Understanding US Cryptocurrency Regulations in 2025

The landscape of US Cryptocurrency Regulations in 2025 is a complex and evolving framework, combining federal and state-level rules. Each of the 50 states, Washington D.C., and U.S. territories—such as Guam, Puerto Rico, and the U.S. Virgin Islands—has its own set of laws governing money services businesses (MSBs), virtual currencies, and crypto assets. While compliance requirements vary, many states mandate a money transmitter license (MTL) to operate with cryptocurrency.

At the federal level, MSBs and virtual currency service providers must adhere to regulations enforced by agencies like the Financial Crimes Enforcement Network (FinCEN) and the Treasury Department’s Office of Foreign Assets Control (OFAC). These include registering with FinCEN and complying with anti-money laundering (AML) and know-your-customer (KYC) requirements.

Below, we’ve compiled a detailed, state-by-state table outlining licensing requirements for cryptocurrency businesses under US Cryptocurrency Regulations. This resource is continuously updated to reflect the latest developments in this dynamic regulatory environment. While some states have clear guidelines, others are still crafting specific rules, and federal oversight remains a work in progress as agencies clarify how existing laws apply to virtual currencies.


State of Cryptocurrency Regulations by US States 2025 – Licensing Requirements and Key Details

Cryptocurrency Laws: State by State

StateLicense Requirement for Cryptocurrency BusinessesLicense NameRegulatorLegal Code / Reference LinkApplicability to Specific Crypto ActivitiesHistorical Trends
AlabamaYes – Alabama requires a money transmitter license for businesses dealing in cryptocurrency (virtual currency is included as “monetary value” under state law).Money Transmitter License (Alabama Monetary Transmission Act)Alabama Securities CommissionAla. Code § 8-7A-2(8),(10) (Monetary Transmission Act) Alabama Securities CommissionPersonal Buying/Selling: No license required for individuals (only if you’re in the business of transmission).

OTC Trading (Business): Yes – businesses buying/selling crypto for customers must be licensed.

Bitcoin/Crypto ATMs: Yes – considered money transmission if exchanging cash for crypto.

Crypto Exchanges/Wallet Services: Yes – exchanges/custodial wallets must be licensed.

Stablecoin Issuers: Yes – stablecoin issuance is treated as “monetary value” transmission.
2017: Enacted the Alabama Monetary Transmission Act, explicitly including virtual currency. Alabama’s Securities Commission actively supervises crypto MSBs, requiring they be licensed and comply with anti-fraud measures.
AlaskaYes – Effective January 1, 2023, Alaska requires a money transmitter license for virtual currency activities (previously not regulated if purely crypto-only).Money Transmitter License (updated to include virtual currency)Alaska Division of Banking & SecuritiesAlaska Admin. Code tit. 3, § 13 (updated per 2022 HB 85) Alaska Division of Banking & SecuritiesPersonal Buying/Selling: Not licensed if purely crypto-crypto; new rules cover fiat on/off ramp.

OTC Trading (Business): Yes – if handling fiat or acting as an intermediary for Alaskans.

Bitcoin/Crypto ATMs: Yes – must be licensed after the 2023 law change.

Crypto Exchanges/Wallet Services: Yes – if providing fiat on/off ramp or custodial services.

Stablecoin Issuers: Yes – stablecoin redemption or issuance with Alaskans is deemed money transmission.
Until 2023: Alaska did not regulate virtual currency. 2022: Alaska passed HB 85 to bring crypto within money transmission licensing. Went into effect Jan 2023, bringing ATM operators, exchanges under regulatory scope.
ArizonaYes – Arizona treats cryptocurrency under existing money transmitter laws (no separate crypto license). Exchanges, ATMs, and OTC with fiat must get an AZ MTL.Money Transmitter LicenseArizona Dept. of Insurance and Financial Institutions (AZ-DIFI)Ariz. Rev. Stat. § 6-1201 et seq. AZ-DIFIPersonal Buying/Selling: No license for personal use.

OTC Trading (Business): Yes – if there’s fiat involved in transactions.

Bitcoin/Crypto ATMs: Yes – a two-way ATM is money transmission.

Crypto Exchanges/Wallet Services: Yes – custodial services or fiat on/off ramps require a license.

Stablecoin Issuers: Yes – stablecoins are treated as monetary value under AR law, so licensing is required.
2018: Arizona created a FinTech Sandbox, offering temporary relief to certain startups. However, long-term, crypto businesses must comply with the standard money transmitter rules. Arizona also recognized blockchain signatures as valid in state law.
ArkansasYes – In 2023, Arkansas updated its Uniform Money Services Act to explicitly include “virtual currency” in the definition of money transmission, requiring a license.Money Transmission License (Arkansas Uniform Money Services Act)Arkansas Securities DepartmentArk. Code Ann. § 23-55-102 & § 23-55-201 Arkansas Securities DepartmentPersonal Buying/Selling: No license for personal use.

OTC Trading (Business): Yes – must be licensed if conducting crypto-fiat trades.

Bitcoin/Crypto ATMs: Yes – newly defined as money transmission if exchanging cash/crypto.

Crypto Exchanges/Wallet Services: Yes – regulated if handling Arkansas residents’ funds.

Stablecoin Issuers: Yes – stablecoins are included under “virtual currency” transmission.
2023: Arkansas included virtual currency under its money transmission law, effective August 2023. Previously, Arkansas had no explicit reference to crypto. The new law requires licensing, bonding, and compliance for crypto businesses.
CaliforniaYes – California enacted the Digital Financial Assets Law (DFAL) in 2023, creating a new licensing framework for cryptocurrency. Though it goes into effect in 2025, crypto businesses are generally expected to follow CA money transmitter rules until then.Digital Financial Assets License (under DFAL) – pending 2025California Dept. of Financial Protection and Innovation (DFPI)2023 CA AB 39 / SB 401 (DFAL) CA DFPIPersonal Buying/Selling: No license for personal trades.

OTC Trading (Business): Yes – will need DFAL if serving CA residents (once in effect).

Bitcoin/Crypto ATMs: Yes – subject to money transmitter rules, soon to be DFAL rules.

Crypto Exchanges/Wallet Services: Yes – must obtain DFAL or maintain current money transmitter license.

Stablecoin Issuers: Yes – DFAL includes stablecoin reserve and licensing requirements.
Multiple attempts to pass a “BitLicense”-style law started around 2015.

2023: The Digital Financial Assets Law passed, with an effective date in July 2025. Until then, crypto firms either use standard MSB licensing or no explicit state licensing. Once DFAL is active, CA will have a comprehensive framework.
ColoradoYes (only if fiat is involved) – Colorado’s Division of Banking guidance says purely crypto-to-crypto transactions are not regulated. But receiving or transmitting fiat on behalf of someone else triggers licensing. Most crypto firms that handle fiat do get a CO money transmitter license.Money Transmitter License (if handling fiat)Colorado Division of BankingColorado Division of Banking Guidance (2018)Personal Buying/Selling: No license for person-to-person crypto-only trades.

OTC Trading (Business): If the desk does not hold fiat or transmit it for others, no license. If it does, license is required.

