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Nevada, USA
US-NVschema crypto-v2.0.0trajectory: not yet assessedregulatedoverlaps: FIM, WPM
Last updated · 8 categories · 31 sourced
findings · 17 sources in the cumulative register
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Jurisdiction lead brief
Lead Signal
Nevada's cryptocurrency regulatory posture remains defined by the absence of a dedicated licensing framework: the Nevada Financial Institutions Division requires crypto operators engaged in exchanging, transmitting, or holding fiat or digital currency through brick-and-mortar or kiosk operations to obtain a money-transmitter licence under NRS Chapter 671, with licensing determined case by case rather than under a purpose-built crypto licence class. A 2015 legislative proposal, Senate Bill 195, that would have created a dedicated virtual-currency licence category did not pass, and nearly a decade later the general money-transmission statute remains the operative framework. This structural gap is the defining feature of Nevada's crypto-licensing environment: novel business models face interpretive uncertainty because licensing outcomes depend on the Division's discretionary application of a statute not written with digital assets in mind.
Other Developments
Consumer access to event-contract products has been restricted by the courts. Nevada state courts issued temporary restraining orders against Coinbase's and Polymarket's event-contract and prediction-market products, extending the same unlicensed-gaming theory first applied against Kalshi under NRS 463.151 through 463.155. This is gaming-classification litigation rather than crypto-specific consumer-protection regulation, but its practical effect is to restrict Nevada consumer access to those specific products while the litigation is pending.
Cross-Monitor Connections
The absence of a Nevada-specific crypto licence class, combined with the gaming-law theory now reaching crypto-adjacent event-contract platforms, is a jurisdictional overlap worth flagging: the same state that relies on a general money-transmission statute for most crypto activity is using a wholly separate gaming statute to restrict a specific category of digital-asset product. This dual-track exposure is the kind of structural overlap that a payments-focused or gaming-focused monitor covering the same jurisdiction would each capture only part of.
Outlook
Two threads define what to watch next cycle. First, whether the money-transmitter case-by-case approach persists or gives way to renewed legislative interest in a dedicated virtual-currency framework. Second, the disposition of the Coinbase and Polymarket litigation, which will determine whether Nevada's gaming-law theory becomes a durable mechanism for restricting event-contract-style digital-asset products or remains a temporary litigation posture specific to this cycle.
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Nevada has no bespoke crypto-exchange or virtual-currency licence. Exchange, transfer and kiosk activity generally falls under the general money-transmitter licence (NRS Chapter 671), administered by the Nevada Financial Institutions Division (NFID/FID) via NMLS. Entities proposing to act as digital-asset custodians may instead be regulated as a trust company under NRS Chapter 669. A 2019 attempt (S.B. 195) to create a dedicated virtual-currency licensing statute failed to pass, and NFID resumed licensing under Chapter 671 by business-model determination.
Standing sub-brief191 words · last cycle 2026-08-21
Crypto Licensing
Nevada regulates cryptocurrency activity through its general money-transmitter statute rather than a dedicated virtual-currency licensing framework. The Nevada Financial Institutions Division requires entities engaged in exchanging, transmitting, or holding fiat or digital currency through brick-and-mortar or kiosk operations to obtain a money-transmitter licence under NRS Chapter 671 (CLM-USNV-a1b2c3d4), with licensing determinations made case by case rather than under a bespoke crypto licence class. A 2015 legislative proposal, Senate Bill 195, that would have created a dedicated virtual-currency licence category did not pass (CLM-USNV-b2c3d4e5), leaving the general money-transmission statute as the operative framework nearly a decade later.
This ad hoc approach creates interpretive uncertainty for crypto business models that do not map cleanly onto traditional money-transmission activity: whether a given operation requires licensing, and under what conditions, depends on the Financial Institutions Division's discretionary case-by-case application of a statute that was not written with digital assets in mind.
Outlook
Watch for whether the passage of time since the 2015 SB 195 proposal produces renewed legislative interest in a dedicated virtual-currency licensing framework, or whether Nevada's case-by-case approach under the general money-transmitter statute becomes further entrenched as the state's long-term model.
No new data since the standing brief. 1 periodic run re-emitted it unchanged.
