Cryptoassets Regulatory Intelligence cryptoassets.gi
US-MI v13.3.0
content: ai_generated legal review: never_reviewed (informational) publication gate: 0 failing13 sources retrieved model claude-sonnet-5 · 2026-08-06

Michigan, USA

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

Last updated · 7 categories · 17 sourced findings · 29 sources in the cumulative register

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

Jurisdiction lead brief

Latest update · 18 October 2026

Lead Signal

Michigan's general money-transmission licensing statute, the Money Transmission Services Act (MCL 487.1001 et seq.), is mid-transition via House Bill 5544, which would repeal the current act effective July 1, 2027 and replace it with the Conference of State Bank Supervisors model Money Transmission Modernization Act. The bill passed the Michigan House 97-10 on June 25, 2026 and remains pending in the Senate. There is no bespoke crypto-licensing regime in Michigan; fiat-to-crypto and crypto-to-fiat exchange, on/off-ramps, and any receipt of dollars from a Michigan customer for transmission constitute money transmission on the fiat leg and require a Michigan money transmitter license under the existing statute. The pending replacement would add a requirement that a licensee transmitting virtual currency hold like-kind virtual currency of the same volume obligated to consumers, layering a crypto-specific reserve obligation onto the general licensing regime for the first time.

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Michigan has no bespoke crypto-asset licensing regime. Crypto exchanges, custodians and on/off-ramp businesses touching Michigan-customer fiat must hold a Michigan money-transmitter licence under the Money Transmission Services Act (MCL 487.1001 et seq.), administered by DIFS. A pending bill, HB 5544 (Money Transmission Modernization Act), would repeal and replace that Act and add a like-kind virtual-currency reserve requirement for licensees transmitting virtual currency.

Standing sub-brief · as of 25 August 2026228 words · last cycle 2026-10-18

Crypto Licensing

Michigan currently requires a license under the Money Transmission Services Act, administered by the Michigan Department of Insurance and Financial Services (DIFS), for any person engaged in the business of money transmission, a requirement that reaches virtual-currency exchanges to the extent they touch legal tender. This is the standing, in-force requirement and has not changed this cycle.

Periodic update · new data 2026-10-18

Crypto Licensing

Michigan has no bespoke crypto-licensing regime. Fiat-to-crypto and crypto-to-fiat exchange, on/off-ramps, and any receipt of dollars from a Michigan customer for transmission constitute money transmission on the fiat leg and require a Michigan money transmitter license under the existing Money Transmission Services Act, MCL 487.1001 et seq. The current regime requires a surety bond generally ranging from $500,000 to $1,500,000 at the regulator's discretion, along with a minimum net worth of $100,000 plus $25,000 per branch location.

This general licensing framework is itself in transition. House Bill 5544 would repeal the current Money Transmission Services Act (MCL 487.1001-487.1047) effective July 1, 2027, replacing it with the Conference of State Bank Supervisors model Money Transmission Modernization Act. The bill would add, for the first time, a requirement that a licensee transmitting virtual currency hold like-kind virtual currency of the same volume obligated to consumers, a reserve-backing requirement specific to virtual-currency transmission that does not exist under the current statute. HB 5544 also preserves criminal-fraud liability in the conduct of money transmission business and license-violation liability under the new act as grounds for sanction, notwithstanding the licensing transition.

Outlook

The central open question is whether the virtual-currency like-kind reserve provision survives Senate committee review unchanged, and whether the Senate acts on HB 5544 before the legislative session recesses. A crypto exchange or on/off-ramp provider operating in Michigan today is already required to hold a money transmitter license on the fiat leg of its business; should HB 5544 pass in its current form, it would face a new reserve-backing requirement specific to virtual-currency transmission beginning July 1, 2027.

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

Crypto Licensing

Michigan regulates crypto exchange and custody activity through the general Money Transmission Services Act of 2006 (2006 PA 250), supervised by the Michigan Department of Insurance and Financial Services. The statute has no bespoke crypto provisions; engaging in money transmission, including crypto exchange or custody activity, requires a licence under the current Act's broad definitional scope, though the precise current-Act definitional text was not independently retrieved this cycle, making this a directional rather than confirmed reading of the licensing perimeter.

A replacement statute, House Bill 5544 (H-2), would repeal the 2006 Act effective 1 July 2027 and enact a Money Transmission Modernization Act based on the Conference of State Bank Supervisors model law, with licensed persons grandfathered until repeal takes effect. The bill passed the Michigan House and was referred to the Senate Finance, Insurance, and Consumer Protection Committee on 1 July 2026; no further tracked legislative action was located this cycle, leaving the bill in Senate committee limbo. Final enactment status was not independently confirmed against the Michigan Legislature's own records this cycle, and a third-party tracker's conflicting signal on this point could not be corroborated.

