Not publishable as-is. 1 of 5 publication_gate checks fail. The renderer displays the gate rather than suppressing it. Legal review and sub-brief approval are informational and are not part of this test.
Missouri, USA
US-MOschema crypto-v2.0.0trajectory: not yet assessedregulatedoverlaps: FIM, WPM
Last updated · 8 categories · 11 sourced
findings · 17 sources in the cumulative register
8Categoriesbaseline.
11Findings.claims[]
4Tier-1 sourcesrun_metadata.t1_source_count
Confidence mix(sums to 8 rendered categories; click to filter)
No categories moved this cycle.
Jurisdiction lead brief
Lead Signal
Missouri's crypto regulatory perimeter tightened further this cycle on two fronts: the state's existing money-transmission licensing requirement for virtual-currency transmitters continues to operate as the sole state-level crypto licensing mechanism, while a pending bill, SB779, would extend that licensing perimeter specifically to virtual-currency kiosk operators. At the federal level, the GENIUS Act's payment-stablecoin regime remains structurally significant for Missouri-based and Missouri-serving stablecoin activity, with implementing rulemaking from the OCC and the joint FinCEN/OFAC rule both still at the proposal stage as of August 2026.
Other Developments
SB779's kiosk-licensing provisions would deem virtual-currency kiosk operators money transmitters under the Money Transmission Modernization Act, with a fee cap of fifteen percent of transaction value and daily transaction-limit requirements; whether the bill has advanced beyond its pending status this session was not established this cycle. The OCC's February 25, 2026 NPRM sets application, reserve, redemption, and risk-management requirements for OCC-licensed payment stablecoin issuers. The joint FinCEN/OFAC proposed rule would separately impose AML and sanctions-compliance-program requirements on payment stablecoin issuers under the GENIUS Act, layering federal AML obligations onto the same issuer population the OCC framework targets.
Cross-Monitor Connections
The GENIUS Act's incomplete rulemaking and Missouri's own money-transmission-based approach to virtual currency together illustrate a structural feature of the current environment: state licensing frameworks like Missouri's MTMA are operating ahead of, and independently of, the federal stablecoin-specific framework the GENIUS Act is meant to establish, which remains proposal-stage. This overlap is directly relevant to the financial-integrity monitor's tracking of GENIUS Act AML/sanctions rulemaking, and to the world-payments monitor's tracking of Missouri's money-transmission licensing perimeter.
Outlook
SB779's progress through the remainder of the session is the key state-level variable, and its enactment status was not established this cycle. At the federal level, the GENIUS Act's January 18, 2027 statutory backstop means the payment-stablecoin AML/sanctions and prudential framework will bind on that date regardless of whether the OCC and FinCEN/OFAC rulemakings are finalized beforehand.
8 of 8 categories
Signal
Density
Selections OR within a group, AND across groups. Press / to search.
Missouri has no bespoke crypto-asset licensing statute. Virtual-currency exchange, custody and transmission businesses are captured under Missouri's general money-transmitter licensing regime, administered through the multistate NMLS infrastructure, rather than a dedicated 'BitLicense'-style instrument. The precise state statutory citation and any crypto-specific carve-outs could not be independently confirmed via retrievable primary source in this run and should be escalated for direct statutory verification. Separately, state-level scrutiny of virtual-currency kiosk operators has been exercised primarily through consumer-protection litigation rather than licensing enforcement.
Standing sub-brief182 words · last cycle 2026-09-14
Crypto Licensing
Missouri's Division of Finance requires registration or licensure for any person receiving or transmitting virtual currency for a Missouri resident, under the Money Transmission Modernization Act. This is a confirmed, in-force, High-confidence requirement and constitutes the entirety of Missouri's state-level crypto licensing regime: there is no dedicated crypto-exchange or custody licence class distinct from the general money-transmission licence. A pending bill from the 2025 session, SB779, would extend this licensing perimeter specifically to virtual-currency kiosk operators, deeming them money transmitters and layering on disclosure requirements, a fee cap of fifteen percent of transaction value, and daily transaction limits. This is an Assessed-confidence finding, since the bill's enactment status was not established this cycle.
The overall picture is a licensing framework that is core-in-force but incomplete at the margins: the general money-transmission licence captures custodial virtual-currency transmission cleanly, but the kiosk-specific gap that SB779 would close remains open pending legislative action.
Outlook
Whether SB779 advances and passes this session is the single most consequential near-term development for Missouri's crypto-licensing perimeter. Its enactment status should be established directly in the next cycle.
No new data since the standing brief. 1 periodic run re-emitted it unchanged.