Bitcoin/Crypto ATMs: Generally not considered money transmitters if they only sell their own crypto for cash. If they hold funds for third parties, licensure might apply.

Crypto Exchanges/Wallet Services: If an exchange handles fiat on behalf of customers, it needs a license. Pure crypto-only platforms are exempt. –

Stablecoin Issuers: Not specifically addressed. Holding fiat redeemable for stablecoin may trigger license.
2018: CO Division of Banking stated crypto-only transactions are not money transmission under state law, making Colorado more permissive. The state also recognized digital tokens under the Colorado Digital Token Act (2019). Colorado remains crypto-friendly, regulating only the fiat portion of transactions.
ConnecticutYes – Connecticut requires a money transmitter license for virtual currency businesses and mandates that licensees maintain the same type and amount of crypto as owed to customers.Money Transmitter LicenseConnecticut Department of BankingConn. Gen. Stat. § 36a-597(c) CT Department of BankingPersonal Buying/Selling: No license for personal, non-business use.

OTC Trading (Business): Yes – a business facilitating crypto exchange must be licensed.

Bitcoin/Crypto ATMs: Yes – ATM operators need a license.

Crypto Exchanges/Wallet Services: Yes – must maintain a 1:1 reserve of each crypto owed to customers.

Stablecoin Issuers: Yes – stablecoins also fall under the same “like-kind reserve” requirements, meaning they must hold full reserves in matching assets.
2017: CT enacted specific provisions for virtual currency, becoming an early adopter. Requires 1:1 matching of customer crypto holdings. The Department of Banking actively enforces licensing and participates in multi-state supervision of major exchanges.
DelawareYes – Delaware has no separate virtual currency license, but under existing law, any business transmitting funds (including crypto-fiat exchanges) requires a money transmitter license.Money Transmitter LicenseDelaware Office of the State Bank CommissionerDel. Code Ann. tit.5, § 2301 et seq. Delaware Bank CommissionerPersonal Buying/Selling: No license for personal use.

OTC Trading (Business): Yes – exchanging crypto for fiat as a business is money transmission.

Bitcoin/Crypto ATMs: Yes – an ATM that exchanges cash for crypto or vice versa must be licensed.

Crypto Exchanges/Wallet Services: Yes – any exchange handling fiat or custody must have a DE license.

Stablecoin Issuers: Yes – stablecoin issuance or redemption for fiat triggers money transmitter licensing.
2017: Delaware enacted blockchain-friendly laws for corporate record-keeping. However, for financial regulation, it treats crypto businesses under the same money transmitter rules as any other. Delaware has joined multi-state supervisory arrangements for large crypto exchanges.
FloridaYes – Florida requires cryptocurrency businesses to obtain a Money Services Business (MSB) license. In 2021, the Florida Office of Financial Regulation clarified that selling cryptocurrency (even via an ATM) to the public constitutes money transmission.Money Services Business License (Florida Money Transmitter License)Florida Office of Financial Regulation (OFR)Fla. Stat. § 560.103(23); § 560.204 Florida OFRPersonal Buying/Selling: If done as a business or repeated for profit, a license is required (State v. Espinoza, 2019).

OTC Trading (Business): Yes—any OTC desk dealing in crypto-fiat must register as MSB.

Bitcoin/Crypto ATMs: Yes—two-way Bitcoin ATMs are deemed money transmission.

Crypto Exchanges/Wallet Services: Yes—custodial exchanges need a license.

Stablecoin Issuers: Yes—issuing/redeeming stablecoins for fiat triggers licensure.
2019: State v. Espinoza ruling: selling Bitcoin for cash = money transmission.

2021: OFR warned unlicensed crypto ATM operators to comply.

Florida actively enforces MSB rules for crypto.
GeorgiaYes – Georgia law explicitly includes “virtual currency” as monetary value. Exchanges, brokers, and ATM operators dealing in crypto-fiat must hold a GA money transmitter license.Money Transmitter LicenseGeorgia Department of Banking and FinanceGa. Code Ann. § 7-1-690(b)(1); § 7-1-680(26) Georgia DBFPersonal Buying/Selling: No license for private, individual usage.

OTC Trading (Business): Yes—facilitating crypto trades for customers requires licensure.

Bitcoin/Crypto ATMs: Yes—exchanging cash for crypto is regulated.

Crypto Exchanges/Wallet Services: Yes—custodial or fiat-handling services must be licensed.

Stablecoin Issuers: Yes—stablecoins = “virtual currency,” so issuance/redemption is regulated.
2016: Georgia included virtual currency in state law—among earliest states.- GA requires surety bonds; has enforced licensing for crypto MSBs.
HawaiiNo – As of mid-2024, Hawaii imposes no state licensure requirement on crypto businesses. Its prior pilot ended, and regulators announced no money transmitter requirement for crypto.N/A (No state license required)Hawaii Division of Financial Institutions (DFI)HI DFI UpdatesPersonal Buying/Selling: No license needed.

OTC Trading (Business): No license—Hawaii ended the prior double-reserve rule.

Bitcoin/Crypto ATMs: No state MTL required.

Crypto Exchanges/Wallet Services: No—federal MSB registration still applies, but not state.

Stablecoin Issuers: No separate state requirement.
2017: Double-reserve rule drove major exchanges out.

2020–2022: Digital Currency Innovation Lab pilot.

2024: Pilot ended; Hawaii now imposes no state-level MTL obligations for crypto.
IdahoYes – Idaho’s Money Transmitters Act covers crypto-fiat transactions. The Department of Finance sometimes issues no-action letters if an entity only sells from its own inventory and never holds customer funds, but most business models involving fiat or third-party funds must be licensed.Money Transmitter LicenseIdaho Department of FinanceIdaho Code § 26-2902 Idaho DoFPersonal Buying/Selling: No license for private crypto transactions.

OTC Trading (Business): Generally yes—if you hold customer fiat or crypto, must license.

Bitcoin/Crypto ATMs: Yes—unless only selling your own crypto with no third-party involvement.

Crypto Exchanges/Wallet Services: Yes—custodial or fiat-based require a license.

Stablecoin Issuers: Yes—no special exemption for stablecoins.
– 2015–2018: Idaho compelled large crypto exchanges to license.- No-Action Letters: Limited exemptions for “one-party” sellers who never custody others’ funds.

2022: Adopted Model Act with crypto included.
IllinoisConditional – Illinois does not license purely crypto-to-crypto businesses. If a service involves fiat (deposit/withdrawals), it is subject to the Transmitters of Money Act (TOMA).Transmitter of Money License (TOMA)Illinois Department of Financial & Professional Regulation (IDFPR)205 Ill. Comp. Stat. 657/2017 IDFPR GuidancePersonal Buying/Selling: No license for pure crypto.

OTC Trading (Business): If handling fiat for customers, TOMA license typically required.

Bitcoin/Crypto ATMs: Yes—accepting or dispensing USD is money transmission.

Crypto Exchanges/Wallet Services: Yes—fiat on/off ramps = TOMA license. Pure crypto is exempt.

