Cryptoassets Regulatory Intelligence cryptoassets.gi
US-WA v13.3.0
content: ai_generated legal review: never_reviewed (informational) publication gate: 0 failing10 sources retrieved model claude-sonnet-5 · 2026-08-06

Washington State, USA

US-WA schema crypto-v2.0.0 trajectory: not yet assessedregulated

Last updated · 8 categories · 16 sourced findings · 14 sources in the cumulative register

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Jurisdiction lead brief

Lead Signal

Washington's capital gains excise tax regime has moved from an open question to a confirmed exposure for cryptocurrency holders domiciled in the state. A Challenger-supplied correction, grounded in the Washington Department of Revenue's own FAQ guidance on RCW 82.87, establishes that the excise tax generally applies to gains from cryptocurrency held more than one year and disposed of while the taxpayer is domiciled in Washington, with digital assets treated as intangible personal property for purposes of the tax. This corrects a prior framing that had left the question unresolved, and the correction carries a Probable confidence rating anchored to a single Tier-1 source rather than the Confirmed tier that would require two independently corroborating Tier-1/Tier-2 anchors. The practical effect is that Washington-domiciled holders of appreciated crypto positions face a state-level capital gains exposure notwithstanding the state's much-publicized absence of a general personal income tax -- a nuance that had been understated in the prior baseline.

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Washington has no bespoke crypto-asset statute. Exchange, custody, and cash-to-crypto kiosk businesses are regulated under the general Uniform Money Services Act (RCW 19.230), administered by DFI, with virtual currency expressly defined as 'equivalent value' captured by money-transmission licensing. Two DFI enforcement actions this cycle (a licence-surrender consent order and the Coinme cease-and-desist) confirm active supervisory use of this general MTL regime against crypto-specific business models.

Standing sub-brief268 words · last cycle 2026-09-05

Crypto Licensing

Washington has no bespoke crypto-asset licensing statute. Instead, virtual currency businesses engaged in money transmission must obtain a license under RCW 19.230, the state's Uniform Money Services Act, as extended to virtual currency by 2017's Senate Bill 5031. This licensing obligation has been in force since July 2017 and is unchanged this cycle. Licensed money transmitters, including virtual currency operators, must post a surety bond of between $10,000 and $550,000 (increasable to $1,000,000 in exceptional cases), calculated against the transmitter's prior-year dollar volume; currency exchangers dealing in virtual currency face a separate bond requirement of between $10,000 and $50,000 based on prior-year exchange volume. A Challenger-supplied correction this cycle, grounded in DFI's own published summary of money-transmitter regulation and the SB 5031 bill report (both Tier-1), confirms that licensees may assign a certificate of deposit in favor of the DFI Director in lieu of the surety bond -- correcting an earlier assertion that no alternative security option existed. This is a materially different compliance-cost picture for prospective licensees than the prior framing suggested. Custodial virtual currency operators must additionally undergo a third-party security audit of their data systems as part of licensing.

Periodic update · new data 2026-09-06

Crypto Licensing

Washington requires a Money Transmitter Licence under RCW 19.230, applied for through the Nationwide Multistate Licensing System, covering virtual-currency exchange, custody, and money-transmission activity. This is a general (non-crypto-bespoke) licensing regime: Washington has no separate crypto-specific licence category, and virtual currency is captured within the existing statutory framework as a form of money-transmission activity subject to the same conditions applied to fiat-currency money transmitters. This core requirement carries Confirmed confidence, is treated as in force, and is unchanged this cycle.

This cycle's material development is enforcement rather than legislative or rule change. Washington's DFI entered a consent order requiring a digital-assets-focused money transmitter to surrender its licence within 90 days, citing UMSA violations across net-worth requirements, recordkeeping accuracy, and regulatory filing timeliness. This finding is held at Probable confidence, reflecting reliance on T3 press and legal-alert sourcing without independent retrieval of the underlying DFI order text; the named entity's identity was not disclosed in sources retrieved this cycle. The action demonstrates that DFI is willing to actively enforce the general UMSA licensing regime against digital-asset-specific business models with the same rigor applied to traditional money-services businesses, using licence revocation as the enforcement mechanism of consequence.

