Cryptoassets Regulatory Intelligence cryptoassets.gi
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content: ai_generated legal review: never_reviewed (informational) publication gate: 1 failing13 sources retrieved model claude-sonnet-5 · 2026-08-05

Idaho, USA

US-ID schema crypto-v2.0.0 trajectory: not yet assessedregulatedoverlaps: FIM, WPM

Last updated · 8 categories · 23 sourced findings · 23 sources in the cumulative register

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United States federal law that applies in Idaho, USA is covered once, on the United States page. This page covers Idaho, USA’s own layer: its own law, regulators and enforcement.

Jurisdiction lead brief

Latest update · 11 October 2026

Lead Signal

Idaho's crypto-regulatory architecture moved on two fronts this cycle: active enforcement of the existing money-transmitter licensing gateway against virtual-currency-adjacent businesses, and the enactment of a new statute protecting individual self-custody and node-operation rights. The Idaho Department of Finance entered an Agreement and Order with Rockwallet LLC resolving findings that the firm had conducted unlicensed money-transmission business from at least April 2023, resolved by consent without a disclosed monetary penalty. Separately, the Department denied PayKES L.L.C.'s money-transmitter licence application, dated March 25, 2026, under Idaho Code Sections 26-2905 and 26-2910, for failing net-worth and financial-responsibility requirements. Both actions confirm that no person, except one exempt under Idaho Code Section 26-2904, may engage in the business of money transmission in Idaho, including accepting fiat for later delivery of virtual currency, without an Idaho money-transmitter licence, and that this requirement is being actively tested against real applicants and operators.

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Idaho has no bespoke crypto-asset licensing statute. Crypto exchange, custody, and transmission businesses operating in Idaho are presumed to fall within the state's general money-transmitter licensing regime (administered by the state's banking/financial-institutions authority and processed via NMLS), consistent with the nationwide pattern of applying general MTL law to virtual-currency administrators/exchangers. The exact Idaho Code citation and any crypto-specific carve-outs or exemptions were not independently verified against a primary Idaho statutory source in this run; this is flagged for escalation.

Standing sub-brief · as of 25 August 2026186 words · last cycle 2026-10-11

Crypto Licensing

Idaho requires virtual-currency exchangers and kiosk operators to hold a money-transmitter license under the Idaho Money Transmitters Act, Idaho Code § 26-2901 et seq., in order to accept fiat currency for later delivery of virtual currency to a third party, per longstanding guidance from the Securities Bureau of the Idaho Department of Finance. This cycle's development is the veto of SB1359a, the Virtual Currency Kiosk Fraud Prevention Act, by Governor Little on April 8-9, 2026, on the stated grounds of drafting deficiencies that would undermine enforcement. Had it been enacted, SB1359a would have layered kiosk-specific licensing conditions on top of the generic money-transmitter regime, including a mandatory blockchain-analytics requirement, transaction caps, a settlement delay, and fraud refunds. Its veto preserves the Money Transmitters Act as the sole applicable licensing regime for virtual-currency kiosk operators in Idaho, with no kiosk-specific overlay in force.

Periodic update · new data 2026-10-11

Crypto Licensing

Idaho's crypto licensing gateway is the Money Transmitters Act, Idaho Code Section 26-2901 et seq., which requires that no person, except one exempt under Idaho Code Section 26-2904, may engage in the business of money transmission in Idaho, including accepting fiat currency for later delivery of virtual currency, without an Idaho money-transmitter licence. This core requirement is unchanged this cycle, but two new Department of Finance decisions demonstrate its active enforcement.

The Idaho Department of Finance entered an Agreement and Order with Rockwallet LLC in April 2026, finding that the company had conducted unlicensed money-transmission business from at least April 2023 through the date of the order. The matter was resolved by consent, and no monetary penalty was disclosed in connection with the resolution. Separately, the Department issued an order dated March 25, 2026 denying PayKES L.L.C.'s application for an Idaho money-transmitter licence, on the basis that the applicant failed to meet the net-worth and financial-responsibility requirements of Idaho Code Sections 26-2905 and 26-2910.

