks. The Department has at times issued no-action letters relieving specific digital-asset businesses of licensure.", "effective": "Money transmission expressly includes virtual currency; licensing required subject to case-by-case no-action letters", "lastVerified": "2026-09-02", "sourceText": "\u201c\u2018Money transmission\u2019 means selling or issuing payment instruments, stored value, or prepaid access, or receiving money, virtual currency, or monetary value for transmission\u2026\u201d (A.C.A. \u00a7 23-55-102)", "sourceUrl": "https://arkleg.state.ar.us/Home/FTPDocument?path=/ACTS/2025R/Public/ACT557.pdf", "summary": "In Arkansas, \u201cmoney transmission\u201d expressly includes receiving virtual currency for transmission, so it requires a state money-transmitter license. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "Obtain an Arkansas money-transmitter license from the Securities Department before transmitting virtual currency for Arkansas residents (\u201cmoney transmission\u201d includes virtual currency, A.C.A. \u00a7 23-55-102).", "Virtual-currency kiosk operators are covered by the kiosk provisions added by Act 557 (2025).", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Idaho", "slug": "idaho", "status": "live", "statusLabel": "Live Regime", "framework": "Idaho Money Transmitters Act (Idaho Code \u00a7 26-2902 (definitions), \u00a7 26-2903 (license required)). The Department of Finance treats virtual-currency exchange for fiat as licensable money transmission.", "regulator": "Idaho Department of Finance", "detail": "Idaho requires a money-transmitter license to engage in the business of money transmission (Idaho Code \u00a7 26-2903), subject to the exemptions in \u00a7 26-2904. The Department of Finance takes the position that a virtual-currency exchanger who accepts fiat currency for later delivery in connection with a virtual-currency purchase must be licensed as a money transmitter, so virtual-currency exchange is generally licensable. The Department has at times issued no-action letters relieving particular businesses, such as certain digital-currency ATMs, from licensing, so treatment can be activity-specific. The Department of Finance administers the Act.", "effective": "Department of Finance requires money-transmitter licensing for virtual-currency exchange; activity-specific no-action letters issued", "lastVerified": "2026-09-02", "sourceText": "Idaho Money Transmitters Act: a license is required to engage in money transmission (Idaho Code \u00a7 26-2903); the Department of Finance treats virtual-currency exchange for fiat as licensable money transmission.", "sourceUrl": "https://www.finance.idaho.gov/securities-bureau/money-transmitters/", "summary": "Idaho\u2019s Department of Finance treats virtual-currency exchange for fiat as licensable money transmission. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "Obtain an Idaho money-transmitter license from the Department of Finance before exchanging virtual currency for fiat for Idaho customers (Idaho Money Transmitters Act, Idaho Code \u00a7 26-2903).", "Treatment can be activity-specific; the Department has issued no-action letters for some businesses (for example, certain crypto ATMs).", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Louisiana", "slug": "louisiana", "status": "live", "statusLabel": "Live Regime", "framework": "Louisiana Virtual Currency Businesses Act (La. Rev. Stat. \u00a7\u00a7 6:1381\u20136:1394); dedicated standalone virtual-currency license via the Office of Financial Institutions", "regulator": "Louisiana Office of Financial Institutions", "detail": "Louisiana runs one of the most developed state regimes: the Virtual Currency Businesses Act (VCBA), La. Rev. Stat. \u00a7\u00a7 6:1381 to 6:1394, adopted in 2020, made Louisiana the second state after New York to create a dedicated, standalone licensing scheme for virtual-currency business activity. A license (or equivalent permission) from the Office of Financial Institutions (OFI), applied for through NMLS, is required to conduct virtual-currency business activity with Louisiana residents. Licensing thresholds were tightened in 2023: SB 185 / Act 331 rescinded the former de minimis exception (\u00a7 6:1389), so a license is required regardless of transaction volume. The Act lists