North Dakota, USA

Crypto Licensing

North Dakota requires virtual-currency kiosk operators to hold a North Dakota money transmitter licence under N.D.C.C. §13-09.1-50 before engaging in virtual-currency business activity, or representing themselves as able to do so on another's behalf, a requirement in force since 2025-08-01. Kiosk-specific conditions under §13-09.1-52 additionally require operators to deploy blockchain analytics to detect and prevent suspicious activity and to designate both a full-time compliance officer and a full-time customer-protection officer. A separate, lower-confidence source indicates North Dakota requires a money-transmitter surety bond, generally reported at $150,000 with regulatory discretion to raise it to $500,000, though this figure has not been directly verified against the N.D.C.C. ch. 13-09.1 text this cycle.

The material development this cycle is North Dakota's participation in a 34-state, $2.5M multistate consent settlement with Coinme Inc., a licensed North Dakota money transmitter and kiosk operator, following findings that Coinme's BSA/AML compliance program did not meet requirements. North Dakota's allocated share is $10,000, and Coinme must terminate its North Dakota kiosk operations (approximately 66 locations) by 2027-01-01 or face a further $4M penalty, alongside an independent compliance review. The settlement is the clearest evidence this cycle of active supervisory use of North Dakota's licensing and AML framework: a licensed operator meeting the state's kiosk-specific blockchain-analytics and compliance-officer conditions was nonetheless found deficient under the broader BSA/AML standard, indicating that state licensure and federal compliance-program adequacy are assessed through distinct channels rather than one certifying the other. Whether North Dakota will issue any state-specific consent order against Coinme beyond its role in the multistate settlement remains unresolved on the current record.

Outlook

The 2027-01-01 deadline is the operative date for Coinme's North Dakota kiosk wind-down, as scheduled, with a further $4M penalty attaching to non-compliance. The surety-bond figure reported for North Dakota money transmitters remains unverified against primary statutory text and should be treated as provisional pending direct confirmation.

On-Chain Activity Regime

North Dakota's treatment of on-chain infrastructure activity, specifically blockchain node operation and digital-asset mining, remains genuinely unresolved following the failure of HB 1239 during the 2025 legislative session. The bill would have exempted a person who operates a node or series of nodes on a blockchain protocol, or who engages in digital-asset mining, from the states money-transmitter license requirement. It failed on House second reading by a wide margin, 14 yeas to 75 nays, on February 17, 2025, and accordingly created no exemption; the bills failure means mining and node-operation activity remains subject to whatever the general money-transmitter licensing standard already implies for that activity, without either an explicit statutory exemption or an explicit statutory inclusion having been confirmed this cycle.

This ambiguity is compounded by an unresolved question about pre-existing administrative guidance. North Dakota's state government has previously taken the position, through a Department of Financial Institutions FAQ, that virtual currency control or transmission alone does not necessarily require a money-transmitter license. Whether that FAQ position still holds under the chapter 13-09.1 recodification, and following HB 1447's 2025 amendments extending licensing to virtual-currency kiosks specifically, was not resolved this cycle. The combined effect is that node operators and miners in North Dakota face a statutory and administrative picture that has neither been narrowed by exemption nor clarified by updated guidance, leaving their licensing exposure a matter of interpretation rather than settled law.

Outlook

Resolution of North Dakota's on-chain activity regime will most likely depend on one of two paths: a renewed legislative attempt to establish a mining/node exemption, following HB 1239's decisive rejection, or updated administrative guidance from the Department of Financial Institutions clarifying whether its pre-2023 FAQ position on virtual currency control and transmission still applies under the recodified licensing chapter. Neither path shows evidence of being underway as of this cycle, and the practical exposure facing node operators and miners in North Dakota should be treated as unresolved rather than settled in either direction.

Stablecoin Regime

Roughrider Coin, North Dakota's first stablecoin, went live October 1, 2026, marking the jurisdiction's entry into live stablecoin issuance. The instrument is fully collateralized 1:1 by US dollar reserves, structured for wholesale and interbank use only, with no retail counterparty exposure. VersaBank USA, N.A., an OCC-chartered bank, serves as the issuing entity, while Bank of North Dakota, the state-owned bank, serves as program sponsor. Fireblocks provides tokenization infrastructure, and settlement runs on the Solana blockchain. The program operates on Fiserv's digital asset platform, which activated the same day with Roughrider Coin as its first live use case.