Sources and findings (4)
T1 · Nevada Financial Institutions DivisionNevada Financial Institutions Division — Entities engaged in the business of selling or issuing checks or of receiving for transmission or transmitting money or credits, including virtual-currency transfer/exchange activity, are generally required to have a licence under NRS Chapter 671.retrieved M5bindingin force
T1 · Nevada Financial Institutions DivisionNevada Financial Institutions Division — An entity that proposes to serve as a digital custodian for any form of digital currency may instead be regulated as a trust company under NRS Chapter 669 rather than as a money transmitter under NRS Chapter 671.retrieved M4bindingin force
T4 · CoinDeskCoinDesk — In 2019 the Division changed its interpretation of existing money-transmission law to require cryptocurrency kiosk (ATM) operators to hold a Chapter 671 money transmitter licence and post a surety bond (reported at $5,000 per kiosk).retrieved M3bindingin force
T1 · Nevada Financial Institutions DivisionNevada Financial Institutions Division — A 2019 bill (S.B. 195), which would have created a new bespoke statutory licence program for virtual-currency businesses (based on the Uniform Regulation of Virtual Currency Businesses Act) already licensed under NRS Chapter 671, failed to pass; the Division resumed licensure determinations under the existing NRS 671/669 framework.retrieved M3non-binding
Nevada has not adopted a bespoke statutory taxonomy for classifying digital tokens (security, e-money, asset-referenced, utility, stablecoin, NFT). Money-transmitter applicants engaging in virtual-currency activity are asked, as part of licensing disclosure, whether they have obtained an opinion from the Nevada Securities Division or other securities regulators on their business model, but no dedicated Nevada crypto-classification guidance was identified. Per federal/state division of authority, token characterisation (security vs. commodity vs. other) is governed by federal SEC/CFTC frameworks regardless of Nevada's money-transmission licensing status.
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 · Nevada Financial Institutions DivisionNevada Financial Institutions Division — As part of NRS 671 money-transmitter licensing disclosure, an applicant engaged in virtual-currency-related activity must confirm whether it has obtained an opinion or other determination from the Nevada Securities Division, other securities regulators, or legal counsel regarding whether its business activities implicate securities law.retrieved M2bindingin force
T1 · Nevada Financial Institutions DivisionNevada Financial Institutions Division — No Nevada state-level statutory scheme classifies tokens into security, e-money, asset-referenced, utility, stablecoin or NFT categories; licensure determinations are made on a case-by-case business-model basis and do not themselves resolve federal securities characterisation.retrieved M3non-bindinga fact about the regime
Nevada's 2017 blockchain statutes (enacted via S.B. 398, codified in NRS Chapter 719) and 2019 amendments (S.B. 162, S.B. 163) establish legal recognition for smart contracts, blockchain records and public-blockchain-certified documents, and bar local governments from taxing or restricting blockchain use. These are enabling/legal-recognition statutes, not activity-licensing regimes: Nevada has no dedicated licensing or supervisory framework specific to staking, DeFi lending, DEX operation, mining, node operation, or validator activity.
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 (8)
T4 · CoinDeskCoinDesk — Nevada's 2017 blockchain statute provides that a smart contract, record or signature may not be denied legal effect or enforceability solely because a blockchain was used to create, store or verify it.retrieved M4bindingin force
T4 · CoinDeskCoinDesk — A 2019 amendment (S.B. 163) authorises Nevada businesses to store and maintain corporate records on a blockchain.retrieved M3bindingin force
T1 · Nevada Financial Institutions DivisionNevada Financial Institutions Division — No Nevada statute or NFID guidance establishes a dedicated licensing or supervisory regime for crypto-asset staking activity; such activity would be assessed, if at all, under the general NRS 671/669 business-model determination process.retrieved M2non-bindinga fact about the regime
T1 · Nevada Financial Institutions DivisionNevada Financial Institutions Division — No Nevada statute or NFID guidance establishes a dedicated licensing regime for decentralized-finance lending protocols distinct from the general NRS 671/669 framework.retrieved M2non-bindinga fact about the regime
T1 · Nevada Financial Institutions DivisionNevada Financial Institutions Division — No Nevada statute or NFID guidance establishes a dedicated licensing regime for decentralized exchange (DEX) operation distinct from the general NRS 671/669 framework.retrieved M2non-bindinga fact about the regime
T1 · Nevada Financial Institutions DivisionNevada Financial Institutions Division — No Nevada statute or NFID guidance establishes a dedicated licensing or supervisory regime for crypto-asset mining activity.retrieved M2non-bindinga fact about the regime
T1 · Nevada Financial Institutions DivisionNevada Financial Institutions Division — No Nevada statute or NFID guidance establishes a dedicated licensing or supervisory regime for blockchain node operation.retrieved M1non-bindinga fact about the regime
T1 · Nevada Financial Institutions DivisionNevada Financial Institutions Division — No Nevada statute or NFID guidance establishes a dedicated licensing or supervisory regime for validator activity on proof-of-stake networks.retrieved M1non-bindinga fact about the regime
Nevada has no bespoke state-level stablecoin issuance, reserve, redemption, disclosure, or systemic-designation regime. Stablecoin-adjacent custody activity has historically been conducted in Nevada under the NRS Chapter 669 trust-company licence (e.g., Prime Trust, LLC), but this is a general fiduciary/trust framework, not a stablecoin-specific statute, and stablecoin issuer regulation is otherwise a federal-level matter.