Stablecoin Issuers: Likely yes—fiat redemption/issuance triggers TOMA.
2017: IDFPR guidance: crypto alone ≠ “money,” but mixing fiat triggers licensing.- Illinois created a Blockchain Task Force; most exchanges got IL licenses to handle bank transfers.
IndianaYes (for fiat handling) – Indiana does not license purely crypto transactions. If a business accepts/transmits fiat on behalf of customers to buy/sell crypto, it must get an Indiana MTL.Money Transmitter LicenseIndiana Department of Financial Institutions (DFI)Ind. Code § 28-8-4.1 Indiana DFIPersonal Buying/Selling: No license for personal or crypto-only trades.

OTC Trading (Business): Yes—if holding fiat or acting as an intermediary.

Bitcoin/Crypto ATMs: Yes—cash in/out = money transmission.

Crypto Exchanges/Wallet Services: Yes—fiat involvement triggers licensure.

Stablecoin Issuers: Yes—receiving fiat for stablecoins is money transmission.
2021–2022: Adopted Model Money Transmission Modernization Act.- Indiana clarifies it doesn’t regulate pure crypto usage, only the fiat side. This fosters crypto innovation while still overseeing fiat transmissions.
IowaYes – Iowa uses its Uniform Money Services Act to regulate crypto as “monetary value.” Exchanges, OTC desks, and ATM operators must have an Iowa money transmitter license.Money Transmission License (Iowa UMSA)Iowa Division of BankingIowa Code § 533C Iowa DOBPersonal Buying/Selling: No license for private individuals.

OTC Trading (Business): Yes—if handling fiat or acting as a custodian.

Bitcoin/Crypto ATMs: Yes—cash in/out is transmission.

Crypto Exchanges/Wallet Services: Yes—custodial or fiat-based must license.

Stablecoin Issuers: Yes—treated as money transmission.
By 2020: Major crypto exchanges obtained IA licenses.- Iowa is part of multi-state supervision and enforces MSB laws for crypto. No special crypto exemptions exist.
KansasConditional – Kansas exempts purely virtual currency transactions from money transmission. If fiat is involved, a money transmitter license is required.Money Transmitter LicenseKansas Office of the State Bank Commissioner (OSBC)Kan. Stat. Ann. § 9-508 KS OSBC GuidancePersonal Buying/Selling: No license for crypto-only trades.

OTC Trading (Business): If handling fiat for customers, license is needed.

Bitcoin/Crypto ATMs: Yes—any cash exchange triggers money transmission.

Crypto Exchanges/Wallet Services: Yes—fiat on/off ramp requires licensure.

Stablecoin Issuers: Yes—issuance/redeeming with fiat = transmission.
2014: Early official statement that crypto alone isn’t “money.”

2021: OSBC reaffirmed the fiat vs. crypto distinction. Kansas is straightforward: no license for crypto-only, license for any fiat involvement.
KentuckyYes – Kentucky’s money transmitter law defines “monetary value” broadly, covering crypto. Exchanges, brokers, and ATM operators must get a KY money transmitter license.Money Transmitter LicenseKentucky Department of Financial InstitutionsKy. Rev. Stat. § 286.11-003(6); § 286.11-005(1) KY DFIPersonal Buying/Selling: No license for personal usage.

OTC Trading (Business): Yes—if buying/selling crypto for fiat as a business.

Bitcoin/Crypto ATMs: Yes—kiosks exchanging cash for crypto must license.

Crypto Exchanges/Wallet Services: Yes—custodial or fiat services require licensing.

Stablecoin Issuers: Yes—stablecoin issuance/redemption = money transmission.
2020–2021: KY offered incentives for crypto mining but enforces MSB laws for exchange activities.- Major exchanges carry KY licenses, must post surety bonds and maintain net worth/cybersecurity standards.
LouisianaYes – Under the 2020 Virtual Currency Business Act (VCBA), any person engaging in “virtual currency business activity” with Louisiana residents must be licensed or registered if eligible for minimal-activity exemptions.Virtual Currency Business License (Louisiana)Louisiana Office of Financial Institutions (OFI)La. Rev. Stat. § 6:1381 et seq. Louisiana OFIPersonal Buying/Selling: Exempt for personal (non-business) use.

OTC Trading (Business): Must be licensed if regularly exchanging crypto for money.

Bitcoin/Crypto ATMs: Yes – considered virtual currency business activity unless exempt.

Crypto Exchanges/Wallets: Yes – custody or exchange for LA residents requires a license.

Stablecoin Issuers: Also covered as “virtual currency” under the Act, requiring a license (unless exempt).
2020: Louisiana enacted the VCBA, establishing a crypto-specific license. It allows some smaller businesses to register instead of getting a full license. Prior to this, LA relied on general money transmitter rules.
MaineYes – In April 2024, Maine enacted an updated Money Transmitters Modernization Act including virtual currency; crypto businesses serving ME residents must hold a license.Money Transmitter LicenseMaine Bureau of Consumer Credit Protection (Dept. of Professional & Financial Regulation)Me. Rev. Stat. tit. 32, § 6100-QQ (2024) Maine GovPersonal Buying/Selling: No license for purely personal transactions.

OTC Trading (Business): Yes – must license if exchanging crypto for fiat.

Bitcoin/Crypto ATMs: Yes – operating crypto ATMs requires licensure under the new law.

Crypto Exchanges/Wallets: Yes – custodial or exchange services fall under “virtual currency business activity.”

Stablecoin Issuers: Yes – issuance/redemption of stablecoins is included.
Historically, Maine had no explicit crypto regulations until 2024. The new Money Transmission Modernization Act (LD 2112) clarifies that virtual currency businesses require a license, aligning with other states adopting updated uniform standards.
MarylandYes – Maryland treats virtual currency as “monetary value” under its Money Transmitters Act. Crypto exchanges, ATM operators, and custodians must be licensed.Money Transmitter LicenseMaryland Commissioner of Financial Regulation (DLLR)Md. Code Ann., Fin. Inst. § 12-401 et seq. MD NMLS InfoPersonal Buying/Selling: No license for personal use.

OTC Trading (Business): Yes – if buying/selling crypto for customers.

Bitcoin/Crypto ATMs: Yes – must be licensed if handling cash-to-crypto in Maryland.

Crypto Exchanges/Wallets: Yes – custodial exchanges and wallet providers need a license.

Stablecoin Issuers: Yes – no special carve-out; stablecoins are treated as monetary value.
Maryland updated its law in 2021 to align with model standards and clarified crypto is “monetary value.” MD enforces licensing and joined multi-state supervisory actions for major crypto firms. Requires like-kind reserves and cybersecurity compliance.
MassachusettsNo separate crypto license – Massachusetts does not explicitly regulate virtual currency as “money.” However, if a business holds fiat on behalf of customers, the state’s Foreign Transmittal Agency License may apply.Foreign Transmittal Agency License (Money Transmitter)Massachusetts Division of Banks (MDOB)Mass. Gen. Laws ch. 169 MA Division of BanksPersonal Buying/Selling: No license for purely private crypto trading.