exceptions in \u00a7 6:1383(B) and (C) (for example, virtual currency regulated under Louisiana securities law and personal or academic use). Requirements include a business plan, FinCEN registration and BSA/AML compliance, control-person background checks, a surety bond, and minimum net worth of the greater of $100,000 or 3% of total assets. The VCBA sits alongside the traditional money-transmitter license, and OFI\u2019s 2014 guidance already treated virtual-currency exchangers as requiring money-transmitter licensing.", "effective": "VCBA licensing in force (license required to operate after June 30, 2023); de minimis exception removed by SB 185 / Act 331 (2023)", "lastVerified": "2026-09-02", "sourceText": "La. Rev. Stat. \u00a7\u00a7 6:1381\u20136:1394 (Virtual Currency Businesses Act); SB 185 / Act 331 (2023); LA Office of Financial Institutions.", "sourceUrl": "https://ofi.la.gov/non-depository/virtual-currency-business-activity", "summary": "Louisiana has a dedicated Virtual Currency Businesses Act with a standalone virtual-currency license through the Office of Financial Institutions. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "Obtain a Louisiana virtual-currency license from the Office of Financial Institutions before engaging in virtual-currency business activity (Virtual Currency Businesses Act, La. R.S. \u00a7\u00a7 6:1381 to 6:1394).", "Meet the licensing law\u2019s prudential requirements (surety bond or net worth, permissible investments or reserve holdings) and comply with AML, reporting, and consumer-disclosure obligations.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Montana", "slug": "montana", "status": "excluded", "statusLabel": "No MT Regime", "framework": "No Montana money-transmitter licensing statute: Montana does not license money transmitters. Affirmative digital-asset laws include SB 178 (2023) and SB 265 (2025).", "regulator": "None, no money transmitter licensing statute", "detail": "Montana is the only state with no money-transmitter licensing regime: the Division of Banking and Financial Institutions does not license money transmitters, so there is no state money-transmitter license requirement for transmitting or exchanging fiat or virtual currency, including stablecoins. Montana has instead legislated affirmatively on digital assets: SB 178 (2023) addresses the treatment of digital assets and protects crypto mining, and SB 265 (2025), the Financial Freedom and Innovation Act, protects the right to use digital assets and self-hosted wallets and bars state use of a central bank digital currency. Firms operating from Montana remain subject to federal money-services-business registration with FinCEN under the Bank Secrecy Act.", "effective": "No state money-transmission licensing; federal FinCEN/BSA still applies", "lastVerified": "2026-09-02", "sourceText": "Montana has no money-transmitter licensing statute (Division of Banking and Financial Institutions); digital-asset laws include SB 178 (2023) and SB 265 (2025), the Financial Freedom and Innovation Act.", "sourceUrl": "https://banking.mt.gov/", "summary": "Montana has no money-transmitter licensing regime at all, so no state license is required to transmit fiat or virtual currency. Issuing a payment stablecoin is still governed federally by the GENIUS Act.", "keyPoints": [ "No Montana money-transmitter license exists or is required for transmitting or exchanging fiat or virtual currency (Montana has no money-transmitter licensing statute).", "Montana\u2019s digital-asset laws (SB 178 (2023); SB 265 (2025)) protect the use of digital assets and self-hosted wallets rather than imposing licensing.", "Federal FinCEN money-services-business registration and a Bank Secrecy Act / AML program still apply to virtual-currency businesses regardless of state licensing.