Alongside these enforcement and licensing actions, Idaho enacted the Distributed Ledger Technology Act, Senate Bill 1296, Session Law Chapter 78, signed March 19, 2026 and effective July 1, 2026. The Act creates rights to self-custody DLT private and public keys and to operate DLT nodes, sitting alongside, rather than replacing, the existing money-transmitter licensing regime for commercial activity. The content of the Act's substantive provisions is drawn here from the 2024 amended predecessor bill text and has not been independently re-verified against the final 2026 enrolled text, which introduces a degree of residual uncertainty about the precise final statutory language, even though the fact of enactment and the effective date are independently confirmed through the Legislature's own records.

The overall licensing picture for Idaho is one of a functioning and actively-enforced gateway: a licence is required for commercial money-transmission activity involving virtual currency, the Department is both pursuing unlicensed operators and screening out under-capitalised applicants, and a newly-enacted statute protects a distinct category of individual self-custody and node-operation activity that falls outside the licensing perimeter.

Outlook

Continued active administration of the Money Transmitters Act's licensing gateway appears likely, given the Department's willingness this cycle to pursue an enforcement order against an operating-without-a-licence business and to deny an application that failed the statutory capital-adequacy tests. Material gaps in the licensing architecture, including treatment of custody-only arrangements, crypto-to-crypto exchange, and stablecoin issuance, remain unaddressed by statute as scheduled, and whether the enrolled 2026 DLT Act text diverges from the 2024 predecessor text used to characterize it here has not been independently verified.

1 further periodic run re-emitted the standing brief unchanged and is not shown.

Sources and findings (3)
  1. T4 · SEC EDGAR (company filing)SEC EDGAR (company filing) — Businesses engaged in the transmission and custody of bitcoin and other digital assets, including brokers and custodians, can be subject to Treasury money-services-business regulation as well as state money transmitter licensing requirements.retrieved M4bindingin force
  2. T2 · Conference of State Bank Supervisors / State Regulatory Registry LLCConference of State Bank Supervisors / State Regulatory Registry LLC — Idaho, like most participating states, uses the Nationwide Multistate Licensing System (NMLS) as the licensing/registration infrastructure for non-depository financial-services companies, including money transmitters, and NMLS Consumer Access allows verification of licensee status.retrieved M2non-binding
  3. T2 · Conference of State Bank Supervisors / State Regulatory Registry LLCConference of State Bank Supervisors / State Regulatory Registry LLC — No bespoke Idaho crypto-asset licensing statute distinct from the state's general money-transmitter law was independently verified in this run; Idaho crypto exchange/custody activity is presumed to fall under the general Idaho money-transmitter regime pending primary-source confirmation of the exact statutory citation and any crypto-specific carve-outs.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run

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Idaho has no state-specific securities-token or crypto-classification statute; token characterisation is governed by federal SEC/CFTC jurisdiction. In March 2026 the SEC, joined by the CFTC, issued a joint interpretation creating a taxonomy of digital commodities, digital collectibles, digital tools, stablecoins, and digital securities, which functionally governs how Idaho-based crypto activity is classified.

Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

no periodic updates on record for this sub-brief

Sources and findings (4)
  1. T1 · U.S. Securities and Exchange CommissionU.S. Securities and Exchange Commission — The SEC, joined by the CFTC, issued an interpretation in March 2026 clarifying how federal securities laws apply to crypto assets, providing a coherent token taxonomy spanning digital commodities, digital collectibles, digital tools, stablecoins, and digital securities.retrieved M5bindingin force
  2. T1 · U.S. Securities and Exchange CommissionU.S. Securities and Exchange Commission — Under the 2026 SEC/CFTC interpretation, non-security 'digital commodities' such as Bitcoin, Ether, Solana and comparable network tokens derive their value from the programmatic operation of an associated functional crypto system plus supply/demand dynamics, rather than from a promoter's managerial efforts.retrieved M4bindingin force
  3. T3 · CoinDeskCoinDesk — The SEC's 2026 interpretation excludes airdrops, protocol staking, and protocol mining from the scope of its digital-securities/investment-contract analysis.retrieved M4bindingin force
  4. T4 · The BlockThe Block — Federal payment stablecoins are governed by the GENIUS Act, passed by the House and Senate and signed into law, establishing a stablecoin-issuer framework that operates alongside, and separately from, state money-transmitter licensing.retrieved M5bindingin force

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On-chain activity (staking, node operation, DeFi lending, mining) is addressed primarily at the federal level, with recent OCC and SEC/CFTC interpretive actions loosening prior restrictions on bank participation and clarifying staking's non-security status. Comprehensive federal market-structure legislation (the Digital Asset Market Clarity Act and its Senate successor) that would definitively settle DeFi/DEX oversight had not been enacted as of early 2026. No Idaho-specific on-chain activity statute was identified.

