ARTICLE
24 March 2026

Wyoming Establishes Licensing Framework For Virtual Currency Kiosks

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Sheppard, Mullin, Richter & Hampton LLP

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On March 6, Wyoming Governor Mark Gordon signed HB 0075 into law, establishing a regulatory framework for virtual currency kiosks and requiring compliance with the Wyoming Money Transmitters Act.
United States Wyoming Finance and Banking
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On March 6, Wyoming Governor Mark Gordon signed HB 0075 into law, establishing a regulatory framework for virtual currency kiosks and requiring compliance with the Wyoming Money Transmitters Act.

The new law brings virtual currency kiosks within Wyoming’s existing financial regulatory structure and clarifies that these consumer-facing terminals cannot operate outside the state’s money transmission and banking regimes. The statute defines a “virtual currency kiosk” broadly to include publicly accessible electronic terminals that facilitate exchanges of virtual currency for money, bank credit, or other virtual currency, including terminals that connect to a separate exchange or use the operator’s own virtual currency holdings. By covering both models, the law appears designed to reach a wide range of kiosk arrangements already in the market.

Key provisions include:

  • Licensing requirement. A person may not own, operate, or manage a virtual currency kiosk in Wyoming unless the person is licensed under the Wyoming Money Transmitters Act or is a financial institution chartered under Wyoming law.
  • Criminal penalties. A person who knowingly violates the licensing requirement is guilty of a felony punishable by imprisonment for not less than three years, a fine of not less than $10,000, or both.
  • Rulemaking authority. The banking commissioner must adopt rules regulating the operation of virtual currency kiosks by authorized persons.
  • Confidentiality protections. Information or reports obtained by the commissioner relating to kiosk operations are confidential, subject to limited disclosure to other regulators, prosecuting attorneys, or pursuant to court order.
  • Immediate applicability. Persons already owning, operating, or managing virtual currency kiosks in Wyoming must comply beginning on the law’s effective date.

Putting It Into Practice: States are increasingly adopting kiosk-specific licensing and compliance frameworks for digital asset businesses (previously discussed here and here). Wyoming’s law reflects the same broader approach, using the state’s existing money transmission and banking framework to regulate consumer-facing digital asset kiosks. Businesses operating kiosks or similar models should assess licensing obligations and update compliance procedures as necessary.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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