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Kansas, USA
US-KSschema crypto-v2.0.0trajectory: not yet assessedin transitionoverlaps: FIM, WPM
Last updated · 8 categories · 20 sourced
findings · 24 sources in the cumulative register
8Categoriesbaseline.
20Findings.claims[]
9Tier-1 sourcesrun_metadata.t1_source_count
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Jurisdiction lead brief
Lead Signal
Kansas has newly and explicitly deemed virtual currency kiosk operation, marketing, or facilitation to be money transmission requiring licensure under the Kansas Money Transmission Act, through House Bill 2591, effective 1 July 2026. Any person who owns, operates, solicits, markets, advertises, or facilitates a kiosk in the state must now hold a licence, with a 60-day cure window for currently unlicensed operators running from the effective date. This is corroborated directly by the enrolled Kansas Register text and by the Kansas Office of the State Bank Commissioner's own implementation guidance, giving the finding high confidence. The development is a targeted, sectoral hardening move rather than a comprehensive overhaul of Kansas's crypto-regulatory posture: the state's broader statutory definition of virtual currency remains undifferentiated by token type, and no separate on-chain-activity, stablecoin, or tax-treatment regime accompanies the kiosk-specific change.
Other Developments
Consumer-protection provisions attach to the same statute. Kiosk operators must disclose, on screen and before a transaction completes, that virtual currency is not government-backed, is volatile, and that transactions may be irreversible. Fees are capped at the greater of five dollars or eighteen percent of the transaction amount, with a one-thousand-dollar cap on an initial transaction. These are explicit, new consumer-protection provisions directly on point for the crypto-ATM fraud vector, a previously under-regulated area of Kansas's virtual-currency landscape, and they take effect on the same 1 July 2026 timeline as the licensing extension.
Cross-border transfer exposure by extension. Kansas imposes no state-specific cross-border virtual-currency transfer restriction of its own; such matters continue to run through the federal Bank Secrecy Act framework. The practical effect of the new kiosk-licensing requirement, however, is to pull a previously unlicensed cash-in and cash-out channel under that federal BSA framework by extension of the new state money-transmitter licensure, a tightening that operates indirectly rather than through any direct cross-border rule change.
Cross-Monitor Connections
The same House Bill 2591 kiosk-licensing statute is tracked by the Financial Integrity monitor as an AML/CFT perimeter-extension question, closing a channel that had previously sat outside licensed money-transmission oversight, and by the World Payments monitor as a market-access and consumer-protection question under its own licensing, conduct, and consumer-protection modules. This monitor's own reading is confined to the crypto-specific licensing, consumer-protection, and cross-border-transfer dimensions of the identical underlying statute. No overlap with the advennt gambling-regulatory monitor was identified this cycle.
Outlook
The date to watch is 1 July 2026, when the licensing requirement, the consumer-protection disclosure and fee-cap provisions, and the practical extension of federal BSA obligations to the kiosk channel all take effect together. The central open question is how many kiosk operators currently active in Kansas are not already licensed as money transmitters and will need to use the 60-day cure window, and whether the Kansas Office of the State Bank Commissioner issues further guidance narrowing the statutory scope of facilitating a kiosk for licensing purposes. Separately, Kansas's token-classification, on-chain-activity, and tax-treatment regimes remain unaddressed at the state level, and a previously noted state bill on a Bitcoin and Digital Assets Reserve Fund had not been confirmed beyond committee referral as of this cycle.
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Kansas has no bespoke crypto-asset licensing statute. Crypto exchange, custody and transmission businesses fall, in principle, under the state's general Money Transmitter Act, administered by the Kansas Office of the State Bank Commissioner (OSBC) via the NMLS multistate licensing infrastructure. However, the OSBC has historically taken the interpretive position (circa mid-2010s, referenced in later SEC filings) that bitcoin does not constitute 'money' and that mere transmission of bitcoin does not itself trigger MTL licensure -- a position whose current validity has not been independently re-confirmed against present-day OSBC guidance. Separately, all administrators/exchangers of convertible virtual currency remain subject to federal FinCEN money-services-business (MSB) registration regardless of state licensing outcome. Token characterisation for securities purposes is governed by federal SEC/CFTC jurisdiction, not Kansas-specific rules.
