The Minnesota money transmitter license guide (Faisal Khan LLC, July 2026) covers one of only three states — alongside Maine and North Dakota — that adopted the MTMA's optional virtual currency provisions, and one that has just banned crypto kiosks outright.
S.F. 3868, signed 5 May 2026, adds § 53B.751: from 1 August 2026 no person may install, operate or make available a virtual currency kiosk in Minnesota, and by 31 December 2026 kiosks must be removed and kiosk-only operators must pay out all customer holdings within 30 days, recorded on-chain. This repeals the kiosk conduct regime enacted only two years earlier. The guide is blunt: "If you are evaluating a kiosk business in Minnesota, the answer is no."
What the guide covers:
- License fee of $4,000 — high nationally — plus $2,500 annual renewal under Minn. Stat. §§ 53B.28–53B.75
- Bond under § 53B.60: greater of $100,000 or 100% of average daily in-state liability, capped at $500,000, filed only as an Electronic Surety Bond through NMLS
- Tangible net worth under § 53B.59: greater of $100,000 or the standard 3%/2%/0.5% bands, worked example $6,000,000 on $250M in assets
- Crypto reached through a separate article (§§ 53B.69–53B.75) rather than the core money transmission definition, with its own exemption set including a $5,000/year de minimis and infrastructure-provider carve-outs
- A genuine 120-day deemed-approval clock, and a six-month incomplete application treated as withdrawn with no fee refund
- Customer fund protection via the permissible investments mechanism and a statutory trust on insolvency — not mandated segregation or daily reconciliation
The guide also flags exemptions other sources overstate: there is no insurance-company or telecommunications-carrier exemption in Minnesota, only a narrow carve-out for carriers providing solely network access.
