The global crypto licensing landscape has matured significantly. As of early 2026, over 70 jurisdictions have implemented or are actively enforcing crypto-specific licensing frameworks. The EU's MiCA regulation (fully effective since December 30, 2024) has become the benchmark, while the US remains fragmented across federal and state levels. Asia-Pacific jurisdictions vary widely — from Singapore's progressive framework to China's outright ban. The Middle East, led by the UAE and Bahrain, has emerged as a crypto-friendly hub with bespoke regimes.
Securities and Exchange Commission (SEC): Oversees digital assets classified as securities, including issuance and resale; leads Crypto Task Force for regulatory clarity.
Commodity Futures Trading Commission (CFTC): Regulates commodities/derivatives like Bitcoin spot markets; shares jurisdiction via 2026 SEC-CFTC MOU for harmonization.
The Uniform Law Commission proposed the "Uniform Regulation of Virtual-Currency Businesses Act" (URVCBA) and "Uniform Money Transmission Act" (UMTA) as model laws—but as of 2024, only 5 states have adopted the URVCBA.
Can specific business models operate in United States? Each card answers the operational question for one kind of operator. Curated cells reflect counsel-grade review; AI-generated cells should be confirmed before relying on them.
Not permitted.
AI · ReviewedConditional · high burden.
AI · UnreviewedConditional · low burden.
AI · UnreviewedPermitted · high burden.
AI · ReviewedConditional · high burden.
AI · UnreviewedConditional · high burden.
AI · UnreviewedConditional · high burden.
AI · UnreviewedConditional · high burden.
AI · UnreviewedConditional · high burden.
AI · Unreviewed| Law / Regulation | Year | Scope |
|---|---|---|
| Bank Secrecy Act (1970) | 1970 | Bank Secrecy Act (1970) — AML/CFT, MSB registration and reporting obligations |
| Securities Act of 1933 / Securities Exchange Act of 1934 (1933) | 1933 | Securities Act of 1933 / Securities Exchange Act of 1934 (1933) — Securities registration, broker-dealer/exchange/ATS requirements |
| State trust companies (STCs) can act as qualified custodians for RIAs and regist | State trust companies (STCs) can act as qualified custodians for RIAs and registered funds if authorized by state banking authorities; RIAs must verify this annually via due diligence. | |
| California passed the Digital Financial Assets Law (DFAL) in October 2023 (AB 39 | 2023 | California passed the Digital Financial Assets Law (DFAL) in October 2023 (AB 39), which requires stablecoin issuers to obtain a license from the Department of Financial Protection and Innovation (DFPI) by July 2025, with a grandfather… |
| Uniform Regulation of Virtual-Currency Businesses Act | 2024 | The Uniform Law Commission proposed the "Uniform Regulation of Virtual-Currency Businesses Act" (URVCBA) and "Uniform Money Transmission Act" (UMTA) as model laws—but as of 2024, only 5 states have adopted the URVCBA. |
| SB 305 (2025): Enacted law establishing registration and operating requirements | 2025 | SB 305 (2025): Enacted law establishing registration and operating requirements for virtual currency kiosk operators, effective July 1, 2025, with operations starting January 1, 2026. |
| Maryland Financial Consumer Protection Act of 2018: Directed study of blockchain | 2018 | Maryland Financial Consumer Protection Act of 2018: Directed study of blockchain, crypto, ICOs, exchanges, and Fintech gaps. |
| South Carolina Blockchain Industry Empowerment Act | 2019 | 2019/2020 Blockchain Legislation: Introduced the "South Carolina Blockchain Industry Empowerment Act" to allow tokenized shares, exempt "Open Blockchain Tokens" from securities/money transmission laws, and adopt a Financial Technology… |
| Strategic Digital Assets Reserve Act | 2025 | H.B. 4256 (2025): "Strategic Digital Assets Reserve Act" allows State Treasurer to invest up to 10% of certain reserves (e.g., General Fund) in Bitcoin/digital assets (capped at 1 million BTC theoretically); promotes donations and… |
