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Vermont, USA
US-VTschema crypto-v2.0.0trajectory: not yet assessedregulatedoverlaps: FIM, WPM
Last updated · 8 categories · 23 sourced
findings · 21 sources in the cumulative register
8Categoriesbaseline.
23Findings.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
Vermont's virtual-currency regulatory perimeter tightened this cycle through Act 142, signed June 16, 2026, which permanently bans virtual-currency kiosks statewide and terminates existing kiosk registrations effective July 1, 2026. The core money-transmitter licensing requirement for virtual-currency business activity under 8 V.S.A. chapter 79, covering exchanging, storing, administering, buying, selling, or controlling virtual currency, remains unchanged and in force, so this cycle's material development is a targeted prohibition on one channel rather than a restructuring of the licensing regime as a whole. Both the kiosk prohibition and the continuing licence requirement are High-confidence, Tier 1 findings, resting on the enacted statutory text itself rather than secondary commentary.
Other Developments
Binding transaction-disclosure duties remain in force. Licensees conducting a virtual-currency transaction in Vermont must disclose who imposes each charge and how to cancel the transaction to avoid additional fees, under 8 V.S.A. section 2574(c). This obligation is unaffected by Act 142's kiosk provisions and continues to apply to the licensed virtual-currency business activity that remains permitted in the state. The same Act 142 also expands the statutory definition of money-transmission control to include control of a private key, though this cycle's disclosure-duty finding is independent of that expansion and rests on the standing consumer-protection provision already in force.
Cross-Monitor Connections
Act 142's kiosk ban and its expansion of the money-transmission control test to cover private-key control are also tracked by the Financial Integrity Monitor, which reads the same statute through an AML/CTF-architecture lens, and by the World Payments Monitor, which tracks the licensing and market-access implications for nonbank payment providers. This is architectural rather than coincidental: Act 142 was enacted as a single omnibus statute spanning virtual-currency licensing, consumer disclosure, money-transmission scope, and commercial-financing licensing, so any monitor reading Vermont's virtual-currency perimeter this cycle is necessarily reading a different facet of the same instrument.
Outlook
The item to watch is whether the Department of Financial Regulation issues interpretive guidance on Act 142's private-key control test as it applies to arrangements beyond kiosks, and whether the kiosk prohibition prompts any interim guidance or enforcement activity before the July 1, 2026 registration-termination date takes full effect.
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Vermont has no bespoke crypto-asset licence; virtual-currency business activity is regulated as money transmission under 8 V.S.A. Chapter 79, administered by DFR via NMLS. The regime was rebuilt on the CSBS Money Transmission Modernization Act model in 2024 (Act 110) and amended in 2025 (Act 23) and 2026 (Act 142/H.648); the virtual-currency-kiosk moratorium under §2577 now runs to 1 July 2027.
Standing sub-brief193 words · last cycle 2026-09-21
Crypto Licensing
Vermont's virtual-currency licensing framework rests on 8 V.S.A. chapter 79, which requires any person engaging in virtual-currency business activity in the state, exchanging, storing, administering, buying, selling, or controlling virtual currency, to hold a money-transmitter licence unless an exemption applies. This core requirement is High confidence, Tier 1 sourced, and unchanged this cycle.
Vermont Act 142, signed by Governor Scott on June 16, 2026, imposes a permanent, statewide ban on virtual-currency kiosks; kiosk operators' existing registrations terminate on July 1, 2026. This is also a High-confidence, Tier 1 finding. Taken together, these two claims describe a licensing regime that is stable at its core, since the general money-transmitter licence requirement for virtual-currency business activity is unchanged, but has tightened sharply on one specific channel: kiosks move from a licensed or registered activity to outright prohibition, with no cure or re-registration pathway described in the statute.
Outlook
Whether the Department of Financial Regulation issues further guidance interpreting Act 142's expanded control test, including control via private key, for arrangements such as staking or custodial DeFi services was not confirmed this cycle and remains an open question for the licensing perimeter's practical reach.
