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Delaware, USA
US-DEschema crypto-v2.0.0trajectory: not yet assessedin transitionoverlaps: FIM, WPM
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Delaware has no bespoke crypto-asset licensing statute. Virtual-currency exchange, custody and transmission businesses fall under Delaware's general money-transmitter licensing regime, administered by the Delaware Department of Banking/Financial Institutions via the multistate NMLS platform, because the state has not enacted a dedicated digital-asset licence distinct from money transmission. Two bills filed in March 2026 (SB19 'Delaware Payment Stablecoin Act' and SB16 'Delaware Banking Modernization Act of 2026'), plus an anticipated 'Delaware Money Transmission & Virtual Currency Modernization Act', would create a purpose-built licensing track for stablecoin issuers/digital-asset service providers and update the four-decade-old banking code, but none of these bills had been enacted as of dispatch date.
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)
T1 · Nationwide Multistate Licensing System (CSBS)Nationwide Multistate Licensing System (CSBS) — Businesses engaged in virtual-currency exchange, custody or transmission activity involving Delaware residents must hold a money-transmitter licence under Delaware's general money-transmission statute, processed through the Nationwide Multistate Licensing System (NMLS), because Delaware has not enacted a crypto-specific licensing law.retrieved M4bindingin force
T4 · The BlockThe Block — SB19 (Delaware Payment Stablecoin Act) and SB16 (Delaware Banking Modernization Act of 2026), filed March 2026 and assigned to the Senate Banking Committee, would create a dedicated licensing regime for payment-stablecoin issuers and digital-asset service providers and authorize state-chartered banks to hold digital assets fiduciarily, but neither bill has passed as of the dispatch date.retrieved M4non-binding
T4 · The BlockThe Block — A further bill, the Delaware Money Transmission & Virtual Currency Modernization Act, based on Conference of State Bank Supervisors model legislation, was described by lawmakers in March 2026 as scheduled for filing to replace the state's existing money-transmission law with a standardized, virtual-currency-aware licensing framework; it had not been filed or enacted as of dispatch date.retrieved M3non-binding
Delaware has no state-level token-classification taxonomy. Whether a given crypto-asset is a security, commodity, or other instrument is determined at the federal level (SEC/CFTC), not by Delaware statute, per the disambiguation directive for this JID. Federal developments materially shape the practical classification landscape: the GENIUS Act confirms payment stablecoins are not securities, and a March 2026 joint SEC/CFTC interpretive release classified bitcoin as a 'digital commodity' rather than a security.
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)
T1 · Nationwide Multistate Licensing System (CSBS)Nationwide Multistate Licensing System (CSBS) — Delaware has not enacted a state-level token taxonomy; classification of crypto-assets as securities, commodities, or other instruments for this JID is governed by federal SEC/CFTC jurisdiction rather than Delaware law.retrieved M3non-binding
T1 · U.S. Securities and Exchange CommissionU.S. Securities and Exchange Commission — The federal GENIUS Act, signed into law July 18, 2025, confirms that payment stablecoins are not securities, a federal classification overlay that applies regardless of Delaware's own (currently absent) token taxonomy.retrieved M4bindingenacted not yet effective
T3 · SEC EDGAR (issuer filing)SEC EDGAR (issuer filing) — On March 17, 2026, the SEC and CFTC jointly issued a Commission-level interpretive release confirming bitcoin as a 'digital commodity' under a five-category federal token taxonomy and not a security, though the release is interpretive (not APA rulemaking) and not binding on courts or future administrations.retrieved M3non-binding
Delaware has no dedicated statute addressing on-chain activities such as staking, DeFi lending, DEX operation, mining, node operation/validation, or tokenization. Absent state-specific carve-outs, the only applicable baseline for mining/self-directed activity is the federal FinCEN 'user' exemption framework, under which a person mining virtual currency solely for their own purposes is not a money transmitter. Staking, DeFi lending, DEX, node operation/validator activity and tokenization have no confirmed Delaware-specific or directly-applicable federal licensing treatment identified 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 (2)
T1 · FinCENFinCEN — Under federal FinCEN guidance (applicable absent a Delaware-specific rule), a person who mines virtual currency solely for their own purposes and not for the benefit of another is not a money transmitter and is not subject to MSB registration, reporting or recordkeeping obligations.retrieved M3bindingin force
T1 · Nationwide Multistate Licensing System (CSBS)Nationwide Multistate Licensing System (CSBS) — No Delaware-specific or confirmed federal licensing/registration requirement addressing staking activity by Delaware residents or entities was identified in this research pass.retrieved M2non-bindingour coverage gap, expected to resolve on a re-run
Stablecoin regulation for this JID is currently driven almost entirely at the federal level. The GENIUS Act (signed July 18, 2025) is the first comprehensive federal payment-stablecoin statute, establishing issuance authorization pathways (OCC/Fed/FDIC/NCUA for federal issuers; certified 'substantially similar' state regimes for state-qualified issuers), reserve, redemption and disclosure requirements — but implementing regulations remain proposals as of mid-2026, and the agencies missed the Act's own July 18, 2026 rulemaking deadline. At the state level, Delaware's SB19 (pending, not enacted) would create a parallel state licensing regime for payment-stablecoin issuers and digital-asset service providers, adopting GENIUS Act definitions and layering reserve, capital, redemption-timing, AML and data-privacy requirements, with a federal-to-state charter conversion pathway.