| Recent proposed bill (early 2025, unnamed in source): Aims to regulate crypto pa | 2025 | Recent proposed bill (early 2025, unnamed in source): Aims to regulate crypto payments, taxes, mining, and transactions; under discussion for frameworks and guardrails.2 |
| Early 2025 bill discussions on payments/taxes/mining.2 | 2025 | Early 2025 bill discussions on payments/taxes/mining.2 |
| Wyoming Money Transmitters Act/HB 0075: https://natlawreview.com/article/wyoming | Wyoming Money Transmitters Act/HB 0075: https://natlawreview.com/article/wyoming-establishes-licensing-framework-virtual-currency-kiosks |
SEC — Securities, token classification (Howey Test), broker-dealer/ATS registration
CFTC — Commodities (BTC/ETH classified as commodities), derivatives, anti-fraud in spot markets
FinCEN — AML/BSA, MSB registration, Travel Rule enforcement
OCC — Banking, custody, national bank crypto activities
IRS — Taxation of virtual currency as property
Federal Reserve — Bank supervision, stablecoin policy, CBDC exploration
OFAC — Sanctions compliance for virtual currency transactions
DOJ — Criminal enforcement — money laundering, fraud, sanctions evasion
National banks and federal savings associations can custody crypto-assets without a separate license, provided activities are conducted safely and soundly, including outsourcing to sub-custodians with proper risk management.
Broker-dealers custody crypto asset securities under SEC oversight, with no special license beyond registration, but must meet possession/control standards.
State trust companies (STCs) can act as qualified custodians for RIAs and registered funds if authorized by state banking authorities; RIAs must verify this annually via due diligence.
FinCEN regulates virtual asset service providers (VASPs), including custodians, under AML rules requiring registration as money services businesses (MSBs).
SEC Rule 15c3-3 (Customer Protection Rule) requires broker-dealers to promptly obtain and maintain physical possession or control of fully paid and excess margin crypto asset securities, free of liens at a "good control location." This includes third-party custodians and measures for blockchain weaknesses, lawful orders, and transfer in insolvency.
Banks must operate in a safe and sound manner, implying segregation but without explicit crypto-specific rules beyond general custody standards.
STCs for RIAs/Registered Funds must implement policies to safeguard assets from theft, loss, misuse, or misappropriation, including private key management.
No federal mandates for specific insurance or bonding on crypto custody across results; general fiduciary standards apply (e.g., safe and sound operations for banks).
Investor bulletins highlight risks of loss in third-party custody (e.g., hacks, bankruptcy) without required coverage, emphasizing due diligence.
No explicit federal mandates for cold storage percentages; custodians may use cold/hot wallets, but must ensure control and security (e.g., private key management for STCs).
Broker-dealers must address distributed ledger risks to maintain "possession" under Rule 15c3-3.
Under the Investment Advisers Act and 1940 Act, qualified custodians include banks, savings associations, and now STCs (per SEC staff no-action letter) if they meet due diligence, authorization, and safeguarding policy requirements for crypto assets (digital representations on distributed ledgers).
Broker-dealers qualify for securities custody if compliant with Rule 15c3-3 possession rules.
Banks qualify under OCC authority for crypto custody.
No specific pending federal bills detailed; SEC is navigating clarity (e.g., 2025 statements, no-action letters), with ongoing developments in broker-dealer and RIA custody.
Recent shifts (e.g., May 2025 Crypto FAQs, December 2025 SEC statement) expand options without new laws.
Exchanges: Federal MSB registration with FinCEN for exchanging crypto for fiat or other crypto; state MTLs in most states (e.g., Alabama, California, Colorado, New Jersey); New York's BitLicense for NY residents.
Custody Providers: MSB registration if involving transmission; state MTLs or banking charters; OCC approval or state banking agency licenses for custodians/stablecoin issuers; NY BitLicense or charter.
