Cryptoassets Regulatory Intelligence cryptoassets.gi
US-VA v13.3.0
content: ai_generated legal review: never_reviewed (informational) publication gate: 0 failing17 sources retrieved model claude-sonnet-5 · 2026-08-06

Virginia, USA

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

Last updated · 7 categories · 19 sourced findings · 31 sources in the cumulative register

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

Jurisdiction lead brief

Latest update · 28 September 2026

Lead Signal

Virginia's crypto-regulatory perimeter tightened this cycle through the Money Transmission Modernization Act, Chapter 19.1 of Title 6.2, effective July 1, 2026. The statute defines virtual currency for the first time in Virginia's money-transmission code, describing it as a digital representation of value used as a medium of exchange, unit of account, or store of value that is not money, but expressly excludes virtual currency from the statutory definition of money itself. The practical consequence is a clear licensing boundary: a business that receives fiat currency in Virginia for transmission and also deals in virtual currency must hold a Virginia money-transmitter licence under Chapter 19.1, while a platform dealing exclusively in virtual currency, with no fiat-transmission leg, falls outside the licensing requirement entirely.

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Virginia has no bespoke crypto-asset statute. Virtual-currency exchange and custody businesses are regulated under the Commonwealth's general money-transmitter law, now Chapter 19.1 of Title 6.2 (Money Transmission Modernization Act, effective July 1, 2026), which defines 'virtual currency' but expressly excludes it from the definition of 'money'. Platforms dealing exclusively in virtual currency, with no fiat-transmission leg, fall outside MTL licensure.

Standing sub-brief · as of 26 August 2026430 words · last cycle 2026-10-11

Crypto Licensing

Virginia's crypto licensing landscape shifted on two statutory fronts this cycle, both effective within the same eighteen-month window but pointed in different directions. Chapter 19.1, effective July 1, 2026, replaced the Commonwealth's general money-transmission statute and, within that replacement, defined virtual currency explicitly as not "money." The consequence is direct: a platform dealing exclusively in virtual currency, with no fiat-currency leg to its Virginia business, is exempted from the state's money-transmission licensure requirement altogether, regardless of transaction volume.

Periodic update · new data 2026-10-11

Crypto Licensing

Virginia does not operate a bespoke crypto-asset licensing statute. Crypto-related activity with a fiat leg is captured by extension under the general money-transmitter licensing regime, now codified at Chapter 19.1 of Title 6.2 of the Code of Virginia, which took effect 1 July 2026 and replaced the prior Chapter 19 regime in its entirety. Supervision of this regime sits with the Virginia State Corporation Commission's Bureau of Financial Institutions.

The confirmed finding this cycle is a definitional one: Va. Code § 6.2-1922 excludes virtual currency from the statutory definition of money. The statutory text states directly that money does not include virtual currency. The consequence for crypto licensing specifically is that a business whose Virginia activity consists of transmitting virtual currency alone, without a fiat, stored-value or payment-instrument component, is carved out of the Chapter 19.1 licensing requirement by the statute's own terms, rather than by any administrative interpretation or enforcement discretion. This creates genuine classification uncertainty for crypto businesses operating in Virginia: a business must determine whether its activity profile includes any fiat-facing leg, because that determination now directly governs whether Chapter 19.1 licensure applies.

A second, distinct instrument addresses part of this gap but has not yet closed it. The Virtual Currency Kiosk License, created under Chapter 22.2 pursuant to HB665 and enacted 13 April 2026, will establish a standalone licensing pathway specifically for kiosk operators. However, this licence does not take effect until 1 July 2027, over a year after the Chapter 19.1 exclusion commenced. The probable-confidence rating on this finding reflects that its substantive terms were sourced this cycle from secondary commentary, since the primary HB665 bill text was not independently retrieved; the fact and approximate timing of enactment are reasonably well evidenced, but precise statutory wording awaits direct confirmation.

For crypto businesses holding or requiring a Chapter 19.1 licence because their Virginia activity includes a fiat leg, the general money-transmitter enforcement regime applies. The State Corporation Commission may impose a civil penalty of up to 2,500 dollars per violation, with each unlicensed transaction constituting a separate violation; this is a probable finding sourced from secondary legal commentary on the general Chapter 19.1 enforcement provision, which is not crypto-specific.

A material evidentiary gap should be stated plainly: the Bureau of Financial Institutions' implementing regulation, 10VAC5-120, has revision dates consistent with adoption aligned to the Chapter 19.1 commencement date, but a final-adoption order was not independently confirmed this cycle, and no crypto-specific interpretive guidance addressing the money/virtual-currency boundary was located. Until such guidance surfaces, the precise administrative treatment of mixed-activity businesses, those with both a virtual-currency component and a separate fiat-facing component, remains to be clarified from a primary source.