The applicable legal framework is the GENIUS Act's state-issuer carve-out, under which payment stablecoins are classified as payment instruments rather than securities or commodities. This classification currently applies at the federal level, though the GENIUS Act's implementing rules determining whether state programs like North Dakota's are 'substantially similar' to the federal framework remain pending, with Treasury's finalization expected in Q4 2026 as scheduled via the GENIUS Act's state/federal substantial-similarity rulemaking process. This positions Roughrider Coin as a live, operational program resting on a currently provisional federal legal foundation rather than a fully settled one.

No North Dakota-specific statute or Department of Financial Institutions guidance addressing stablecoins directly was identified this cycle; the state's existing virtual-currency framework is the narrower kiosk-licensing statute under NDCC Chapter 13-09.1, which does not itself address wholesale interbank stablecoin issuance of the kind Roughrider Coin represents. Whether the Department of Financial Institutions will issue state-specific guidance characterizing Roughrider Coin for purposes of the existing virtual-currency statute, before the federal implementing rules finalize, was not resolved this cycle.

The wholesale, institution-only design is itself a meaningful risk-scoping feature: by confining the counterparty universe to banks and credit unions rather than retail customers, the program narrows its direct consumer-protection exposure while concentrating its primary open questions in the licensing and federal-preemption space rather than in retail market conduct.

Outlook

The finalization of the GENIUS Act's state/federal 'substantial similarity' implementing rules, expected in Q4 2026 as scheduled, is the single most consequential near-term event for Roughrider Coin's regulatory durability. Until that rulemaking concludes, North Dakota's reliance on the state-issuer carve-out remains a live and open structural question rather than a settled legal position, and the program's long-term compliance architecture should be read as provisional pending that outcome.

Consumer Protection

North Dakota enacted a concrete, in-force consumer-protection instrument for crypto users during the 2025 session. HB 1447 requires virtual-currency kiosk operators to display fraud-warning disclosures and cap individual customer transactions at 2,000 dollars per calendar day, in force since August 1, 2025. The legislative record ties these provisions directly to advocacy from AARP North Dakota, which cited FBI-reported losses showing North Dakota residents reported approximately 6.5 million dollars in digital-currency scam losses across 103 FBI complaints in 2023. This is a well-evidenced, targeted response to a documented and quantified harm pattern rather than a general consumer-protection framework applied to crypto as a category.

The design of the intervention, combining a hard transaction cap with a mandatory disclosure requirement, indicates the legislature judged disclosure alone insufficient to address the scam pattern identified in the FBI data. A per-day cap limits the maximum financial exposure a single victim faces even if a scam succeeds, which is a structurally different and more forceful protection than a disclosure-only regime would provide. The specific vector targeted, virtual-currency kiosks, is notable because kiosks are a common on-ramp used in romance-scam and impersonation-scam patterns that regulators nationally have identified as a growing share of reported crypto fraud losses.

Outlook

The consumer-protection provisions of HB 1447 have been in force only since August 2025, and no post-implementation data on scam-loss trends among North Dakota kiosk users was available this cycle to assess effectiveness. The natural next signal to track is whether the Department of Financial Institutions or another state body publishes data on kiosk-related fraud complaints following implementation, which would allow an assessment of whether the transaction cap and disclosure requirements are achieving their stated purpose.

Commercial Activity

Coinme Inc., a Seattle-based money transmitter and kiosk operator licensed in North Dakota, will terminate its approximately 66 North Dakota virtual-currency kiosk locations by 2027-01-01 under the terms of a 2026-10-08 multistate consent settlement with a 34-state regulatory coalition. The settlement followed findings that Coinme's Bank Secrecy Act and anti-money-laundering compliance program did not meet applicable requirements; the total settlement amount is $2.5M, with North Dakota's allocated share set at $10,000, and Coinme faces an additional $4M penalty should it fail to complete the wind-down by the deadline. The settlement is recorded as cleared with conditions by North Dakota's regulatory review.

This is a market-exit event for a licensed North Dakota crypto-kiosk operator, directly triggered by regulatory compliance findings rather than an independent commercial decision. The scale of the departure, roughly 66 kiosk locations, is material to North Dakota's virtual-currency kiosk sector irrespective of the comparatively modest $10,000 state-level settlement allocation. Coinme's exit coincides with its existing obligations under North Dakota's kiosk-licensing statute, N.D.C.C. ch. 13-09.1, which already required blockchain-analytics controls and designated compliance and customer-protection officers; the settlement demonstrates that these state-level kiosk conditions did not themselves prevent the BSA/AML program deficiency that produced the multistate action and the resulting market exit.

Outlook

The wind-down deadline of 2027-01-01 is the date to track for this market-exit event, as scheduled, with a defined $4M penalty for non-compliance. No signal in the current record indicates whether another operator will enter the North Dakota kiosk market to replace Coinme's withdrawn presence.