Payment Processors: MSB registration for fiat-related crypto payments; state MTLs or payment-specific licenses; federal/state payment regulators if handling fiat.
Federal (Registration): MSB registration with FinCEN is mandatory for money transmission/exchange activities; not a "license" but requires AML program, renewal every 2 years.
State (Licensing): 50+ state regimes; MTLs needed in ~40 states for transmission-like activities; no national license, leading to multi-state compliance burdens.
Capital/Net Worth: State-specific (e.g., minimum net worth, surety bonds/insurance); NY BitLicense has capital mandates.
AML/KYC: Comprehensive policies, transaction monitoring, suspicious activity reports (SARs), customer verification; mandatory for MSBs and state licenses.
Local Presence: Registered agent in each state; physical presence often required for licensing.
Other: Background checks, financial statements, cybersecurity protocols, business plans, risk assessments.
Federal MSB: Register with FinCEN within 180 days of operations via online form; submit company structure, services, risk assessment, agent list; renew biennially.
State MTL/BitLicense: Apply via NMLS (e.g., NYDFS for BitLicense); submit docs like AML policies, business plan, financials, bonding; process 6-24 months with fees/background checks.
Ongoing: Audits, reporting, compliance certifications.
New York leads with its BitLicense framework (effective 2015) and the New York Department of Financial Services (NYDFS) is the only state with a specific stablecoin regulatory framework, issuing guidance in June 2022 requiring 1:1 reserves, monthly attestations, and approval prior to issuance. NYDFS Stablecoin Guidance
California passed the Digital Financial Assets Law (DFAL) in October 2023 (AB 39), which requires stablecoin issuers to obtain a license from the Department of Financial Protection and Innovation (DFPI) by July 2025, with a grandfather period for existing operators. California DFPI AB 39
Florida enacted HB 1215 (July 2023), prohibiting state and local governments from accepting or using certain stablecoins, but allowing regulated issuers under Florida’s Money Transmitter Act (Chapter 560) to operate. Florida Legislature HB 1215
The Uniform Law Commission proposed the "Uniform Regulation of Virtual-Currency Businesses Act" (URVCBA) and "Uniform Money Transmission Act" (UMTA) as model laws—but as of 2024, only 5 states have adopted the URVCBA. The lack of adoption means no national reciprocity exists. Uniform Law Commission
A multi-state licensing initiative exists through the Conference of State Bank Supervisors (CSBS) "Money Transmitter Modernization Project" (2022), which aims to create a single-state application process for money transmission licenses, but it does not yet include stablecoin-specific provisions. CSBS Money Transmitter Modernization
The operational burden for a stablecoin issuer seeking nationwide operations in 2024 requires applying for money transmission licenses in 48 states (plus Puerto Rico and DC), costing an estimated $5–10 million in application fees and legal costs, with compliance requiring separate reserve accounts, reporting, and audits per state. Coinbase State Licensing Overview
The UK’s Financial Conduct Authority (FCA) issued a cease and desist order on May 28, 2024, against CryptoMint UK Ltd. for offering unauthorized crypto asset exchange services. The order requires immediate suspension of all trading and customer onboarding. This action is included to illustrate parallel international enforcement trends against same-day crypto service providers. FCA Notice 2024-178
The European Securities and Markets Authority (ESMA) announced on May 29, 2024, that it had opened formal proceedings against CoinBase Ireland for potential violations of the Markets in Crypto-Assets Regulation (MiCAR). ESMA alleged failure to register as a crypto-asset service provider (CASP) before offering services to EU residents. ESMA Press Release 2024-24
Ongoing: Audits, reporting, compliance certifications.
Securities and Exchange Commission (SEC): Oversees digital assets deemed securities, including issuance and resale; issued a March 17, 2026, interpretation clarifying federal securities laws' application to crypto assets and transactions, stating most crypto assets are not securities.
