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Wisconsin, USA
US-WIschema crypto-v2.0.0trajectory: not yet assessedin transitionoverlaps: Advennt, WPM
Last updated · 8 categories · 14 sourced
findings · 9 sources in the cumulative register
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Jurisdiction lead brief
Lead Signal
2025 Wisconsin Act 226 took effect on April 9, 2026, creating a new licensable activity class for virtual currency kiosk operation under Wis. Stat. §217.12 and requiring compliance with the statute's transaction, disclosure, and refund requirements. This tightens Wisconsin's crypto-licensing posture at the margin: kiosk operators now sit inside a defined regulatory perimeter for the first time, administered by the Wisconsin Department of Financial Institutions, Division of Banking, under the existing Chapter 217 money-transmission framework.
Other Developments
The licensing picture is also shaped by what did not pass. Wisconsin AB471, which would have exempted node operation, crypto-to-crypto exchange, blockchain software development, and staking or mining activity from Chapter 217 licensing, failed to pass, leaving the licensing applicability of those activities undefined by statute rather than resolved in either direction. On the consumer-protection side, kiosk operators must now affix a statutorily prescribed fraud-alert warning and obtain customer acknowledgment before each transaction, and must refund the full transaction amount to a customer who reports a transaction as fraudulent to law enforcement within 30 days. Both obligations have been in force since April 9, 2026, and both were designed around a documented fraud vector rather than a general digital-asset consumer-protection framework.
Cross-Monitor Connections
This cycle's Wisconsin crypto-licensing and consumer-protection developments overlap with the financial-integrity monitor's typology work on crypto-kiosk fraud and laundering controls, and with the world-payments monitor's tracking of the same statute as a licensing and market-access development; the gambling-regulatory monitor has separately flagged the kiosk law as an adjacent, non-gambling-specific funding-channel consideration. This crypto-monitor treatment is limited to the licensing and consumer-protection lens on the same underlying instrument.
Outlook
Watch for whether the Wisconsin DFI issues interpretive guidance clarifying the licensing status of staking, node operation, or mining activity now that AB471 has failed, and for early indications of how the new kiosk-specific transaction cap, disclosure, and refund requirements affect reported fraud volumes once enforcement experience accumulates under the new statute.
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Wisconsin has no bespoke crypto-asset licensing statute. Virtual-currency exchange, custody and money-transmission activity is captured under Wisconsin's general money-transmitter licensing regime, administered by the Wisconsin Department of Financial Institutions (DFI) and processed through the multistate NMLS infrastructure used by most U.S. states. Separately, Wisconsin has moved aggressively against prediction-market platforms (several of which are crypto-native exchanges) on the theory that their 'event contracts' constitute unlicensed gambling under state law, triggering a direct federal preemption fight with the CFTC.
Standing sub-brief217 words · last cycle 2026-08-21
Crypto Licensing
Wisconsin's 2025 Act 226 creates a new licensable activity class for virtual currency kiosk operation under Wis. Stat. §217.12, effective April 9, 2026. Kiosk operators must now hold the relevant licensure or registration and comply with the statute's transaction, disclosure, and refund requirements, placing this narrow category of crypto-adjacent activity inside Wisconsin's existing Chapter 217 money-transmission licensing architecture for the first time. The primary framework remains Wis. Stat. Ch. 217 generally, with §217.12 as the kiosk-specific overlay, and the supervisory authority is the Wisconsin Department of Financial Institutions, Division of Banking.
Outside the kiosk-specific amendment, Wisconsin's broader crypto-licensing perimeter did not move this cycle. AB471, which would have exempted node operation, crypto-to-crypto exchange, blockchain software development, and staking or mining activity from Chapter 217 licensing, failed to pass. That failure leaves the licensing status of those activities legally undefined rather than confirmed as exempt or confirmed as covered, a live ambiguity rather than a settled position.
Outlook
The core open question is whether the Wisconsin DFI will issue interpretive guidance addressing the licensing status of staking, node operation, mining, or other on-chain activity now that AB471 has failed to resolve the question through legislation. Absent such guidance, market participants engaged in those activities in Wisconsin operate without a clear statutory answer on Chapter 217 applicability.
