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Hawaii, USA
US-HIschema crypto-v2.0.0trajectory: not yet assessedin transitionoverlaps: FIM, WPM
Last updated · 8 categories · 19 sourced
findings · 23 sources in the cumulative register
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Jurisdiction lead brief
Lead Signal
Hawaii's crypto-licensing posture is defined by an unusual combination: a state regulator determination exempting standalone digital-currency trading and transmission activity from the state's Money Transmitters Act, sitting alongside a 2026 legislative proposal that would reintroduce state oversight through a new chartering framework. The Hawaii Division of Financial Institutions determined, effective July 1, 2024, that digital-currency activity no longer requires a state money-transmitter license, following the conclusion of the Digital Currency Innovation Lab. SB2757, the Digital Asset Charters bill, would establish a new chartering regime for digital-asset businesses in Hawaii and finds, in its own legislative text, that the digital-asset industry is largely unregulated in the United States. Firms conducting both USD money transmission and digital-currency activity are not covered by the exemption for their USD-denominated activity, which still requires a Hawaii money-transmitter license.
Other Developments
Federal stablecoin rulemaking advances on two fronts. FinCEN has proposed a stand-alone Bank Secrecy Act framework for Permitted Payment Stablecoin Issuers in a new Part 1033 of 31 CFR chapter X, implementing the AML/CFT and sanctions provisions of the GENIUS Act. Separately, the FDIC has proposed a prudential regulatory framework for FDIC-supervised stablecoin issuers under the same Act. Neither has a Hawaii state-level analog; both apply to Hawaii-based issuers purely through the federal layer.
Consumer guidance flags volatility and the absence of state oversight. The Hawaii Department of Commerce and Consumer Affairs publishes consumer-facing guidance warning that digital-currency values are volatile and unregulated at the state level. This guidance is advisory only and creates no binding obligation.
Cross-Monitor Connections
The crypto money-transmission exemption and SB2757 proposal are shared findings with the financial-integrity monitor, which reads the same facts through an AML supervisory-perimeter lens, and the world-payments monitor, which reads them through a licensing and market-access lens. The federal GENIUS Act stablecoin rulemaking recurs across all three monitors as well.
Outlook
SB2757's progress through the remainder of the 2026 session is the clearest marker of whether Hawaii's crypto-licensing gap closes or persists. On the federal stablecoin track, both the FinCEN AML/sanctions NPRM and the FDIC prudential proposal are moving through their respective rulemaking processes and would apply to Hawaii-based issuers once finalized, independent of the state legislative outcome.
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Hawaii has no bespoke crypto-asset licensing statute. Crypto exchange, custody and transmission businesses fall under the state's general Money Transmitters Act (HRS Chapter 489D), administered by the Division of Financial Institutions (DFI) within the Department of Commerce and Consumer Affairs (DCCA). From 2017-2022 DFI imposed a 'double-reserve' condition on crypto-licensees (fiat reserves equal to customer crypto holdings) that drove several exchanges, including Coinbase, out of the state. A 2020-2022 'Digital Currency Innovation Lab' sandbox let selected firms operate without an MTL, waiving the double-reserve rule; the sandbox concluded June 30, 2022, after which firms could operate as unregulated businesses subject only to federal requirements. Coinbase resumed Hawaii service in August 2024 citing DCCA/DFI regulatory clarifications, but the precise current statutory basis (i.e., whether HRS 489D-8's reserve mandate was formally amended) was not independently verified against primary statute text in this pass.
Standing sub-brief152 words · last cycle 2026-08-21
Crypto Licensing
Hawaii's Money Transmitters Modernization Act, as interpreted by the Hawaii Division of Financial Institutions, exempts digital currency and digital-asset trading and transmission activity from the state's money transmitter licensing requirement, effective July 1, 2024, following conclusion of the Digital Currency Innovation Lab. This is a regulator determination rather than a statutory amendment. Hawaii's 2026 legislature is separately considering SB2757, which proposes a new chartering framework, Digital Asset Charters, for digital-asset businesses; the bill has not been enacted. A firm conducting both USD money transmission and digital-currency activity must still hold a Hawaii money-transmitter license for the USD-denominated activity, since the exemption applies only to standalone crypto activity, not to mixed-activity firms.
Outlook
SB2757's disposition this session is the key marker: enactment would reintroduce a formal state licensing pathway for digital-asset businesses, while continued reliance on the regulator determination would leave Hawaii's crypto-licensing posture exposed to reversal by a future redetermination.
No new data since the standing brief. 1 periodic run re-emitted it unchanged.