Standing sub-brief242 words · last cycle 2026-09-21
Crypto Licensing
Kansas has newly and explicitly deemed virtual currency kiosk operation, marketing, or facilitation to be money transmission requiring licensure under the Kansas Money Transmission Act, through House Bill 2591, effective 1 July 2026. Any person who owns, operates, solicits, markets, advertises, or facilitates a kiosk in Kansas must now hold a licence, with unlicensed operators as of the effective date given a 60-day window to apply. Kiosk operators are separately required to submit quarterly location reports to the Office of the State Bank Commissioner within 45 days of each calendar quarter's end, giving the regulator a standing visibility mechanism over the kiosk population that did not previously exist. This is an extension of the pre-existing, broader Kansas Money Transmission Act licensing perimeter to a specific, previously unlicensed kiosk channel; general crypto-exchange and custody activity continues to be governed by that same broader statutory definition, which itself remains undifferentiated by token type. The finding is corroborated by the enrolled Kansas Register text and the OSBC's own implementation guidance, both confirming the 1 July 2026 effective date and the licensing mechanism.
Outlook
The 60-day cure window running from 1 July 2026 is the near-term compliance milestone. Watch for how many currently unlicensed Kansas kiosk operators use the window to apply, and whether the OSBC issues further guidance on the statutory scope of facilitating a kiosk. Kansas's broader crypto-licensing posture, undifferentiated token classification and no separate on-chain-activity regime, remains otherwise unchanged this cycle.
Periodic update · new data 2026-09-22
Crypto Licensing
Kansas's crypto-licensing regime tightened materially this cycle with the entry into force of 2026 HB 2591, the Virtual Currency Kiosk Consumer Protection Act, on July 1, 2026. The statute amends the Kansas Money Transmission Act (K.S.A. 9-508 et seq.) so that any person owning, operating, soliciting, marketing, advertising, or facilitating virtual-currency kiosks in Kansas is deemed to be engaged in money transmission and must obtain licensure from the Kansas Office of the State Bank Commissioner. The Kansas Register's enrolled text is explicit that the new section is part of and supplemental to the Kansas Money Transmission Act, confirming this as a binding statutory amendment rather than mere guidance.
This licensing tightening is narrow in scope rather than comprehensive. It applies specifically to the kiosk product category, meaning unattended physical machines that facilitate virtual-currency transactions. Outside that category, the OSBC's standing 2014 interpretive guidance continues to apply: an entity engaged solely in the transmission of decentralized cryptocurrency, with no fiat leg, is not required to obtain a license in Kansas, since the KMTA does not apply to transmission of decentralized cryptocurrencies alone. Kansas Legislative Research Department materials corroborate that Kansas statute does not consider cryptocurrency money, so the exchange of one cryptocurrency for another does not itself count as money transmission.
The resulting picture is a jurisdiction with two coexisting rules for what is functionally similar underlying activity: a newly-licensed, closely-supervised kiosk channel, and a still-exempt peer-to-peer decentralized-transmission channel. Kansas-licensed money transmitters, including now-licensed kiosk operators, are also generally expected to register with FinCEN as money services businesses and to maintain a BSA/AML compliance program, layering a federal obligation on top of the new state licensing duty.
Outlook
Whether the new licensure requirement has yet produced any actual OSBC-issued kiosk-operator licences remains unestablished this cycle. That question, together with whether the OSBC will revisit its 2014 decentralized-cryptocurrency exemption in light of the kiosk carve-out, are the two clearest markers to watch for whether Kansas's split licensing structure holds or converges toward a broader crypto-transmission perimeter.
1 further periodic run re-emitted the standing brief unchanged and is not shown.