Standing sub-brief · as of 11 October 2026335 words · last cycle 2026-10-11

On-Chain Activity Regime

Idaho's on-chain activity regime changed materially this cycle with the enactment of the Distributed Ledger Technology Act, Senate Bill 1296, signed by the Governor on March 19, 2026 as Session Law Chapter 78 and effective July 1, 2026. The Act provides that neither the state nor a local government may enact an ordinance, resolution, or rule prohibiting, restricting, or impairing an individual's ability to run a distributed-ledger-technology or bitcoin node, or to self-custody a software or hardware cryptocurrency wallet. This establishes an affirmative, government-facing protection for individual on-chain participation that did not previously exist in Idaho statute in this form.

no periodic updates on record for this sub-brief

Sources and findings (3)
  1. T3 · CoinDeskCoinDesk — The OCC clarified in a March 2025 interpretive letter that national banks and federal savings associations may provide crypto custody, engage in certain stablecoin-related activities, and run nodes without seeking prior OCC approval.retrieved M3bindingin force
  2. T3 · CoinDeskCoinDesk — The SEC's 2026 interpretive guidance treats protocol-level staking as outside the scope of its digital-securities analysis, meaning staking does not by itself trigger investment-contract/security status.retrieved M3bindingin force
  3. T3 · CoinDeskCoinDesk — Comprehensive federal market-structure legislation covering DeFi (the Digital Asset Market Clarity Act and its Senate successor) remained unenacted as of early 2026, leaving DeFi lending and DEX oversight without a settled statutory framework.retrieved M4non-binding

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Payment stablecoin issuance and reserve/disclosure requirements are governed federally by the GENIUS Act, with FinCEN's implementing AML/CFT rule for Permitted Payment Stablecoin Issuers (PPSIs) still at proposed-rule stage. No Idaho-specific stablecoin issuance-authorisation or reserve regime was identified.

Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

no periodic updates on record for this sub-brief

Sources and findings (3)
  1. T4 · The BlockThe Block — The GENIUS Act requires payment stablecoins to be fully backed by U.S. dollars or similarly liquid assets and mandates annual audits for issuers with a market capitalization exceeding $50 billion.retrieved M5bindingin force
  2. T1 · Financial Crimes Enforcement Network (FinCEN)Financial Crimes Enforcement Network (FinCEN) — FinCEN's proposed AML/CFT rule implementing the GENIUS Act's Permitted Payment Stablecoin Issuer (PPSI) framework remained at the notice-of-proposed-rulemaking stage, with the specific stablecoins and issuers qualifying as PPSIs not yet finally determined.retrieved M4bindingproposed
  3. T1 · Financial Crimes Enforcement Network (FinCEN)Financial Crimes Enforcement Network (FinCEN) — No Idaho state-specific stablecoin issuance-authorisation or reserve-disclosure regime was identified; payment stablecoin issuance touching Idaho is presumed governed exclusively by the federal GENIUS Act framework pending confirmation.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run

#

Crypto consumer protection touching Idaho residents is shaped principally by federal SEC guidance on custody segregation and risk disclosure for broker-dealers handling non-security crypto assets; no Idaho-specific crypto consumer-protection statute (marketing restrictions, suitability rules, complaint-handling mandates) was identified in this run.