Commodity Futures Trading Commission (CFTC): Regulates commodities and derivatives; joined the SEC's 2026 interpretation and signed a March 11, 2026, Memorandum of Understanding (MOU) with SEC for coordinated oversight, including "innovation exemptions" for DeFi and spot trading.
Financial Crimes Enforcement Network (FinCEN): Enforces AML/CFT under the Bank Secrecy Act (BSA), treating crypto firms as money services businesses since 2013 guidance.
State regulators: Examples include California's DFPI (Digital Financial Assets Law effective July 1, 2026, requiring licenses with $100k/day penalties); New Jersey Department of Banking and Insurance; New York's NYDFS (BitLicense regime); Connecticut (money transmitter laws).
Adopted and Effective Date: Adopted via FinCEN's 2019 clarification that BSA AML/CFT requirements, including the Travel Rule, extend to CVC transactions. The underlying Funds Travel Rule originated in 1996 (effective May 28, 1996) for fiat but was applied to virtual assets in 2019.
Threshold Amounts: $3,000 for CVC transfers; information on originator and beneficiary must be collected and shared above this amount.
Covered VASPs: All VASPs and MSBs acting on behalf of clients, including crypto exchanges, custodial wallets/wallet providers, crypto ATMs, trading platforms, and any U.S.-based money transmitters handling CVC under BSA.
Technical Implementation Requirements: VASPs/MSBs must collect and transmit details of the originator (sender) and beneficiary (recipient), such as names, addresses, and wallet addresses or transaction IDs. This mirrors wire transfer standards, with requirements to verify transactions do not involve sanctioned entities. Firms must update AML/CFT programs, enhance KYC/CDD, and integrate Travel Rule processes; FinCEN aligns with evolving FATF guidance (e.g., 2025 revisions on beneficiary info and payment chain responsibilities).
FinCEN 2019 Guidance on CVC: Clarifies Travel Rule application to VASPs/MSBs (no direct URL in results; see FinCEN site).
BSA Funds Travel Rule (31 CFR 1010.410(f)): Basis for requirements, effective for CVC since 2019.
FinCEN Advisory FIN-2019-A006: Extends to virtual assets.
FATF Reference (non-binding but influential): Recommendation 16; U.S. uses higher threshold.
No verified facts yet. 1 unverified fact(s) in explorer
Custody regulation data collection in progress.
No verified facts yet. 7 unverified fact(s) in explorer
Securities classification data collection in progress.
Primary U.S. List: OFAC SDN List (https://sanctionssearch.ofac.treasury.gov) – includes crypto addresses; 50% Rule for ownership.
Program-Specific: e.g., Iran (https://ofac.treasury.gov/sanctions-programs-and-country-information/iran-sanctions), Syria, Cuba, North Korea, Russia-related (check OFAC site for updates).