Outlook

The period between 1 July 2026 and 1 July 2027 is the interval in which Virginia has no licensing instrument reaching virtual-currency-only business models directly: the general licence excludes them, and the kiosk-specific licence is not yet operative. Direct retrieval of the HB665 bill text and confirmation of the Bureau of Financial Institutions' final-adoption order for 10VAC5-120 are the two items most likely to sharpen this classification picture ahead of the kiosk licence's 2027 commencement.

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

Crypto Licensing

Virginia's crypto-licensing perimeter is defined entirely through its general money-transmitter statute rather than a crypto-specific licensing regime. Chapter 19.1 of Title 6.2, effective July 1, 2026, requires any business that receives fiat currency in Virginia for transmission and also deals in virtual currency to hold a Virginia money-transmitter licence, a requirement confirmed directly on the primary statutory text at Confirmed confidence. This captures fiat-crypto on/off-ramp businesses, exchanges accepting fiat deposits, and similar hybrid models operating in the Commonwealth.

The corresponding boundary condition is that a platform dealing exclusively in virtual currency, without any fiat-transmission leg, falls outside the scope of this licensing requirement, since Chapter 19.1 defines virtual currency but expressly excludes it from the statutory definition of money that triggers licensure. This consequence is assessed at Probable confidence: it follows directly from the statutory exclusion, but no Bureau of Financial Institutions interpretive guidance confirming the boundary in practice was identified this cycle, and no State Corporation Commission interim guidance under 10 VAC 5-120 reconciling the prior regulatory framework with the new chapter for virtual-currency-adjacent licensees was located either. This is an unregulated-gap condition worth monitoring rather than a settled interpretive matter: pure crypto-to-crypto platforms operate in Virginia without a licensing touchpoint by design of the current statutory text, not by any affirmative regulatory exemption decision.

The statute governing this licensing boundary is the Virginia Bureau of Financial Institutions' primary framework, Title 6.2, Chapter 19.1 (Money Transmitters / MTMA), which is the sole instrument governing this module for the Commonwealth; no separate crypto-specific licensing statute or supervisory authority exists in Virginia.

Outlook

The open question for this module is whether the Bureau of Financial Institutions or the State Corporation Commission will issue guidance directly addressing the fiat-crypto licensing boundary now that Chapter 19.1 is in force, particularly for business models that sit close to the fiat/virtual-currency line, such as platforms offering limited fiat on-ramp functionality alongside predominantly crypto-native services.

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

Sources and findings (2)
  1. T2 · Nationwide Multistate Licensing SystemNationwide Multistate Licensing System — Virtual currency exchange and custody businesses operating in Virginia must obtain a money transmitter license under Virginia's general money-transmission licensing law, since Virginia has no separate crypto-asset licensing statute distinct from that regime.retrieved M4bindingin force
  2. T1 · FinCENFinCEN — Persons engaged as an 'exchanger' or 'administrator' of convertible virtual currency must register with FinCEN as a money services business under the Bank Secrecy Act, a federal registration obligation that applies regardless of Virginia's state licensing status.retrieved M4bindingin force

#

Virginia does not independently classify crypto-asset tokens; characterization is governed at the federal level. In March 2026, the SEC and CFTC jointly issued a Commission-level interpretive release adopting a five-category token taxonomy (digital commodities, digital collectibles, digital tools, stablecoins, digital securities), superseding the SEC's 2019 staff-level framework. The federal GENIUS Act separately confirms that permitted payment stablecoins are not securities.

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 · SEC EDGAR filerSEC EDGAR filer — On March 17, 2026, the SEC and CFTC jointly issued an interpretive release confirming bitcoin as a "digital commodity" under a new five-category token taxonomy (digital commodities, digital collectibles, digital tools, stablecoins, digital securities) and not a security under federal securities laws.retrieved M5non-binding
  2. T3 · SEC EDGAR filerSEC EDGAR filer — The federal GENIUS Act establishes that a compliant payment stablecoin issued by a permitted payment stablecoin issuer categorically will not be a security by operation of statute after the Act's effective date; other stablecoins may still meet the definition of security depending on facts and circumstances.retrieved M5bindingenacted not yet effective

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Virginia has not enacted activity-specific state rules for staking, DeFi lending, DEX operation, mining, node operation, validator activity, or tokenization. Such activities are assessed, if at all, under the general Virginia money-transmission framework (where custodial/transmission elements are present) or under overlapping federal securities/commodities and tax frameworks (e.g., the IRS's November 2025 staking safe harbor for grantor trusts).

