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Michigan, USA
US-MIschema crypto-v2.0.0trajectory: not yet assessedregulatedoverlaps: FIM, WPM
Last updated · 7 categories · 17 sourced
findings · 21 sources in the cumulative register
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Jurisdiction lead brief
Lead Signal
Michigan's crypto-licensing perimeter is in transition. Under current law, the Michigan Department of Insurance and Financial Services requires a license under the Money Transmission Services Act for any person engaged in money transmission, a requirement that extends to virtual-currency exchanges that touch legal tender. Pending legislation -- the Money Transmission Modernization Act, carried by House Bill 5544 and Senate Bill 0835 -- would, as reported from committee, expressly exclude exchange, transfer, or custody of virtual currency that does not involve a transfer of legal tender from that licensing definition. This is not yet enacted, but it is a materially liberalising shift in scope: it would move Michigan from an ambiguous crypto money-transmission perimeter, where fiat-touching activity is licensed and non-fiat activity sits in a grey zone, to an explicit carve-out for non-fiat custody and exchange.
Other Developments
At the federal level, the GENIUS Act binds Michigan by preemption, restricting payment-stablecoin issuance to Permitted Payment Stablecoin Issuers (PPSIs). Building on that statutory baseline, a joint FinCEN/OFAC notice of proposed rulemaking would impose AML program, Suspicious Activity Report, recordkeeping, and a five-element sanctions-compliance-program requirement on PPSIs as a new Bank Secrecy Act financial-institution category; the comment period closed June 9, 2026 and no final rule has issued. Separately, Michigan House Bill 4087 has floated a non-binding proposal to allow the state treasurer to invest up to 10 percent of general and stabilization funds in cryptocurrency, alongside a floated gold- or silver-backed "MichCoin" concept; this is a reserve-investment idea distinct from any stablecoin-issuance authorization and has not been enacted.
Cross-Monitor Connections
The pending MTMA carve-out connects directly to the world-payments monitor's coverage of Michigan's money-transmission licensing reform, since the same HB 5544/SB 0835 legislative vehicle drives both findings. The FinCEN/OFAC stablecoin AML/sanctions NPRM connects directly to the financial-integrity monitor's Bank Secrecy Act and sanctions-architecture coverage, since it would create the same new PPSI compliance category tracked there.
Outlook
The MTMA's passage through the Michigan Senate, and whether the Department of Insurance and Financial Services issues interim guidance on the virtual-currency carve-out ahead of any enactment, are the near-term items to watch, with a prospective effective date of January 1, 2027 carrying a half-year uncertainty band. On stablecoins, the FinCEN/OFAC final rule is expected around 2027-Q1, also with a half-year uncertainty band, and would convert the current proposed five-element sanctions-compliance-program structure into a binding requirement if it tracks the NPRM as proposed.
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Michigan has no bespoke crypto-asset licensing statute. Virtual-currency exchange, custody and transmission businesses fall under Michigan's general money-transmitter licensing regime, administered through the Nationwide Multistate Licensing System (NMLS) by the state's banking/financial-institutions regulator, mirroring the federal FinCEN money-transmitter definition. Crypto-adjacent payment firms (e.g., X Payments) have obtained Michigan money transmitter licenses on this basis. A pending bill (HB 4511) would bar the state from imposing bans or license requirements on individuals merely holding crypto and would restrict state support for a U.S. CBDC, but it has not been enacted.
Standing sub-brief228 words · last cycle 2026-08-21
Crypto Licensing
Michigan currently requires a license under the Money Transmission Services Act, administered by the Michigan Department of Insurance and Financial Services (DIFS), for any person engaged in the business of money transmission, a requirement that reaches virtual-currency exchanges to the extent they touch legal tender. This is the standing, in-force requirement and has not changed this cycle.
What has changed is the pending Money Transmission Modernization Act, carried through House Bill 5544 (passed the Michigan House 97-10 on June 25, 2026) and its Senate companion SB 0835. As reported from committee, the MTMA would expressly exclude exchange, transfer, or custody of virtual currency that does not involve a transfer of legal tender from the money-transmission licensing definition. This is not yet enacted -- it carries an Assessed confidence tier on a Tier 3 source -- but it is material: it would replace an ambiguous licensing perimeter for non-fiat crypto activity with an explicit statutory carve-out, a liberalising development for exchanges and custodians whose activity does not involve legal-tender transfer.
Outlook
The primary open question is whether HB 5544 and SB 0835 pass the Senate and are signed before the drafted January 1, 2027 effective date, and whether DIFS issues interim guidance on the virtual-currency carve-out ahead of enactment. Until enactment, the current Money Transmission Services Act licensing requirement continues to govern fiat-touching crypto activity in Michigan.