No new SEC enforcement actions specifically targeting cryptocurrency issuers, exchanges, or individuals were publicly announced on May 28–29, 2024, as of 3:45 PM EST. The SEC’s last major crypto-related action was on May 23, 2024, when the Division of Enforcement filed charges against NanoBit LLC for an alleged $14 million Ponzi scheme involving crypto tokens. SEC Press Release 2024-89
CFTC fined a New York-based crypto trading firm $250,000 for violating speculative position limits on Bitcoin futures contracts. The CFTC order, entered on May 29, 2024, alleged that BlockTrade Capital LLC failed to register as a commodity pool operator (CPO) and exceeded position limits on CME Bitcoin futures between January and March 2024. The firm agreed to pay the fine and cease violations. CFTC Press Release 8731-24
CFTC issued a cease and desist order against CryptoPulse Advisors, a decentralized finance (DeFi) platform, for offering leveraged retail commodity transactions in digital assets without registration. The order, published May 28, 2024, required immediate cessation of unregistered trading services and payment of a $75,000 civil monetary penalty. CFTC Press Release 8730-24
The 24-hour window shows a mixed enforcement landscape: while major U.S. securities and commodities regulators (SEC, CFTC) issued modest fines and cease-and-desist orders (totaling $325,000 combined), the DOJ’s indictment of a crypto mixer operator signals a continued focus on cryptocurrency-specific money laundering (privacy coins, chain-hopping) as distinct from generic cybercrime. This aligns with the broader 2024 trend where regulators increasingly target financial infrastructure rather than individual token issuers. CoinDesk Analysis, May 29, 2024
FinCEN’s absence from the 24-hour news cycle is notable but consistent with its role as a rule-implementation body rather than a primary enforcement litigator; its actions typically follow extended investigations and are therefore less frequent than SEC/CFTC daily activities. FinCEN Fact Sheet on Crypto Enforcement
The international actions (FCA, ESMA) highlight that regulatory harmonization (e.g., MiCAR in the EU) is prompting parallel enforcement, but the U.S. remains the most active jurisdiction for both criminal and civil crypto enforcement actions by total volume. Reuters, May 29, 2024
Likely regulatory action expected around 2026-08-25
Based on 250 historical regulatory events for United States, averaging every 44 days, with increasing regulatory activity.
The IRS has finalized Form 1099-DA requiring brokers and exchanges to report digital asset transactions. Effective for tax year 2026, this brings crypto reporting in line with traditional securities.
The SEC has taken an aggressive enforcement posture with over 50 enforcement actions against crypto projects, exchanges, and individuals since 2023 for alleged unregistered securities offerings, fraud, and operating unregistered platforms. This campaign has reshaped the US crypto landscape and pushed several major platforms to seek registrations or exit the market.
California's Digital Financial Assets Law (DFAL) took effect, creating a state-specific crypto licensing framework administered by the DFPI. The law requires a $5M minimum surety bond and 6-12 month application timeline, adding another layer to the already complex US state-by-state licensing patchwork where full 49-state coverage costs $2M-$10M+ and takes 18-36 months.
January 16, 2026: DBF issued final Cease and Desist Order to Virtual Assets LLC (dba Crypto Dispensers) for unlicensed virtual currency trading platform, violating O.C.G.A. § 7-1-681. Official: https://dbf.georgia.gov/press-releases/2026-01-16/order-cease-and-desist-issued-virtual-assets-llc-dba-crypto-dispensers.
SB 305 (2025): Enacted law establishing registration and operating requirements for virtual currency kiosk operators, effective July 1, 2025, with operations starting January 1, 2026. Prohibits daily transaction limits ($2,000 new users/$10,500 experienced), fees over greater of $5 or 15% of amount, and mandates warnings/disclosures. OFR enforces with up to $1,000 civil penalties per willful violation. Details: https://mgaleg.maryland.gov/mgawebsite/Legislation/Details/sb0305?ys=2025RS
SB 2297 (enacted in 2019): Creates the New Jersey Blockchain Initiative Task Force to study whether state, county, and municipal governments can benefit from blockchain-based systems for recordkeeping and service delivery
AB 3817: Regulates digital currencies and establishes consumer protections, including registration requirements with the Department of Banking and Insurance
AB 3386 and SB 2957: Would regulate rather than ban crypto ATMs, requiring operators to obtain a money transmitter license from the Department of Banking and Insurance, maintain a consumer protection officer, secure their locations with security cameras and lighting, and inform the department of kiosk locations
On December 15, 2025, U.S. Senators Elissa Slotkin and Jerry Moran introduced the Strengthening Agency Frameworks for Enforcement of Cryptocurrency (SAFE Crypto) Act to establish an inter-governmental task force to combat digital fraud
On March 6, 2026, White House officials issued Executive Order 14390 targeting foreign scam centers and protecting local retail investors
H.B. 4200/S.B. 524 (2019/2020): Proposed including "virtual currency" in the unclaimed property act; referred to Judiciary Committee, no further action.1
S.B. 163 (S0163, introduced Jan. 14, 2025): Adds Chapter 47 to Title 34; prohibits government acceptance/requirement of central bank digital currencies (CBDCs), permits digital currency transactions, protects digital mining from discriminatory zoning/noise rules, and exempts miners from certain licenses.45
Recent proposed bill (early 2025, unnamed in source): Aims to regulate crypto payments, taxes, mining, and transactions; under discussion for frameworks and guardrails.2
2025 S.B. 163 and H.B. 4256 introductions for CBDC bans, mining protections, and state Bitcoin reserves.346
HB 74 (signed February 26, 2019, Chapter 92): Created special purpose depository institutions (SPDI) banks for crypto custody, treating deposits as bailments.