Periodic update · new data 2026-09-22
Crypto Licensing
Vermont's virtual-currency licensing regime sits within 8 V.S.A. Chapter 79, the state's money-transmission statute, which requires any person engaged in virtual-currency business activity — including the operation of virtual-currency kiosks — to hold a money-transmission licence unless a statutory exemption applies. This core licensing requirement is structurally unchanged this cycle; what has moved is the treatment of new kiosk entrants specifically. Act 142, enacted in the 2026 legislative session, extends the moratorium on new virtual-currency kiosks operating in Vermont from its previous 1 July 2026 expiry to 1 July 2027. That moratorium was itself an extension: the original prohibition was set at 1 July 2026 by Act 23 in 2025, meaning Vermont has now amended Chapter 79's virtual-currency-kiosk provisions in three consecutive legislative sessions (2024's Act 110, 2025's Act 23, and 2026's Act 142). The Vermont Department of Financial Regulation remains the supervisory authority throughout.
The pattern across these three sessions reads as continuous, deliberate tightening rather than a single settled framework with occasional maintenance. Each session has narrowed or extended restrictions on the kiosk sub-segment specifically, even as the broader money-transmission licensing requirement for virtual-currency businesses generally has remained stable since its 2024 rebuild. This distinction matters for any operator assessing the jurisdiction: an existing money-transmission licensee conducting virtual-currency business outside the kiosk channel faces no new obligation this cycle, while any prospective new kiosk operator faces a door that has now been closed, re-closed, and closed again for a further year.
Confidence in the moratorium extension itself is Confirmed, anchored to the Tier-1 statutory text at 8 V.S.A. § 2577. The underlying general licensing requirement is also Confirmed, though sourced to a Tier-3 secondary legal-commentary source rather than the statute directly this cycle. Whether the Department of Financial Regulation has issued implementing rules or guidance specific to the 2026 amendments, beyond the bare statutory text, was not confirmed this cycle and is recorded as an open gap.
Outlook
The moratorium's current expiry date of 1 July 2027 is the key date to track. Given three consecutive annual extensions, continuation of that pattern into a fourth extension during the 2027 session is a plausible but unconfirmed scenario; nothing in this cycle's evidence base commits to that outcome. Separately, confirmation of whether DFR has issued implementing guidance for Act 142's kiosk and licensing provisions remains an open research item for the next cycle.
1 earlier distinct update(s)
Periodic update · new data 2026-09-06
Crypto Licensing
Vermont requires virtual-currency businesses operating in the state, including exchanges and custodians, to hold a money transmitter licence under 8 V.S.A. Chapter 79; there is no separate crypto-specific licence class. This general-licensing approach means crypto businesses are subject to the same fee, bond, and net-worth requirements as any other money transmitter, with no bespoke crypto-licensing pathway or exemption.
The cycle's lead development is Act 142 (H.648), signed June 16, 2026, which extended the existing prohibition on new virtual-currency kiosks under 8 V.S.A. Section 2577(f) from July 1, 2026 to July 1, 2027. Kiosks that were operational on or before June 30, 2024 remain grandfathered and may continue operating; only new kiosk deployment is restricted. This is the third consecutive year Vermont has amended Chapter 79's virtual-currency provisions in a tightening direction, indicating a deliberate and sustained cautious regulatory posture toward crypto on-ramps that is distinct from the state's otherwise CSBS Model Act-aligned general money-transmission regime, which itself has not been the subject of restrictive amendment.
Outlook
The moratorium is scheduled to lift July 1, 2027 absent further legislative extension. The three-year consistency of the tightening pattern makes a further extension a plausible, though not certain, outcome for the 2027 legislative session. The retrieved primary statutory text may not yet fully reflect the Act 142 extension in every rendering, so confirmation against the authoritative current text of Section 2577 remains an open item for the next cycle.