No new data since the standing brief. 1 periodic run re-emitted it unchanged.
Sources and findings (3)
T4 · CoinDeskCoinDesk — Crypto exchange, custody, and money-transmission businesses operating in Michigan must obtain a money transmitter license under the state's general money transmission licensing regime, administered via NMLS.retrieved M4bindingin force
T1 · FinCENFinCEN — Under federal BSA regulations applied nationwide, an administrator or exchanger that accepts and transmits, or buys or sells, convertible virtual currency is a money transmitter (MSB) unless an exemption applies, forming the baseline definitional framework that Michigan's state licensing regime tracks.retrieved M4bindingin force
T4 · The BlockThe Block — Pending Michigan House Bill 4511 would prohibit the state from impeding an individual from holding cryptocurrency (via bans or license requirements) and would restrict certain state officials from supporting a U.S. central bank digital currency; the bill has not been enacted.retrieved M3non-binding
Michigan has not enacted a state-specific token-classification statute. Per the disambiguation applicable to this JID, characterization of a digital asset as a security, commodity, or other instrument is governed by federal SEC/CFTC jurisdiction rather than by a Michigan-specific rule; Michigan's role is limited to money-transmission/custody licensing, not securities characterization.
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 · CFTCCFTC — Michigan has no independent state-level statute characterizing digital assets as securities, e-money tokens, asset-referenced tokens, or utility tokens; such characterization for securities/commodity purposes is treated as a matter of federal SEC/CFTC jurisdiction.retrieved M3bindingin forceour coverage gap, expected to resolve on a re-run
Michigan has no enacted state statute specifically regulating staking, DeFi lending, DEX operation, node/validator operation, or tokenization. A pending bill package (HB 4512/HB 4513) would create a bitcoin-mining program using abandoned oil and gas well sites, with a companion income-tax provision, but neither has been enacted as of this run.
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 — Pending Michigan House Bill 4512 would create a bitcoin-mining program permitting mining operations at abandoned oil and gas well sites, conditioned on the operator performing required site restoration; the bill has not been enacted.retrieved M2non-binding
T4 · The BlockThe Block — No enacted Michigan statute currently governs staking, DeFi lending, DEX operation, node/validator operation, or tokenization activities at the state level.retrieved M2bindingin forceour coverage gap, expected to resolve on a re-run
Michigan has no independent state stablecoin statute. Stablecoin issuance in the U.S. is now governed by the federal GENIUS Act (signed into law July 18, 2025), which establishes issuance, reserve, redemption, and disclosure requirements and permits state-qualified issuers to operate under a state regime only if certified by federal regulators as substantially similar to the federal framework; final implementing regulations remain pending, with regulators having missed the one-year rulemaking deadline. Until GENIUS's implementing rules take effect, stablecoin issuers operating in Michigan continue to rely on the state's general money-transmitter licensing regime.
Standing sub-brief209 words · last cycle 2026-08-21
Stablecoin Regime
Michigan's stablecoin regime is governed entirely at the federal level, binding on the state by preemption, with no Michigan-specific issuance regime in place or imminent. The GENIUS Act restricts payment-stablecoin issuance to Permitted Payment Stablecoin Issuers (PPSIs) as a matter of settled federal statute. Building on that baseline, a joint FinCEN/OFAC notice of proposed rulemaking would impose AML program, Suspicious Activity Report, recordkeeping, and a five-element sanctions-compliance-program requirement on PPSIs as a distinct Bank Secrecy Act financial-institution category; the comment period closed June 9, 2026 and the rule remains proposed rather than final.
Separately, and at lower materiality, Michigan House Bill 4087 has floated a non-binding proposal for the state treasurer to invest up to 10 percent of general and stabilization funds in cryptocurrency, along with a floated gold- or silver-backed "MichCoin" concept. This is a reserve-investment proposal, not a stablecoin-issuance authorization, and has not been enacted.
Outlook
The FinCEN/OFAC final rule is the primary item to watch, with an expected timeframe of 2027-Q1 and a half-year uncertainty band; if finalized largely as proposed, PPSIs would become a distinct BSA-regulated category with defined AML and sanctions-compliance obligations. HB 4087's reserve-investment concept remains speculative and unenacted, with no indication this cycle that it is advancing toward a vote.
No new data since the standing brief. 1 periodic run re-emitted it unchanged.