Sources and findings (3)
T1 · FinCENFinCEN — An administrator or exchanger of convertible virtual currency that accepts and transmits, or buys or sells, convertible virtual currency is a money transmitter under federal FinCEN regulations and must register as a money services business unless an exemption applies.retrieved M4bindingin force
T3 · U.S. Securities and Exchange Commission (EDGAR filer disclosure)U.S. Securities and Exchange Commission (EDGAR filer disclosure) — The Kansas Office of the State Bank Commissioner has historically found that bitcoin does not constitute money, and that mere transmission of bitcoin does not constitute money transmission requiring state licensure.retrieved M4non-bindingour coverage gap, expected to resolve on a re-run
T2 · Conference of State Bank Supervisors (CSBS)Conference of State Bank Supervisors (CSBS) — Money transmission businesses operating in Kansas, including those transmitting value on behalf of customers, are generally required to hold a Kansas money transmitter license administered through the NMLS multistate system unless a specific state-recognized exemption applies.retrieved M3bindingin force
Token characterisation in Kansas follows federal SEC/CFTC frameworks; there is no Kansas-specific token taxonomy. The SEC has moved through 2025-2026 to formalize a Howey-test-anchored taxonomy distinguishing security tokens from digital commodities, collectibles, digital tools and payment stablecoins, while reiterating that tokenized securities remain securities. The GENIUS Act (federal, 2025) separately confirms that qualifying 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 (3)
T1 · U.S. Securities and Exchange CommissionU.S. Securities and Exchange Commission — Crypto assets that meet the prongs of the Howey investment-contract test are securities under federal law and fall within SEC oversight, while most crypto assets are not themselves securities absent an accompanying investment contract.retrieved M5bindingin force
T1 · U.S. Securities and Exchange CommissionU.S. Securities and Exchange Commission — The SEC anticipates establishing a formal token taxonomy anchored in the Howey test to delineate categories such as network tokens, digital tools, digital collectibles and tokenized securities, with this taxonomy still under active development as of late 2025.retrieved M3non-binding
T1 · U.S. Securities and Exchange Commission (Commissioner Peirce)U.S. Securities and Exchange Commission (Commissioner Peirce) — The GENIUS Act confirms that qualifying payment stablecoins are not securities under federal law.retrieved M4bindingenacted not yet effective
No Kansas-specific regulation of mining, staking, node operation, validator activity, DeFi/dex participation or tokenization was identified. Activity in this space is governed exclusively by evolving federal SEC/CFTC staff positions, which have moved toward treating certain proof-of-work mining and protocol staking as generally administrative/ministerial and therefore outside Howey's 'efforts of others' prong, though these remain non-binding staff statements rather than codified rules.
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 · U.S. Securities and Exchange CommissionU.S. Securities and Exchange Commission — SEC staff have issued a statement addressing certain proof-of-work mining activities, informing the analysis of whether such activities involve securities transactions under Howey.retrieved M2non-binding
T1 · U.S. Securities and Exchange CommissionU.S. Securities and Exchange Commission — SEC Division of Corporation Finance has issued a statement on certain protocol staking activities, informing whether custodial and non-custodial staking arrangements involve the offer or sale of investment contract securities under Howey.retrieved M2non-binding
T2 · Conference of State Bank Supervisors (CSBS)Conference of State Bank Supervisors (CSBS) — No Kansas state-level or Kansas-specific federal on-chain regulation of DeFi lending, DEX operation, node operation or tokenization activity was identified in this research pass.retrieved M2non-bindinga fact about the regime
Kansas has no state-level stablecoin statute. The controlling framework is federal: the GENIUS Act (signed July 18, 2025) establishes the first comprehensive U.S. federal payment-stablecoin regime, restricting issuance to permitted issuers, mandating 1:1 high-quality liquid reserves, par redemption, and monthly disclosure. As of the research date, implementing rules from the OCC, FDIC, Federal Reserve, NCUA and Treasury remain proposals; the statutory one-year rulemaking deadline (July 18, 2026) was missed, and operative provisions take effect on the earlier of 120 days after final implementing regulations or January 18, 2027.
