A working map of how state money-transmission and digital-asset licensing regimes interact with the federal GENIUS Act framework, tracked jurisdiction by jurisdiction and linked to primary sources.
A running record of verifications and reclassifications, drawn from automated source monitoring and primary-source review.
Every jurisdiction as machine-readable data: status, regulator, framework, effective dates, and primary-source links. Take it as CSV, JSON, or a print-ready PDF. Free to use with attribution.
Updates go out through The Clarity Brief, primary-source analysis of state and federal stablecoin regulation. Subscribe to hear when a jurisdiction moves.
Every jurisdiction as machine-readable data: status, regulator, framework, effective dates, and primary-source links. Take it as CSV, JSON, or a print-ready PDF. Free to use with attribution.
Signed into law on July 18, 2025 (P.L. 119-27, S. 1582), the GENIUS Act created the first comprehensive federal framework for payment stablecoins. Issuers with $10 billion or less in outstanding stablecoins may elect state-level supervision if their state regime is "substantially similar" to the federal framework; issuers above that threshold must transition to federal oversight (OCC, Fed, FDIC, or NCUA depending on issuer type) within 360 days of crossing it. On April 3, 2026, Treasury proposed broad-based principles for evaluating whether a state regime qualifies as substantially similar, with most implementing rulemakings due by July 18, 2026. In December 2025, the OCC granted conditional national trust bank charters to five digital asset firms: Circle (as First National Digital Currency Bank), Paxos, Ripple, BitGo, and Fidelity Digital Assets. The Act's core requirements are expected to take effect on January 18, 2027 (18 months after enactment), the date that anchors most state rules keyed to the GENIUS Act. On August 18, 2026, Treasury proposed a further rule (12 CFR Part 1523) implementing the Act's Section 3 prohibitions: only a permitted payment stablecoin issuer may issue a payment stablecoin, and digital asset service providers such as exchanges may not offer or sell a stablecoin that is not issued by a permitted issuer (that restriction phases in three years after enactment, with separate rules for foreign issuers taking effect on the Act's effective date).
Sources: Federal Register, Apr. 3, 2026 NPRM · Federal Register, Aug. 18, 2026 NPRM (Section 3) · OCC Bulletin 2026-3
State money-transmission law and the federal GENIUS Act regulate different activities, so a state can "exclude" virtual currency while federal rules still apply.
State licensing (what the map tracks): whether a state requires a money-transmitter license to transmit, exchange, or custody stablecoins and other virtual currency for others. States marked VC Excluded do not require a state transmitter license for this activity.
Federal issuance, under the GENIUS Act: the Act governs the issuance of payment stablecoins. Only a permitted issuer may issue one: a federally regulated issuer, or a state-qualified issuer under a regime deemed "substantially similar" to the federal framework. FinCEN's federal anti-money-laundering rules also reach crypto money-services businesses independently.
Preemption for permitted issuers: a federally-permitted payment stablecoin issuer (PPSI) is preempted from state money-transmitter licensing for its stablecoin activity, even where a license is otherwise required. Third parties that transmit or custody stablecoins for a fee still fall under state licensing where required.
Issuance vs. transmission: GENIUS governs the issuance of stablecoins, not the transmission or exchange of them by third parties. It does not require a state to license that transmission activity, which stays a matter of state money-transmission law plus federal FinCEN and Bank Secrecy Act registration. That state-transmission question is the axis the map's VC Excluded status describes. Either way, the coins themselves must still be issued by a GENIUS-permitted issuer.
In short, a VC Excluded state is not one where stablecoins are unregulated: no state transmitter license is required to move virtual currency there, while payment-stablecoin issuance stays federally governed, and states like Georgia are building dedicated issuer regimes to qualify for the state pathway.
The Money Transmission Modernization Act is a model law from the Conference of State Bank Supervisors that standardizes money-transmitter licensing. Roughly 31 states have adopted it in full or in part. Adoption mostly concerns general licensing standards, so it does not, by itself, tell you how a state treats stablecoins.
The exception is the Act's optional virtual-currency provisions (Title XIII): only Minnesota and North Dakota adopted them, expressly bringing virtual-currency business under licensing. Those two are flagged on their state cards.
In plain terms: any digital representation of value recorded on a blockchain or similar cryptographically secured ledger.
The term “digital asset” means any digital representation of value that is recorded on a cryptographically secured distributed ledger.
Source: GENIUS Act § 2(6)
In plain terms: a digital asset used to pay or settle, whose issuer promises to redeem it for a fixed amount of money and to keep its value stable. National currencies and bank deposits do not count.
The term “payment stablecoin”—
(A) means a digital asset—
(i) that is, or is designed to be, used as a means of payment or settlement; and
(ii) the issuer of which—
(I) is obligated to convert, redeem, or repurchase for a fixed amount of monetary value, not including a digital asset denominated in a fixed amount of monetary value; and
(II) represents that such issuer will maintain, or create the reasonable expectation that it will maintain, a stable value relative to the value of a fixed amount of monetary value; and
(B) does not include a digital asset that—
(i) is a national currency (the statute lists further exclusions, including certain deposits).
Source: GENIUS Act § 2(22)
In plain terms: the umbrella term for anyone legally allowed to issue a payment stablecoin in the United States. Only these three kinds of entity may issue one.
The term “permitted payment stablecoin issuer” means a person formed in the United States that is—
(A) a subsidiary of an insured depository institution that has been approved to issue payment stablecoins under section 5;
(B) a Federal qualified payment stablecoin issuer; or
(C) a State qualified payment stablecoin issuer.
Source: GENIUS Act § 2(23)
In plain terms: a company set up under a state's laws and approved by that state's stablecoin regulator to issue payment stablecoins — the state-supervised path the GENIUS Act allows. It excludes national banks, federal branches, and insured depository institutions, which are federally regulated instead.
The term “State qualified payment stablecoin issuer” means an entity that—
(A) is legally established under the laws of a State and approved to issue payment stablecoins by a State payment stablecoin regulator; and
(B) is not an uninsured national bank chartered by the Comptroller pursuant to title LXII of the Revised Statutes, a Federal branch, an insured depository institution, or a subsidiary of such national bank, Federal branch, or insured depository institution.
Source: GENIUS Act § 2(31)
In plain terms: a business (such as a crypto exchange or custodian) that, for profit, trades, transfers, or custodies digital assets for people in the United States. It excludes the underlying software and infrastructure — protocols, self-custodial wallet interfaces, validators, and liquidity pools.
The term “digital asset service provider”—
(A) means a person that, for compensation or profit, engages in the business in the United States (including on behalf of customers or users in the United States) of—
(i) exchanging digital assets for monetary value;
(ii) exchanging digital assets for other digital assets;
(iii) transferring digital assets to a third party;
(iv) acting as a digital asset custodian; or
(v) participating in financial services relating to digital asset issuance; and
(B) does not include—
(i) a distributed ledger protocol;
(ii) developing, operating, or engaging in the business of developing distributed ledger protocols or self-custodial software interfaces;
(iii) an immutable and self-custodial software interface;
(iv) developing, operating, or engaging in the business of validating transactions or operating a distributed ledger; or
(v) participating in a liquidity pool or other similar mechanism for the provisioning of liquidity for peer-to-peer transactions.
Source: GENIUS Act § 2(7)