OTC Trading (Business): May need a license if holding fiat or acting as an intermediary. Case-by-case interpretive letters.

Bitcoin/Crypto ATMs: Possibly no license if the operator is merely selling its own crypto; but many operators still register to avoid ambiguity.

Crypto Exchanges/Wallets: Typically get licensed for the fiat side.

Stablecoin Issuers: Not explicitly addressed; if fiat is held, licensing may apply.
Massachusetts relies on interpretive letters rather than a crypto-specific statute. If purely crypto, no license required; if any fiat handling or custody, the state often applies its Foreign Transmittal Agency law. Many major exchanges hold an MA license “for fiat transmissions only.”
MichiganYes – Michigan’s Money Transmission Services Act (MTSA) covers receiving money (fiat) for transmission. While not naming crypto explicitly, the regulator applies it to crypto-fiat services.Money Transmission Services LicenseMichigan Dept. of Insurance and Financial Services (DIFS)Mich. Comp. Laws § 487.1001 et seq. MI DIFSPersonal Buying/Selling: No license for private crypto usage.

OTC Trading (Business): Yes – if handling customer fiat or acting as a broker, must be licensed.

Bitcoin/Crypto ATMs: Yes – two-way ATMs dealing with fiat are considered money transmitters.

Crypto Exchanges/Wallets: Yes – custodial or fiat deposit/withdrawal services require a license.

Stablecoin Issuers: Yes – issuance/redemption for fiat is money transmission.
Michigan never explicitly amended its law for crypto, but enforces licensing via broad “monetary value” interpretations. Since mid-2010s, large exchanges comply with MI licensing. The state is part of multi-state regulatory actions on crypto MSBs.
MinnesotaDe facto Yes – Minnesota does not explicitly define virtual currency as money, yet crypto-fiat businesses generally obtain a money transmitter license. Minnesota’s Commerce Dept. enforces licensing through multi-state compacts.Money Transmitter LicenseMinnesota Department of Commerce (Financial Institutions Division)Minn. Stat. § 53B.01 et seq. MN Commerce Dept.Personal Buying/Selling: No license if purely private.

OTC Trading (Business): Yes – if holding fiat or facilitating third-party trades.

Bitcoin/Crypto ATMs: Typically need a license for two-way ATMs dealing with cash.

Crypto Exchanges/Wallets: Yes – major exchanges are licensed for fiat transactions.

Stablecoin Issuers: No specific mention, but issuance/redeeming for fiat likely triggers licensing.
Historically, MN lacked explicit crypto language, but in practice, regulators treat crypto businesses as MSBs if fiat is involved. Minnesota has joined multi-state oversight of large crypto firms.

2023: The state imposed consumer protection rules for crypto ATMs (transaction limits).
MississippiYes – Mississippi requires a license for “money transmission,” which the state interprets to include crypto-fiat transactions. There’s no separate crypto law, so MSB licensing is the default.Money Transmitter LicenseMississippi Dept. of Banking and Consumer FinanceMiss. Code Ann. § 75-15-1 et seq. MS DBCFPersonal Buying/Selling: No license for individuals.

OTC Trading (Business): Yes – exchanging crypto for fiat on behalf of others requires a license.

Bitcoin/Crypto ATMs: Yes – operating ATMs for crypto-cash transactions is money transmission.

Crypto Exchanges/Wallets: Yes – custodial exchanges must license.

Stablecoin Issuers: Yes – no exemption for stablecoins; issuance is money transmission.
Mississippi never created a crypto-specific exemption. Since 2010s, the state quietly enforces standard MSB rules for crypto. It has participated in multi-state supervision and has occasionally taken enforcement action against unlicensed ATM operators.
MissouriYes – Missouri updated its Money Transmitter Act in 2023 to explicitly include virtual currency in the definition. Crypto exchanges, ATM operators, and custodial services must hold a license.Money Transmitter LicenseMissouri Division of FinanceMo. Rev. Stat. § 361.700 et seq. MO Division of FinancePersonal Buying/Selling: No license for personal use.

OTC Trading (Business): Yes – if facilitating crypto-fiat trades.

Bitcoin/Crypto ATMs: Yes – now explicitly covered.

Crypto Exchanges/Wallets: Yes – custodial or fiat-based services must license.

Stablecoin Issuers: Yes – stablecoin issuance is money transmission.
2023: Missouri passed S.B. 384 adopting the Model Money Transmission Modernization Act with virtual currency provisions. Before that, it was unclear, but major exchanges typically licensed anyway. Now, the law is explicit.
MontanaNo – Montana does not have a general money transmitter law at the state level, meaning crypto businesses do not need a state MSB license. (Federal MSB registration still applies.)N/A (No state MSB licensing law)N/A (No state licensing agency for money transmitters)Montana has no Money Transmitter Act [Montana Code Annotated – no MTL chapter]Personal Buying/Selling: No state license needed.

OTC Trading (Business): No state requirement.

Bitcoin/Crypto ATMs: No state license for ATM operators.

Crypto Exchanges/Wallets: No state license needed, but must comply with federal FinCEN rules.

Stablecoin Issuers: No state regulation.
Montana is the only state with no money transmitter law, so it does not license or supervise MSBs (crypto or otherwise). This made Montana a haven for crypto firms seeking fewer regulatory hurdles, though federal compliance (FinCEN) still applies.
NebraskaYes – Nebraska’s Money Transmitters Act defines “monetary value” broadly, covering virtual currency. In 2021, the state also introduced the Digital Asset Depository charter for crypto banks.Money Transmitter LicenseNebraska Department of Banking & FinanceNeb. Rev. Stat. § 8-2715(8); § 8-2720 NE Banking & FinancePersonal Buying/Selling: No license for personal usage.

OTC Trading (Business): Yes – must license or become a Digital Asset Depository.

Bitcoin/Crypto ATMs: Yes – exchanging crypto for cash triggers the MTL.

Crypto Exchanges/Wallets: Yes – either obtain an MTL or apply for the NE digital asset bank charter.

Stablecoin Issuers: Yes – stablecoins are included under money transmission unless operated as a state-chartered bank.
2021: Nebraska enacted LB 649, creating a Digital Asset Depository framework (similar to Wyoming’s SPDI). Non-bank crypto businesses must get a money transmitter license if handling fiat or custodial crypto. The state aims to attract crypto businesses via specialized charters while enforcing standard MSB rules for others.
NevadaYes – Nevada’s Money Transmitter Act covers businesses receiving money for transmission. While “money” historically referred to fiat, in practice NV requires crypto-fiat operators (exchanges, ATMs) to be licensed.Money Transmitter LicenseNevada Financial Institutions Division (FID)Nev. Rev. Stat. § 671.040 et seq. NV FIDPersonal Buying/Selling: No license for personal use.

OTC Trading (Business): Yes – handling fiat for crypto triggers licensing.

Bitcoin/Crypto ATMs: Yes – especially two-way ATMs dealing with USD.

Crypto Exchanges/Wallets: Yes – major exchanges are licensed in NV.