A related but analytically distinct finding: Washington has no state-specific token-classification statute, and token-as-security-or-commodity status is determined at the federal level by the SEC and CFTC rather than by DFI. This absence of a state-specific classification regime is itself the finding, held at Probable confidence, and it means that DFI's licensing enforcement authority under UMSA operates independently of, and does not resolve, federal token-classification questions that might separately affect a crypto business's regulatory exposure.

Outlook

Continued DFI enforcement against further crypto-facing money transmitters in coming cycles would strengthen the case that Washington's general licensing regime is being applied as an active, ongoing supervisory tool against crypto business models specifically, rather than reflecting an isolated enforcement action. Resolution of the named-entity gap in the February 2026 consent order, through independent retrieval of the underlying DFI order text, would materially improve confidence in this finding.

1 earlier distinct update(s)
Periodic update · new data 2026-08-26

Crypto Licensing

Washington regulates virtual-currency money transmission through the same Uniform Money Services Act framework (RCW 19.230, WAC 208-690) applied to conventional money transmitters, supervised by the Washington Department of Financial Institutions; this licensing requirement is confirmed at high confidence from a Tier-1 DFI source and is unchanged in structure this cycle. Supervisory activity against a licensee within that framework intensified in February 2026, when the DFI entered a consent order requiring a digital-assets-focused money transmitter to surrender its licence within ninety days for UMSA violations including net-worth and reporting failures; this finding is sourced to a Tier-3 secondary account, with the primary DFI order document not independently retrieved this cycle. The module's traffic light is amber: the regime is settled and licence is required, but the February 2026 enforcement action signals heightened supervisory scrutiny of crypto-sector money-services businesses within that established framework.

Outlook

The item to watch is whether the affected licensee completes its licence surrender within the ninety-day window without further contested proceedings, and whether a primary Washington DFI document becomes available in a future cycle to corroborate this cycle's sole secondary source. A second enforcement instance against another digital-asset money transmitter operating under Washington's Uniform Money Services Act framework would indicate a broader supervisory campaign rather than an isolated action.

Sources and findings (5)
  1. T4 · CoinDeskCoinDesk — Virtual currency businesses engaged in money transmission in Washington must obtain a license from the Washington State Department of Financial Institutions under the money transmitter laws as extended to virtual currency by Senate Bill 5031.retrieved M5bindingin force
  2. T4 · CoinDeskCoinDesk — Virtual currency licensees that store virtual currency on behalf of customers must provide a third-party security audit of their data systems as part of the licensing process.retrieved M4bindingin force
  3. T4 · CoinDeskCoinDesk — Licensed money transmitters, including virtual currency operators, must post a surety bond of between $10,000 and $550,000 (increasable to $1 million in exceptional cases), calculated on the transmitter's dollar volume for the prior year, with no alternative security option permitted.retrieved M4bindingin force
  4. T4 · CoinDeskCoinDesk — Currency exchangers dealing in virtual currency must separately post a surety bond of between $10,000 and $50,000, based on the dollar volume of currency exchanged in the prior year.retrieved M3bindingin force
  5. T4 · CoinDeskCoinDesk — Washington does not maintain a bespoke crypto-asset licensing statute distinct from its general money-transmitter law; the same Uniform Money Services Act licensing standards apply to virtual currency businesses as to traditional fiat money transmitters, with 'virtual currency' defined as a digital representation of value used as a medium of exchange, unit of account, or store of value lacking legal tender status.retrieved M3non-binding

#

Washington has no state-level token classification framework. Whether a given crypto asset is a security, commodity, or other instrument is determined at the federal level by the SEC and CFTC (see US federal JID); the state licensing regime addresses money-transmission and custody activity only, not the legal character of the underlying token.

