Cryptoassets Regulatory Intelligence cryptoassets.gi
US-MO v13.3.0
content: ai_generated legal review: never_reviewed (informational) publication gate: 1 failing10 sources retrieved model claude-sonnet-5 · 2026-08-06

Missouri, USA

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

Last updated · 9 categories · 12 sourced findings · 25 sources in the cumulative register

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

Jurisdiction lead brief

Latest update · 18 October 2026

Lead Signal

Missouri's crypto-kiosk regulatory architecture moved into active contest this cycle. GPD Holdings LLC, operating as CoinFlip, has moved to dismiss the Missouri Attorney General's suit brought under the Merchandising Practices Act, arguing that the Virtual Currency Kiosk Consumer Protection Act (RSMo 361.1100) is the controlling, industry-specific regime that displaces the AG's general fraud theory. The underlying suit, filed 21 May 2026, alleges CoinFlip's roughly 143 Missouri kiosks charged fees up to 21.9 percent while facilitating fraud. Separately, pending Senate Bill 1510 would grant the Attorney General sole civil-enforcement authority over kiosk-statute violations, with penalties of up to $10,000 per violation.

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Missouri has no bespoke crypto-asset licensing statute. Virtual-currency exchange, custody and transmission businesses are captured under Missouri's general money-transmitter licensing regime, administered through the multistate NMLS infrastructure, rather than a dedicated 'BitLicense'-style instrument. The precise state statutory citation and any crypto-specific carve-outs could not be independently confirmed via retrievable primary source in this run and should be escalated for direct statutory verification. Separately, state-level scrutiny of virtual-currency kiosk operators has been exercised primarily through consumer-protection litigation rather than licensing enforcement.

Standing sub-brief · as of 25 August 2026182 words · last cycle 2026-10-18

Crypto Licensing

Missouri's Division of Finance requires registration or licensure for any person receiving or transmitting virtual currency for a Missouri resident, under the Money Transmission Modernization Act. This is a confirmed, in-force, High-confidence requirement and constitutes the entirety of Missouri's state-level crypto licensing regime: there is no dedicated crypto-exchange or custody licence class distinct from the general money-transmission licence. A pending bill from the 2025 session, SB779, would extend this licensing perimeter specifically to virtual-currency kiosk operators, deeming them money transmitters and layering on disclosure requirements, a fee cap of fifteen percent of transaction value, and daily transaction limits. This is an Assessed-confidence finding, since the bill's enactment status was not established this cycle.

Periodic update · new data 2026-10-18

Crypto Licensing

Missouri's Virtual Currency Kiosk Consumer Protection Act, codified at RSMo 361.1100, is the standing in-force licensing instrument for crypto kiosks in the state, deeming a kiosk operator a money transmitter and requiring a Missouri money-transmitter licence, an enhanced-due-diligence policy, and designation of both a compliance officer and a consumer-protection officer. That baseline framework is unchanged this cycle, but its scope and enforcement are both now in active dispute. GPD Holdings LLC, operating as CoinFlip, has moved to dismiss the Missouri Attorney General's Merchandising Practices Act suit, filed 21 May 2026 over alleged fraud-facilitation and fees up to 21.9 percent at its roughly 143 Missouri kiosks, arguing that RSMo 361.1100 is the controlling, industry-specific regime displacing the AG's general theory.

Running in parallel, pending Senate Bill 1510 would amend RSMo 361.1100 to grant the Attorney General sole civil-action authority over violations of the statute, with penalties up to $10,000 per violation and $1,000 per injunction breach. The bill has not been enacted. Together, the litigation and the pending bill place the licensing-cum-enforcement relationship between the kiosk statute and general consumer-protection law in flux: a functioning licensing and AML framework exists for kiosks, but whether the Attorney General's enforcement reach extends beyond that statute into general consumer-protection law is not yet settled, and the statute's own penalty and enforcement-authority structure may itself be about to change via SB 1510.

Outlook

Two processes will determine the shape of Missouri's crypto-kiosk licensing and enforcement regime going forward: the court's ruling on CoinFlip's motion to dismiss, which will clarify whether the kiosk statute displaces general consumer-protection enforcement, and the Missouri Senate's handling of SB 1510, which would concentrate civil-penalty authority for kiosk-statute violations in the Attorney General regardless of the litigation's outcome. Whether either SB 1510 or the related SB 1177 passes before the 2026 session ends is not yet established.

1 earlier distinct update(s)
Periodic update · new data 2026-09-28

Crypto Licensing

Missouri's crypto-licensing regime tightened materially this cycle. The Missouri Division of Finance issued guidance, effective August 28, 2025, deeming virtual-currency kiosk operators to be engaged in money transmission and requiring licensure under RSMo Section 361.1100 of the Money Transmission Modernization Act. This is the first Missouri-specific instrument to name a crypto-adjacent activity class directly, rather than relying solely on the general money-transmission statute's application to crypto activity by regulatory interpretation. The guidance was confirmed directly on the Division of Finance's own published page, which states that kiosk operators shall be deemed to be engaged in money transmission and require licensure pursuant to the Act.