Stablecoin Issuers: Yes – no special stablecoin exemption, so issuance/redemption of fiat is money transmission.
2017: Nevada passed blockchain-friendly laws (banning local blockchain taxes) but didn’t exempt crypto from MSB rules. Crypto businesses have typically licensed under existing money transmitter statutes. NV FID coordinates with other states for multi-state oversight.
New HampshireNo – Under HB 436 (2017), New Hampshire exempted virtual currency businesses from its money transmitter laws. No license is required for crypto exchanges, brokers, or ATM operators purely dealing in crypto.N/A (Crypto exempt from money transmitter requirements)New Hampshire Banking DepartmentN.H. Rev. Stat. Ann. § 399-G:3, VII NH Banking Dept.Personal Buying/Selling: No license needed.

OTC Trading (Business): No license – fully exempt if only dealing in crypto.

Bitcoin/Crypto ATMs: No license – NH does not treat crypto as money.

Crypto Exchanges/Wallets: No NH license required.

Stablecoin Issuers: Also exempt under the same statute (unless dealing with something else regulated by NH).
2017: NH passed HB 436, removing crypto from the definition of money transmission. Many crypto businesses operate in NH without a state license. NH remains one of the most permissive states.
New JerseyYes – New Jersey does not have a dedicated “BitLicense,” but crypto businesses handling fiat fall under the state’s existing Money Transmitters Act. Proposed bills to create a digital asset license remain pending.Money Transmitter LicenseNew Jersey Department of Banking & Insurance (DOBI)N.J. Stat. Ann. § 17:15C-1 et seq. NJ DOBIPersonal Buying/Selling: No license for personal use.

OTC Trading (Business): Yes – if exchanging fiat for crypto as a service.

Bitcoin/Crypto ATMs: Yes – NJ has enforced actions against unlicensed ATM operators.

Crypto Exchanges/Wallets: Yes – fiat-handling exchanges must be licensed.

Stablecoin Issuers: Probably yes – until a specific bill passes, stablecoins are treated like money transmission.
Multiple attempts to pass a “Digital Asset and Blockchain Technology Act” have stalled. Meanwhile, NJ applies existing MSB law. The state is active in multi-state enforcement (e.g. actions against unlicensed ATMs, crypto lenders).
New MexicoYes – New Mexico includes “money or monetary value” in its Money Transmitters Act. Despite not naming crypto, the Financial Institutions Division has required exchanges, brokers, and ATM operators to get licensed.Money Transmitter LicenseNew Mexico Financial Institutions Division (FID)N.M. Stat. Ann. § 58-32-102(P); § 58-32-103 NM FIDPersonal Buying/Selling: No license for personal use.

OTC Trading (Business): Yes – NM has enforced rules on unlicensed crypto brokerages.

Bitcoin/Crypto ATMs: Yes – two-way ATMs handling cash and crypto require a license.

Crypto Exchanges/Wallets: Yes – if providing fiat on/off ramps, must be licensed.

Stablecoin Issuers: Yes – no explicit exemption; stablecoin issuance is money transmission.
2016: NM forced some crypto companies (e.g. ShapeShift) to exit due to licensing demands.

2019: A bill to exempt “cryptocurrency” from NM’s MSB law failed. NM remains strict: any crypto-fiat activity = money transmission, requiring a state license.
New YorkYes – New York has the BitLicense regime (23 NYCRR Part 200). Any “virtual currency business activity” with NY residents requires either a BitLicense or a limited-purpose trust charter from NYDFS.“BitLicense” (Virtual Currency Business License)New York State Department of Financial Services (NYDFS)23 NYCRR Part 200 NYDFS “BitLicense” InfoPersonal Buying/Selling: Not for personal use.

OTC Trading (Business): Yes – if serving NY customers.

Bitcoin/Crypto ATMs: Yes – BTM operators need a BitLicense or trust charter.

Crypto Exchanges/Wallets: Yes – must be licensed; includes ongoing supervision and capital requirements.

Stablecoin Issuers: Yes – must comply with NYDFS stablecoin reserve and redemption standards.
2015: NY introduced the first U.S. crypto-specific license. Some companies left NY due to stringent requirements. Over time, many major exchanges and stablecoin issuers (like Paxos, Circle) obtained BitLicenses or trust charters. NYDFS actively supervises compliance, including audits and approval of coins listed by licensees.
North CarolinaYes – North Carolina updated its Money Transmitters Act in 2016 to explicitly include virtual currency in “monetary value.” Crypto exchanges, brokers, and ATM operators must be licensed, although certain administrative/issuance roles are exempt.Money Transmitter LicenseNorth Carolina Office of the Commissioner of Banks (NCCOB)N.C. Gen. Stat. § 53-208.42(13); § 53-208.46 NC BanksPersonal Buying/Selling: No license for individuals paying with crypto.

OTC Trading (Business): Yes – if buying/selling crypto for customers.

Bitcoin/Crypto ATMs: Yes – considered money transmission.

Crypto Exchanges/Wallets: Yes – typically must hold like-kind reserves for customer obligations.

Stablecoin Issuers: Possibly exempt if they’re only “administrators,” but typically require a license if also transmitting.
2016: NC passed legislation explicitly referencing virtual currency, partly modeled on the Uniform Act. Exemptions exist for merchants accepting crypto. The state requires 1:1 cryptocurrency reserves for any obligations to customers, similar to Connecticut’s approach. NC remains considered a “regulated but crypto-friendly” state.
North DakotaYes – North Dakota has no specific crypto exemption, so any entity transmitting funds (fiat or otherwise) for customers is subject to ND’s Money Transmitters Act. The state interprets this to include crypto-fiat activity.Money Transmitter LicenseNorth Dakota Department of Financial InstitutionsN.D. Cent. Code § 13-09-01 et seq. ND DFIPersonal Buying/Selling: No license for personal use.

OTC Trading (Business): Yes – if acting as an intermediary for fiat or custodial crypto.

Bitcoin/Crypto ATMs: Yes – ND treats them as money transmission.

Crypto Exchanges/Wallets: Yes – if handling fiat or customer funds.

Stablecoin Issuers: Yes – no special exemption; stablecoin issuance is money transmission.
North Dakota quietly applies standard MSB law to crypto. The state is part of multi-state supervisory compacts, requiring large crypto exchanges to obtain ND licenses and undergo joint examinations. No dedicated crypto legislation has been passed, so the default framework remains.
OhioYes – Ohio’s Money Transmitter Act applies to businesses transmitting “money,” which regulators interpret to include fiat aspects of crypto transactions. Crypto-only transfers (with no fiat handling) are generally not covered, but most major exchanges handle fiat and obtain an Ohio license.Money Transmitter LicenseOhio Division of Financial Institutions (Dept. of Commerce)Ohio Rev. Code Ann. § 1315.01 et seq.Ohio DFIPersonal Buying/Selling: No license for private, one-off crypto trades.

OTC Trading (Business): Yes—if handling or transmitting fiat for customers, a license is needed.

Bitcoin/Crypto ATMs: Yes—taking or dispensing cash in exchange for crypto is money transmission.

Crypto Exchanges/Wallet Services: Yes—any fiat on/off ramp or custodial service must license.