Standing sub-brief144 words · last cycle 2026-08-06

Token Classification

Washington has not enacted its own token-classification taxonomy. Whether a given digital asset is a security, and thus subject to registration and disclosure obligations, remains a matter governed by federal SEC and CFTC jurisdiction rather than Washington law. The state's money-transmitter licensing regime addresses money-transmission and custodial activity but does not itself speak to securities status; a token that triggers Washington's money-transmission licensing requirement may or may not separately be a security under federal doctrine, and the two analyses are independent of one another.

no periodic updates on record for this sub-brief

Sources and findings (1)
  1. T1 · U.S. Securities and Exchange CommissionU.S. Securities and Exchange Commission — Token characterisation for securities purposes affecting Washington-based crypto activity is governed by federal SEC/CFTC jurisdiction rather than by any Washington-specific statute; Washington's money-transmitter licensing addresses money-transmission and custody, not securities status.retrieved M3bindingin force

#

Washington has no state-specific licensing or regulatory regime that separately addresses on-chain activities such as staking, DeFi lending, DEX operation, node operation, validation, or tokenization. These activities would only be captured incidentally if they meet the general money-transmission definition under RCW 19.230. At the federal level, FinCEN has clarified that a person who mines convertible virtual currency solely for their own purposes is not a money transmitter, which is the only closely on-point interpretive guidance bearing on on-chain activity and is federal, not Washington-specific.

Standing sub-brief191 words · last cycle 2026-08-06

On-Chain Activity Regime

No Washington-specific statute or DFI rule addressing staking, DeFi lending, DEX operation, node operation, validator activity, or tokenization has been identified. To the extent any of these activities are regulated in Washington at all, it would be only through the general money-transmission definition applied on a facts-and-circumstances basis, with no activity-specific carve-outs or interpretive guidance located. Separately, at the federal level, FinCEN has ruled that a company renting computer systems for mining virtual currency, and a user mining virtual currency solely for their own purposes, are not money transmitters under the Bank Secrecy Act -- the one closely on-point piece of interpretive authority bearing on on-chain activity for Washington-based actors, notwithstanding that it is federal rather than state guidance.

no periodic updates on record for this sub-brief

Sources and findings (2)
  1. T1 · FinCENFinCEN — FinCEN has ruled that a company renting computer systems for mining virtual currency, and a user mining virtual currency solely for their own purposes, are not money transmitters under federal BSA rules; this federal interpretation is the primary relevant guidance color for mining activity absent a Washington-specific carve-out.retrieved M2bindingin force
  2. T1 · Nationwide Multistate Licensing System / Washington State DFINationwide Multistate Licensing System / Washington State DFI — No Washington-specific statute or DFI rule addressing staking, DeFi lending, DEX operation, node operation, validator activity, or tokenization was identified; these activities are governed, if at all, only by the general money-transmission definition applied on a facts-and-circumstances basis.retrieved M2non-bindinga fact about the regime

#

Washington has no state-level stablecoin issuance, reserve, redemption, disclosure, or systemic-designation regime. Stablecoin issuance in the U.S. is increasingly governed at the federal level (e.g., the GENIUS Act framework referenced in federal payment-stablecoin legislative activity), which would apply to any Washington-domiciled issuer, but no Washington-specific stablecoin statute was identified.

Standing sub-brief102 words · last cycle 2026-08-06

Stablecoin Regime

No Washington-specific statute establishing stablecoin issuance authorisation, reserve requirements, redemption rights, disclosure obligations, or systemic-designation thresholds has been identified. Any such requirements applicable to Washington-domiciled stablecoin issuers currently derive from federal law rather than state rulemaking, with substantive treatment depending on the evolving federal GENIUS Act framework, which had not been finalized as of this research pass.

no periodic updates on record for this sub-brief

Sources and findings (1)
  1. T1 · Nationwide Multistate Licensing System / Washington State DFINationwide Multistate Licensing System / Washington State DFI — No Washington-specific statute establishing stablecoin issuance authorisation, reserve requirements, redemption rights, disclosure obligations, or systemic designation thresholds was identified; any such requirements applicable to Washington-domiciled issuers currently derive from federal law.retrieved M3non-bindinga fact about the regime

#

Washington's SB 5031 amendments to the Uniform Money Services Act impose specific consumer-facing obligations on virtual currency licensees: disclosure of whether products are insured/guaranteed, an itemized list of fees and charges, and rules restricting the use of license/trade names confusingly similar to existing licensees.