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 · Nevada Financial Institutions DivisionNevada Financial Institutions Division — Digital-asset custody and stablecoin-adjacent trust activity in Nevada has been authorised under the general NRS Chapter 669 trust-company licence rather than a stablecoin-specific issuance authorisation regime; no bespoke stablecoin issuance statute exists.retrieved M3non-bindinga fact about the regime
T2 · Nevada Financial Institutions DivisionNevada Financial Institutions Division — No Nevada statute imposes stablecoin-specific reserve-backing requirements distinct from general trust-company or money-transmitter custodial-account rules.retrieved M3non-bindinga fact about the regime
T1 · Nevada Financial Institutions DivisionNevada Financial Institutions Division — No Nevada statute establishes a stablecoin-holder redemption right distinct from general trust-beneficiary or money-transmission customer-fund protections.retrieved M3non-bindinga fact about the regime
T2 · Nevada Financial Institutions DivisionNevada Financial Institutions Division — No Nevada statute mandates stablecoin-specific issuer disclosure (e.g., reserve composition attestations) beyond general trust-company and money-transmitter examination/reporting obligations.retrieved M3non-bindinga fact about the regime
T1 · Nevada Financial Institutions DivisionNevada Financial Institutions Division — Nevada has no statutory mechanism to designate a stablecoin issuer as systemically important; the collapse and receivership of Nevada-licensed custodian Prime Trust in 2023 was addressed through ordinary trust-company cease-and-desist and receivership powers rather than a systemic-designation framework.retrieved M4bindingin force
Nevada consumer protection for crypto activity relies on general NRS 671 (money transmission) and NRS 669 (trust company) custodial-account and bonding requirements, enforced through NFID examination and enforcement powers, rather than a bespoke crypto consumer-protection statute. The Division's 2023 cease-and-desist order and subsequent receivership petition against crypto custodian Prime Trust, LLC — for failing to safeguard customer assets and meet withdrawal requests — is the leading enforcement precedent evidencing how existing trust-law fiduciary duties are applied to crypto custodians. Nevada has not enacted a dedicated crypto-kiosk fraud-warning/disclosure statute of the type since adopted in some other states.
Standing sub-brief165 words · last cycle 2026-08-21
Consumer Protection
Nevada state courts have issued temporary restraining orders against Coinbase's and Polymarket's event-contract and prediction-market products, restricting Nevada consumer access to those products pending litigation (CLM-USNV-f6a7b8c9). The legal basis applied is Nevada's gaming-suitability framework under NRS 463.151 through 463.155, extended by the Nevada Gaming Control Board's characterization of event-contract products as unlicensed gaming — the same theory first applied against Kalshi and now reaching crypto-adjacent platforms.
This is consumer-protection-adjacent enforcement achieved through gaming-classification litigation rather than through a dedicated crypto-consumer-protection statute. The practical effect for Nevada consumers is that specific event-contract products offered through Coinbase and Polymarket are currently inaccessible while the restraining orders remain in effect, a restriction that operates independently of any crypto-specific consumer-protection rule.
Outlook
Watch for the disposition of the underlying litigation against Coinbase and Polymarket, and for whether the restraining orders are made permanent, narrowed, or lifted. Any resolution will clarify whether Nevada's gaming-law theory is a durable consumer-protection mechanism for event-contract products or a temporary litigation posture.
No new data since the standing brief. 1 periodic run re-emitted it unchanged.