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "South Dakota", "slug": "south-dakota", "status": "live", "statusLabel": "Live Regime", "framework": "South Dakota money transmission law (SDCL ch. 51A-17; SDCL 51A-17-1(13)). The Division of Banking treats \u201cmonetary value\u201d as including virtual currency, so receiving crypto for transmission requires compliance.", "regulator": "South Dakota Division of Banking", "detail": "South Dakota regulates money transmission under SDCL ch. 51A-17, defining \u201cmonetary value\u201d as any medium of exchange, whether or not redeemable in money, and \u201cmoney transmission\u201d as the sale or issuance of payment instruments or stored value or the receipt of money or monetary value for transmission (SDCL 51A-17-1). In guidance titled \u201cVirtual Currency Transmission in South Dakota\u201d (May 25, 2019), the Division of Banking stated that virtual currencies including Bitcoin are \u201cmonetary value\u201d under chapter 51A-17, so any South Dakota firm that receives cryptocurrency for transmission within or outside the United States must comply with South Dakota\u2019s money-transmission laws.", "effective": "Money-transmitter license required; Division of Banking guidance (2019) treats \u201cmonetary value\u201d as covering virtual currency", "lastVerified": "2026-09-02", "sourceText": "South Dakota SDCL 51A-17-1(13) defines \u201cmonetary value\u201d broadly; the Division of Banking\u2019s May 25, 2019 guidance treats virtual currency as \u201cmonetary value,\u201d so receiving crypto for transmission requires compliance.", "sourceUrl": "https://dlr.sd.gov/banking/legal/documents/11_002_virtual_currency_transmission_in_sd.pdf", "summary": "South Dakota\u2019s Division of Banking treats virtual currency as \u201cmonetary value,\u201d so receiving crypto for transmission requires compliance with the money-transmission law. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "Obtain a South Dakota money-transmitter license from the Division of Banking before receiving virtual currency for transmission for South Dakota customers (SDCL ch. 51A-17; \u201cmonetary value\u201d includes virtual currency per the Division\u2019s 2019 guidance).", "Meet the licensing law\u2019s prudential requirements (surety bond or net worth, permissible investments or reserve holdings) and comply with AML, reporting, and consumer-disclosure obligations.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "North Dakota", "slug": "north-dakota", "status": "live", "statusLabel": "Live Regime", "framework": "North Dakota Money Transmission Modernization Act (SB 2119, 2023; N.D.C.C. ch. 13-09.1), including the model act\u2019s virtual-currency provisions", "regulator": "North Dakota Department of Financial Institutions", "detail": "North Dakota enacted the Money Transmission Modernization Act via SB 2119, signed March 15, 2023 and effective August 1, 2023, and is one of only three states (with Maine and Minnesota) to enact the model act\u2019s virtual-currency title. The Act requires any person engaging in \u201cvirtual currency business activity\u201d to obtain a money-transmitter license from the Department of Financial Institutions. Payment-stablecoin issuance remains federally governed by the GENIUS Act.", "effective": "MTMA with virtual-currency provisions effective August 1, 2023 (SB 2119)", "lastVerified": "2026-09-02", "sourceText": "N.D.C.C. ch. 13-09.1 (Money Transmission Modernization Act, SB 2119, 2023); ND Department of Financial Institutions", "sourceUrl": "https://www.nd.gov/dfi/news/north-dakota-enacts-money-transmission-modernization-act", "mtma": "One of only two states to adopt the MTMA\u2019s optional virtual-currency provisions (Title XIII), which expressly bring virtual-currency business under money-transmitter licensing (SB 2119, eff. Aug. 1, 2023)", "summary": "North Dakota licenses virtual-currency business activity under its Money Transmission Modernization Act, one of only three states to adopt the model act\u2019s virtual-currency provisions. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "Obtain a North Dakota license from the Department of Financial Institutions before engaging in virtual-currency business activity for North Dakota residents (Money Transmission Modernization Act, N.D.C.C. ch. 13-09.1, SB 2119 (2023)).", "Meet the licensing law\u2019s prudential requirements (surety bond or net worth, permissible investments or reserve holdings) and comply with AML, reporting, and consumer-disclosure obligations.