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 (5)
T1 · Federal Reserve BoardFederal Reserve Board — Under the GENIUS Act, only permitted entities -- federally chartered bank subsidiaries, OCC-supervised nonbank issuers, and state-qualified issuers operating under a certified 'substantially similar' state regime -- may issue payment stablecoins to U.S. customers.retrieved M4bindingenacted not yet effective
T1 · Federal Reserve BoardFederal Reserve Board — Permitted payment stablecoin issuers under the GENIUS Act must back every stablecoin one-to-one with high-quality liquid reserves such as insured deposits, short-term U.S. Treasury securities, and Federal Reserve balances.retrieved M5bindingenacted not yet effective
T4 · The BlockThe Block — Permitted payment stablecoin issuers must support redemption of stablecoins at par on demand, with implementing proposals specifying redemption generally within two business days.retrieved M4bindingenacted not yet effective
T1 · Federal Reserve BoardFederal Reserve Board — GENIUS Act permitted issuers must publish monthly reserve composition disclosures, with issuers exceeding $50 billion in outstanding issuance also required to publish audited annual financials under GAAP.retrieved M3bindingenacted not yet effective
T4 · The BlockThe Block — As of the research date, federal regulators (OCC, FDIC, NCUA, Federal Reserve, Treasury) had missed the GENIUS Act's one-year statutory deadline for finalizing implementing regulations, leaving final systemic and prudential standards unsettled.retrieved M3non-binding
Kansas has no crypto-specific consumer-protection statute. The Kansas Office of the Securities Commissioner issued a public investor warning in January 2018 flagging risks in cryptocurrency and ICO investments, including fraud red flags, but this is a general risk-disclosure advisory rather than a binding rule creating custody, suitability, or marketing-restriction obligations specific to crypto.
Standing sub-brief146 words · last cycle 2026-09-21
Consumer Protection
House Bill 2591's Virtual Currency Kiosk Consumer Protection Act imposes mandatory point-of-transaction disclosures on kiosk operators: an on-screen warning, requiring customer acknowledgment, that virtual currency is not government-backed, is volatile, and that completed transactions may be irreversible. The statute additionally caps fees on kiosk transactions at the greater of five dollars or eighteen percent of the transaction amount, with a further one-thousand-dollar cap on an initial transaction. These are new, explicit consumer-protection provisions squarely addressing the crypto-ATM fraud vector, an area that had previously lacked kiosk-specific regulation in Kansas, and they take effect on the same 1 July 2026 timeline as the licensing extension.
Outlook
Watch for whether the fee caps, transaction caps, and mandatory disclosures measurably affect kiosk-related fraud reporting once they take effect on 1 July 2026, though no baseline Kansas kiosk-fraud-loss data was evidenced this cycle against which to measure change.
Periodic update · new data 2026-09-22
Consumer Protection
Kansas introduced its first crypto-specific consumer-protection regime this cycle through 2026 HB 2591, the Virtual Currency Kiosk Consumer Protection Act, which took effect July 1, 2026 as part of the Kansas Money Transmission Act. The Act establishes refund rights for kiosk users and a defined, limited carve-out permitting operators to delay a required refund. Specifically, kiosk operators may delay a required refund under reasonable suspicion of fraud only if that suspicion is immediately reported to the Commissioner, the Attorney General, or law enforcement, and the delay may last only until that reporting agency concludes its investigation. This is a confirmed, binding provision, sourced directly from the Kansas Register enrolled bill text, and it represents a genuinely new consumer safeguard rather than an extension of an existing one, since Kansas previously had no crypto-specific consumer-protection statute at all.
The new regime is explicitly scoped to the kiosk product category that HB 2591 also newly licenses, meaning the consumer-protection obligations and the licensing obligations arrived in the same statutory vehicle and apply to the same population of regulated entities. This pairing is significant: Kansas is not merely requiring kiosk operators to register, it is simultaneously constraining how those operators may treat consumer funds once registered, closing what had been an unregulated space for physical crypto-cash conversion machines.
Outlook
The near-term marker to watch is enforcement practice: whether the Commissioner, Attorney General, or law enforcement receive and process any fraud-suspicion reports under the new refund-delay carve-out, and whether the consumer-protection regime is extended by future legislation beyond the kiosk category to other crypto-facing consumer touchpoints in Kansas.
1 further periodic run re-emitted the standing brief unchanged and is not shown.