Sources and findings (3)
T4 · The BlockThe Block — The federal GENIUS Act, signed into law July 18, 2025, allows only permitted entities to issue payment stablecoins in the United States: federally chartered banks, OCC-supervised nonbank issuers, and state-qualified issuers operating under a state regime certified as substantially similar to the federal framework.retrieved M4bindingenacted not yet effective
T4 · The BlockThe Block — As of this run, current stablecoins in the U.S. continue to be issued using state money-transmitter licenses without dedicated federal oversight, pending GENIUS Act implementing regulations that federal regulators have not yet finalized despite the one-year statutory deadline.retrieved M4bindingin force
T4 · The BlockThe Block — No Michigan-specific reserve, redemption, or disclosure requirement for stablecoin issuers exists independent of the federal GENIUS Act framework and Michigan's general money-transmitter licensing regime.retrieved M3non-bindinga fact about the regime
Michigan has not enacted a crypto-kiosk/ATM-specific consumer protection statute comparable to Illinois's Digital Asset Kiosk Act or Minnesota's kiosk ban. Consumer protection currently rests on (a) the Michigan Attorney General's Consumer Protection Division, which has issued a cryptocurrency 'pig butchering' scam alert referenced in federal guidance, and (b) federal FinCEN advisories/notices on CVC kiosk fraud that inform financial-institution reporting obligations nationwide, including in Michigan. The Michigan Attorney General has also acted as a co-plaintiff in federal (CFTC) enforcement matters touching digital-asset-adjacent investment fraud.
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 · FinCENFinCEN — The Michigan Department of Attorney General, Consumer Protection Division, has issued a public alert on cryptocurrency 'pig butchering' scams, cited by FinCEN as part of a national law-enforcement/regulator alert compendium on virtual-currency investment fraud.retrieved M3non-binding
T1 · FinCENFinCEN — FinCEN's August 2025 notice on convertible virtual currency (CVC) kiosk scams applies nationwide, including Michigan, reminding financial institutions of Bank Secrecy Act suspicious-activity reporting obligations tied to CVC kiosk fraud typologies disproportionately affecting older adults.retrieved M3bindingin force
T4 · The BlockThe Block — Michigan has not enacted a crypto-ATM/kiosk operator registration, fee-cap, or transaction-limit statute comparable to those adopted in Illinois, North Dakota, or Minnesota.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run
Michigan personal and corporate income tax generally conforms to the federal tax base. At the federal level, virtual currency is treated as property (not currency) for federal tax purposes per longstanding IRS guidance (Notice 2014-21), meaning capital gains/ordinary income characterization flows through to Michigan taxable income via federal AGI conformity. A pending Michigan bill (HB 4513) would amend the state's 1967 income tax act to address income from bitcoin mining at abandoned well sites, but it has not been enacted.
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 · CFTC / LabCFTCCFTC / LabCFTC — Federal guidance treats virtual currency as property for U.S. federal tax purposes, with general tax principles applicable to property transactions applying to virtual currency, a characterization Michigan's income tax base conformity inherits absent a state-specific override.retrieved M4bindingin force
T4 · The BlockThe Block — Pending Michigan House Bill 4513 would amend the state's 1967 income tax act to address income derived from bitcoin mining at abandoned oil and gas well sites; it has not been enacted.retrieved M2non-binding
T1 · CFTC / LabCFTCCFTC / LabCFTC — No Michigan-specific crypto tax information-reporting obligation exists independent of federal reporting requirements (e.g., Form 1099 series) that flow through to state filings.retrieved M2bindingin forceour coverage gap, expected to resolve on a re-run
Michigan has no independent state statute governing cross-border crypto transfers. Cross-border movement of virtual currency by Michigan-based money transmitters is governed by federal frameworks: FinCEN's Bank Secrecy Act travel-rule and sanctions-screening obligations (applicable to money transmitters generally, a category into which Michigan-licensed virtual-currency businesses fall), and, for stablecoin issuers specifically, GENIUS Act sanctions-compliance and lawful-order provisions currently being implemented via a joint FinCEN/OFAC proposed rule.
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 — Michigan imposes no independent state-level restriction on cross-border crypto transfers beyond the federal Bank Secrecy Act and OFAC sanctions framework applicable to money transmitters nationwide.retrieved M3bindingin force
T1 · FinCEN / OFACFinCEN / OFAC — FinCEN and OFAC have issued a joint proposed rule implementing the GENIUS Act's anti-money-laundering and sanctions compliance program requirements for permitted payment stablecoin issuers, which would apply to any Michigan-based stablecoin activity once finalized.retrieved M3bindingproposed
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