Cryptoassets Regulatory Intelligence cryptoassets.gi
US-MA v13.3.0
content: ai_generated legal review: never_reviewed (informational) publication gate: 0 failing14 sources retrieved model claude-sonnet-5 · 2026-08-06

Massachusetts, USA

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

Last updated · 7 categories · 17 sourced findings · 30 sources in the cumulative register

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

Jurisdiction lead brief

Latest update · 18 October 2026

Lead Signal

Massachusetts' crypto-kiosk regulatory picture continues to fragment across three levels of governance operating at different speeds. The general money-transmission licensing framework under M.G.L. c. 169B, administered by the Division of Banks, is now fully operative: licensure requirements took effect January 1, 2026, and the firm-filing transition deadline of July 1, 2026, has passed. Convertible virtual currency is treated as monetary value under this regime, meaning crypto exchanges and kiosk operators fall within the Division's general money-transmitter licensing architecture via NMLS filing rather than under any bespoke crypto statute. At the same time, a targeted statewide prohibition on cryptocurrency ATMs and kiosks has stalled: Amendment 374 to the economic-development bill S.3178 passed the Massachusetts Senate on July 23-24, 2026, but the House version did not include the measure, and the amendment remains stuck in a House-Senate conference committee with no confirmed enactment date.

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Massachusetts has no bespoke crypto-asset licensing statute. Crypto exchanges, custodians and kiosk operators are captured as money transmitters under M.G.L. c. 169B; a statewide kiosk ban remains stalled in conference committee while at least 21 municipalities, including Dennis (voted 2026-10-06/07), have enacted local bylaw bans.

Standing sub-brief · as of 29 September 2026239 words · last cycle 2026-10-18

Crypto Licensing

Massachusetts Division of Banks now requires registration before offering custody or exchange services under the general money-transmitter licensing framework established by M.G.L. c.169B, effective January 1, 2026. This is the first time domestic money-transmission activity -- a category virtual-currency exchange and custody businesses fall into if the statute's general scope is read to reach them -- has been licensed at the state level in Massachusetts; the state had previously been one of only two nationwide without domestic-transfer coverage. Firms not licensed or transitioned under the new regime by July 1, 2026 were required to immediately cease all licensable money-transmission activity, an enforcement cliff that is already in force.

Periodic update · new data 2026-10-18

Crypto Licensing

Massachusetts regulates crypto-adjacent activity through two distinct and currently diverging tracks. The general money-transmission framework under M.G.L. c. 169B, which replaced the prior foreign-only Foreign Transmittal Agency Act, is fully operative: licensure requirements took effect January 1, 2026, and firms were required to file via NMLS by July 1, 2026, to continue operating while their applications remained pending. The Division of Banks treats convertible virtual currency as monetary value under this framework, meaning there is no separate crypto licence; crypto exchanges and kiosk operators are captured within the Commonwealth's general money-transmitter licensing architecture.

Separately, a targeted prohibition on cryptocurrency ATMs and kiosks specifically has not achieved statewide enactment. Amendment 374 to the economic-development bill S.3178 passed the Massachusetts Senate on July 23-24, 2026, but the House version of the bill did not include the measure, leaving it pending in a House-Senate conference committee with no confirmed enactment date. In the resulting gap, individual municipalities have moved unilaterally: Dennis adopted a local bylaw banning cryptocurrency kiosks at a special town meeting on October 6, 2026, reported October 11, 2026, joining at least 20 other Massachusetts towns that have done the same. The Attorney General's Municipal Law Unit has approved at least 19 such municipal bylaws, giving this patchwork approach formal state-level validation even without a uniform statewide rule.

The net effect is a regime in transition: the general money-transmission licensing baseline is settled and in force, but the kiosk-specific question remains unresolved and is being answered differently in different towns rather than through a single statewide instrument.

Outlook

The House-Senate conference committee's handling of the S.3178 kiosk-ban amendment is the development most likely to resolve this fragmentation. Enactment would impose a uniform statewide prohibition, superseding the current municipal patchwork; continued stalemate would likely see additional municipalities adopt their own bylaws, further entrenching the fragmented approach documented this cycle.