Stablecoin Issuers: Yes—issuing or redeeming stablecoins for fiat is regulated as money transmission.
2018: Ohio briefly allowed tax payments in crypto (via a third-party), which ended in 2019 due to licensing concerns.

Ohio has enforced licensing for crypto firms through multi-state actions. Major exchanges (Coinbase, Kraken, etc.) hold an Ohio MTL.
OklahomaYes – Oklahoma’s Money Transmitter Act requires a license for “receiving money or monetary value” for transmission. Although it does not explicitly mention crypto, regulators apply it to crypto-fiat transactions.Money Transmitter LicenseOklahoma State Banking DepartmentOkla. Stat. tit. 6, § 1512; tit. 6, § 2101 et seq. OK Banking Dept.Personal Buying/Selling: No license for personal use.

OTC Trading (Business): Yes—facilitating fiat-to-crypto or crypto-to-fiat for others requires a license.

Bitcoin/Crypto ATMs: Yes—two-way ATMs are deemed money transmission.

Crypto Exchanges/Wallet Services: Yes—custodial or fiat-based exchanges must be licensed.

Stablecoin Issuers: Yes—no separate exemption, so stablecoins fall under money transmission.
Oklahoma has not adopted special crypto legislation but has quietly required crypto businesses to comply with MSB rules. The state is part of multi-state regulatory efforts; major exchanges have an OK license. No official carve-outs or exemptions for crypto, meaning standard money transmitter provisions apply.
OregonYes – Oregon’s Money Transmitters Act defines “money” broadly enough to include digital representations of value. Regulators consider crypto-fiat businesses to be money transmitters, requiring a license.Money Transmitter LicenseOregon Division of Financial Regulation (DFR)Or. Rev. Stat. § 717.200(9); § 717.205 Oregon DFRPersonal Buying/Selling: No license for purely private transactions.

OTC Trading (Business): Yes—if handling fiat or customer funds for crypto trades.

Bitcoin/Crypto ATMs: Yes—two-way ATMs are considered money transmitters under OR law.

Crypto Exchanges/Wallet Services: Yes—custodial or fiat-based platforms must license.

Stablecoin Issuers: Yes—no exemption; issuing or redeeming stablecoins for fiat is money transmission.
2019: Oregon clarified restrictions on state agencies and political donations in crypto but continued applying its MSB laws to crypto-fiat operations.Oregon participates in multi-state exams of major exchanges, requiring compliance with net worth, bonding, and permissible investment rules.
PennsylvaniaNo – In 2019, the Pennsylvania Department of Banking and Securities issued guidance stating that virtual currency is not “money” under the PA Money Transmission Business Licensing Law. Therefore, businesses dealing only in crypto (exchanges, ATMs) do not need a state money transmitter license.N/A (Crypto not regulated as “money”)Pennsylvania Department of Banking and Securities (DoBS)PA DoBS Guidance (Jan 2019) PA DoBSPersonal Buying/Selling: No license required.

OTC Trading (Business): No license under PA law if it’s strictly crypto transactions.

Bitcoin/Crypto ATMs: No—exchanging cash for crypto via an ATM is considered a sale of goods (crypto), not money transmission, per 2019 guidance.

Crypto Exchanges/Wallet Services: Not regulated as money transmitters if dealing only in crypto.

Stablecoin Issuers: Also not covered, since stablecoins are not “money” under PA law.
Jan 2019: PA DoBS interpretive memo concluded that “virtual currency” does not meet the definition of “money” under the Money Transmission Business Licensing Law. This stance is among the most crypto-friendly. Pennsylvania enforces federal rules but does not require state MTL for crypto activities.
Rhode IslandYes – In 2020, Rhode Island revised its Money Transmitters Act to explicitly include virtual currency business. Businesses maintaining control of virtual currency (custody or exchange) on behalf of others must obtain a Currency Transmitter License.Currency Transmitter License (includes crypto)Rhode Island Department of Business Regulation (Banking Division)R.I. Gen. Laws § 19-14-1(4)(ii); § 19-14-2 RI DBRPersonal Buying/Selling: No license for one’s personal use.

OTC Trading (Business): Yes—facilitating trades for customers is “currency transmission.”

Bitcoin/Crypto ATMs: Yes—operating crypto ATMs in RI requires a currency transmitter license.

Crypto Exchanges/Wallet Services: Yes—custodial or exchange services must license and maintain 1:1 reserves of each crypto type owed to customers.

Stablecoin Issuers: Yes—treated as a form of virtual currency business, unless exempt.
2020: Rhode Island adopted portions of the Uniform Virtual Currency Businesses Act, making “currency transmission” law explicitly cover crypto. Licensees must maintain like-kind reserves (no fractional reserves) and follow cybersecurity and consumer protection rules. This made RI one of the more stringent states, similar to Connecticut, regarding 1:1 crypto reserves.
South CarolinaPartial – South Carolina’s Money Transmitters Act does not explicitly cover purely crypto transactions (the Attorney General’s office opined that virtual currency alone is not “money”), but fiat-related transmission (e.g., holding or transferring USD for crypto trades) does require a state money transmitter license.Money Transmitter LicenseSouth Carolina Attorney General (Money Services Division)S.C. Code Ann. § 35-11-110(9); § 35-11-210 SC AG GuidancePersonal Buying/Selling: No license if it’s purely person-to-person crypto, no fiat involvement.

OTC Trading (Business): If the business holds or transmits fiat for customers, it must be licensed.

Bitcoin/Crypto ATMs: If the ATM only dispenses the owner’s crypto for cash (no third-party custody), it might not need a license. However, many operators do license to avoid enforcement risk.

Crypto Exchanges/Wallets: If they handle customer fiat, license is required.

Stablecoin Issuers: Typically yes if receiving and sending USD; purely crypto issuance might not be covered.
2019: SC AG’s Money Services Division clarified crypto alone is not “money,” but the fiat leg is subject to licensure.

2023–2024: SC is moving toward adopting the Uniform Money Transmission Modernization Act, which may explicitly include virtual currency. Until that takes effect, SC remains in a partial-regulation stance.
South DakotaYes – South Dakota treats virtual currency as “monetary value” for money transmission. Its Division of Banking has required exchanges, ATMs, and other crypto-fiat businesses to be licensed under the SD Money Transmitter laws.Money Transmitter LicenseSouth Dakota Division of BankingS.D. Codified Laws § 51A-17-1(6) SD Division of BankingPersonal Buying/Selling: No license for private use.

OTC Trading (Business): Yes – if handling fiat or customer funds for crypto trades.

Bitcoin/Crypto ATMs: Yes – two-way ATMs exchanging cash for crypto are considered money transmitters.

Crypto Exchanges/Wallets: Yes – custodial or fiat-based services require licensing.

Stablecoin Issuers: Yes – stablecoin issuance/redemption is treated as transmitting monetary value.
2019: SD’s Division of Banking published guidance that virtual currencies are “monetary value.”