Standing sub-brief · as of 25 August 2026124 words · last cycle 2026-10-11

Consumer Protection

Idaho has no crypto-specific consumer-protection statute. SB1359a's proposed kiosk-specific mandatory fraud disclosures, fee-refund rights, and live customer-service requirements did not take effect following Governor Little's veto of the bill on April 8-9, 2026. In their absence, the general Idaho Consumer Protection Act, Idaho Code § 48-601 et seq., enforced by the Idaho Office of the Attorney General's Consumer Protection Division, remains the applicable baseline for virtual-currency-kiosk consumers in the state, with no kiosk-specific disclosure or refund right in force.

Periodic update · new data 2026-10-11

Consumer Protection

Idaho's crypto consumer-protection landscape is defined this cycle by an absence rather than a new rule: the Virtual Currency Kiosk Fraud Prevention Act, Senate Bill 1359, which would have required virtual-currency kiosk operators to post fraud warnings, provide mandatory fee and exchange-rate disclosures, offer live customer service, and give refunds to defrauded new users, passed both chambers of the Idaho Legislature but was vetoed by Governor Little on April 28, 2026. As a direct consequence, no state-specific consumer-protection duty applicable to virtual-currency kiosk operators is currently in force in Idaho.

This leaves kiosk-based virtual-currency transactions in Idaho governed only by the general money-transmitter licensing framework and whatever general consumer-protection or fraud statutes apply across sectors, rather than by a kiosk-tailored disclosure, warning, and refund regime. Whether Idaho Code Section 26-2906 or Department of Finance guidance addresses custody-segregation requirements for virtual-currency exchangers specifically was not located this cycle, leaving an additional open question about the depth of consumer protection available to users of licensed virtual-currency exchange services more broadly, separate from the kiosk-specific gap created by the veto.

The veto itself is a confirmed fact, drawn directly from the Idaho Legislature's own official vetoes index, and the bill's substantive terms are drawn from the bill as passed by both chambers before the veto. The practical significance for Idaho consumers is that the specific protections the bill would have introduced, pre-transaction fraud warnings tailored to the kiosk channel, mandatory fee and rate disclosure at the point of transaction, live customer service availability, and a refund mechanism for defrauded new users, do not currently exist in Idaho law.

Outlook

Public reaction to the veto, including expressed disappointment from the bill's sponsor and from AARP Idaho, suggests the kiosk consumer-protection gap is likely to remain a live legislative issue, with reintroduction of a successor bill plausible in the 2027 session. Whether a reintroduced bill would address whatever concerns motivated the veto, and what its final terms would be, is unknown as scheduled. In the interim, Idaho consumers using virtual-currency kiosks are not covered by any state-specific disclosure, warning, or refund requirement beyond the general money-transmitter licensing framework.

1 further periodic run re-emitted the standing brief unchanged and is not shown.

Sources and findings (3)
  1. T1 · U.S. Securities and Exchange CommissionU.S. Securities and Exchange Commission — SEC staff guidance indicates a broker-dealer may agree with customers to treat non-security crypto assets custodied for them as 'financial assets' in a 'securities account' under UCC Article 8, which can help keep such assets out of the broker-dealer's estate in an insolvency.retrieved M4bindingin force
  2. T1 · U.S. Securities and Exchange CommissionU.S. Securities and Exchange Commission — Non-security crypto assets held by a broker-dealer are not protected by SIPA and may not be protected by any other specific insolvency regime, exposing customers to potential loss of such assets on insolvency.retrieved M4bindingin force
  3. T2 · Conference of State Bank Supervisors / State Regulatory Registry LLCConference of State Bank Supervisors / State Regulatory Registry LLC — No Idaho-specific crypto consumer-protection statute (e.g., marketing restrictions, mandatory risk disclosures, or suitability rules comparable to some other states' digital-asset laws) was identified in this run.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run

#

Federal tax treatment of crypto as property (triggering capital gains/losses on sale or exchange) applies to Idaho residents by default, with new IRS Form 1099-DA broker reporting phasing in from the 2025 tax year. Pending federal legislation (the PARITY Act) would modify aspects of crypto tax treatment but had not been enacted. Idaho's own state income-tax conformity treatment of crypto gains was not independently confirmed against a primary Idaho State Tax Commission source.

Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

no periodic updates on record for this sub-brief

Sources and findings (4)
  1. T3 · CoinDeskCoinDesk — For the past decade the IRS has treated cryptocurrency as property rather than currency, treating every sale and exchange as a taxable event generating capital gain or loss.retrieved M5bindingin force
  2. T3 · CoinDeskCoinDesk — Starting with 2025 transactions, cryptocurrency exchanges must issue Form 1099-DA declaring cost basis and proceeds directly to the IRS, with brokers also reporting cost basis to the IRS from the 2026 tax year onward.retrieved M5bindingin force
  3. T3 · CoinDeskCoinDesk — The bipartisan PARITY Act, reintroduced in Congress in March 2026, proposes relief mechanisms for regulated payment stablecoins and staking-reward deferral options, but had not been enacted as of its reintroduction.retrieved M3non-binding
  4. T2 · Conference of State Bank Supervisors / State Regulatory Registry LLCConference of State Bank Supervisors / State Regulatory Registry LLC — Idaho's state income-tax conformity treatment of cryptocurrency gains (i.e., whether Idaho taxable income tracks the federal property-based treatment without state-specific modification) was not independently confirmed against a primary Idaho State Tax Commission source in this run.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run

#

Cross-border crypto transfers touching Idaho are governed by federal OFAC sanctions and FinCEN travel-rule obligations; no Idaho-specific outbound restriction was identified. Federal enforcement activity continues to target sanctions-evasion use of stablecoins by state-linked illicit actors.

Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

no periodic updates on record for this sub-brief

Sources and findings (2)
  1. T1 · Financial Crimes Enforcement Network (FinCEN)Financial Crimes Enforcement Network (FinCEN) — U.S. authorities have pursued enforcement actions alleging that DPRK-linked IT workers and co-conspirators used stablecoins to launder proceeds and evade sanctions, underscoring active federal sanctions-nexus scrutiny of crypto cross-border flows.retrieved M4bindingin force
  2. T1 · Financial Crimes Enforcement Network (FinCEN)Financial Crimes Enforcement Network (FinCEN) — No Idaho-specific outbound restriction on crypto-asset transfers beyond the federal OFAC sanctions and FinCEN travel-rule framework was identified in this run.retrieved M2non-bindingour coverage gap, expected to resolve on a re-run

#

Crypto AML/CFT obligations (KYC/CDD, travel rule, SAR/STR reporting, sanctions screening, recordkeeping) applicable to Idaho money-transmitter-licensed crypto businesses are governed by the Bank Secrecy Act/FinCEN MSB framework and are captured under the fleet's shared Financial Integrity Module (FIM) subscription for aml_ctf. This baseline does not duplicate AML/CFT claims; only disambiguation context is provided here.

Rules for crypto-asset service providers · from Sentinel.gi · verified 2026-07-05
  • Idaho Code §26-2901 et seq. — Any person engaging in the business of money transmission in Idaho, absent an exemption, must hold an Idaho money-transmitter licence conditioned on net worth, bonding and financial responsibility. (in force) source, 2026-10-11

Not yet covered by Sentinel.gi for this jurisdiction: suspicious transaction reporting for CASPs: recipient FIUs, deadlines, consent or moratorium periods, account freezes, suspension duties and recognition criteria; sanctions asset freezes as distinct from AML reporting, sectoral crypto-service bans, designation list sources and crypto-relevant designations; travel rule obligations: thresholds and currency, data sets, self-hosted wallet tests, binding status of guidance and repeated-failure reporting channels; prohibitions on anonymous accounts and anonymity-enhancing assets and their application dates; wallet-address screening and on- and off-chain transaction monitoring requirements and supervisory expectations; recent changes to crypto-transfer AML instruments, including revocations and replacements.

Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

no periodic updates on record for this sub-brief

Sources and findings (1)
  1. T1 · Financial Crimes Enforcement Network (FinCEN)Financial Crimes Enforcement Network (FinCEN) — AML/CFT obligations applicable to Idaho money-transmitter-licensed crypto businesses (BSA/FinCEN MSB registration, customer due diligence, SAR/CTR filing, recordkeeping) are governed under the fleet's shared Financial Integrity Module (FIM) subscription for aml_ctf and are not duplicated as claims in this crypto baseline.retrieved M2non-bindinga fact about the regime
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Editorial metadata for Idaho, USA
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