1 earlier distinct update(s)
Periodic update · new data 2026-10-11

Crypto Licensing

Massachusetts captures custodial virtual-currency businesses within its general money-transmitter licensing regime rather than through a dedicated crypto-specific statute, and that general regime has just undergone a complete structural replacement. Under 209 CMR 44.01, the Massachusetts Division of Banks requires a licence to engage in money transmission, a category explicitly defined to include transmission of convertible virtual currency treated as monetary value. This implementing regulation reached final effect on 7 November 2025, following the broader legislative consolidation of Massachusetts money-service licensing law. The underlying authorising statute, Chapter 169B of the Massachusetts General Laws, is itself new: it replaced the former Foreign Transmittal Agency Act, Chapter 169, and the non-bank check-seller provisions of Chapter 167F Section 4, both of which were repealed.

The transition arrangements built into the new regime set a clear compliance timeline that has now run its course. Entities already engaged in money transmission as of 1 January 2026, when the statute became effective, were permitted to continue operating on a pending-application basis only if they filed for or completed their transition to licensure by 1 July 2026. That deadline has passed. The Division's own guidance states that an entity which did not transition in time must immediately stop conducting licensable money-transmission activity, and that continued unlicensed operation may draw civil penalties under Chapter 169B Section 10. For a custodial virtual-currency business operating in or serving Massachusetts residents, this means the licensing question is no longer prospective: it is a live compliance requirement enforced under an active deadline that has already expired.

Probable, though not yet confirmed against the regulation text itself, is a reported prudential capital standard applicable to licensees generally: a tangible net worth requirement of the greater of 100,000 dollars or 3 percent of total assets up to 100 million dollars, rising by 2 percent of assets between 100 million and 1 billion dollars and by 0.5 percent above 1 billion dollars. This figure derives from a law-firm summary of the new regime rather than from 209 CMR 44.00 directly, and should be treated as probable guidance pending primary confirmation. If it applies to virtual-currency custodians as it does to other money-transmitter licensees, it represents a materially more demanding prudential bar for a crypto custody business than many lighter-touch state licensing regimes impose.

Enforcement activity under the new framework has continued through the first half of 2026. The Division of Banks issued a Cease Directive to M&M Tech Solutions Corp. on 2 April 2026 over allegations of unlicensed money transmission, as recorded in the Division's Q2 2026 Enforcement Bulletin. The available sourcing does not establish that this entity is a virtual-currency business specifically; the action is recorded here because it demonstrates active enforcement of the unlicensed-money-transmission prohibition under the consolidated regime that custodial crypto businesses are also subject to. No public record identifying a custodial virtual-currency business as the subject of enforcement action under 209 CMR 44.00 has been located to date.

No public, consolidated list of entities currently licensed under 209 CMR 44.00 has been located, so it is not possible from the available sourcing to confirm which, if any, crypto-asset custody businesses currently hold the Massachusetts money-transmitter licence following the 1 July 2026 transition deadline. Similarly, the precise civil-penalty figure specified in Chapter 169B Section 10(d) has not been confirmed against the statute text itself; only a secondary-source figure has been located to date, and that gap is carried forward rather than resolved by inference.

Outlook

The most consequential open question for crypto-asset businesses operating in Massachusetts is whether the Division of Banks directs enforcement specifically at an unlicensed virtual-currency custodian in a forthcoming cycle, which would be the clearest evidence of how the general money-transmitter perimeter is being applied in practice to the digital-asset sector, as distinct from the conventional money-service and check-cashing enforcement disclosed to date. A second open question is whether the Division publishes, or whether research in a later cycle locates, a public licensee list under 209 CMR 44.00, which would allow a direct assessment of which crypto custody businesses have completed licensure ahead of or following the 1 July 2026 deadline.

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

Sources and findings (2)
  1. T1 · FinCENFinCEN — Massachusetts Division of Banks, housed within the Office of Consumer Affairs & Business Regulation, is the state authority responsible for money-transmitter licensing that applies to virtual-currency exchange and custody businesses operating in the Commonwealth.retrieved M5bindingin force
  2. T1 · FinCENFinCEN — No bespoke Massachusetts crypto-asset licensing statute distinct from the Commonwealth's general money-transmission licensing regime has been confirmed; crypto exchange/custody businesses appear to be regulated exclusively via that general regime absent contrary primary-source evidence.retrieved M4non-binding

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Massachusetts has no independent state token-taxonomy. Token characterization for securities purposes is governed by federal SEC/CFTC doctrine (the Howey test and, since early 2026, the SEC's five-category crypto-asset framework), while the Massachusetts Securities Division (within the Office of the Secretary of the Commonwealth) independently enforces the state Uniform Securities Act against unregistered token/ICO offerings sold to Massachusetts residents.