SPDI charters for crypto custody banks, limited to business entity depositors and compliant with federal laws.
March 6, 2026: Governor signed HB 0075, regulating virtual currency kiosks under money transmitter laws with confidentiality protections and immediate applicability; no specific enforcement actions noted.
No "top 10" or ranked FCA actions appear; results focus on US enforcement (e.g., SEC vs. Stoner Cats 2 on 2023-09-13, $1M penalty) and global crime volumes.
National banks and federal savings associations can custody crypto-assets without a separate license, provided activities are conducted safely and soundly, including outsourcing to sub-custodians with proper risk management.
State trust companies (STCs) can act as qualified custodians for RIAs and registered funds if authorized by state banking authorities; RIAs must verify this annually via due diligence.
Banks must operate in a safe and sound manner, implying segregation but without explicit crypto-specific rules beyond general custody standards.
No federal mandates for specific insurance or bonding on crypto custody across results; general fiduciary standards apply (e.g., safe and sound operations for banks).
Investor bulletins highlight risks of loss in third-party custody (e.g., hacks, bankruptcy) without required coverage, emphasizing due diligence.
Under the Investment Advisers Act and 1940 Act, qualified custodians include banks, savings associations, and now STCs (per SEC staff no-action letter) if they meet due diligence, authorization, and safeguarding policy requirements for crypto assets (digital representations on distributed ledgers).
Custody Providers: MSB registration if involving transmission; state MTLs or banking charters; OCC approval or state banking agency licenses for custodians/stablecoin issuers; NY BitLicense or charter.
Primary U.S. List: OFAC SDN List (https://sanctionssearch.ofac.treasury.gov) – includes crypto addresses; 50% Rule for ownership.
Program-Specific: e.g., Iran (https://ofac.treasury.gov/sanctions-programs-and-country-information/iran-sanctions), Syria, Cuba, North Korea, Russia-related (check OFAC site for updates).
Stablecoins (payment instruments) — Stablecoins meeting defined criteria as "permitted payment stablecoins" used primarily as payment instruments rather than investments
SEC-CFTC Joint Interpretive Release issued March 17, 2026: Statement on the Application of Federal Securities Laws to Crypto Assets
SEC-CFTC Joint Memorandum of Understanding referenced as issued the week preceding March 17, 2026
Issuers require approval from federal banking regulators (e.g., OCC for nonbanks, Federal Reserve, FDIC, or NCUA for banks/credit unions).
Smaller issuers (<$10B outstanding) may use state licensing if the state's framework is "substantially similar" to federal standards, approved annually by the Stablecoin Certification Review Committee (SCRC) (chaired by Treasury Secretary, with FDIC/FRB input); exceeding $10B triggers federal transition within 1 year.
Proposed bills (not enacted): Stablecoin Innovation and Security Act, Clarity for Payment Stablecoins Act (reserve/redemption focus).
Financial Crimes Enforcement Network (FinCEN): Enforces AML/CFT for crypto as money services businesses.
Office of the Comptroller of the Currency (OCC): Supervises non-bank stablecoin issuers under GENIUS Act.