Standing sub-brief105 words · last cycle 2026-09-05

Consumer Protection

Under SB 5031's 2017 amendments to RCW 19.230, virtual currency licensees must disclose whether their products are insured or guaranteed and must provide an itemized list of fees and charges to customers. Separately, money transmitters -- including virtual currency licensees -- are subject to name rules under which DFI can deny licensure where a proposed business name is confusingly similar to an existing licensee's name. Both requirements have been in force since July 2017 and are unchanged this cycle.

Periodic update · new data 2026-09-06

Consumer Protection

Washington's DFI ordered Coinme, a Bitcoin-ATM and kiosk operator, to halt money-transmission activity and repay more than $8 million in customer voucher balances that were allegedly misclassified as company revenue rather than held as consumer funds. This finding rests on a single tier-4 aggregator source, and is accordingly held at Uncertain confidence pending stronger corroboration; the underlying DFI cease-and-desist order text was not independently retrieved this cycle. Despite the confidence limitation on this specific finding, the action itself demonstrates that Washington's general consumer-protection and money-services enforcement apparatus, exercised through UMSA and general consumer-protection authority rather than any crypto-bespoke consumer-protection statute, is capable of reaching kiosk-based cash-to-crypto business models and ordering meaningful consumer redress.

This is a structurally important finding for how Washington's consumer-protection backstop functions for crypto consumers specifically: there is no dedicated crypto consumer-protection statute in Washington, so consumer-facing crypto business models are protected, to whatever extent they are protected, through the same general UMSA and consumer-protection framework applied to any other money-services business. The Coinme action is this cycle's evidence that the backstop is operative rather than merely theoretical, since DFI both identified an alleged misclassification of customer funds and ordered specific monetary redress exceeding $8 million.

Outlook

Independent, higher-tier corroboration of the Coinme cease-and-desist order and its full terms would materially strengthen confidence in this finding. Whether DFI's consumer-protection attention to voucher-balance characterisation and safeguarding practices extends to other Washington-licensed Bitcoin-ATM or kiosk operators beyond Coinme is a question this cycle's evidence does not resolve.

Sources and findings (2)
  1. T4 · CoinDeskCoinDesk — Virtual currency licensees must disclose to customers whether their products are insured and guaranteed, and must provide an itemized list of fees and charges, per the disclosure requirements added by SB 5031.retrieved M4bindingin force
  2. T4 · CoinDeskCoinDesk — Money transmitters, including virtual currency licensees, are subject to license and trade-name rules under which licensure can be denied if a proposed name is confusingly similar to an existing licensee's name.retrieved M2bindingin force

#

Washington State levies no general state personal income tax, so cryptocurrency capital gains are not subject to a Washington-specific state income tax layer (federal IRS treatment of digital assets as property, generating capital gains/losses on disposition, still applies). Washington does operate a state capital gains excise tax (RCW 82.87) on certain long-term gains above a statutory threshold, but no Department of Revenue guidance confirming or excluding cryptocurrency from that excise tax's scope was located in this pass — this is flagged as an open question requiring primary-source escalation.

Standing sub-brief245 words · last cycle 2026-08-06

Tax Treatment

Washington has no general state personal income tax, and realized cryptocurrency gains are not subject to a Washington-specific state income tax layer. However, a Challenger-supplied correction this cycle, grounded in a Washington Department of Revenue FAQ, confirms that the state's capital gains excise tax (RCW 82.87) generally applies to gains from cryptocurrency held more than one year and sold while the taxpayer is domiciled in Washington, with cryptocurrency treated as intangible personal property for purposes of the tax. This corrects a prior framing that had characterized the tax's applicability to crypto as an unresolved open question, and is held at Probable confidence because it rests on a single Tier-1 anchor rather than the two Tier-1/Tier-2 anchors required for a Confirmed rating. Separately, at the federal level, current IRS guidance treats digital assets such as bitcoin as property, meaning dispositions can trigger capital gain or loss recognition and associated federal reporting obligations irrespective of Washington's lack of a state income tax.