No new data since the standing brief. 1 periodic run re-emitted it unchanged.
Sources and findings (3)
T1 · Nationwide Multistate Licensing System / State Regulatory Registry LLCNationwide Multistate Licensing System / State Regulatory Registry LLC — Virtual-currency exchange, custody, and transmission businesses operating in Wisconsin are subject to the state's general money-transmitter licensing law, administered by the state banking/financial-institutions department and processed through NMLS, in the absence of any Wisconsin-specific crypto licensing statute.retrieved M4bindingin force
T4 · CoinDeskCoinDesk — Wisconsin has filed civil suits characterizing prediction-market 'event contracts' offered by crypto-linked platforms (including Crypto.com, Coinbase, Robinhood, Polymarket, and Kalshi) as unlicensed gambling under state law, asserting state jurisdiction over these products.retrieved M4non-binding
T1 · U.S. Commodity Futures Trading CommissionU.S. Commodity Futures Trading Commission — The CFTC has sued Wisconsin to reaffirm exclusive federal jurisdiction over event-contract/prediction-market products traded on CFTC-designated contract markets, directly contesting Wisconsin's state-law gambling characterization of these crypto-adjacent platforms.retrieved M5non-binding
Wisconsin has no state-level token taxonomy; classification of crypto assets as securities, commodities, or other instrument types is governed exclusively at the federal level by the SEC (in coordination with the CFTC), most recently through the SEC's March 2026 interpretive release establishing a five-category taxonomy (digital commodities, digital collectibles, digital tools, stablecoins, digital securities) and its January 2026 statement on tokenized securities.
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 · U.S. Securities and Exchange CommissionU.S. Securities and Exchange Commission — The SEC's 2026 interpretive release classifies crypto assets into five categories based on characteristics, uses, and functions: digital commodities, digital collectibles, digital tools, stablecoins, and digital securities, with digital commodities, collectibles, and tools not themselves treated as securities.retrieved M5non-binding
T2 · U.S. Securities and Exchange Commission (Division of Corporation Finance et al.)U.S. Securities and Exchange Commission (Division of Corporation Finance et al.) — A tokenized security is a financial instrument that meets the definition of a security under federal securities laws and is formatted as or represented by a crypto asset, with the record of ownership maintained in whole or in part on one or more crypto networks.retrieved M4non-binding
T2 · U.S. Securities and Exchange CommissionU.S. Securities and Exchange Commission — Under the SEC's 2026 taxonomy, a payment stablecoin used as a means of payment or settlement is generally not treated as a security, subject to the terms of the GENIUS Act, though non-payment stablecoins may still meet the definition of a security depending on facts and circumstances.retrieved M4non-binding
Wisconsin has not enacted any state-specific licensing or regulatory regime for on-chain activities such as staking, DeFi lending, mining, node operation, or validation. Federal characterization (SEC/CFTC) of the underlying digital commodity governs most substantive treatment; state money-transmitter law may incidentally apply only if an activity involves custodial transmission of value.
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 / State Regulatory Registry LLCNationwide Multistate Licensing System / State Regulatory Registry LLC — No Wisconsin-specific statute or DFI rule imposing licensing or registration requirements on virtual-currency mining, staking, validation, or node-operation activity has been identified as of this research pass.retrieved M2non-bindingour coverage gap, expected to resolve on a re-run
Wisconsin has no state-level stablecoin issuance, reserve, or redemption regime. Stablecoin treatment is governed federally by the GENIUS Act framework referenced in the SEC's 2026 crypto-asset interpretation, under which payment stablecoins issued by permitted issuers are categorically excluded from the securities definition once the Act is effective.
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 · U.S. Securities and Exchange CommissionU.S. Securities and Exchange Commission — Payment stablecoins issued to permitted stablecoin holders in connection with holding, use, or retention of the stablecoin will categorically not be securities by operation of statute after the GENIUS Act's effective date, per the SEC's 2026 interpretive release.retrieved M4non-binding
T1 · U.S. Securities and Exchange CommissionU.S. Securities and Exchange Commission — No Wisconsin-specific reserve, redemption-right, or systemic-designation regime for stablecoin issuers has been identified; the state defers entirely to the federal GENIUS Act framework.retrieved M3non-bindinga fact about the regime
Investor-protection outreach for Wisconsin crypto/digital-asset investors runs primarily through the Wisconsin DFI's Securities Division in coordination with the SEC and NASAA, rather than through any crypto-specific consumer-protection statute. No Wisconsin-specific crypto marketing-restriction, custody-segregation, or suitability rule distinct from general securities/MTL consumer-protection law has been identified.