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 (4)
T4 · The BlockThe Block — The GENIUS Act establishes a federal authorization framework for payment-stablecoin issuers, with federally chartered bank issuers supervised by the OCC, Federal Reserve, or FDIC, nonbank issuers opting into the federal framework supervised by the OCC, and state-qualified issuers supervised by their state regulator if the state regime is certified 'substantially similar' to the federal one.retrieved M5bindingenacted not yet effective
T4 · The BlockThe Block — As of the one-year statutory deadline (July 18, 2026), the OCC, FDIC, NCUA and Treasury had not finalized their GENIUS Act implementing regulations, which remain proposals; Treasury's 'substantially similar' state-regime certification standard is also still unfinished, leaving state-federal jurisdictional questions unresolved.retrieved M4non-binding
T4 · The BlockThe Block — Delaware's pending SB19 (Delaware Payment Stablecoin Act) would adopt GENIUS Act definitions and impose reserve requirements, mandatory redemption-timing standards, capital requirements, AML obligations and data-privacy provisions on payment-stablecoin issuers and digital-asset service providers operating with or on behalf of Delaware residents, plus a federal-to-state charter conversion pathway; the bill was not enacted as of dispatch date.retrieved M4non-binding
T1 · Nationwide Multistate Licensing System (CSBS)Nationwide Multistate Licensing System (CSBS) — No systemic-designation mechanism specific to stablecoins was identified for Delaware; this category remains federally determined and unresearched at the state level for this JID.retrieved M2non-bindingour coverage gap, expected to resolve on a re-run
Delaware has no crypto-specific consumer-protection statute. General money-transmitter licensee obligations (bonding, financial-responsibility, examination) apply by extension to virtual-currency businesses licensed under the general MTL regime. SB16 (pending) would, for the first time since 1981, update Delaware's banking code to authorize state-chartered banks and trust companies to hold and administer digital assets in a fiduciary capacity — implicitly introducing custody/segregation standards for digital assets that are not currently codified.
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)
T4 · The BlockThe Block — Delaware's pending SB16 (Delaware Banking Modernization Act of 2026) would amend Title 5 of the Delaware Code to define 'digital asset' and 'virtual currency', clarify that 'personal property' under the state's fiduciary statutes includes digital assets, and authorize state-chartered banks and trust companies to hold and administer digital assets in a fiduciary capacity — a custody/segregation standard not currently codified for digital assets under Delaware's banking code, unchanged since 1981.retrieved M4non-binding
T1 · Nationwide Multistate Licensing System (CSBS)Nationwide Multistate Licensing System (CSBS) — General Delaware money-transmitter licensee obligations (financial responsibility, bonding, examination) are presumed to apply to virtual-currency money transmitters by extension of the general statute, pending confirmation of specific statutory text and pending the anticipated Delaware Money Transmission & Virtual Currency Modernization Act.retrieved M3bindingin force
No Delaware Division of Revenue guidance specific to virtual-currency tax treatment was identified in this research pass. Federal IRS treatment (crypto-assets as property, taxable gain/loss on disposition, a November 2025 grantor-trust staking safe harbor, and phased-in broker 1099 reporting effective for 2025/2026 transactions) forms the presumed baseline that Delaware's state income tax, which generally conforms to federal adjusted gross income, would inherit, but this state-level conformity was not independently confirmed by a Delaware-specific primary source.
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)
T4 · CoinDeskCoinDesk — Under current federal IRS guidance, digital assets are treated as property; the IRS has stated each sale or disposition of a digital asset (e.g., by a bitcoin trust) constitutes a taxable event giving rise to gain or loss, a treatment Delaware's state income tax is presumed to inherit via federal AGI conformity, though this state-level linkage was not independently confirmed.retrieved M4bindingin force
T4 · CoinDeskCoinDesk — Federal Treasury/IRS broker-reporting rules for digital-asset transactions took effect for transactions beginning in 2025, with cost-basis tracking required starting 2026; stablecoin sales are subject to aggregated (rather than per-transaction) reporting and NFTs carry a $600 annual reporting threshold.retrieved M3bindingin force
T1 · Nationwide Multistate Licensing System (CSBS)Nationwide Multistate Licensing System (CSBS) — No Delaware Division of Revenue guidance specifically addressing income-tax treatment of virtual-currency transactions (e.g., mining income, staking rewards, or airdrops) was located in this research pass.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run
Delaware has no state-specific cross-border crypto-transfer restriction. The applicable baseline is the federal FinCEN Funds Travel Rule and OFAC sanctions-screening regime, which apply uniformly to Delaware-licensed money transmitters (including virtual-currency businesses) regardless of state licensing status, per the seed's disambiguation that federal AML/sanctions rules govern independently of state MTL licensing.
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)
T1 · FinCENFinCEN — FinCEN's Funds Travel Rule (31 CFR 1010.410(f)) applies to money transmitters, including virtual-currency businesses, for qualifying transmittals of funds, including cross-border convertible-virtual-currency transfers; this federal baseline applies to Delaware-licensed transmitters absent any state-specific carve-out.retrieved M4bindingin force
T1 · Nationwide Multistate Licensing System (CSBS)Nationwide Multistate Licensing System (CSBS) — Delaware has not enacted any state-level outbound restriction on cross-border crypto transfers distinct from the federal BSA/OFAC baseline.retrieved M2non-binding
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