no periodic updates on record for this sub-brief

Sources and findings (3)
  1. T3 · SEC EDGAR filing exhibitSEC EDGAR filing exhibit — Washington State does not have a general state personal income tax, relying instead on property taxes, retail sales/use taxes, and business and occupation taxes for revenue; this means realized cryptocurrency gains are not subject to a Washington-specific state income tax layer.retrieved M3bindingin force
  2. T3 · SEC EDGAR filing exhibitSEC EDGAR filing exhibit — Whether Washington's state capital gains excise tax (RCW 82.87) applies to gains from cryptocurrency and other digital-asset disposals has not been confirmed via Department of Revenue guidance located in this research pass.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run
  3. T3 · SEC EDGAR filingSEC EDGAR filing — Under current federal IRS guidance, digital assets such as bitcoin are treated and taxed as property, meaning dispositions (including payments for goods and services) can trigger capital gain or loss recognition and associated federal reporting obligations that apply irrespective of Washington's lack of a state income tax.retrieved M2bindingin force

#

No Washington-specific restriction on outbound or cross-border cryptocurrency transfers was identified. Cross-border transmission is governed by the same state money-transmission licensing framework applicable to domestic transfers, layered under federal sanctions (OFAC) and FinCEN funds-travel-rule requirements, neither of which is Washington-specific.

Standing sub-brief85 words · last cycle 2026-08-06

Cross-Border Transfer

Washington imposes no state-specific outbound restriction on cross-border cryptocurrency transfers beyond its general money-transmission licensing framework. Cross-border compliance obligations relevant to crypto transfers -- sanctions screening and funds-travel-rule compliance -- derive from federal law rather than any Washington-specific rule.

Outlook

Absent a change in federal sanctions or travel-rule frameworks, or the introduction of a Washington-specific cross-border rule, this module's posture is expected to remain stable; substantive monitoring of cross-border exposure for Washington-based activity properly belongs with monitors tracking federal sanctions and travel-rule developments.

no periodic updates on record for this sub-brief

Sources and findings (1)
  1. T1 · Nationwide Multistate Licensing System / Washington State DFINationwide Multistate Licensing System / Washington State DFI — Washington imposes no state-specific outbound restriction on cross-border cryptocurrency transfers beyond the general money-transmission licensing framework; cross-border compliance obligations (sanctions screening, funds-travel-rule) derive from federal law.retrieved M2non-bindinga fact about the regime

#

AML/CFT obligations for crypto businesses (KYC/CDD, travel rule, SAR/STR reporting, sanctions screening, record-keeping, risk assessment) are addressed under the crypto consumer's subscription to the FIM aml_ctf module rather than in this baseline. This module is emitted for structural completeness only; substantive AML/CFT claims are intentionally out of scope here per the fleet subscription model. For disambiguation context only: federal FinCEN guidance treats virtual-currency administrators and exchangers as money transmitters/MSBs subject to BSA obligations, which is the substrate the FIM module draws upon.

Standing sub-brief85 words · last cycle 2026-08-06

AML/CFT Regime

Substantive AML/CFT obligations applicable to Washington-based crypto activity are not populated within this baseline. This is a structural subscription notice rather than original analysis: coverage of AML/CFT requirements for crypto activity in this jurisdiction is subscribed from the financial-integrity monitor's AML/CFT module under the fleet's cross-monitor subscription model, and no original AML/CFT findings were generated here this cycle.

no periodic updates on record for this sub-brief

Sources and findings (1)
  1. T1 · FinCENFinCEN — AML/CFT substantive obligations for Washington-based crypto activity are not populated in this baseline; they are covered under the crypto consumer's subscription to the FIM aml_ctf module.retrieved M1non-bindinga fact about the regime
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tier_a_b_national_primary_pct50.0
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Editorial metadata for Washington State, USA
FieldValue
trust.lawyer_review.statusnever_reviewed
trust.lawyer_review.reviewerno reviewer on record
trust.content_sourceai_generated

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Suppressed by doctrine: derived risk score; per-module RAG traffic light; derived_scores = {}.

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Envelope: baseline resolved at jurisdiction_json.baseline; 8 module(s), 16 finding(s), 14 source(s) in the cumulative register.

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