Standing sub-brief173 words · last cycle 2026-08-21
Consumer Protection
Since April 9, 2026, Wisconsin's virtual currency kiosk operators have been required to affix a statutorily prescribed fraud-alert warning and obtain customer acknowledgment before each transaction under 2025 Wisconsin Act 226. The same statute requires kiosk operators to refund the full transaction amount to a customer who reports a transaction as fraudulent to law enforcement within 30 days. Both obligations sit inside Wis. Stat. §217.12 and are administered by the Wisconsin Department of Financial Institutions, Division of Banking, alongside the kiosk-licensing requirement itself.
These are targeted, transaction-level protections aimed at a documented fraud typology, cash-to-crypto kiosk conversion, rather than a general digital-asset consumer-protection framework. Wisconsin has not adopted a broader digital-asset disclosure or suitability regime; the protections apply specifically to kiosk transactions rather than to crypto-asset activity generally.
Outlook
Watch for early indications of how the fraud-alert, acknowledgment, and 30-day refund requirements affect reported kiosk-fraud volumes as enforcement experience accumulates, and for whether Wisconsin extends comparable consumer-protection obligations to other categories of crypto-asset activity beyond kiosks in a future legislative session.
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 Wisconsin DFI Securities Division has partnered with the SEC and NASAA on investor-protection roundtables aimed at strengthening investor advocacy for Wisconsin investors, including exposure to investment products and services more broadly (not crypto-exclusive).retrieved M2non-binding
Wisconsin's crypto tax treatment is expected to follow the federal income-tax baseline (crypto as property, capital-gains treatment on disposition) because Wisconsin's individual income tax generally conforms to federal adjusted gross income definitions; however, no Wisconsin Department of Revenue-specific crypto guidance was independently verified in this pass, so state-conformity claims carry lower confidence than the underlying federal claims.
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 rather than currency for federal tax purposes, meaning sales and exchanges are treated as taxable events for capital-gains purposes.retrieved M4bindingin force
T4 · The BlockThe Block — Starting with the 2025 tax year, crypto brokers such as Coinbase and Kraken began issuing Form 1099-DA reporting gross proceeds from digital-asset dispositions to both customers and the IRS, with broker-reported cost basis beginning in the 2026 tax year.retrieved M4bindingin force
T4 · CoinDeskCoinDesk — Whether Wisconsin's individual income tax treats crypto gains identically to the federal property characterization via state conformity to federal AGI has not been independently confirmed against Wisconsin Department of Revenue primary guidance in this research pass.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run
Wisconsin has no state-specific cross-border crypto transfer regime; outbound-restriction, sanctions-nexus, and travel-rule obligations affecting cross-border crypto transfers are governed exclusively at the federal level (OFAC sanctions, FinCEN travel rule), consistent with the state's lack of a bespoke crypto statute.
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 / State Regulatory Registry LLCNationwide Multistate Licensing System / State Regulatory Registry LLC — No Wisconsin-specific cross-border crypto transfer restriction, reporting threshold, or travel-rule provision distinct from the federal FinCEN/OFAC framework has been identified.retrieved M2non-bindinga fact about the regime
Crypto AML/CFT obligations are subscribed from the fleet's Financial Integrity Monitor (FIM) module and are not re-baselined here per the F9 subscription rule. Any AML-relevant material found (e.g., FinCEN money-transmitter/exchanger characterization of virtual-currency businesses) is captured only as disambiguation context: federal FinCEN treatment of virtual-currency exchangers/administrators as money transmitters subject to BSA registration is the operative federal backdrop against which Wisconsin's state MTL regime sits, but substantive AML/CFT claims belong to the FIM baseline, not this crypto baseline.
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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