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. T3 · CoinDeskCoinDesk — In January 2018 the Massachusetts Securities Division charged a Brookline, MA resident and his company with selling unregistered securities through an ICO of 'caviar' tokens, alleging the token sale was a textbook unregistered securities offering under state law.retrieved M4bindingin force
  2. T3 · CoinDeskCoinDesk — In March 2018 the Massachusetts Secretary of the Commonwealth ordered five ICO issuers to halt their token campaigns and offer investor refunds after finding the offerings violated the state's securities laws governing unregistered securities.retrieved M4bindingin force
  3. T1 · U.S. Securities and Exchange CommissionU.S. Securities and Exchange Commission — The federal SEC's 2026 interpretive release classifies crypto assets into five categories — digital commodities, digital collectibles, digital tools, stablecoins, and digital securities — a framework that governs token-as-security characterization applicable to Massachusetts market participants regardless of state MTL licensing status.retrieved M4bindingin force

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No Massachusetts-specific licensing, registration, or prohibition regime targeting on-chain activities (staking, DeFi lending, mining, node/validator operation, tokenization) has been identified. Such activities are subject to the general MTL framework only insofar as they constitute money transmission, and to federal banking-agency statements on crypto-asset custody/safekeeping that flow through to MA-chartered or MA-supervised institutions.

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 · Federal Reserve BoardFederal Reserve Board — No Massachusetts-specific regulatory regime for on-chain activities such as staking, DeFi lending, mining, or validator/node operation has been identified; the closest applicable overlay is federal banking-agency guidance on crypto-asset safekeeping for MA-chartered or MA-supervised institutions.retrieved M2non-bindinga fact about the regime

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Massachusetts has not enacted a state-specific stablecoin issuance, reserve, or redemption regime. Stablecoin regulation in the U.S. is now anchored at the federal level under the GENIUS Act framework, referenced in the SEC's 2026 interpretive release, which will categorically exclude qualifying 'payment stablecoins' from the securities definition once the Act's provisions take effect; non-qualifying stablecoins remain subject to case-by-case federal securities analysis. No Massachusetts-specific overlay on this federal baseline was located.

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 · U.S. Securities and Exchange CommissionU.S. Securities and Exchange Commission — Payment stablecoins issued by a permitted stablecoin issuer under the GENIUS Act will categorically not be treated as securities once the Act's provisions become effective; as of the SEC's 2026 release, the GENIUS Act was not yet effective.retrieved M4bindingenacted not yet effective
  2. T1 · FinCENFinCEN — No Massachusetts-specific stablecoin issuance, reserve-requirement, or redemption-right statute has been identified; the Commonwealth appears to rely entirely on the federal framework for stablecoin regulation.retrieved M3non-bindinga fact about the regime

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Massachusetts consumer protection relevant to crypto is enforced primarily through the Attorney General's Office (general consumer-protection authority) and the Securities Division (investment-fraud enforcement). The AGO has issued public consumer alerts on crypto-enabled scams and has formally advocated to the SEC for enhanced crypto-custody and DeFi risk-disclosure requirements, citing the practical difficulty of tracing or recovering funds lost through unregulated decentralized exchanges.

Standing sub-brief · as of 18 October 2026262 words · last cycle 2026-10-18

Consumer Protection

Massachusetts has no dedicated crypto consumer-protection statute; enforcement against harms arising from cryptocurrency kiosks instead proceeds under the Commonwealth's general consumer-protection law, M.G.L. c. 93A. The Attorney General filed suit against Bitcoin Depot Inc. on February 3, 2026, and against Coinhub on July 24, 2026, alleging deceptive drip-pricing practices and inadequate fraud safeguards at crypto kiosks that facilitated scam-related transactions, with particular concern for elderly consumers. Both matters continue, and no new enforcement milestone in either case was identified this cycle beyond their continuation.