This kiosk-specific extension sits atop the broader MTMA framework, codified at RSMo Sections 361.900 through 361.1035, which itself repealed and replaced the former Sale of Checks Law effective August 28, 2024. Under that broader framework, general crypto exchange and custody businesses operating in Missouri have required MTMA licensure since the 2024 effective date, with the Missouri Division of Finance serving as the supervisory authority throughout. The regime remains, in character, a general money-transmission statute applied to crypto activity through regulator interpretation rather than a bespoke crypto-licensing framework, which is why the module's traffic-light assessment reflects an active but non-dedicated regime rather than a purpose-built crypto licensing statute.

The kiosk guidance closes a gap that has been exploited nationally for elder-fraud and romance-scam cash-out schemes routed through crypto ATMs, since kiosk operators in Missouri are now explicitly named as licensable money-transmission businesses rather than left to an ambiguous application of the general statute.

Outlook

The near-term question for this module is whether the Division of Finance extends similarly explicit guidance to other crypto-adjacent activity classes beyond kiosk operation, following the pattern set by the August 2025 guidance. Absent further state-specific instruments, general crypto exchange and custody activity continues to be governed by the MTMA's general money-transmission framework as interpreted by the regulator, with token classification, on-chain activity, stablecoin issuance, tax treatment, and cross-border transfer all remaining deferred to federal frameworks by default.

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

Sources and findings (2)
  1. T1 · Nationwide Multistate Licensing System (NMLS)Nationwide Multistate Licensing System (NMLS) — Virtual-currency exchange and custody businesses operating in Missouri are expected to obtain a state money-transmitter license administered through NMLS, as Missouri has no bespoke crypto-asset licensing statute distinct from its general money-transmission law.retrieved M4bindingin force
  2. T4 · The BlockThe Block — Missouri's Attorney General has pursued consumer-protection litigation (rather than licensing-based enforcement) against a crypto-ATM kiosk network, indicating that state oversight of virtual-currency businesses currently runs primarily through general consumer-protection and money-transmission channels rather than a crypto-specific licensing gate.retrieved M3non-binding

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Missouri defers token-as-security/commodity characterization to the federal SEC/CFTC framework rather than maintaining an independent state taxonomy. Within that federal overlay, the Missouri Secretary of State's Securities Division actively enforces the state's blue-sky (Missouri Securities Act) regime against crypto-investment offerings that meet the security definition and are marketed to Missouri 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 (2)
  1. T3 · CoinDeskCoinDesk — The Missouri Secretary of State's Securities Division has exercised state blue-sky enforcement authority against crypto-investment offerings soliciting Missouri residents, issuing cease-and-desist orders and civil penalties where such offerings constituted unregistered securities or fraudulent investment-adviser representations.retrieved M4bindingin force
  2. T1 · U.S. Securities and Exchange CommissionU.S. Securities and Exchange Commission — Token-as-security-or-commodity characterization for crypto assets accessible to Missouri residents is governed by federal SEC/CFTC interpretive guidance rather than any Missouri-specific statute; Missouri does not maintain an independent token taxonomy.retrieved M3bindingin force

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Missouri has no bespoke statute addressing crypto mining, staking, DeFi lending, DEX operation, node operation, validator activity or tokenization. A 2023 legislative effort to grant statutory protections to crypto-mining operations (comparable to laws enacted in Arkansas and Montana) died without passage, leaving miners subject only to general business, zoning and utility law. No evidence of subsequent enactment was found.

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. T3 · CoinDeskCoinDesk — A Missouri legislative bill intended to grant statutory protections to cryptocurrency mining operations, comparable to laws passed in Arkansas and Montana, died without passage, leaving crypto miners in Missouri subject only to general business, zoning and utility regulation rather than a bespoke mining-protection statute.retrieved M3non-binding
  2. T1 · Nationwide Multistate Licensing System (NMLS)Nationwide Multistate Licensing System (NMLS) — No Missouri-specific statute or regulation addressing staking, DeFi lending, DEX operation, node operation, validator activity or tokenization has been identified; these activities fall by default under general federal securities/commodities law and Missouri's general money-transmission and securities frameworks.retrieved M2non-bindinga fact about the regime

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Missouri has not enacted a state-specific stablecoin issuance-authorisation, reserve, redemption, disclosure or systemic-designation regime. Payment stablecoin issuance nationally, including for issuers serving Missouri residents, is governed by the federal GENIUS Act framework, which preempts the need for a Missouri-specific regime for compliant federally-permitted issuers. Implementation of GENIUS Act rules was still being finalized as of the most recent available reporting.

Standing sub-brief · as of 25 August 2026159 words · last cycle 2026-09-14

Stablecoin Regime

Missouri has no state-specific stablecoin statute; its stablecoin regime is entirely a function of the federal GENIUS Act framework, which remains at the implementing-rulemaking stage. The OCC's February 25, 2026 NPRM sets application, reserve, redemption, and risk-management requirements for OCC-licensed payment stablecoin issuers, a confirmed, Tier 1, High-confidence, proposed-stage finding. Separately, FinCEN and OFAC have issued a joint proposed rule implementing the GENIUS Act's AML and sanctions-compliance-program requirements for payment stablecoin issuers, also confirmed at Tier 1 with High confidence and also still at proposal stage.