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Nebraska", "slug": "nebraska", "status": "live", "statusLabel": "Live Regime + Digital Asset Charter", "framework": "Nebraska money transmission law (Neb. Rev. Stat. \u00a7 8-2715) covers virtual currency; Nebraska Financial Innovation Act creates state-chartered digital-asset depository institutions (\u00a7 8-2724 exemption)", "regulator": "Nebraska Department of Banking and Finance", "detail": "Nebraska treats virtual currency as within money transmission: \u201cmonetary value\u201d is defined as a medium of exchange, whether or not redeemable in money (Neb. Rev. Stat. \u00a7 8-2715), which encompasses digital currency, so money transmission involving virtual currency is licensable. Separately, the Nebraska Financial Innovation Act authorizes state-chartered \u201cdigital asset depository institutions,\u201d which (effective Oct. 1, 2022) have the same exemption from money-transmission registration as other banks (Neb. Rev. Stat. \u00a7 8-2724) and can provide digital-asset custody and services under a dedicated charter with strong reserve and capital requirements. Payment-stablecoin issuance remains federally governed by the GENIUS Act.", "effective": "Money transmission covers virtual currency; digital-asset depository charter effective Oct. 1, 2022 (Nebraska Financial Innovation Act)", "lastVerified": "2026-09-02", "sourceText": "Neb. Rev. Stat. \u00a7 8-2715, \u00a7 8-2724 (Nebraska Financial Innovation Act); NE Dept. of Banking and Finance.", "sourceUrl": "https://ndbf.nebraska.gov/about/legal/nebraska-financial-innovation-act", "summary": "Nebraska\u2019s money-transmission law covers virtual currency, and its Financial Innovation Act authorizes state-chartered digital-asset depository institutions. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "Obtain a Nebraska money-transmitter license from the Department of Banking and Finance before transmitting virtual currency for Nebraska customers (Neb. Rev. Stat. \u00a7 8-2715).", "State-chartered digital-asset depository institutions under the Nebraska Financial Innovation Act are separately chartered and exempt from money-transmitter licensing (\u00a7 8-2724).", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Oklahoma", "slug": "oklahoma", "status": "live", "statusLabel": "Live Regime", "framework": "Oklahoma Financial Transaction Reporting Act (6 O.S. \u00a7\u00a7 1511\u20131515) through Oct. 31, 2026; Oklahoma Money Transmission Modernization Act (6 O.S. \u00a7 1551) from Nov. 1, 2026, defining \u201cmoney\u201d to include qualifying stablecoins; digital-asset kiosks under \u00a7 1520.1", "regulator": "Oklahoma State Banking Department", "detail": "Oklahoma licenses money transmission, and virtual-currency exchanges operating in the state hold Oklahoma money-transmitter licenses. Through October 31, 2026, licensing runs under the Oklahoma Financial Transaction Reporting Act (6 O.S. \u00a7\u00a7 1511\u20131515), whose definition of \u201cmoney transmitter\u201d is fiat-centric: it reaches a person who accepts and transmits \u201ccurrency or funds denominated in currency\u201d (legal tender), or the value of that currency (6 O.S. \u00a7 1512). The Act does not expressly name virtual currency, so crypto firms are captured mainly through their fiat on- and off-ramp activity. The one express digital-asset provision is 6 O.S. \u00a7 1520.1 (SB 1083, 2025), regulating digital-asset kiosks (crypto ATMs): operators must be licensed as money transmitters, cap new-customer activity at $2,000 per day, limit aggregate fees to 15% per transaction, give prominent fraud warnings, provide receipts, refund fraudulently-induced customers, run blockchain-analytics screening, and employ a full-time compliance officer, with unlicensed operation a misdemeanor and kiosks subject to seizure by the Attorney General. Effective November 1, 2026, the Oklahoma Money Transmission Modernization Act (HB 3521) repeals \u00a7\u00a7 1511\u20131515 and recodifies money transmission at 6 O.S. \u00a7 1551, and, unlike the old act, expressly defines \u201cmoney\u201d to include a stablecoin that is (a) pegged to a sovereign currency, (b) fully backed by assets held in reserve, and (c) redeemable for sovereign currency from the issuer; the kiosk provisions (\u00a7\u00a7 1520, 1520.1) are retained with their cross-reference updated. Non-stablecoin virtual currency (e.g., Bitcoin) is not \u201cmoney\u201d under either act. Payment-stablecoin issuance also remains federally governed by the GENIUS Act.", "effective": "Financial Transaction