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 · SEC EDGAR filerSEC EDGAR filer — Virginia has not adopted state-level rules addressing the licensing or characterization of crypto-asset staking; treatment instead flows from federal frameworks, including an IRS safe harbor (released November 10, 2025) for grantor trusts that stake digital assets.retrieved M3non-binding
  2. T2 · Nationwide Multistate Licensing SystemNationwide Multistate Licensing System — Virginia has not enacted, and no Virginia regulator has adopted, activity-specific rules for DeFi lending, DEX operation, mining, node operation, validator activity, or tokenization; these activities lack a dedicated state analog and are assessed only under general money-transmission and federal securities/commodities principles.retrieved M3non-bindinga fact about the regime

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The federal GENIUS Act (signed July 18, 2025) is the first comprehensive U.S. federal stablecoin statute, establishing issuance, reserve, redemption, disclosure, and supervisory requirements for payment stablecoins. As of the July 18, 2026 statutory rulemaking deadline, the OCC, Federal Reserve, FDIC, NCUA and Treasury had not finalized implementing regulations; the Act's substantive framework becomes effective on the earlier of January 18, 2027 or 120 days after final implementing rules issue. In the interim, stablecoins continue to be issued under pre-existing state money-transmitter licenses, including Virginia's, without dedicated federal oversight.

Standing sub-brief · as of 11 October 2026299 words · last cycle 2026-10-11

Stablecoin Regime

Virginia does not maintain a dedicated stablecoin-issuance regime addressing reserve backing, redemption rights or issuer-specific licensure for fiat-referenced tokens. The only touchpoint this cycle is indirect, arising from the general money-transmission statute rather than from stablecoin-specific legislation. Va. Code § 6.2-1922, part of the Chapter 19.1 modernisation that took effect 1 July 2026, defines money in a way that excludes virtual currency. Depending on how a particular stablecoin arrangement is structured, this definitional boundary could bear on whether a stablecoin issuer or transmitter's activity falls inside or outside the general Chapter 19.1 money-transmitter licensing perimeter, but no Virginia source retrieved this cycle addresses stablecoins as a distinct category separate from virtual currency generally.

no periodic updates on record for this sub-brief

Sources and findings (5)
  1. T4 · The BlockThe Block — The GENIUS Act permits only federally chartered banks, OCC-supervised nonbank issuers, and state-qualified issuers operating under a state regime certified as substantially similar to the federal framework to issue payment stablecoins.retrieved M5bindingenacted not yet effective
  2. T3 · CoinDeskCoinDesk — Pending finalization of GENIUS Act implementing rules, stablecoins continue to be issued in practice using pre-existing state money transmitter licenses, including in Virginia, without dedicated federal oversight.retrieved M4bindingin force
  3. T1 · Federal Reserve BoardFederal Reserve Board — The GENIUS Act limits permissible payment-stablecoin reserve assets to an itemized list of highly liquid instruments, including insured/uninsured deposits, short-term U.S. Treasury securities, and Federal Reserve account balances.retrieved M5bindingenacted not yet effective
  4. T4 · The BlockThe Block — The GENIUS Act mandates redemption rights, reserve segregation, and monthly disclosures for permitted payment stablecoin issuers as consumer-protection features of the federal framework.retrieved M4bindingenacted not yet effective
  5. T4 · The BlockThe Block — As of the July 18, 2026 statutory deadline, the OCC, Federal Reserve, FDIC, NCUA and Treasury had not issued final GENIUS Act implementing regulations covering reserves, licensing, customer identification and AML compliance; several proposals remained open for public comment.retrieved M4bindingproposed

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Virginia has no crypto-specific consumer-protection statute. General Virginia consumer-protection and money-transmitter bonding/net-worth requirements apply to licensed transmitters. Virginia has separately enacted HB 798 (signed 2026, effective July 1, 2026), amending the state's unclaimed-property statute so that dormant crypto assets held in customer accounts for five years are escheated to state custody in-kind rather than liquidated.

Standing sub-brief · as of 26 August 2026321 words · last cycle 2026-10-04

Consumer Protection

Chapter 22.2 builds a substantial consumer-protection framework around Virginia's new virtual-currency-kiosk licensing regime, though none of its protections are yet in force. The statute requires kiosk operators to display prominent warnings regarding fraud risk and the volatility of virtual currency at the point of transaction.

Transaction-level limits are specific and tiered by user tenure: new users face a 2,000-dollar daily limit, existing users a 5,000-dollar daily limit, and all users a combined 10,000-dollar monthly limit regardless of tenure. Per-transaction fees are capped at 18 percent.