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

Sources and findings (1)
  1. T1 · U.S. Securities and Exchange CommissionU.S. Securities and Exchange Commission — The federal GENIUS Act establishes the primary U.S. payment-stablecoin issuance and reserve framework, which will apply uniformly to issuers serving Missouri residents once its implementing regulations take full effect; Missouri has not layered any additional state-specific stablecoin authorisation regime on top of this federal framework.retrieved M3bindingenacted not yet effective

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Missouri's principal live consumer-protection vector for crypto is Attorney General enforcement against virtual-currency kiosk (crypto-ATM) operators under general state consumer-protection law, driven by a documented and rising volume of fraud complaints. No crypto-specific marketing-restriction, custody-segregation or suitability statute distinct from this general enforcement posture has been identified.

Standing sub-brief · as of 18 October 2026257 words · last cycle 2026-10-18

Consumer Protection

The Missouri Attorney General's consumer-protection case against CoinFlip (GPD Holdings LLC) remains an active, unresolved dispute this cycle. The AG alleges that CoinFlip charged hidden fees of up to 21.9 percent at Missouri bitcoin ATMs, in violation of the state's Merchandising Practices Act, while failing to adequately prevent fraud facilitated through its kiosks. CoinFlip disputes the AG's theory of liability on jurisdictional grounds, arguing that the Virtual Currency Kiosk Consumer Protection Act (RSMo 361.1100), a statute enacted specifically to regulate crypto kiosks including through licensing and enhanced-due-diligence requirements, is the controlling regime and that the Merchandising Practices Act claim is therefore displaced.

no periodic updates on record for this sub-brief

Sources and findings (2)
  1. T4 · The BlockThe Block — The Missouri Attorney General filed suit against crypto-ATM operator CoinFlip (GPD Holdings LLC), alleging the network facilitated fraudulent transactions and charged excessive fees, and seeking consumer restitution, civil penalties of up to $1.826 million, and an injunction against continued operation in the state.retrieved M5bindingin force
  2. T4 · The BlockThe Block — Missouri reported roughly 350 crypto-ATM-related fraud cases over a two-year period tied to kiosks including those operated by CoinFlip, underscoring material and rising state-level consumer complaint volume associated with virtual-currency kiosks.retrieved M4non-binding

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No Missouri-specific statute altering the treatment of cryptocurrency for state tax purposes was identified in this pass. Missouri state income tax is generally understood to follow federal adjusted-gross-income conformity, implying that federal property/capital-gains characterization of crypto would flow through by default absent contrary state guidance, but this inference could not be independently confirmed against a live Missouri Department of Revenue source in this run and should be escalated.

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 · Nationwide Multistate Licensing System (NMLS)Nationwide Multistate Licensing System (NMLS) — No Missouri-specific statute altering the federal property/capital-gains characterization of cryptocurrency for state income-tax purposes has been identified; Missouri income tax is expected to follow the federal characterization by conformity, pending direct confirmation from the Missouri Department of Revenue.retrieved M3bindingin forceour coverage gap, expected to resolve on a re-run

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Missouri imposes no identified state-specific restriction on cross-border transfer of virtual currency. Applicable controls derive from the federal Bank Secrecy Act / FinCEN framework, including the Travel Rule and 2025 FinCEN guidance specifically flagging convertible-virtual-currency kiosks as a vector for illicit cross-border fund movement — a typology directly relevant given Missouri's documented crypto-ATM fraud caseload.

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 · FinCENFinCEN — Missouri imposes no state-specific restriction on cross-border transfer of virtual currency; applicable controls derive from the federal BSA/FinCEN framework, including CVC-kiosk-focused guidance highlighting illicit cross-border fund-movement typologies relevant to Missouri's crypto-ATM fraud caseload.retrieved M3bindingin force

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Crypto AML/CFT obligations applicable to Missouri-based virtual-asset businesses are sourced via the fleet's shared Financial Integrity Module (FIM) aml_ctf subscription and are not duplicated in this crypto baseline, per the module subscription reminder. As disambiguation context only: FinCEN is the primary federal AML/CFT regulator for money-services businesses, including Missouri-licensed money transmitters engaged in virtual-currency activity, and has issued kiosk-specific typology guidance relevant to Missouri's active crypto-ATM caseload.

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

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No standing position recorded for this category.

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. UnsourcedMissouri crypto-sector commercial activity — no qualifying crypto-sector commercial event involving a Missouri party within the declared windowM1non-binding
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Editorial metadata for Missouri, USA
FieldValue
trust.lawyer_review.statusnever_reviewed
trust.lawyer_review.reviewerno reviewer on record
trust.content_sourceai_generated

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Envelope: baseline resolved at jurisdiction_json.baseline; 9 module(s), 12 finding(s), 25 source(s) in the cumulative register.

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