Sources and findings (5)
T3Mondaq (K&L Gates) — New virtual-currency kiosks are prohibited from operating in Vermont until July 1, 2027, per Act 142 (H.648, signed June 16, 2026).retrieved M4bindingin force
T4 · CoinDeskCoinDesk — Vermont's 2017 amendment to its money-transmission statute added a definition of 'virtual currency' and allows licensed money transmitters to hold digital currency as a permissible investment, limited to the extent of outstanding transmission obligations received in identical denomination of virtual currency.retrieved M5bindingin force
T2 · New York State Department of Financial ServicesNew York State Department of Financial Services — A 2011 multistate regulatory survey by the New York Department of Financial Services identifies Vermont (8 Vt. Statutes Ann. § 2502) among states that license out-of-state money transmitters doing business with in-state residents under a general MTL statute.retrieved M4bindingin force
T4 · CoinDeskCoinDesk — Vermont's licensing process for digital-currency businesses has involved a case-by-case review of the business plan and executives, considering factors such as prior criminal convictions, whether the business is audited, and whether other states have licensed the entity, before a money-transmitter licence is granted.retrieved M3non-binding
T1 · State Regulatory Registry LLC / Conference of State Bank SupervisorsState Regulatory Registry LLC / Conference of State Bank Supervisors — Money-transmitter licensing for Vermont, including for virtual-currency businesses, is processed through the Nationwide Multistate Licensing System (NMLS), the common multistate licensing infrastructure used by state financial regulators; NMLS does not itself set substantive state licensing standards.retrieved M3bindingin force
Vermont does not operate a state-level token taxonomy. Token characterisation as a security or commodity is governed federally (SEC/CFTC, applying the Howey test and 2026 SEC interpretive guidance distinguishing 'digital commodities' from securities). Vermont's own role is confined to enforcement under its Uniform Securities Act against token sales it determines to be unregistered securities offerings, as illustrated by a 2018 cease-and-desist action.
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 — Vermont's Department of Financial Regulation issued a 2018 cease-and-desist notice against an ongoing ICO issuer, accusing it of violations related to the Vermont Uniform Securities Act and ordering it to stop selling tokens tied to its platform.retrieved M4bindingin force
T1 · U.S. Securities and Exchange CommissionU.S. Securities and Exchange Commission — The SEC provided interpretive guidance in 2026 on the application of federal securities laws to crypto assets, including criteria for identifying 'digital commodities' as distinct from securities; Vermont has not adopted a supplementary state-specific token taxonomy.retrieved M3bindingin force
Vermont has no bespoke statute or supervisory framework addressing staking, DeFi lending, DEX operation, mining, node operation, validator activity, or tokenization. Historically, the state's approach to virtual-currency business activity has been described as lacking concrete rules outside of the general MTL and securities statutes, leaving these on-chain activities to be assessed only insofar as they might constitute money transmission or a securities offering under existing general law.
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)
T4 · CoinDeskCoinDesk — Vermont has historically lacked concrete rules for many virtual-currency business activities, leaving areas such as cryptocurrency mining without a dedicated state regulatory framework distinct from general business and money-transmission law.retrieved M3non-bindinga fact about the regime
T4 · CoinDeskCoinDesk — No Vermont-specific statute or DFR guidance addresses the regulatory treatment of crypto-asset staking; any applicability would depend on whether a staking service is found to constitute money transmission or a securities offering under existing general law.retrieved M3non-bindinga fact about the regime
T4 · CoinDeskCoinDesk — Vermont has no dedicated framework for decentralized finance (DeFi) lending activity; the DFR's crypto-related enforcement to date (e.g., BlockFi, Celsius) has addressed centralized lending products under securities and consumer-protection authority rather than a DeFi-specific rule.retrieved M3non-bindinga fact about the regime
T4 · CoinDeskCoinDesk — No Vermont statute or supervisory notice addresses node operation or validator activity as a distinct regulated category.retrieved M2non-bindinga fact about the regime
The federal GENIUS Act (signed into law 18 July 2025) establishes the first comprehensive U.S. framework for payment stablecoins, permitting issuance only by federally chartered banks, OCC-supervised nonbank issuers, or state-qualified issuers operating under a state regime certified 'substantially similar' to the federal standard (with a threshold allowing state supervision of issuers with up to $10 billion outstanding). Vermont has not enacted its own stablecoin-specific statute or sought state-regime certification; as of mid-2026 the primary federal regulators (OCC, Federal Reserve, FDIC, NCUA) and Treasury missed the Act's one-year rulemaking deadline, leaving implementing regulations unfinished and the statutory effective date set for the earlier of 18 January 2027 or 120 days after final rules issue.