Sources and findings (1)
T1 · Kansas Office of the Securities CommissionerKansas Office of the Securities Commissioner — The Kansas Office of the Securities Commissioner issued a public statement warning that investments in cryptocurrencies, including ICOs and crypto futures contracts, are not government-insured and carry substantial investment risk.retrieved M2non-binding
Kansas has no distinct state-level published guidance on digital-asset taxation identified in this pass; state income tax treatment of crypto gains presumably follows federal adjusted gross income conformity but this has not been independently verified against Kansas Department of Revenue guidance. At the federal level, the IRS treats digital assets as property (not currency), making sales and exchanges taxable events subject to capital gains treatment, and has introduced Form 1099-DA broker reporting for the 2025 tax year onward, with the first forms due by February 17, 2026.
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)
T3 · U.S. Securities and Exchange Commission (EDGAR filer disclosure)U.S. Securities and Exchange Commission (EDGAR filer disclosure) — Current IRS guidance treats digital assets such as bitcoin as property for federal tax purposes, meaning sales and exchanges are taxable events generally subject to capital gains treatment.retrieved M4bindingin force
T4 · CoinDeskCoinDesk — Crypto brokers such as exchanges are required to issue Form 1099-DA reporting gross proceeds from digital asset sales and exchanges to both customers and the IRS, with the first forms covering 2025-tax-year transactions due by February 17, 2026, and cost-basis reporting beginning with the 2026 tax year.retrieved M4bindingin force
Kansas imposes no state-specific outbound restriction on cross-border crypto asset transfers. Cross-border crypto activity is governed by federal frameworks: BSA/FinCEN Travel Rule obligations (with a pending proposal to lower the international funds-transfer recordkeeping threshold from $3,000 to $250 for transfers involving convertible virtual currency), OFAC sanctions screening, and, for stablecoin issuers, GENIUS Act BSA/sanctions compliance obligations.
Standing sub-brief127 words · last cycle 2026-08-21
Cross-Border Transfer
Kansas imposes no state-specific restriction on cross-border virtual-currency transfers; such matters continue to be governed exclusively by the federal Bank Secrecy Act framework as applied to licensed money transmitters. The practical effect of House Bill 2591's new kiosk-licensing requirement is to bring a previously unlicensed cash-in and cash-out channel under that federal BSA framework by extension of the new state money-transmitter licensure, rather than through any direct state-level cross-border rule change. No dedicated Kansas cross-border virtual-currency transfer statute exists as of this cycle.
Outlook
Because this is a tightening by extension rather than a direct rule change, watch for whether Kansas kiosk operators newly captured by the licensing requirement experience any distinct cross-border compliance obligations once fully licensed and subject to BSA obligations in practice.
No new data since the standing brief. 1 periodic run re-emitted it unchanged.
Sources and findings (3)
T2 · Conference of State Bank Supervisors (CSBS)Conference of State Bank Supervisors (CSBS) — Kansas imposes no state-specific outbound restriction on crypto asset cross-border transfers beyond the federal AML/sanctions framework applicable to money transmitters generally.retrieved M2non-binding
T1 · Federal Reserve BoardFederal Reserve Board — GENIUS Act permitted payment stablecoin issuers must comply with the Bank Secrecy Act and U.S. sanctions rules as a condition of federal authorization.retrieved M4bindingenacted not yet effective
T1 · Federal Reserve Board / FinCENFederal Reserve Board / FinCEN — Federal regulators have proposed reducing the Recordkeeping and Travel Rule threshold from $3,000 to $250 for funds transfers and transmittals, including those involving convertible virtual currency, that begin or end outside the United States; this proposal is not yet finalized.retrieved M3non-binding
Crypto AML/CFT obligations are handled via the fleet's FIM aml_ctf module subscription and are intentionally excluded from this baseline per module-subscription doctrine. Contextually, Kansas crypto businesses that qualify as money transmitters remain subject to federal BSA obligations (FinCEN MSB registration, SAR/CTR filing, recordkeeping) administered by FinCEN; these are captured under the FIM aml_ctf feed rather than restated here.
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
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