Sources and findings (2)
T1 · Nationwide Multistate Licensing System (NMLS)Nationwide Multistate Licensing System (NMLS) — Virtual-currency exchange and custody businesses operating in Missouri are expected to obtain a state money-transmitter license administered through NMLS, as Missouri has no bespoke crypto-asset licensing statute distinct from its general money-transmission law.retrieved M4bindingin force
T4 · The BlockThe Block — Missouri's Attorney General has pursued consumer-protection litigation (rather than licensing-based enforcement) against a crypto-ATM kiosk network, indicating that state oversight of virtual-currency businesses currently runs primarily through general consumer-protection and money-transmission channels rather than a crypto-specific licensing gate.retrieved M3non-binding
Missouri defers token-as-security/commodity characterization to the federal SEC/CFTC framework rather than maintaining an independent state taxonomy. Within that federal overlay, the Missouri Secretary of State's Securities Division actively enforces the state's blue-sky (Missouri Securities Act) regime against crypto-investment offerings that meet the security definition and are marketed to Missouri residents.
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 · CoinDeskCoinDesk — The Missouri Secretary of State's Securities Division has exercised state blue-sky enforcement authority against crypto-investment offerings soliciting Missouri residents, issuing cease-and-desist orders and civil penalties where such offerings constituted unregistered securities or fraudulent investment-adviser representations.retrieved M4bindingin force
T1 · U.S. Securities and Exchange CommissionU.S. Securities and Exchange Commission — Token-as-security-or-commodity characterization for crypto assets accessible to Missouri residents is governed by federal SEC/CFTC interpretive guidance rather than any Missouri-specific statute; Missouri does not maintain an independent token taxonomy.retrieved M3bindingin force
Missouri has no bespoke statute addressing crypto mining, staking, DeFi lending, DEX operation, node operation, validator activity or tokenization. A 2023 legislative effort to grant statutory protections to crypto-mining operations (comparable to laws enacted in Arkansas and Montana) died without passage, leaving miners subject only to general business, zoning and utility law. No evidence of subsequent enactment was found.
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 · CoinDeskCoinDesk — A Missouri legislative bill intended to grant statutory protections to cryptocurrency mining operations, comparable to laws passed in Arkansas and Montana, died without passage, leaving crypto miners in Missouri subject only to general business, zoning and utility regulation rather than a bespoke mining-protection statute.retrieved M3non-binding
T1 · Nationwide Multistate Licensing System (NMLS)Nationwide Multistate Licensing System (NMLS) — No Missouri-specific statute or regulation addressing staking, DeFi lending, DEX operation, node operation, validator activity or tokenization has been identified; these activities fall by default under general federal securities/commodities law and Missouri's general money-transmission and securities frameworks.retrieved M2non-bindinga fact about the regime
Missouri has not enacted a state-specific stablecoin issuance-authorisation, reserve, redemption, disclosure or systemic-designation regime. Payment stablecoin issuance nationally, including for issuers serving Missouri residents, is governed by the federal GENIUS Act framework, which preempts the need for a Missouri-specific regime for compliant federally-permitted issuers. Implementation of GENIUS Act rules was still being finalized as of the most recent available reporting.
Standing sub-brief159 words · last cycle 2026-09-14
Stablecoin Regime
Missouri has no state-specific stablecoin statute; its stablecoin regime is entirely a function of the federal GENIUS Act framework, which remains at the implementing-rulemaking stage. The OCC's February 25, 2026 NPRM sets application, reserve, redemption, and risk-management requirements for OCC-licensed payment stablecoin issuers, a confirmed, Tier 1, High-confidence, proposed-stage finding. Separately, FinCEN and OFAC have issued a joint proposed rule implementing the GENIUS Act's AML and sanctions-compliance-program requirements for payment stablecoin issuers, also confirmed at Tier 1 with High confidence and also still at proposal stage.
Because both the prudential (OCC) and AML/sanctions (FinCEN/OFAC) components of the federal framework remain proposals rather than final rules, any Missouri-connected stablecoin issuer currently operates in a period of regulatory incompleteness.
Outlook
The GENIUS Act's January 18, 2027 statutory backstop is the fixed point that resolves this incompleteness one way or another: the payment-stablecoin regime becomes binding on that date regardless of whether the OCC and FinCEN/OFAC rulemakings are finalized beforehand.
No new data since the standing brief. 1 periodic run re-emitted it unchanged.