Periodic update · new data 2026-09-28

Consumer Protection

Virginia's crypto-adjacent consumer protection runs through the same money-transmission statute governing licensure. Chapter 19.1 of Title 6.2 provides that permissible investments of a Virginia money-transmitter licensee, even where commingled with other assets of the licensee, are deemed held in trust for the benefit of the purchasers and holders of the licensee's outstanding money-transmission obligations, a protection confirmed directly on primary statutory text at Confirmed confidence. In practice, this creates an insolvency-remoteness safeguard: should a licensee holding customer funds for transmission become insolvent, the permissible investments backing those obligations are statutorily protected from being treated as general assets of the licensee available to its other creditors.

This protection is scoped specifically to the fiat leg of a licensee's money-transmission obligations, as Chapter 19.1 defines money-transmission obligations by reference to money, and virtual currency is expressly excluded from that definition. The consequence is that no equivalent crypto-specific custody-segregation rule exists under Virginia law for a licensee's pure virtual-currency holdings; a customer's crypto balance held by a Virginia-licensed MSB does not benefit from the same statutory trust protection that applies to the fiat-denominated transmission obligations of that same licensee. This is a material asymmetry for consumers of hybrid fiat-crypto platforms operating under Virginia licensure, worth surfacing distinctly rather than assuming the statutory trust protection extends uniformly across a licensee's full balance-sheet exposure to customers.

Outlook

Whether Virginia extends an equivalent custody-segregation protection to virtual-currency holdings specifically, either through future legislation or Bureau of Financial Institutions rulemaking, is the open question for this module; no such extension was identified in this cycle's research.

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

Sources and findings (2)
  1. T4 · The BlockThe Block — Under Virginia HB 798, signed into law and effective July 1, 2026, unclaimed crypto assets in customer accounts that remain dormant for five years must be transferred to state custody in-kind, meaning the tokens are transferred in their original form rather than liquidated or converted to cash.retrieved M3bindingenacted not yet effective
  2. T2 · Nationwide Multistate Licensing SystemNationwide Multistate Licensing System — No Virginia-specific suitability or appropriateness standard for crypto-asset sales to retail consumers has been independently verified in this research pass.retrieved M2non-bindingour coverage gap, expected to resolve on a re-run

#

Federal tax treatment of virtual currency as property (IRS Notice 2014-21) underlies U.S. taxation of crypto transactions, including in Virginia. Beginning tax year 2025, crypto brokers must issue Form 1099-DA reporting gross proceeds to the IRS, with cost-basis reporting phased in from tax year 2026, materially increasing automated compliance visibility. Virginia's own conformity treatment of crypto-asset gains under state income tax has not been independently verified in this research pass.

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 — For U.S. federal tax purposes, virtual currency is treated as property, and general tax principles applicable to property transactions govern crypto transactions, meaning gains or losses realized are generally characterized as capital gain or loss where the asset is a capital asset in the taxpayer's hands.retrieved M4bindingin force
  2. T4 · The BlockThe Block — Crypto exchanges operating as brokers were required to issue Form 1099-DA reporting gross proceeds to the IRS and taxpayers for the 2025 tax year, with cost-basis reporting for covered digital assets phased in beginning tax year 2026.retrieved M4bindingin force
  3. T1 · CFTC LabCFTCCFTC LabCFTC — Virginia's specific state-income-tax conformity treatment of federally characterized crypto-asset gains has not been independently verified against a Virginia Department of Taxation primary source in this research pass.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run

#

Virginia imposes no independent state-level restriction on outbound or cross-border crypto transfers beyond federal frameworks. Federal OFAC sanctions screening obligations and FinCEN's Funds Travel Rule (extended to convertible virtual currency transmittals) apply uniformly, and a joint Treasury/FinCEN/OFAC proposed rule (April 2026) would extend AML and sanctions compliance-program obligations specifically to permitted payment stablecoin issuers under the GENIUS Act.

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 · FinCENFinCEN — Where convertible virtual currency transactions constitute a "transmittal of funds" under FinCEN's regulations, the host or money transmitter must comply with the Funds Travel Rule, applying irrespective of whether the transfer crosses a U.S. state or international border.retrieved M4bindingin force
  2. T1 · FinCENFinCEN — Treasury's FinCEN and OFAC issued a joint proposed rule in April 2026 to implement the GENIUS Act's anti-money-laundering and sanctions-compliance-program requirements for permitted payment stablecoin issuers, an obligation that would apply to any qualifying Virginia-based issuer.retrieved M4bindingproposed
  3. T2 · Nationwide Multistate Licensing SystemNationwide Multistate Licensing System — No Virginia-specific outbound restriction on crypto-asset transfers beyond the applicable federal sanctions and travel-rule frameworks has been identified; Virginia has no independent cross-border crypto transfer regime.retrieved M2non-bindinga fact about the regime
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Editorial metadata for Virginia, USA
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