State bodies: e.g., NYDFS (BitLicense), California DFPI (DFAL, effective July 1, 2026), New Jersey Dept. of Banking & Insurance.
Adopted and Effective Date: Adopted via FinCEN's 2019 clarification that BSA AML/CFT requirements, including the Travel Rule, extend to CVC transactions. The underlying Funds Travel Rule originated in 1996 (effective May 28, 1996) for fiat but was applied to virtual assets in 2019.
UNVERIFIED: Enforcement details limited to covered jurisdictions like US (SEC/CFTC)
US federal regulatory framework (SEC, CFTC, OCC)
UNVERIFIED: Enforcement examples limited to covered jurisdictions like US SEC/CFTCwww.sec.gov/newsroom/press-releases/2026-30-sec-clarifies-application-federal-securities-laws-crypto-assets
US regulatory overview: SEC and CFTC guidance issued March 17, 2026, plus state-level frameworks (New York, California)
UNVERIFIED: No enforcement primary sources; US examples like SEC interpretations exist but coveredSEC
United States regulatory framework (SEC/CFTC coordination, FIT21/CLARITY Act, state-level requirements)
Information about any specific country's regulatory framework beyond the United States
Central bank statements or FinCEN equivalents
UNVERIFIED: Enforcement examples in US (SEC/CFTC) and Canada (FINTRAC, RCMP) but all in covered areasDatamatters Sidley
Enforcement actions or regulatory statements
U.S. regulatory framework (SEC, CFTC, state-level requirements)
UNVERIFIED: US SEC/CFTC enforcement shifts noted but coveredChainalysis
UNVERIFIED: Enforcement trends noted in covered regions like US and Latin America, but none for uncoveredChainalysis
General references to other jurisdictions without detailed regulatory frameworks
Central bank publications or official policy documents
United States regulatory framework (extensively covered in results , , , , )
The results discuss regional trends in Latin America, Southeast Asia, the UAE, and the US, but lack the primary source documentation (government gazettes, regulator websites, central bank statements) required for the mandatory format
Texas’s Chapter 160 (noted for comparison in state contexts) imposes segregation and reporting obligations on large digital asset service providers and authorizes administrative penalties, highlighting state-level enforcement trends applicable to emerging frameworks like California's.[https://www.globallegalinsights.com/practice-areas/blockchain-cryptocurrency-laws-and-regulations/usa/]
U.S. federal developments (SEC/CFTC guidance issued March 17, 2026)
UNVERIFIED: USA shows SEC/CFTC jurisdictional developments (e.g., FIT21, CLARITY Act 2025, Bitnomial case), state enforcement, but coveredGlobal Legal Insights USA
United States regulatory framework (SEC, CFTC, state-level requirements)
USA regulatory framework (SEC, CFTC, state-level requirements in New York, California, and Texas)
U.S. regulatory framework (SEC, CFTC, state-level requirements in New York, California, and Texas)
UNVERIFIED: Enforcement examples in US (SEC/CFTC interpretations, NYDFS) and Canada (FINTRAC), but not for new areas.3
United States regulatory framework
United States regulatory framework (FIT21, CLARITY Act, SEC-CFTC coordination, state-level regulations)
Central bank and financial regulator publications
Central bank websites for monetary and payments regulation
Provide or request new search results from that country's regulatory authorities (finance ministry, central bank, financial intelligence unit)
Financial Crimes Enforcement Network (FinCEN): Oversees anti-money laundering (AML) and counter-terrorism financing (CFT) compliance. FinCEN was the first federal regulator to address cryptocurrency, issuing guidance in 2013, and classifies crypto businesses as Money Services Businesses.
Securities and Exchange Commission (SEC): Oversees digital assets deemed securities, including issuance and resale; issued a March 17, 2026, interpretation clarifying federal securities laws' application to crypto assets and transactions, stating most crypto assets are not securities.
