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Washington has no bespoke crypto-asset statute. Crypto exchanges, custodians, and especially cryptocurrency kiosk ('Bitcoin ATM') operators are licensed and supervised as money transmitters under the general Uniform Money Services Act (RCW 19.230 / WAC 208-690) by DFI. DFI's multi-state consent order against Coinme, Inc. (Oct 7-8, 2026; $2.5m penalty, nationwide crypto-kiosk shutdown by Jan 1 2027, independent BSA/AML program review) and a parallel Statement of Charges against Bitcoin Depot Operating LLC are the material developments this cycle.
Outlook
The underlying licensing statute and its bonding structure are stable and unlikely to change absent new legislative action. The principal open item is verificational rather than substantive: the primary text of RCW 19.230 as amended by SB 5031 has still not been independently retrieved from the Washington Legislature's own statute portal, with several bonding and disclosure claims still resting on secondary CoinDesk reporting from 2017 pending direct statutory confirmation in a future pass.
Crypto Licensing
Washington's crypto-kiosk licensing enforcement activity intensified materially this cycle. The Department of Financial Institutions entered a multi-state consent order (C-25-4009-26-CO02) against Coinme, Inc. on 7-8 October 2026, coordinated with 34 other state regulators, following charges that the firm's conduct, including alleged misappropriation of more than $8 million owed to customers, violated the Uniform Money Services Act. The order imposes a $2.5 million penalty-and-cost package, requires Coinme to cease crypto-kiosk operations in Washington by 1 January 2027, and mandates engagement of an independent consultant to evaluate the firm's BSA/AML program and implement corrective measures.
This enforcement action sits atop an unchanged statutory licensing perimeter. RCW 19.230.010(18) defines money transmission broadly to include receiving money or its equivalent value, expressly including virtual currency, and RCW 19.230.030 requires a licence for any person conducting that business for Washington residents, with no deemed-approval provision available to a firm awaiting licensure. These provisions were not amended this cycle; the Coinme action proceeds under the existing framework rather than any new statutory basis. Separately, standing prudential requirements continue to apply to virtual-currency licensees: WAC 208-690 sets a minimum tangible net worth of $100,000 for companies providing virtual-currency storage, and RCW 19.230.200(1)(b) requires a money-transmitter licensee transmitting virtual currencies to hold like-kind virtual currencies of the same volume as that obligated to consumers. Neither provision changed this cycle, but both remain the backdrop against which Coinme's alleged conduct, claiming customer funds as its own income, is read as a direct breach of the like-kind holding obligation specifically.
A second, unresolved enforcement matter compounds the sector's licensing picture: a Statement of Charges against Bitcoin Depot Operating LLC and its chief executive, entered 8 June 2026 under the same statute, remains pending in DFI's enforcement register. The charges have not been independently detailed beyond their register listing this cycle, but their continued presence alongside the now-settled Coinme matter indicates that Washington's licensing-enforcement programme for crypto-kiosk money transmitters extends to more than one major brand, and that this period's enforcement activity should be read as a sustained supervisory programme targeting a specific licensee sub-class rather than a single-firm episode.
The remedial structure imposed on Coinme, requiring an independent consultant to evaluate its BSA/AML program before implementing corrective measures, is a governance-level remedy uncommon at the state money-transmitter enforcement level; its presence signals that DFI judged the underlying compliance deficiencies serious enough to require external verification rather than accepting the firm's own self-certified remediation.
Outlook
The key date to track is 1 January 2027, the deadline by which Coinme must complete its Washington crypto-kiosk wind-down. Whether the independent BSA/AML consultant's findings, once the evaluation is commissioned, surface further compliance gaps is the next concrete development to watch. The unresolved Bitcoin Depot Statement of Charges is the second licensing-enforcement thread; its eventual disposition, whether through a comparable consent order or a different remedy, will clarify whether DFI's current enforcement template is becoming standard for the crypto-kiosk licensee class as a whole.