2023: South Dakota adopted parts of the Model Money Transmission Modernization Act, imposing 1:1 crypto reserve requirements on licensees. The state has consistently enforced MSB licensing for crypto-fiat business.
TennesseeYes – Tennessee applies its Money Transmitter Act to the exchange or transmission of cryptocurrency when fiat is involved (receiving money for transmission). Purely crypto-to-crypto might not trigger licensure, but in practice, any business handling fiat for customers is required to get a TN money transmitter license.Money Transmitter LicenseTennessee Department of Financial InstitutionsTenn. Code Ann. § 45-7-205(6); § 45-7-207 TN DFIPersonal Buying/Selling: No license for private, non-custodial crypto trades.

OTC Trading (Business): Yes – if receiving or transmitting fiat on behalf of customers.

Bitcoin/Crypto ATMs: Yes – two-way ATMs taking cash to dispense crypto or vice versa are considered money transmitters.

Crypto Exchanges/Wallets: Yes – exchanges handling fiat must be licensed. Custodial wallet providers dealing with fiat also require a license.

Stablecoin Issuers: Yes – if receiving USD for stablecoins, it’s money transmission.
2018: TN recognized blockchain signatures/contracts but made no crypto-specific license. The state simply enforces existing MSB law. Ongoing: Tennessee is part of multi-state supervision; major exchanges carry TN MTL. The approach is standard: no special crypto carve-outs, but no added restrictions either.
TexasYes (with nuances) – Texas does not consider a direct sale of one’s own crypto to be “money transmission.” But if a business holds fiat or facilitates transfers between third parties, it must obtain a money transmitter license. Texas also explicitly includes fiat-backed stablecoins as “money” in its statutes.Money Transmitter LicenseTexas Department of BankingTex. Fin. Code Ann. § 151.301(b)(3) TX DOB Guidance (Memo 1037)Personal Buying/Selling: No license if selling from personal inventory (principal capacity), with no third-party funds.

OTC Trading (Business): If acting as a broker/agent (holding customer funds or matching buyers/sellers), a license is needed.

Bitcoin/Crypto ATMs: If they merely sell the machine owner’s crypto, no license; if they transmit funds for third parties, license is required.

Crypto Exchanges/Wallets: Generally must be licensed if they custody users’ fiat or crypto.

Stablecoin Issuers: Yes – stablecoins are “money,” requiring licensing and full reserve requirements.
2014: Texas was the first to publish official crypto guidance, distinguishing principal sales from money transmission.

2019: Updated supervisory memo reaffirmed the stance.

2023: Texas clarified stablecoins = “money,” requiring licensing and introduced proof-of-reserves requirements (HB 1666). Texas remains relatively friendly for direct sellers but regulates custodial or third-party transactions strictly.
UtahYes – Utah has no crypto exemption; businesses transmitting fiat or acting as custodians for crypto-fiat trades must obtain a money transmitter license. Purely crypto-to-crypto transactions might not be covered if no fiat is involved, but in practice, most crypto platforms with fiat rails do get licensed.Money Transmitter LicenseUtah Department of Financial InstitutionsUtah Code Ann. § 7-25-102(9) Utah DFIPersonal Buying/Selling: No license for personal, crypto-only use.

OTC Trading (Business): License required if handling fiat for customers.

Bitcoin/Crypto ATMs: Yes – if they accept or dispense cash, it’s money transmission.

Crypto Exchanges/Wallet Services: Yes – exchanges handling fiat or holding user funds must be licensed.

Stablecoin Issuers: Yes – receiving money for stablecoins is money transmission.
2019: Utah created a fintech sandbox, offering limited regulatory relief but no permanent crypto exemption. Ongoing: Utah’s Money Transmitters Act remains broad, covering fiat transmissions. Crypto-only operations that never touch fiat might be outside scope, but most major exchanges have a UT license.
VermontYes – Vermont requires a money transmitter license for virtual currency businesses. In 2024, the state updated its law to fully adopt Model Money Transmission Act provisions on crypto, mandating licensees maintain 1:1 like-kind reserves and additional consumer protections.Money Transmitter LicenseVermont Department of Financial Regulation (DFR)Vt. Stat. Ann. tit. 8, § 2500 et seq. VT DFRPersonal Buying/Selling: Not licensed for personal use.

OTC Trading (Business): Yes – if exchanging crypto (especially for fiat) on behalf of Vermont residents.

Bitcoin/Crypto ATMs: Yes – ATM operators must be licensed.

Crypto Exchanges/Wallet Services: Yes – they must hold an equal amount of each crypto that they owe to customers (no fractional reserves).

Stablecoin Issuers: Yes – 1:1 reserve and licensing are required if dealing with Vermont customers.
2017: Vermont had limited references to crypto under older laws.

2024: Enacted a comprehensive update adopting the MTMA with strong consumer protections (like-kind reserves, no commingling). Now among the stricter states for crypto oversight.
VirginiaNo (for virtual currency itself)** – Virginia’s Money Transmitter Act covers fiat transmissions only. State licenses apply to the fiat side of crypto businesses, but the license “does not cover virtual currency transmission.” Many crypto exchanges get the VA license to handle customers’ fiat transactions.Money Transmitter License (Foreign Transmittal Agency License)Virginia Bureau of Financial Institutions (State Corporation Commission)Va. Code Ann. § 6.2-1900 et seq. Virginia SCCPersonal Buying/Selling: No license for personal use.

OTC Trading (Business): If you hold or transmit fiat on behalf of customers, you need a VA license. The license explicitly does not cover the crypto portion.

Bitcoin/Crypto ATMs: Possibly not required if purely selling the operator’s crypto. Many operators do license to handle any fiat aspect.

Crypto Exchanges/Wallet Services: Large exchanges typically hold a VA money transmitter license for the fiat side, but VA disclaimers say it “does not cover virtual currency.”

Stablecoin Issuers: Unclear – the fiat portion is subject to licensure, but the “virtual currency” aspect is not regulated by VA law.
2019–2020: Exchanges like CEX.io, Coinbase, etc., obtained a VA license. They must display disclaimers that it does not cover crypto transmissions. Virginia has not updated its statutes to explicitly address crypto. So, it requires licensing for fiat transmissions but does not regulate the crypto side.
WashingtonYes – Washington amended its Uniform Money Services Act in 2017 to explicitly include virtual currency as “money transmission.” It is known for strict requirements, such as annual third-party audits, high net-worth standards, and like-kind reserves.Money Transmitter LicenseWashington State Department of Financial Institutions (DFI)Rev. Code Wash. (RCW) § 19.230.010(18); § 19.230.020 WA DFIPersonal Buying/Selling: No license if purely private.

OTC Trading (Business): Yes – any business facilitating crypto trades with fiat or acting as custodian must license.

Bitcoin/Crypto ATMs: Yes – WA is strict; many ATM operators initially left when the 2017 amendment passed.

Crypto Exchanges/Wallet Services: Yes – WA demands audits, net worth compliance, and 1:1 reserve in the same crypto.