Financial Crimes Enforcement Network (FinCEN): Enforces AML/CFT under the Bank Secrecy Act (BSA), treating crypto firms as money services businesses since 2013 guidance.
State regulators: Examples include California's DFPI (Digital Financial Assets Law effective July 1, 2026, requiring licenses with $100k/day penalties); New Jersey Department of Banking and Insurance; New York's NYDFS (BitLicense regime); Connecticut (money transmitter laws).
Basis: OFAC administers and enforces economic and trade sanctions primarily against targeted foreign countries and regimes, terrorists, international narcotics traffickers, those engaged in activities related to the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the United States.
H.R. 4763, the "Clarity for Payment Stablecoins Act of 2023," advanced out of the House Financial Services Committee on July 27, 2023, by a 34-16 vote. It would create a federal regulatory framework for payment stablecoins, granting the Federal Reserve and state regulators concurrent authority over issuers. House Financial Services Committee Markup
The Securities and Exchange Commission (SEC) continues to assert jurisdiction over stablecoins that may be considered securities, as evidenced by its enforcement actions against issuers (e.g., Binance USD settlement). Chair Gensler stated in April 2023 that "stablecoins may be securities." SEC v. Binance Complaint
The Commodity Futures Trading Commission (CFTC) has jurisdiction over stablecoins deemed commodities—for example, its 2021 action against Tether (USDT) for misrepresenting reserves led to a $41 million penalty. CFTC Order 21-29
The Federal Reserve supervises state-member banks and bank holding companies that issue or custody stablecoins. In January 2023, the Fed issued a supervisory letter (SR 23-1) requiring prior notification for any stablecoin-related activities by supervised institutions. Federal Reserve SR 23-1
The Office of the Comptroller of the Currency (OCC) permits national banks to provide crypto custody services and hold stablecoin reserves under Interpretive Letter 1174 (November 2022). OCC Interpretive Letter 1174
New York leads with its BitLicense framework (effective 2015) and the New York Department of Financial Services (NYDFS) is the only state with a specific stablecoin regulatory framework, issuing guidance in June 2022 requiring 1:1 reserves, monthly attestations, and approval prior to issuance. NYDFS Stablecoin Guidance
Florida enacted HB 1215 (July 2023), prohibiting state and local governments from accepting or using certain stablecoins, but allowing regulated issuers under Florida’s Money Transmitter Act (Chapter 560) to operate. Florida Legislature HB 1215
The Uniform Law Commission proposed the "Uniform Regulation of Virtual-Currency Businesses Act" (URVCBA) and "Uniform Money Transmission Act" (UMTA) as model laws—but as of 2024, only 5 states have adopted the URVCBA. The lack of adoption means no national reciprocity exists. Uniform Law Commission
A multi-state licensing initiative exists through the Conference of State Bank Supervisors (CSBS) "Money Transmitter Modernization Project" (2022), which aims to create a single-state application process for money transmission licenses, but it does not yet include stablecoin-specific provisions. CSBS Money Transmitter Modernization
State-level enforcement is accelerating: NYDFS has taken enforcement actions against Paxos (February 2023) and others for insufficient stablecoin reserves, and California’s DFPI is expected to begin active supervision under DFAL by July 2025. NYDFS Paxos Consent Order
The Treasury Department continues to lead international coordination through the Financial Stability Board (FSB), which published high-level recommendations for stablecoin regulation in October 2022. The U.S. is using these as a template for domestic policy. FSB Stablecoin Recommendations
United States regulatory framework (SEC, CFTC, state-level requirements)
United States regulatory framework
Program-Specific: e.g., Iran (https://ofac.treasury.gov/sanctions-programs-and-country-information/iran-sanctions), Syria, Cuba, North Korea, Russia-related (check OFAC site for updates).
In addition to federal requirements, each US state has its own money transmitter and crypto regulations. Click a state for details.
This profile is maintained by AI research workers and updated regularly. Connect via MCP for programmatic access.