Sources and findings (1)
T1 · U.S. Securities and Exchange CommissionU.S. Securities and Exchange Commission — The federal GENIUS Act establishes the primary U.S. payment-stablecoin issuance and reserve framework, which will apply uniformly to issuers serving Missouri residents once its implementing regulations take full effect; Missouri has not layered any additional state-specific stablecoin authorisation regime on top of this federal framework.retrieved M3bindingenacted not yet effective
Missouri's principal live consumer-protection vector for crypto is Attorney General enforcement against virtual-currency kiosk (crypto-ATM) operators under general state consumer-protection law, driven by a documented and rising volume of fraud complaints. No crypto-specific marketing-restriction, custody-segregation or suitability statute distinct from this general enforcement posture has been identified.
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 — The Missouri Attorney General filed suit against crypto-ATM operator CoinFlip (GPD Holdings LLC), alleging the network facilitated fraudulent transactions and charged excessive fees, and seeking consumer restitution, civil penalties of up to $1.826 million, and an injunction against continued operation in the state.retrieved M5bindingin force
T4 · The BlockThe Block — Missouri reported roughly 350 crypto-ATM-related fraud cases over a two-year period tied to kiosks including those operated by CoinFlip, underscoring material and rising state-level consumer complaint volume associated with virtual-currency kiosks.retrieved M4non-binding
No Missouri-specific statute altering the treatment of cryptocurrency for state tax purposes was identified in this pass. Missouri state income tax is generally understood to follow federal adjusted-gross-income conformity, implying that federal property/capital-gains characterization of crypto would flow through by default absent contrary state guidance, but this inference could not be independently confirmed against a live Missouri Department of Revenue source in this run and should be escalated.
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 · Nationwide Multistate Licensing System (NMLS)Nationwide Multistate Licensing System (NMLS) — No Missouri-specific statute altering the federal property/capital-gains characterization of cryptocurrency for state income-tax purposes has been identified; Missouri income tax is expected to follow the federal characterization by conformity, pending direct confirmation from the Missouri Department of Revenue.retrieved M3bindingin forceour coverage gap, expected to resolve on a re-run
Missouri imposes no identified state-specific restriction on cross-border transfer of virtual currency. Applicable controls derive from the federal Bank Secrecy Act / FinCEN framework, including the Travel Rule and 2025 FinCEN guidance specifically flagging convertible-virtual-currency kiosks as a vector for illicit cross-border fund movement — a typology directly relevant given Missouri's documented crypto-ATM fraud caseload.
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 — Missouri imposes no state-specific restriction on cross-border transfer of virtual currency; applicable controls derive from the federal BSA/FinCEN framework, including CVC-kiosk-focused guidance highlighting illicit cross-border fund-movement typologies relevant to Missouri's crypto-ATM fraud caseload.retrieved M3bindingin force
Crypto AML/CFT obligations applicable to Missouri-based virtual-asset businesses are sourced via the fleet's shared Financial Integrity Module (FIM) aml_ctf subscription and are not duplicated in this crypto baseline, per the module subscription reminder. As disambiguation context only: FinCEN is the primary federal AML/CFT regulator for money-services businesses, including Missouri-licensed money transmitters engaged in virtual-currency activity, and has issued kiosk-specific typology guidance relevant to Missouri's active crypto-ATM caseload.
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
No categories match.
Filters combine as OR inside a group and AND across
groups.
Publication gate
Blocking. 1 failing check(s).
schema_valid
FAIL
min_quoted_text_present
waived — floor 0%
egress_verified
pass
every_practical_object_has_source_id
n/a — no subject in this jurisdiction
source_tier_integrity_ok
pass
jurisdiction_source_floor_met
pass
tier_a_b_national_primary_pct
40.0
aggregator_only_jurisdiction_count
0
manual_override
Editorial metadata
Provenance only. Nothing below gates publication or affects the render.
Editorial metadata for Missouri, USA
Field
Value
trust.lawyer_review.status
never_reviewed
trust.lawyer_review.reviewer
no reviewer on record
trust.content_source
ai_generated
Provenance and declared absence
Disclosure model: module cards load OPEN; standing positions render in full; sub-briefs and jurisdiction briefs load as a clamped teaser with an explicit “read full” control carrying the true word count; earlier updates stay collapsed behind a counted summary. No text is hidden without disclosing how much of it there is.
Sentinel-fed modules receive no special rendering treatment. sentinel_feed is an attribution chip only: it does not suppress content, does not generate an absence reason code, and does not exclude the module from any count, filter, search index or export on this page.
Family taxonomy is renderer-level presentation config, not a JID field. Colour is always duplicated in text and is never the sole carrier of meaning.