4 earlier distinct update(s)
Crypto Licensing
Washington regulates crypto-asset exchange, custody, and kiosk operation as money transmission under the Uniform Money Services Act (RCW 19.230), with no separate crypto-specific licensing statute. Registration under RCW 19.230 is required before offering money transmission services, including virtual-currency transmission, in the state, and licensees must maintain tangible net worth and a surety bond calibrated to transaction volume under RCW 19.230.050, with reported ranges running from ten thousand dollars at the low end to several million dollars in net worth and up to five hundred fifty thousand dollars in surety bond coverage at the upper end. The Washington State Department of Financial Institutions is the supervisory authority administering this regime.
The defining development this cycle is a 34-regulator multi-state consent order entered against Coinme, Inc. on 7 October 2026, in which DFI acted as one of seven lead agencies. The order requires Coinme to cease all crypto-kiosk operations nationwide before 1 January 2027, undergo an independent review of its Bank Secrecy Act and anti-money-laundering program, replace compliance-responsible managers, and pay a $2.5 million penalty distributed across the settling agencies. The action demonstrates that Washington's generic money-transmission statute, rather than leaving crypto kiosks in an under-supervised gap, is being actively and materially enforced against them, placing the module's trajectory on an escalating footing even though no new statute or rule took effect this cycle.
Outlook
The 1 January 2027 nationwide kiosk-shutdown deadline is the near-term marker for whether this consent order produces a durable exit from the kiosk business model. Independent verification of the required BSA/AML compliance review and management replacement will be the next evidenced milestone. Whether Washington moves beyond enforcement under the general statute toward a crypto-specific amendment to RCW 19.230 or implementing WAC 208-690 provisions remains unverified this cycle, and no legislative activity toward that end has been evidenced.
Crypto Licensing
Washington has no bespoke crypto-licensing statute. Instead, the Washington State Department of Financial Institutions regulates virtual-currency businesses exclusively through the Uniform Money Services Act (RCW 19.230, implementing rule WAC 208-690), which has treated persons receiving money or virtual currency for transmission to another location as money transmitters requiring a licence since 2017. This general money-transmission framework is now being actively and increasingly enforced against digital-asset businesses specifically. In February 2026, DFI entered a consent order against an unnamed digital-assets-focused money transmitter, requiring cease-and-desist from UMSA violations, surrender of the licence within 90 days, a $150,000 penalty (with $50,000 stayed to 2029), a $4,170 investigation fee, and a three-year industry bar. This action is corroborated by law-firm-blog syndication reporting on a primary DFI order, though the underlying document was not independently retrieved this cycle.
A second, larger action followed in September 2026: DFI filed a Statement of Charges against crypto-kiosk operator CoinFlip (GPD Holdings LLC), seeking licence cancellation, an industry bar, customer refunds and a civil penalty of $1,029,600. The stated basis was elevated fraud risk in cash-to-crypto kiosks disproportionately used by customers aged 60 and older, a demographic the regulator identified as being targeted in crypto-ATM scams. This action is currently reported only through trade-press coverage of a pending regulatory filing, and its outcome, whether by settlement, contested hearing, or default, remains unknown.
Taken together, these two actions within roughly seven months signal that Washington's supervisory attention to the crypto-money-transmission segment is intensifying even without any change to the underlying statute. The licensing pathway itself remains clear and unchanged; what has changed is the intensity with which DFI is exercising its existing authority against operators it judges to be non-compliant.
Outlook
The resolution of the CoinFlip Statement of Charges will be the clearest near-term signal of how aggressively DFI intends to pursue this theory against other kiosk operators. Absent a change to the underlying UMSA framework, licensing risk for crypto businesses in Washington is best understood as an enforcement-intensity risk rather than a framework risk.
Crypto Licensing
Washington requires a Money Transmitter Licence under RCW 19.230, applied for through the Nationwide Multistate Licensing System, covering virtual-currency exchange, custody, and money-transmission activity. This is a general (non-crypto-bespoke) licensing regime: Washington has no separate crypto-specific licence category, and virtual currency is captured within the existing statutory framework as a form of money-transmission activity subject to the same conditions applied to fiat-currency money transmitters. This core requirement carries Confirmed confidence, is treated as in force, and is unchanged this cycle.
