This update summarizes several recent federal and state developments affecting the regulation of money transmission and digital asset activity. These developments reflect how regulators are addressing stablecoin-based payment activity, digital asset kiosks, and modernization of existing money transmitter licensing frameworks.
Federal – The GENIUS Act and Stablecoin Activity
The GENIUS Act, signed into law in July 2025, establishes a federal framework for permitted payment stablecoins and for entities authorized to issue and redeem them. The Act creates a regulatory structure for stablecoin issuance and redemption that operates alongside, and in some cases may alter how regulators evaluate, traditional state money transmitter licensing requirements for certain payment models.
The legislation positions stablecoin issuance and redemption within a defined payments regulatory framework and provides a pathway for entities to operate under a unified oversight structure rather than navigating the traditional multi-state licensing model for particular categories of activity involving stablecoins.
Oklahoma – Digital Asset Kiosks Require Money Transmitter Licensing
Effective November 1, 2025, Oklahoma requires digital asset kiosk operators, commonly referred to as crypto ATMs, to be licensed as money transmitters under state law.
In addition to the licensing requirement, operators must provide advance notice before placing or relocating kiosks, submit quarterly reporting of kiosk locations, provide prominent disclosures regarding transaction irreversibility and fraud risk, and issue transaction receipts containing specified transaction information. The law also imposes daily transaction limits for new customers and requires operators to implement fraud monitoring tools designed to detect scam-related activity.
Massachusetts – Implementation of Updated Money Transmission Regulations
Massachusetts finalized comprehensive regulations implementing its Money Transmission Act, which took effect in November 2025. These regulations establish detailed expectations for licensing, financial responsibility, and ongoing compliance for money transmitters operating in the Commonwealth.
Applicants must meet tangible net worth thresholds tied to statutory liabilities, maintain permissible investments equal to outstanding obligations, and post surety bonds sized according to risk. Licensees are subject to periodic reporting, multi-year record retention requirements, audited financial statement obligations, and notification requirements for material changes in ownership, control, or key personnel.
Maine – Enforcement Action Involving Digital Asset Kiosks
In January 2026, Maine entered into a consent agreement with a bitcoin kiosk operator related to alleged unlicensed activity and consumer protection deficiencies associated with scam losses. The settlement included monetary penalties and compliance obligations.
Maine emphasized that digital asset kiosk transactions present elevated fraud risk and that money transmission laws apply to both licensing and consumer protection responsibilities. The state also addressed the need for operators to take steps to verify wallet control rather than relying solely on customer representations when funds are transmitted to external wallets.