Reporting Act (6 O.S. \u00a7\u00a7 1511\u20131515, fiat-centric) in force through Oct. 31, 2026; digital-asset kiosks expressly regulated under \u00a7 1520.1 (SB 1083, 2025); Money Transmission Modernization Act (HB 3521) effective Nov. 1, 2026, recodifies at \u00a7 1551 and expressly adds qualifying stablecoins to \u201cmoney\u201d", "lastVerified": "2026-08-27", "sourceText": "6 O.S. \u00a7 1512 (Financial Transaction Reporting Act definitions, fiat-centric) and \u00a7 1520.1 (kiosks, SB 1083 2025); HB 3521 (enrolled) Oklahoma Money Transmission Modernization Act, \u00a7 55 repealer (\u00a7\u00a7 1511\u20131515), \u00a7 56 eff. Nov. 1 2026, \u201cmoney\u201d incl. stablecoin (\u00a7 1551)", "sourceUrl": "https://www.oklegislature.gov/cf_pdf/2025-26%20ENR/hB/HB3521%20ENR.PDF", "keyPoints": [ "Today (through Oct. 31, 2026): the Financial Transaction Reporting Act (6 O.S. \u00a7\u00a7 1511\u20131515) licenses money transmission of currency/funds (fiat); it does not expressly name virtual currency, and crypto exchanges are licensed mainly for their fiat on/off-ramps", "Crypto ATM / kiosk operators are expressly regulated (6 O.S. \u00a7 1520.1): licensed as money transmitters, $2,000/day new-customer cap, 15% fee cap, fraud warnings, receipts, and refunds, rules that continue after Nov. 1, 2026", "From November 1, 2026: the Money Transmission Modernization Act (6 O.S. \u00a7 1551) replaces \u00a7\u00a7 1511\u20131515 and, unlike the old law, defines \u201cmoney\u201d to include a stablecoin that is pegged to a sovereign currency, fully reserve-backed, and redeemable from the issuer", "Non-stablecoin virtual currency (e.g., Bitcoin) is not \u201cmoney\u201d under either act, so its transmission is not squarely captured outside the kiosk rules", "Separate federal track: issuing a payment stablecoin is governed by the GENIUS Act" ], "summary": "Oklahoma licenses money transmission, and crypto exchanges operating here hold Oklahoma licenses. The current law is fiat-focused and does not expressly name virtual currency; a modernized law effective November 1, 2026 writes fully-reserved, fiat-backed stablecoins directly into the legal definition of \u201cmoney,\u201d and crypto ATMs are separately regulated." }, { "name": "Utah", "slug": "utah", "status": "excluded", "statusLabel": "VC Excluded", "framework": "Utah Money Transmitter Act (Utah Code \u00a7 7-25-102): the definition of \u201cmoney transmission\u201d excludes a blockchain token, so standalone virtual-currency transmission is not licensed. HB 72 (2026) carves virtual-currency kiosks back into licensing.", "regulator": "Utah Department of Financial Institutions", "detail": "Utah does not require a money-transmitter license for standalone virtual-currency transmission. The Money Transmitter Act\u2019s definition of \u201cmoney transmission\u201d expressly excludes a \u201cblockchain token\u201d (Utah Code \u00a7 7-25-102), a 2020 change confirming that ordinary cryptocurrency transactions are not money transmission, so crypto firms are generally exempt. HB 72 (2026) creates an exception: operating a virtual-currency kiosk in Utah requires a license under the Money Transmitter Act and constitutes money transmission regardless of whether the transactions involve blockchain tokens. The Department of Financial Institutions administers the Act through the Nationwide Multistate Licensing System (NMLS).", "effective": "Express virtual-currency exclusion in the Money Transmitter Act; VC-kiosk operators licensed under HB 72 (2026), effective May 6, 2026", "lastVerified": "2026-09-02", "sourceText": "Utah Code \u00a7 7-25-102 (definition of \u201cmoney transmission\u201d excludes a blockchain token); HB 72 (2026) requires virtual-currency kiosk operators to be licensed under the Money Transmitter Act.", "sourceUrl": "https://le.utah.gov/xcode/Title7/Chapter25/7-25-S102.html", "summary": "Utah excludes \u201cblockchain tokens\u201d from money transmission, so standalone virtual-currency transmission is not licensed, but virtual-currency kiosk operators must be licensed under HB 72 (2026). Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "No Utah money-transmitter license is required for standalone virtual-currency transmission (\u201cmoney transmission\u201d excludes a blockchain token, Utah Code \u00a7 7-25-102).", "Operating a virtual-currency kiosk requires a license under the Money Transmitter Act and is money transmission regardless of blockchain tokens (HB 72 (2026)), administered by the Department of Financial Institutions via NMLS.", "Federal FinCEN money-services-business registration and a Bank Secrecy Act / AML program still apply to virtual-currency businesses regardless of state licensing.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "New Mexico", "slug": "new-mexico", "status": "live", "statusLabel": "Live Regime", "framework": "New Mexico Uniform Money Services Act (NMSA 1978 \u00a7 58-32-102 (definitions); \u00a7 58-32-201 (license required)). Virtual currency is reached by regulator interpretation of \u201cmonetary value,\u201d not by an express virtual-currency statute.", "regulator": "New Mexico Financial Institutions Division (Regulation and Licensing Department)", "detail": "New Mexico requires a money-transmitter license to deal in virtual currency, reaching that result by regulator interpretation rather than express statute. The Uniform Money Services Act defines \u201cmoney transmission\u201d as receiving money or monetary value for transmission, and \u201cmonetary value\u201d as \u201ca medium of exchange, whether or not redeemable in money\u201d (NMSA 1978 \u00a7 58-32-102). The Regulation and Licensing Department\u2019s Financial Institutions Division (FID) has stated that any business exchanging virtual currency for money, monetary value, or stored value for New Mexico residents must be licensed as a money transmitter under \u00a7 58-32-201.", "effective": "Uniform Money Services Act in force; FID interprets it to require money-transmitter licensing for virtual-currency exchange/transmission", "lastVerified": "2026-09-02", "sourceText": "\u201cMonetary value\u201d means a medium of exchange, whether or not redeemable in money (NMSA 1978 \u00a7 58-32-102); license required under \u00a7 58-32-201.", "sourceUrl": "https://www.rld.nm.gov/financial-institutions/", "summary": "New Mexico requires a money-transmitter license for virtual-currency dealing, reaching that result by regulator interpretation of \u201cmonetary value.\u201d Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "Obtain a New Mexico money-transmitter license from the Financial Institutions Division before exchanging virtual currency for money or other value for New Mexico residents (Uniform Money Services Act, NMSA 1978 \u00a7 58-32-201; \u00a7 58-32-102 \u201cmonetary value\u201d).", "Meet the licensing law\u2019s prudential requirements (surety bond or net worth, permissible investments or reserve holdings) and comply with AML, reporting, and consumer-disclosure obligations.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Mississippi", "slug": "mississippi", "status": "live", "statusLabel": "Live Regime", "framework": "Mississippi money transmission law (Miss. Code \u00a7 75-15-3; broad \u201cmonetary value\u201d definition) and the Mississippi Money Transmission Modernization Act. Virtual-currency kiosk operators are licensed as money transmitters under HB 1625 (2026), effective July 1, 2026.", "regulator": "Mississippi Department of Banking and Consumer Finance", "detail": "Mississippi treats virtual-currency transmission as licensable money transmission. The statute defines \u201cmonetary value\u201d as \u201ca medium of exchange, whether or not redeemable in money\u201d (Miss. Code \u00a7 75-15-3), language broad enough to reach virtual currency, and major exchanges hold Mississippi money-transmitter licenses. HB 1625 (2026), the Mississippi Virtual Currency Kiosk Consumer Protection Act, makes this explicit for kiosks: a virtual-currency kiosk operator may not operate without a license under the Money Transmission Modernization Act and must comply with money-transmitter requirements, effective July 1, 2026, with the Department of Banking and Consumer Finance exercising authority over kiosk operators.", "effective": "Money transmission covers virtual currency via the broad \u201cmonetary value\u201d definition; VC-kiosk operators licensed under HB 1625, effective July 1, 2026", "lastVerified": "2026-09-02", "sourceText": "HB 1625 (2026), Mississippi Virtual Currency Kiosk Consumer Protection Act: virtual-currency kiosk operators must be licensed under the Money Transmission Modernization Act, effective July 1, 2026; \u201cmonetary value\u201d defined at Miss. Code \u00a7 75-15-3.", "sourceUrl": "https://billstatus.ls.state.ms.us/documents/2026/html/HB/1600-1699/HB1625SG.htm", "summary": "Mississippi treats virtual-currency transmission as licensable money transmission, and virtual-currency kiosk operators are licensed under HB 1625 (2026). Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "Obtain a Mississippi money-transmitter license from the Department of Banking and Consumer Finance before transmitting virtual currency for Mississippi customers (\u201cmonetary value\u201d reaches virtual currency, Miss. Code \u00a7 75-15-3).", "Virtual-currency kiosk operators must be licensed under the Money Transmission Modernization Act, effective July 1, 2026 (HB 1625 (2026)).", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "West Virginia", "slug": "west-virginia", "status": "live", "statusLabel": "Live Regime", "framework": "West Virginia Money Transmission Modernization Act (W. Va. Code \u00a7 32A-2-1 et seq., as amended by HB 5353 (2026)). \u201cMoney transmission\u201d expressly reaches virtual currency (control of virtual currency, virtual-currency kiosks, digital wallets, and exchange).", "regulator": "West Virginia Division of Financial Institutions", "detail": "West Virginia\u2019s money transmission statute, W. Va. Code \u00a7 32A-2 (the Money Transmission Modernization Act), expressly reaches virtual currency. Section 32A-2-1 defines \u201ccontrol of virtual currency,\u201d \u201cdigital wallet,\u201d and \u201cexchange\u201d (which includes virtual currency), and the definition of \u201cmoney transmission\u201d includes \u201cengaging in the business of owning or operating a virtual currency kiosk.\u201d HB 5353 (2026) amended \u00a7 32A-2-1 and related sections to modernize licensing and bring virtual-currency activity, including kiosks, within money-transmission licensure. (The tracker\u2019s prior citation to HB 2585 (2019) was incorrect; HB 2585 was a 2017 money-laundering measure.) The Division of Financial Institutions administers the Act.", "effective": "Money-transmission definition amended to reach virtual currency by HB 2585 (2019); licensing administered by the Division of Financial Institutions", "lastVerified": "2026-09-02", "sourceText": "W. Va. Code \u00a7 32A-2-1 defines \u201ccontrol of virtual currency\u201d and includes \u201cengaging in the business of owning or operating a virtual currency kiosk\u201d within money transmission (Money Transmission Modernization Act, as amended by HB 5353 (2026)).", "sourceUrl": "https://code.wvlegislature.gov/32A-2-1/", "summary": "West Virginia\u2019s Money Transmission Modernization Act expressly reaches virtual currency (control of virtual currency, kiosks, digital wallets, exchange). Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "Obtain a West Virginia money-transmitter license from the Division of Financial Institutions before transmitting virtual currency for West Virginia customers (Money Transmission Modernization Act, W. Va. Code \u00a7 32A-2-1 et seq., as amended by HB 5353 (2026)).", "Meet the licensing law\u2019s prudential requirements (surety bond or net worth, permissible investments or reserve holdings) and comply with AML, reporting, and consumer-disclosure obligations.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Vermont", "slug": "vermont", "status": "live", "statusLabel": "Live Regime", "framework": "Vermont money transmission law (8 V.S.A. ch. 79), amended by Act 110 (2023 Adj. Sess., effective July 1, 2024) to include virtual-currency business activity; virtual-currency kiosk operators are governed by 8 V.S.A. \u00a7 2577.", "regulator": "Vermont Department of Financial Regulation", "detail": "Vermont overhauled its money-transmission law through Act 110 (2023 Adj. Sess.), effective July 1, 2024, adopting the Money Transmission Modernization Act and bringing virtual-currency business activity within licensing: persons exchanging, storing, or transmitting virtual currency, or receiving virtual currency or control of it for transmission, as a business must be licensed by the Department of Financial Regulation. Virtual-currency kiosk operators are separately regulated under 8 V.S.A. \u00a7 