Stablecoin Issuers: Yes – stablecoins are subject to money transmission licensing and must maintain permissible investments.
2017: WA passed SB 5031, specifically adding “virtual currency” to money transmission. Some crypto firms left WA due to rigorous compliance (similar to NY). Since

2018: WA has been active in multi-state enforcement, requiring annual audits and consumer disclosures. It remains one of the toughest states for crypto compliance, second only to New York in regulatory strictness.
West VirginiaYes – West Virginia’s Money Transmitters Act includes broad definitions covering crypto-fiat exchanges, ATM operations, etc. WV has taken enforcement action against unlicensed Bitcoin ATM operators in coordination with federal agencies.Money Transmitter LicenseWest Virginia Division of Financial InstitutionsW. Va. Code R. § 106-7-2; W. Va. Code § 32A-2-3 WV DFIPersonal Buying/Selling: No license for private usage.

OTC Trading (Business): Yes – if exchanging crypto for fiat as a service.

Bitcoin/Crypto ATMs: Yes – WV has actively prosecuted unlicensed ATM operators.

Crypto Exchanges/Wallet Services: Yes – must obtain a WV money transmitter license.

Stablecoin Issuers: Yes – stablecoins are treated as forms of stored value or monetary value.
2019: WV was involved in a high-profile bust of unlicensed ATM operators. The state also tested blockchain-based voting for overseas military but kept a firm stance on requiring MSB licensing for crypto-fiat businesses. No crypto-specific carve-outs exist, so standard money transmitter law applies.
WisconsinYes – In 2018, Wisconsin enacted a new Money Transmitter Act (replacing older laws). Though it doesn’t specifically name crypto, regulators apply it to crypto-fiat transmission.Money Transmitter LicenseWisconsin Department of Financial Institutions (DFI)Wis. Stat. § 217.02 WI DFIPersonal Buying/Selling: No license for personal transactions.

OTC Trading (Business): Yes – handling fiat or receiving funds for crypto trades requires a license.

Bitcoin/Crypto ATMs: Yes – operators exchanging cash and crypto must be licensed.

Crypto Exchanges/Wallet Services: Yes – custodial or fiat-based services need WI licensing.

Stablecoin Issuers: Yes – issuance/redemption involving fiat is money transmission.
Pre-2018: WI had no explicit money transmitter law, leading to a regulatory gap.

2018: Adopted a new law under Subchapter II of Chapter 217, bringing crypto-fiat under MSB licensing. Wisconsin is part of multi-state supervision, requiring major exchanges to comply with MSB rules.
WyomingNo – Wyoming exempts “virtual currency” from its Money Transmitter Act. Under 2018 legislation, crypto exchanges and businesses solely dealing with virtual currency do not need a state money transmitter license. However, Wyoming also offers Special Purpose Depository Institution (SPDI) charters for crypto banks.N/A (Crypto-only businesses exempt)Wyoming Division of BankingWyo. Stat. Ann. § 40-22-102(a)(vi); 2018 HB 19 WY Division of BankingPersonal Buying/Selling: No license needed for crypto.

OTC Trading (Business): No license if purely crypto-based.

Bitcoin/Crypto ATMs: No license if only dealing with crypto.

Crypto Exchanges/Wallet Services: Exempt from MTL under state law if they do not handle fiat.

Stablecoin Issuers: Potentially exempt if purely crypto-based; if fiat is involved, they may choose an SPDI charter or other route.
2018: Wyoming passed multiple pro-crypto bills, exempting virtual currency from MTL. This attracted exchanges to re-enter WY.

2019–2021: WY introduced the SPDI bank framework (Kraken Bank, Custodia) for digital assets. Wyoming has the nation’s most crypto-friendly statutory environment at the state level.

Cryptocurrency Laws: Washington D.C. and U.S. Territories

JurisdictionLicense RequirementLicense NameRegulatorLegal Code / ReferencesApplicabilityHistorical Trends
Washington D.C.Yes – Must obtain a Money Transmitter License to operate virtual currency businessesMoney Transmitter LicenseD.C. Dept. of Insurance, Securities and Banking (DISB)D.C. Money Transmitters Act, D.C. Code § 26‑1001 et seq.Personal Trading: No license required for private transactions.

OTC Trading: Yes – Must be licensed if acting as a broker or intermediary.

Bitcoin ATMs: Yes – Operators must have a money transmitter license.

Exchanges & Wallets: Yes – Any custodial service or exchange must obtain a license.

Stablecoin Issuers: No specific law, but likely regulated under existing money transmission rules.
2020: U.S. v. Harmon ruled Bitcoin is ‘money’ under D.C.’s law.

2022: DISB issued guidance requiring licensing for all custodial or exchange businesses.

2023: D.C. intensified enforcement, targeting unlicensed Bitcoin ATM operators.
Puerto RicoYes – Must obtain a Money Transmitter License under Act 136-2010Money Transmitter LicenseOffice of the Commissioner of Financial Institutions (OCIF)P.R. Laws Ann. tit. 10, § 2581 et seq.Personal Trading: No license required for private transactions.

OTC Trading: Yes – Brokers and OTC desks must be licensed.

Bitcoin ATMs: Yes – Must obtain MSB license; OCIF has enforced penalties for unlicensed operators.

Exchanges & Wallets: Yes – Must be licensed if offering services to Puerto Rico residents.

Stablecoin Issuers: Covered as ‘convertible virtual currency’ under MSB licensing rules.
2010: Act 136 established MSB licensing.

2019-2021: OCIF included virtual currency in MSB requirements.

2022: Enforcement actions against unlicensed crypto ATMs signaled regulatory strictness.
GuamYes – A Foreign Exchange License is required for money transmission businessesForeign Exchange LicenseGuam Dept. of Revenue & Taxation – Commissioner of Banking & InsuranceGuam Code Ann. tit. 11, ch. 109 (‘Foreign Exchange’ Act)Personal Trading: No license required for private crypto trades.

OTC Trading: Yes – If acting as a broker or custodian for fiat, a license is needed.

Bitcoin ATMs: Yes – Operators must be licensed under foreign exchange law.

Exchanges & Wallets: Yes – Any custodial or exchange service requires registration.

Stablecoin Issuers: No explicit law, but fiat-backed stablecoins may fall under money transmission.
2014: CSBS included Guam in virtual currency regulation frameworks.

2024: A Guam resident was prosecuted under federal law for running an unlicensed crypto exchange.
U.S. Virgin IslandsYes – Must obtain a Money Transmitter License under the Uniform Money Services ActMoney Transmitter LicenseOffice of the Lieutenant Governor – Division of Banking, Insurance and Financial RegulationV.I. Code tit. 9, ch. 22 (Uniform Money Services Act)Personal Trading: No license required for personal use.

OTC Trading: Yes – Brokers and intermediaries must register as money transmitters.

Bitcoin ATMs: Yes – Crypto ATMs require money transmitter licensing.

Exchanges & Wallets: Yes – Must register as MSBs if providing custodial services.

Stablecoin Issuers: No explicit framework, but likely regulated as money transmitters.
2014: VI regulators contributed to early CSBS virtual currency model frameworks.

2022: A regulatory bulletin reaffirmed that crypto businesses require money transmitter licensing.

This page was last updated on February 6, 2025.