Sources and findings (5)
T4 · CoinDeskCoinDesk — Hawaii requires a company to obtain a state money transmitter license if it provides financial instruments for sale or transaction with Hawaii residents, even if the business has no physical presence in the state.retrieved M5bindingin force
T4 · CoinDeskCoinDesk — Between 2017 and 2022, DFI required licensed crypto money transmitters to hold fiat reserves equal to the value of virtual currency held for customers (the 'double-reserve' requirement), which caused Coinbase and other exchanges to exit Hawaii.retrieved M3non-binding
T4 · The BlockThe Block — Hawaii's 'Digital Currency Innovation Lab' sandbox (2020-2022), run jointly by DCCA/DFI and the Hawaii Technology Development Corporation, allowed selected digital currency issuers to operate without a state money transmitter license and waived the double-reserve requirement for participants.retrieved M3non-binding
T4 · The BlockThe Block — Following the sandbox's conclusion on June 30, 2022, crypto companies could continue operating in Hawaii as an unregulated business without a state MTL, provided they adhere to federal licensing and regulatory requirements.retrieved M4bindingin force
T4 · The BlockThe Block — In August 2024, Coinbase resumed offering crypto services in Hawaii, stating this followed regulatory changes made by DCCA's Division of Financial Institutions that provided clarity for cryptocurrency firms.retrieved M3non-binding
Hawaii has no state-level statute characterizing tokens as securities, e-money, asset-referenced tokens, or utility tokens. Per the seed disambiguation, token characterization for securities/commodities purposes is governed by federal SEC/CFTC jurisdiction, currently in flux pending the federal CLARITY Act (passed House, advanced by Senate Banking Committee, not yet law as of mid-2026), which would grant the CFTC jurisdiction over digital-commodity spot markets while SEC retains jurisdiction over investment-contract assets.
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 — Hawaii defers token characterization (security vs. commodity vs. other) to federal SEC/CFTC jurisdiction; the state's general money-transmitter law addresses money-transmission/custody activity, not securities status.retrieved M4bindingin forcea fact about the regime
T4 · The BlockThe Block — The federal CLARITY Act, which would grant the CFTC exclusive jurisdiction over digital-commodity spot markets while preserving SEC jurisdiction over investment-contract assets, passed the House in 2025 but had not become law as of the most recent reporting found.retrieved M3non-binding
No Hawaii statute or DFI rule specifically addresses staking, DeFi lending, DEX operation, mining, node operation, validator activity, or tokenization. The general Money Transmitters Act may reach custodial or transmission-like activity conducted by intermediaries, but decentralized/non-custodial on-chain activity has no identified state-specific treatment.
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 (1)
T4 · The BlockThe Block — Hawaii has not enacted any bespoke statute or regulation governing on-chain activities such as staking, DeFi lending, DEX trading, mining, node operation, or tokenization; these activities fall outside the scope of the general money-transmitter licensing law absent a custodial/transmission nexus.retrieved M2non-bindinga fact about the regime
Hawaii has no state-specific stablecoin statute. The controlling framework is the federal GENIUS Act, signed into law July 18, 2025, which establishes issuance authorization, 1:1 high-quality-liquid-reserve backing, par redemption, and monthly disclosure requirements for 'permitted' payment stablecoin issuers, with state-qualified issuer pathways available if a state regime is certified 'substantially similar.' As of this research pass, GENIUS Act implementing regulations (OCC, FDIC, NCUA, Federal Reserve, Treasury) remain proposals; agencies missed the statute's July 18, 2026 one-year rulemaking deadline, and the law's operative provisions take effect on the earlier of 120 days after final rules or January 18, 2027. Hawaii has not published a state-qualified stablecoin certification framework in the sources reviewed.
Standing sub-brief118 words · last cycle 2026-08-21
Stablecoin Regime
No Hawaii state-level stablecoin regime exists. Federal rulemaking under the GENIUS Act governs the space instead: FinCEN has proposed a stand-alone Bank Secrecy Act framework for Permitted Payment Stablecoin Issuers in a new Part 1033 of 31 CFR chapter X, and the FDIC has separately proposed a prudential regulatory framework for FDIC-supervised stablecoin issuers under the same Act. Both proposals apply to any Hawaii-based stablecoin issuer purely through the federal layer, with no Hawaii-specific supplement or variance identified this cycle.
Outlook
Both federal proposals are in the proposed-rule stage; finalization of either would set the operative compliance baseline for Hawaii-based stablecoin issuers, since no state framework exists to layer on top of or diverge from it.
No new data since the standing brief. 1 periodic run re-emitted it unchanged.