This cycle's material development is enforcement rather than legislative or rule change. Washington's DFI entered a consent order requiring a digital-assets-focused money transmitter to surrender its licence within 90 days, citing UMSA violations across net-worth requirements, recordkeeping accuracy, and regulatory filing timeliness. This finding is held at Probable confidence, reflecting reliance on T3 press and legal-alert sourcing without independent retrieval of the underlying DFI order text; the named entity's identity was not disclosed in sources retrieved this cycle. The action demonstrates that DFI is willing to actively enforce the general UMSA licensing regime against digital-asset-specific business models with the same rigor applied to traditional money-services businesses, using licence revocation as the enforcement mechanism of consequence.
A related but analytically distinct finding: Washington has no state-specific token-classification statute, and token-as-security-or-commodity status is determined at the federal level by the SEC and CFTC rather than by DFI. This absence of a state-specific classification regime is itself the finding, held at Probable confidence, and it means that DFI's licensing enforcement authority under UMSA operates independently of, and does not resolve, federal token-classification questions that might separately affect a crypto business's regulatory exposure.
Outlook
Continued DFI enforcement against further crypto-facing money transmitters in coming cycles would strengthen the case that Washington's general licensing regime is being applied as an active, ongoing supervisory tool against crypto business models specifically, rather than reflecting an isolated enforcement action. Resolution of the named-entity gap in the February 2026 consent order, through independent retrieval of the underlying DFI order text, would materially improve confidence in this finding.
Crypto Licensing
Washington regulates virtual-currency money transmission through the same Uniform Money Services Act framework (RCW 19.230, WAC 208-690) applied to conventional money transmitters, supervised by the Washington Department of Financial Institutions; this licensing requirement is confirmed at high confidence from a Tier-1 DFI source and is unchanged in structure this cycle. Supervisory activity against a licensee within that framework intensified in February 2026, when the DFI entered a consent order requiring a digital-assets-focused money transmitter to surrender its licence within ninety days for UMSA violations including net-worth and reporting failures; this finding is sourced to a Tier-3 secondary account, with the primary DFI order document not independently retrieved this cycle. The module's traffic light is amber: the regime is settled and licence is required, but the February 2026 enforcement action signals heightened supervisory scrutiny of crypto-sector money-services businesses within that established framework.
Outlook
The item to watch is whether the affected licensee completes its licence surrender within the ninety-day window without further contested proceedings, and whether a primary Washington DFI document becomes available in a future cycle to corroborate this cycle's sole secondary source. A second enforcement instance against another digital-asset money transmitter operating under Washington's Uniform Money Services Act framework would indicate a broader supervisory campaign rather than an isolated action.
Sources and findings (5)
- T3 · CoinDeskCoinDesk — Virtual currency businesses engaged in money transmission in Washington must obtain a license from the Washington State Department of Financial Institutions under the money transmitter laws as extended to virtual currency by Senate Bill 5031.retrieved M5bindingin force
- T3 · CoinDeskCoinDesk — Virtual currency licensees that store virtual currency on behalf of customers must provide a third-party security audit of their data systems as part of the licensing process.retrieved M4bindingin force
- T3 · CoinDeskCoinDesk — Licensed money transmitters, including virtual currency operators, must post a surety bond of between $10,000 and $550,000 (increasable to $1 million in exceptional cases), calculated on the transmitter's dollar volume for the prior year, with no alternative security option permitted.retrieved M4bindingin force
- T3 · CoinDeskCoinDesk — Currency exchangers dealing in virtual currency must separately post a surety bond of between $10,000 and $50,000, based on the dollar volume of currency exchanged in the prior year.retrieved M3bindingin force
- T3 · CoinDeskCoinDesk — Washington does not maintain a bespoke crypto-asset licensing statute distinct from its general money-transmitter law; the same Uniform Money Services Act licensing standards apply to virtual currency businesses as to traditional fiat money transmitters, with 'virtual currency' defined as a digital representation of value used as a medium of exchange, unit of account, or store of value lacking legal tender status.retrieved M3non-binding