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 · The BlockThe Block — The GENIUS Act permits only federally chartered banks, OCC-supervised nonbank issuers, or state-qualified issuers operating under a state regime certified as substantially similar to the federal framework to issue payment stablecoins in the United States.retrieved M5bindingenacted not yet effective
T4 · The BlockThe Block — The primary federal payment-stablecoin regulators (OCC, Federal Reserve, FDIC, NCUA) and the Treasury Department reached the GENIUS Act's one-year statutory rulemaking deadline (18 July 2026) without finalizing implementing regulations, though the law's 18 January 2027 effective date is not automatically postponed by the missed deadline.retrieved M5bindingenacted not yet effective
T4 · The BlockThe Block — Treasury's proposed 'substantially similar' state-regime certification standard under the GENIUS Act would allow qualifying state-supervised stablecoin issuers with no more than $10 billion in outstanding stablecoins to remain under state supervision rather than the federal regime.retrieved M4bindingproposed
Vermont's DFR applies existing general consumer-protection and securities-enforcement tools to crypto products rather than a bespoke crypto consumer-protection statute, including multistate-coordinated investigations (Celsius, BlockFi) and cease-and-desist actions against token issuers.
Standing sub-brief142 words · last cycle 2026-09-05
Consumer Protection
Vermont-licensed virtual-currency businesses are required under 8 V.S.A. section 2574(c) to disclose, for any virtual-currency transaction, who imposes each charge and how the transaction may be cancelled to avoid additional fees. This obligation is binding, in force, and High confidence, resting on a Tier 1 primary source.
Act 142's permanent statewide ban on virtual-currency kiosks, effective July 1, 2026, removes a cash-to-crypto conversion channel from the market entirely. Nationally, virtual-currency kiosks have drawn consumer-protection and law-enforcement attention as a scam-facilitation vector, but Vermont's own primary-source record for this cycle does not itself articulate a consumer-protection rationale for the ban, that reading is inferred rather than confirmed, and is flagged accordingly.
Outlook
Whether the Department of Financial Regulation supplements the section 2574(c) disclosure regime with kiosk-specific or DeFi-specific consumer-disclosure rules ahead of any future licensing developments was not confirmed this cycle.
Periodic update · new data 2026-09-06
Consumer Protection
Vermont's virtual-currency kiosk regime under 8 V.S.A. Section 2577 imposes two confirmed, in-force consumer-protection obligations on kiosk operators. First, operators must verify the identity of the customer for every transaction and are prohibited from allowing a transaction to proceed under any name, account, or identity other than the customer's own, a direct control against identity-substitution fraud in the cash-to-crypto conversion channel. Second, aggregate fees and charges on a kiosk transaction are capped at the greater of a specified flat amount or fifteen percent of the U.S.-dollar equivalent value of the virtual currency involved in the transaction, a price-protection control against excessive kiosk fees.
Both obligations are new or newly emphasised within the same statutory provision that carries the moratorium extension, meaning consumer-protection tightening and market-access tightening arrived through the same legislative vehicle this cycle. These are kiosk-specific protections and do not extend automatically to other virtual-currency business models -- exchanges, custodians, or over-the-counter dealers -- operating under Vermont's general money transmitter licence, which are not subject to the same per-transaction identity-verification or fee-cap requirements under this specific statute.
Outlook
These identity-verification and fee-cap requirements are already in force and are not tied to the moratorium's 2027 expiration date; they will continue to apply to kiosk operators regardless of how the moratorium question resolves. Any future extension of kiosk-specific consumer protection in Vermont is likely to build incrementally on this existing template rather than introduce a substantially different framework.