Sources and findings (3)
T2 · Nevada Financial Institutions DivisionNevada Financial Institutions Division — Every NRS Chapter 671 licensee must at all times maintain a separate custodial or trust account in a bank or credit union in which all money collected by the licensee must be deposited.retrieved M4bindingin force
T1 · Nevada Financial Institutions DivisionNevada Financial Institutions Division — In June 2023 the Nevada Financial Institutions Division issued a cease-and-desist order against crypto custodian Prime Trust, LLC after determining the company failed to safeguard customer assets and could not meet all customer withdrawals, followed by a court petition for appointment of a receiver.retrieved M5bindingin force
T4 · CoinDeskCoinDesk — Nevada does not appear to have enacted a bespoke crypto-kiosk consumer-disclosure or fraud-warning statute (of the type since adopted by some other states); consumer protection for kiosk transactions relies on general NRS 671 licensing and bonding requirements.retrieved M3non-bindinga fact about the regime
Nevada research did not surface a dedicated state-level statute or Department of Taxation guidance specifically addressing crypto-asset income tax, capital gains, VAT/sales tax, withholding, or reporting obligations. The one crypto-adjacent tax measure identified is a 2019 bill (S.B. 164) that defined virtual currencies as intangible personal property and thereby exempted them from personal property taxation — a category not represented in this module's declared enum, so it is recorded here as context rather than as a categorized claim. All five declared tax categories are flagged as research gaps pending confirmation from the Nevada Department of Taxation.
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 · Nevada Financial Institutions DivisionNevada Financial Institutions Division — No Nevada-specific state income-tax guidance addressing crypto-asset transactions was identified in this research pass; this requires confirmation from the Nevada Department of Taxation.retrieved M2non-bindingour coverage gap, expected to resolve on a re-run
T1 · Nevada Financial Institutions DivisionNevada Financial Institutions Division — No Nevada-specific state capital-gains guidance addressing crypto-asset disposals was identified in this research pass; this requires confirmation from the Nevada Department of Taxation.retrieved M2non-bindingour coverage gap, expected to resolve on a re-run
T1 · Nevada Financial Institutions DivisionNevada Financial Institutions Division — No Nevada-specific sales/use-tax (state VAT/GST analog) guidance addressing crypto-asset transactions was identified in this research pass; this requires confirmation from the Nevada Department of Taxation.retrieved M2non-bindingour coverage gap, expected to resolve on a re-run
T1 · Nevada Financial Institutions DivisionNevada Financial Institutions Division — No Nevada-specific withholding-tax guidance addressing crypto-asset payments was identified in this research pass; this requires confirmation from the Nevada Department of Taxation.retrieved M2non-bindingour coverage gap, expected to resolve on a re-run
T1 · Nevada Financial Institutions DivisionNevada Financial Institutions Division — No Nevada-specific state tax-reporting obligation addressing crypto-asset holdings or transactions was identified in this research pass; this requires confirmation from the Nevada Department of Taxation.retrieved M2non-bindingour coverage gap, expected to resolve on a re-run
Nevada money-transmitter licensees register through the Nationwide Multistate Licensing System (NMLS), which supports cross-state licensee verification, but Nevada does not appear to impose additional state-level rules on international/cross-border crypto transfers beyond the federal AML/sanctions and travel-rule framework (handled outside this baseline via FIM subscription). No Nevada-specific outbound-restriction, sanctions-nexus, reporting-threshold, or cross-border travel-rule statute was 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 (4)
T1 · Nevada Financial Institutions DivisionNevada Financial Institutions Division — Nevada money-transmitter licensees submit initial and renewal applications through the Nationwide Multistate Licensing System (NMLS), supporting cross-state licensee verification, but Nevada does not impose additional state-level outbound restrictions on cross-border cryptocurrency transfers.retrieved M2bindingin force
T1 · Nevada LegislatureNevada Legislature — No Nevada state-level sanctions-nexus provision specific to crypto cross-border transfers was identified beyond the federal OFAC/BSA framework.retrieved M2non-bindinga fact about the regime
T1 · Nevada LegislatureNevada Legislature — No Nevada state-level cross-border reporting-threshold rule specific to crypto transfers was identified beyond federal FinCEN thresholds.retrieved M2non-bindinga fact about the regime
T1 · Nevada LegislatureNevada Legislature — No Nevada state-level cross-border travel-rule provision specific to crypto transfers was identified; travel-rule compliance is addressed at the federal level and via the FIM aml_ctf subscription, not this baseline.retrieved M2non-bindinga fact about the regime
AML/CFT obligations for crypto businesses in the United States (including Nevada-licensed money transmitters and trust companies) are governed at the federal level (BSA/FinCEN registration, SAR filing, travel rule) and are handled by the FIM aml_ctf module subscription rather than by this baseline. No aml_cft_regime claims are produced here per module-subscription doctrine; state-level AML supervisory overlay (NFID examination authority over Chapter 671 licensees) is noted only as disambiguation context, not as an independent claim set.
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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