2577, which caps single-customer cash transactions (originally $1,000 per day, raised to $2,000 effective July 1, 2025) and bars new virtual-currency kiosks from operating in Vermont before July 1, 2026 unless the kiosk was licensed and operational on or before June 30, 2024. The Department of Financial Regulation administers the law.", "effective": "Money-transmitter law amended 2024 to formally include virtual-currency business activity (incl. kiosks, 8 V.S.A. \u00a7 2577)", "lastVerified": "2026-09-02", "sourceText": "Vermont adopted the Money Transmission Modernization Act via Act 110 (2023 Adj. Sess., eff. July 1, 2024), reaching virtual-currency business activity; virtual-currency kiosks governed by 8 V.S.A. \u00a7 2577.", "sourceUrl": "https://legislature.vermont.gov/statutes/section/08/079/02577", "summary": "Vermont licenses virtual-currency business activity under its Money Transmission Modernization Act (Act 110), with kiosk-specific rules in 8 V.S.A. \u00a7 2577. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "Obtain a Vermont license from the Department of Financial Regulation before engaging in virtual-currency business activity for Vermont customers (8 V.S.A. ch. 79, Act 110 (2023 Adj. Sess.)).", "Virtual-currency kiosk operators face caps and a moratorium on new kiosks before July 1, 2026 (8 V.S.A. \u00a7 2577).", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] }, { "name": "Wisconsin", "slug": "wisconsin", "status": "excluded", "statusLabel": "VC Excluded", "framework": "Wisconsin Money Transmission Modernization Act (Wis. Stat. ch. 217), enacted by 2023 Wisconsin Act 267 (effective Jan. 1, 2025), replacing the former Seller of Checks law. General virtual-currency transmission is not licensed; virtual-currency kiosks are regulated under Wis. Stat. \u00a7 217.12.", "regulator": "Wisconsin Department of Financial Institutions", "detail": "Wisconsin does not license general virtual-currency or stablecoin transmission. 2023 Wisconsin Act 267 (signed April 4, 2024, effective January 1, 2025) repealed the former Seller of Checks law (the prior Wis. Stat. ch. 217) and replaced it with the Money Transmission Modernization Act, now codified at Wis. Stat. ch. 217. Wisconsin adopted the model act without its optional virtual-currency provisions, so transmitting virtual currency by itself generally does not require a Wisconsin money-transmitter license, though a business handling both virtual and fiat currency may need one for the fiat leg. The Act does expressly regulate virtual-currency kiosks under Wis. Stat. \u00a7 217.12, imposing antifraud, disclosure, and customer-identification requirements on kiosk operators. The Department of Financial Institutions administers the Act.", "effective": "DFI interpretation: authority does not extend to virtual-currency transmission (fiat leg still licensed)", "lastVerified": "2026-09-02", "sourceText": "2023 Wisconsin Act 267 replaced the Seller of Checks law with the Money Transmission Modernization Act (Wis. Stat. ch. 217, eff. Jan. 1, 2025); general virtual-currency transmission is not licensed, but virtual-currency kiosks are regulated under Wis. Stat. \u00a7 217.12.", "sourceUrl": "https://docs.legis.wisconsin.gov/statutes/statutes/217", "summary": "Wisconsin does not license general virtual-currency transmission, but virtual-currency kiosks are regulated under its 2023 Money Transmission Modernization Act. Issuing a payment stablecoin is separately governed by the federal GENIUS Act.", "keyPoints": [ "No Wisconsin money-transmitter license is required for general virtual-currency transmission (Money Transmission Modernization Act, Wis. Stat. ch. 217; Wisconsin did not adopt the optional virtual-currency provisions).", "Virtual-currency kiosk operators are regulated under Wis. Stat. \u00a7 217.12 (antifraud, disclosure, customer identification); a business handling fiat may need a license for the fiat leg.", "Federal FinCEN money-services-business registration and a Bank Secrecy Act / AML program still apply to virtual-currency businesses regardless of state licensing.", "To issue a payment stablecoin, be a permitted payment stablecoin issuer under the federal GENIUS Act (federally regulated, or a state-qualified issuer), separate from state money-transmission licensing." ] } ] }