no periodic updates on record for this sub-brief

Sources and findings (4)
  1. T4Cryptopolitan — No statewide rule currently governs crypto-ATM/kiosk operation in Massachusetts; a Senate-passed ban (via bond-bill amendment, passed 2026-07-23/24) is pending House-Senate conference and is not yet in force.retrieved M4non-binding
  2. T3 · CoinDeskCoinDesk — The Massachusetts government issued a public consumer alert warning residents, citing FTC data on crypto-linked fraud, that requests for payment in cryptocurrency are a red flag for romance and impersonation scams, including scams targeting the LGBTQIA+ community during Pride Month.retrieved M3non-binding
  3. T2 · Massachusetts Office of the Attorney General (filed via SEC public comment docket)Massachusetts Office of the Attorney General (filed via SEC public comment docket) — The Massachusetts Attorney General's Office recommended to the SEC that investment advisers trading clients' cryptocurrency assets through decentralized exchanges be required to provide clear, written, pre-trade disclosures of the risks and vulnerabilities associated with such exchanges.retrieved M3non-binding
  4. T2 · Massachusetts Office of the Attorney General (filed via SEC public comment docket)Massachusetts Office of the Attorney General (filed via SEC public comment docket) — The Massachusetts Attorney General's Office noted that decentralized exchanges' lack of KYC protocols and dedicated customer support makes it practically impossible for a state regulator such as the AGO to trace or recoup funds through seizure or forfeiture in connection with unlawful crypto investment activity conducted via such platforms.retrieved M3non-binding

#

Massachusetts personal income tax conforms to the federal characterization of digital assets as property, meaning dispositions generally trigger capital gains or loss recognition; no Massachusetts Department of Revenue guidance specific to virtual currency, staking rewards, or NFTs distinct from this federal conformity baseline was located. New federal Form 1099-DA broker reporting (first issued February 2026, covering 2025 sales) will materially increase third-party reporting relevant to both federal and Massachusetts compliance.

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. T3 · U.S. Securities and Exchange Commission (EDGAR filing)U.S. Securities and Exchange Commission (EDGAR filing) — Current IRS guidance treats digital assets such as bitcoin as property, with transactions involving the payment of ether or bitcoin for goods and services treated as barter transactions triggering capital gains recognition; Massachusetts personal income tax, which conforms to federal gross income concepts, follows this characterization absent contrary state-specific guidance.retrieved M4bindingin force
  2. T3 · CoinDeskCoinDesk — Beginning with the 2025 tax year, cryptocurrency exchanges are required to issue federal Form 1099-DA declaring cost basis and sale proceeds directly to the IRS, with brokers required to have issued the first such forms by February 17, 2026, materially increasing third-party reporting of crypto dispositions relevant to Massachusetts income-tax compliance.retrieved M4bindingin force
  3. T3 · CoinDeskCoinDesk — No Massachusetts Department of Revenue guidance specific to the taxation of virtual currency, staking rewards, or NFTs distinct from federal IRS treatment has been identified in this research pass.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run

#

No Massachusetts-specific outbound restriction on crypto-asset transfers exists. Cross-border crypto transfers by MA-based money transmitters and exchanges are governed by federal sanctions and AML frameworks — OFAC SDN screening and FinCEN's Funds Travel Rule for qualifying transmittals — which the Division of Banks incorporates by reference through general MTL safety-and-soundness and compliance expectations rather than through a distinct state cross-border regime.

Standing sub-brief · as of 29 September 2026164 words · last cycle 2026-10-04

Cross-Border Transfer

The Massachusetts Division of Banks' regulatory perimeter now extends to domestic transfers under M.G.L. c.169B, effective January 1, 2026, alongside the state's pre-existing foreign money-transmittal agency framework. This is a scope extension rather than a new cross-border-specific instrument: no crypto-specific cross-border restriction beyond the general money-transmitter-licensing perimeter has been identified this cycle. For virtual-currency businesses moving value across the Massachusetts border in either direction, the relevant compliance question remains the same underlying general-MTL registration question addressed under crypto licensing, rather than a distinct cross-border rule.

No new data since the standing brief. 1 periodic run re-emitted it unchanged.

Sources and findings (2)
  1. T1 · FinCENFinCEN — U.S. individuals and institutions dealing in digital currency, including Massachusetts-licensed money transmitters, must screen against OFAC's Specially Designated Nationals list and implement policies to prevent persons in sanctioned jurisdictions from opening accounts or trading in digital currency.retrieved M4bindingin force
  2. T1 · FinCENFinCEN — No Massachusetts-specific outbound restriction on crypto-asset transfers has been identified beyond the federal OFAC sanctions and FinCEN Travel Rule baseline.retrieved M2non-bindinga fact about the regime
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