Sources and findings (3)
T4 · The BlockThe Block — Vermont's Department of Financial Regulation joined a multistate investigation into crypto lender Celsius, finding that the platform had not disclosed critical information about its financial condition, investing activities, risk factors, and ability to repay depositors and other creditors.retrieved M4bindingin force
T4 · CoinDeskCoinDesk — Vermont securities regulators gave crypto lender BlockFi 30 days to respond before potentially imposing a cease-and-desist order over its interest-bearing account product, joining regulators in Alabama, Texas and New Jersey scrutinizing the same offering.retrieved M4bindingin force
T4 · CoinDeskCoinDesk — Vermont's 2018 cease-and-desist action against an ICO issuer cited violations of the state's Uniform Securities Act, illustrating DFR's reliance on securities enforcement rather than a crypto-specific marketing rule to police token promotions.retrieved M3bindingin force
No Vermont-specific crypto tax statute exists; federal characterisation of virtual currency as property for tax purposes governs the computation of gains, losses and ordinary income, which flows through to Vermont filers via the state's general reliance on federal tax mechanics. Federal broker reporting via Form 1099-DA began covering 2025-tax-year transactions in early 2026, increasing IRS visibility into crypto gains nationally, including for Vermont taxpayers.
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 — The IRS has treated cryptocurrency as property for tax purposes for the past decade, treating every sale or exchange as a taxable event generating a capital gain or loss.retrieved M4bindingin force
T4 · CoinDeskCoinDesk — Beginning with 2025 transactions, U.S. cryptocurrency brokers were required to issue Form 1099-DA reporting cost basis and proceeds directly to the IRS, with brokers required to issue the forms by 17 February 2026 and cost-basis reporting continuing for the 2026 tax year onward.retrieved M4bindingin force
T4 · CoinDeskCoinDesk — Ordinary income from crypto activities such as airdrops or compensation is recognized at the fair market value of the token as of the time the taxpayer had the power to sell it, and that value becomes the taxpayer's basis for a later capital gain or loss.retrieved M3bindingin force
Vermont imposes no state-specific cross-border restriction on virtual-currency transfers; cross-border transmission by Vermont-licensed money-transmitter/virtual-currency businesses is governed by federal OFAC sanctions and FinCEN's Bank Secrecy Act framework, including the Funds Travel Rule, which apply nationally regardless of state licensure. The pending GENIUS Act AML/sanctions rulemaking will additionally impose sanctions-screening obligations on permitted payment-stablecoin issuers.
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 · FinCEN / U.S. Department of the TreasuryFinCEN / U.S. Department of the Treasury — FinCEN and OFAC issued a joint proposed rule implementing the GENIUS Act's anti-money-laundering and sanctions compliance program requirements, which would require permitted payment-stablecoin issuers to maintain an effective economic sanctions compliance program, including verification against sanctions lists, consistent with federal law.retrieved M4bindingproposed
T1 · FinCENFinCEN — A money transmitter engaged in convertible-virtual-currency transactions must comply with FinCEN's Funds Travel Rule (31 CFR § 1010.410(f)) for qualifying transmittals of funds, in addition to general recordkeeping requirements, regardless of the state issuing its money-transmitter licence.retrieved M3bindingin force
T4 · CoinDeskCoinDesk — Vermont imposes no state-specific outbound restriction on cross-border cryptocurrency transfers beyond the federal sanctions and BSA/Travel Rule requirements applicable nationwide to licensed money transmitters.retrieved M3non-bindinga fact about the regime
AML/CFT obligations applicable to Vermont-licensed money-transmitter/virtual-currency businesses (KYC/CDD, SAR/STR reporting, sanctions screening, record-keeping) are governed by the federal Bank Secrecy Act framework administered by FinCEN and are treated as subscribed content under crypto's Financial Integrity Module (FIM) aml_ctf baseline rather than duplicated in this jurisdiction-level DR 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
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