The practical consequence for a crypto exchange or custody business licensed, or considering licensure, in Michigan is that the current general money-transmission framework remains the operative legal basis for the licence it holds or would need, while the content of that obligation — particularly around authorized delegates and BSA/USA PATRIOT Act compliance language — is poised to tighten materially if and when the Senate acts on the pending bill. Michigan sits as a comparatively late adopter of the CSBS model law relative to the 31 states that had already adopted it as of February 2026.

Outlook

Watch the Senate Finance, Insurance, and Consumer Protection Committee for any scheduling or committee-vote action on HB 5544; the bill has shown no tracked movement since its 1 July 2026 referral. Should the bill advance and be enacted, the 1 July 2027 effective date would govern the transition from the current Act to the new Money Transmission Modernization Act, with grandfathering for existing licensees. Absent further Senate action, the current 2006 Act's broad definitional scope remains the governing licensing perimeter for crypto exchange and custody businesses in Michigan.

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

Sources and findings (3)
  1. T3 · CoinDeskCoinDesk — Crypto exchange, custody, and money-transmission businesses operating in Michigan must obtain a money transmitter license under the state's general money transmission licensing regime, administered via NMLS.retrieved M4bindingin force
  2. T1 · FinCENFinCEN — Under federal BSA regulations applied nationwide, an administrator or exchanger that accepts and transmits, or buys or sells, convertible virtual currency is a money transmitter (MSB) unless an exemption applies, forming the baseline definitional framework that Michigan's state licensing regime tracks.retrieved M4bindingin force
  3. T4 · The BlockThe Block — Pending Michigan House Bill 4511 would prohibit the state from impeding an individual from holding cryptocurrency (via bans or license requirements) and would restrict certain state officials from supporting a U.S. central bank digital currency; the bill has not been enacted.retrieved M3non-binding

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Michigan has not enacted a state-specific token-classification statute. Per the disambiguation applicable to this JID, characterization of a digital asset as a security, commodity, or other instrument is governed by federal SEC/CFTC jurisdiction rather than by a Michigan-specific rule; Michigan's role is limited to money-transmission/custody licensing, not securities characterization.

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 · CFTCCFTC — Michigan has no independent state-level statute characterizing digital assets as securities, e-money tokens, asset-referenced tokens, or utility tokens; such characterization for securities/commodity purposes is treated as a matter of federal SEC/CFTC jurisdiction.retrieved M3bindingin forceour coverage gap, expected to resolve on a re-run

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Michigan has no enacted state statute specifically regulating staking, DeFi lending, DEX operation, node/validator operation, or tokenization. A pending bill package (HB 4512/HB 4513) would create a bitcoin-mining program using abandoned oil and gas well sites, with a companion income-tax provision, but neither has been enacted as of this run.

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. T4 · The BlockThe Block — Pending Michigan House Bill 4512 would create a bitcoin-mining program permitting mining operations at abandoned oil and gas well sites, conditioned on the operator performing required site restoration; the bill has not been enacted.retrieved M2non-binding
  2. T4 · The BlockThe Block — No enacted Michigan statute currently governs staking, DeFi lending, DEX operation, node/validator operation, or tokenization activities at the state level.retrieved M2bindingin forceour coverage gap, expected to resolve on a re-run

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Michigan has no independent state stablecoin statute. Stablecoin issuance in the U.S. is now governed by the federal GENIUS Act (signed into law July 18, 2025), which establishes issuance, reserve, redemption, and disclosure requirements and permits state-qualified issuers to operate under a state regime only if certified by federal regulators as substantially similar to the federal framework; final implementing regulations remain pending, with regulators having missed the one-year rulemaking deadline. Until GENIUS's implementing rules take effect, stablecoin issuers operating in Michigan continue to rely on the state's general money-transmitter licensing regime.

Standing sub-brief · as of 25 August 2026209 words · last cycle 2026-10-04

Stablecoin Regime

Michigan's stablecoin regime is governed entirely at the federal level, binding on the state by preemption, with no Michigan-specific issuance regime in place or imminent. The GENIUS Act restricts payment-stablecoin issuance to Permitted Payment Stablecoin Issuers (PPSIs) as a matter of settled federal statute. Building on that baseline, a joint FinCEN/OFAC notice of proposed rulemaking would impose AML program, Suspicious Activity Report, recordkeeping, and a five-element sanctions-compliance-program requirement on PPSIs as a distinct Bank Secrecy Act financial-institution category; the comment period closed June 9, 2026 and the rule remains proposed rather than final.