Sources and findings (4)
T4 · The BlockThe Block — The federal GENIUS Act, signed July 18, 2025, establishes the first comprehensive U.S. framework for payment stablecoins, setting issuance-authorization, reserve, redemption, and disclosure requirements; Hawaii has no separate state stablecoin statute and would rely on this federal regime plus its general MTL law for any state-qualified issuers.retrieved M5bindingenacted not yet effective
T4 · The BlockThe Block — Under the GENIUS Act, permitted payment stablecoin issuers must back every stablecoin one-to-one in high-quality liquid reserves (cash, insured deposits, short-term Treasurys) and publish monthly reserve disclosures.retrieved M5bindingenacted not yet effective
T4 · The BlockThe Block — Permitted issuers under the GENIUS Act must support redemption of payment stablecoins at par on demand.retrieved M4bindingenacted not yet effective
T4 · The BlockThe Block — As of the one-year anniversary of enactment, the principal GENIUS Act rule packages from OCC, FDIC, NCUA and Treasury remained proposals rather than final rules, meaning the statute's July 18, 2026 rulemaking deadline was missed without automatically extending the law's effective date.retrieved M4bindingin force
Hawaii's consumer-protection posture toward crypto has been shaped primarily through money-transmitter licensing conditions rather than a dedicated crypto consumer-protection statute. DFI historically required licensees trading, transmitting, or custodying crypto to meet financial-statement requirements and treat crypto value as not a 'permissible investment.' Separate legislative proposals (e.g., a 2020 bill enabling bank custody of digital assets, and 2018 bills requiring consumer volatility warnings) were identified in secondary reporting, but their final enactment status was not confirmed against primary legislative records in this 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)
T4 · CoinDeskCoinDesk — DFI historically required applicants that trade, transmit, or custody crypto in Hawaii to meet financial-statement requirements and treat crypto value as not a 'permissible investment' for reserve-calculation purposes.retrieved M3non-binding
T4 · CoinDeskCoinDesk — A 2020 Hawaii Senate bill (SB2594) proposed authorizing Hawaii banks to custody digital securities, virtual currencies, and other digital consumer assets for customers, with statutory ambiguities to be resolved in favor of customers, though it did not resolve the separate double-reserve issue; final enactment status was not confirmed.retrieved M2non-bindingour coverage gap, expected to resolve on a re-run
T4 · CoinDeskCoinDesk — 2018 Hawaii Senate bills (SB2853/SB3082) proposed requiring virtual-currency money transmitters to issue a consumer warning about volatility and lack of government backing prior to enabling transactions; enactment status was not confirmed from available sources.retrieved M2non-bindingour coverage gap, expected to resolve on a re-run
No Hawaii Department of Taxation (DOTAX)-specific statute, form, or published guidance addressing digital-asset taxation was located in this research pass. In the absence of a dedicated state pronouncement, the working assumption is that Hawaii's income tax base, which generally follows federal adjusted gross income, would incorporate the IRS's treatment of virtual currency as property (generating capital gain/loss or ordinary income on disposition), but this specific state-level conformity was not independently verified against a DOTAX 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 (1)
T4 · CoinDeskCoinDesk — The IRS treats virtual currency as property rather than currency for federal tax purposes, meaning dispositions of crypto assets generate a capital gain or loss based on cost basis; absent a Hawaii-specific carve-out, this federal characterization is presumed to flow through to the state's income tax base.retrieved M3bindingin force
Hawaii imposes no identified state-level outbound restriction on crypto-asset transfers. Cross-border movement of virtual currency by Hawaii-licensed or Hawaii-based money-transmission businesses is governed by federal frameworks: FinCEN's Bank Secrecy Act money-transmitter/MSB regime and OFAC sanctions screening, rather than any Hawaii-specific cross-border statute.
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 — Hawaii does not impose any identified state-level outbound restriction on crypto-asset transfers; cross-border movement of virtual currency is governed by federal frameworks rather than a Hawaii-specific statute.retrieved M3bindingin force
T1 · FinCENFinCEN — Hawaii money-transmitter licensees conducting cross-border virtual-currency transmission are subject to federal OFAC sanctions screening and FinCEN BSA/MSB registration and recordkeeping obligations irrespective of state MTL status.retrieved M3bindingin force
AML/CFT obligations for Hawaii-licensed money transmitters (including crypto businesses) derive from the federal Bank Secrecy Act framework administered by FinCEN (MSB registration, BSA program, CTR/SAR filing, recordkeeping) rather than a Hawaii-specific AML statute. Per the crypto consumer's subscription to the fleet's aml_ctf Financial Integrity Module (FIM), substantive AML/CFT claims are tracked there rather than in this crypto baseline; the entry below is disambiguation context only.
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 (1)
T1 · FinCENFinCEN — Hawaii money transmitters engaged in convertible-virtual-currency administration or exchange are money transmitters under FinCEN's BSA regulations and must register as an MSB and maintain an AML program; this substantive AML/CFT content is governed under the fleet's separate aml_ctf FIM rather than this crypto baseline.retrieved M2non-bindinga fact about the regime
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