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

Sources and findings (3)
  1. T4 · The BlockThe Block — The federal GENIUS Act, signed into law July 18, 2025, allows only permitted entities to issue payment stablecoins in the United States: federally chartered banks, OCC-supervised nonbank issuers, and state-qualified issuers operating under a state regime certified as substantially similar to the federal framework.retrieved M4bindingenacted not yet effective
  2. T4 · The BlockThe Block — As of this run, current stablecoins in the U.S. continue to be issued using state money-transmitter licenses without dedicated federal oversight, pending GENIUS Act implementing regulations that federal regulators have not yet finalized despite the one-year statutory deadline.retrieved M4bindingin force
  3. T4 · The BlockThe Block — No Michigan-specific reserve, redemption, or disclosure requirement for stablecoin issuers exists independent of the federal GENIUS Act framework and Michigan's general money-transmitter licensing regime.retrieved M3non-bindinga fact about the regime

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Michigan has not enacted a crypto-kiosk/ATM-specific consumer protection statute comparable to Illinois's Digital Asset Kiosk Act or Minnesota's kiosk ban. Consumer protection currently rests on (a) the Michigan Attorney General's Consumer Protection Division, which has issued a cryptocurrency 'pig butchering' scam alert referenced in federal guidance, and (b) federal FinCEN advisories/notices on CVC kiosk fraud that inform financial-institution reporting obligations nationwide, including in Michigan. The Michigan Attorney General has also acted as a co-plaintiff in federal (CFTC) enforcement matters touching digital-asset-adjacent investment fraud.

Standing sub-brief · as of 11 October 2026286 words · last cycle 2026-10-11

Consumer Protection

Michigan has no dedicated state-level crypto consumer-protection rule located this cycle. The material development bearing on consumer protection for a crypto-adjacent platform is a gambling-regulatory enforcement action: the Michigan Gaming Control Board entered a stipulation with Coinbase Financial Markets, Inc. requiring it to stop offering new sports-related event contracts to Michigan customers and to close out any remaining open customer positions by 10 October 2026. The state is forbearing further enforcement pending the outcome of Sixth Circuit appeals concerning the underlying legal question of whether states may regulate prediction-market sports-event contracts as gambling.

no periodic updates on record for this sub-brief

Sources and findings (3)
  1. T1 · FinCENFinCEN — The Michigan Department of Attorney General, Consumer Protection Division, has issued a public alert on cryptocurrency 'pig butchering' scams, cited by FinCEN as part of a national law-enforcement/regulator alert compendium on virtual-currency investment fraud.retrieved M3non-binding
  2. T1 · FinCENFinCEN — FinCEN's August 2025 notice on convertible virtual currency (CVC) kiosk scams applies nationwide, including Michigan, reminding financial institutions of Bank Secrecy Act suspicious-activity reporting obligations tied to CVC kiosk fraud typologies disproportionately affecting older adults.retrieved M3bindingin force
  3. T4 · The BlockThe Block — Michigan has not enacted a crypto-ATM/kiosk operator registration, fee-cap, or transaction-limit statute comparable to those adopted in Illinois, North Dakota, or Minnesota.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run

#

Michigan personal and corporate income tax generally conforms to the federal tax base. At the federal level, virtual currency is treated as property (not currency) for federal tax purposes per longstanding IRS guidance (Notice 2014-21), meaning capital gains/ordinary income characterization flows through to Michigan taxable income via federal AGI conformity. A pending Michigan bill (HB 4513) would amend the state's 1967 income tax act to address income from bitcoin mining at abandoned well sites, but it has not been enacted.

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. T1 · CFTC / LabCFTCCFTC / LabCFTC — Federal guidance treats virtual currency as property for U.S. federal tax purposes, with general tax principles applicable to property transactions applying to virtual currency, a characterization Michigan's income tax base conformity inherits absent a state-specific override.retrieved M4bindingin force
  2. T4 · The BlockThe Block — Pending Michigan House Bill 4513 would amend the state's 1967 income tax act to address income derived from bitcoin mining at abandoned oil and gas well sites; it has not been enacted.retrieved M2non-binding
  3. T1 · CFTC / LabCFTCCFTC / LabCFTC — No Michigan-specific crypto tax information-reporting obligation exists independent of federal reporting requirements (e.g., Form 1099 series) that flow through to state filings.retrieved M2bindingin forceour coverage gap, expected to resolve on a re-run

#

Michigan has no independent state statute governing cross-border crypto transfers. Cross-border movement of virtual currency by Michigan-based money transmitters is governed by federal frameworks: FinCEN's Bank Secrecy Act travel-rule and sanctions-screening obligations (applicable to money transmitters generally, a category into which Michigan-licensed virtual-currency businesses fall), and, for stablecoin issuers specifically, GENIUS Act sanctions-compliance and lawful-order provisions currently being implemented via a joint FinCEN/OFAC proposed rule.

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 · FinCENFinCEN — Michigan imposes no independent state-level restriction on cross-border crypto transfers beyond the federal Bank Secrecy Act and OFAC sanctions framework applicable to money transmitters nationwide.retrieved M3bindingin force
  2. T1 · FinCEN / OFACFinCEN / OFAC — FinCEN and OFAC have issued a joint proposed rule implementing the GENIUS Act's anti-money-laundering and sanctions compliance program requirements for permitted payment stablecoin issuers, which would apply to any Michigan-based stablecoin activity once finalized.retrieved M3bindingproposed
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Editorial metadata for Michigan, USA
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