Cryptoassets Regulatory Intelligence cryptoassets.gi
US-WY v13.3.0
content: ai_generated legal review: never_reviewed (informational) publication gate: 2 failing13 sources retrieved model claude-sonnet-5 · 2026-08-06

Wyoming, USA

US-WY schema crypto-v2.0.0 trajectory: not yet assessedregulatedoverlaps: FIM, WPM

Last updated · 8 categories · 19 sourced findings · 18 sources in the cumulative register

8Categoriesbaseline.
19Findings.claims[]
5Tier-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

Wyoming enters this baseline cycle as the most institutionally mature state-level crypto framework in the United States, anchored by its Special Purpose Depository Institution (SPDI) Act, which creates a bespoke banking charter permitting SPDI-chartered banks to conduct digital-asset custody, asset servicing and fiduciary asset management outside the standard money-transmitter licensing track. That charter sits alongside a conventional Money Transmitters Act licensing requirement for non-SPDI fiat-money-transmission businesses, giving Wyoming a genuinely multi-track regulatory architecture rather than a single blunt licensing gate. The state's principal remaining constraint is not domestic policy design but federal plumbing: SPDI-chartered banks still lack assured access to a Federal Reserve master account, the mechanism that would let them settle directly in central-bank money rather than through correspondent banking relationships. This cycle's review process surfaced a materiality gap in how that constraint has been tracked. Secondary reporting suggests Custodia Bank, the SPDI at the center of the multi-year Fed master-account dispute, may already have filed a certiorari petition with the U.S. Supreme Court by mid-July 2026 -- a more advanced litigation posture than this baseline's working framing of an open question about whether Supreme Court review would be sought at all. That claim rests solely on secondary press coverage rather than a primary court-docket source, and it has accordingly been held back from confident publication pending verification. A partially offsetting development was also identified: the Federal Reserve reportedly opened a narrower 'skinny' master-account pathway in March 2026, exemplified by a grant to Kraken, representing incremental movement on the same federal-access question. Neither development changes the underlying assessment that Wyoming's state-level regime is comprehensive and in force; what has changed is the confidence with which the federal-access narrative around it can be stated without primary-source confirmation.

8 of 8 categories
Signal
Density

Selections OR within a group, AND across groups. Press / to search.

#

Wyoming exempts virtual currency from its Money Transmitter Act for general buy/sell/custody activity, but has carved virtual-currency kiosks back into the licensing perimeter via HB0075.

Standing sub-brief565 words · last cycle 2026-08-25

Crypto Licensing

Wyoming's crypto licensing framework rests on three complementary tracks rather than a single license type, and all three are confirmed as in force. The first is the Special Purpose Depository Institution (SPDI) Act, which establishes a bespoke banking charter enabling SPDI-chartered institutions to conduct digital-asset custody, asset servicing and fiduciary asset management -- a distinct regulatory lane from a standard money-transmitter license. The second track is the conventional Wyoming Money Transmitters Act (W.S. Title 40, Chapter 22), which requires a money transmitter licence for non-SPDI crypto businesses conducting fiat money transmission -- the baseline licensing gate for a typical exchange or payments business operating without SPDI status. The third track is a pair of narrower exemptions dating to 2018: an amendment (the 'bitcoin bill') exempting virtual-currency transactions from the state money-transmitter licensing requirement, and a companion statute exempting developers and sellers of consumptive-purpose utility tokens from state securities and broker-dealer registration. Both 2018-era exemptions are treated as confirmed and currently in force, but the underlying evidentiary base for each is secondary reporting rather than the Wyoming Legislature's own statutory text; the precise statutory citation and effective date for both remain to be independently retrieved.

Periodic update · new data 2026-08-26

Crypto Licensing

Wyoming's Money Transmitters Act now requires that a person may not own, operate, or manage a virtual currency kiosk in the state unless licensed under the Act or chartered as a Wyoming financial institution. This licensing carve-in, enacted under HB0075 and in force since March 6, 2026, closes a gap that had previously left kiosk operation outside money-transmission licensing entirely. The carve-in sits alongside, rather than replaces, Wyoming's long-standing general exemption: buying, selling, issuing, or taking custody of payment instruments in virtual currency remains exempt from Wyoming money-transmission licensing outside the kiosk context specifically.

This is best read as a targeted correction rather than a reversal of Wyoming's crypto-licensing philosophy. The state's exemption-based approach to general virtual-currency activity remains intact; the legislature chose to narrow the exemption's scope at exactly the point where an identifiable retail fraud pattern had emerged. Operators offering general crypto services outside the kiosk channel continue to operate under the existing exemption; only kiosk operators face a new, affirmative licensing or bank-charter obligation.

Outlook

Watch for Wyoming Division of Banking guidance specifying the licensing application process and any transition timeline for kiosk operators previously operating without a licence.

Sources and findings (4)
  1. T1 · Wyoming Division of BankingWyoming Division of Banking — Wyoming's Special Purpose Depository Institution (SPDI) Act creates a bespoke banking charter under which SPDIs receive deposits and conduct custody, asset servicing and fiduciary asset management for digital assets, distinct from a standard money-transmitter licence.retrieved M5bindingin forceour coverage gap, expected to resolve on a re-run
  2. T1 · Wyoming Division of BankingWyoming Division of Banking — Crypto businesses in Wyoming that engage in fiat money transmission and are not chartered as an SPDI must obtain a money transmitter licence under the Wyoming Money Transmitters Act (W.S. Title 40, Chapter 22).retrieved M4bindingin forceour coverage gap, expected to resolve on a re-run
  3. T4 · CoinDeskCoinDesk — Wyoming law exempts virtual-currency transactions from the state's money-transmitter licensing requirements, following enactment of a 2018 'bitcoin bill' amending the Wyoming Money Transmitters Act.retrieved M4bindingin forceour coverage gap, expected to resolve on a re-run
  4. T4 · CoinDeskCoinDesk — Wyoming exempts developers and sellers of 'utility tokens' from state securities and broker-dealer registration where the token is not marketed as an investment and is issued/sold exclusively for a 'consumptive purpose' (exchangeable for goods or services), under a 2018 law.retrieved M4bindingin forceour coverage gap, expected to resolve on a re-run

#

Wyoming's statutory taxonomy is narrow but binding: a 2018 carve-out defines and exempts 'utility tokens' sold for consumptive purpose from securities law, and the 2023 Stable Token Act creates a distinct state-issued stablecoin category (WYST/rebranded FRNT). Beyond these two defined categories, classification of other token types (security tokens, NFTs, asset-referenced tokens) is not separately codified at state level and remains a facts-and-circumstances analysis, frequently deferring to federal securities/commodities characterization.

Standing sub-brief375 words · last cycle 2026-08-06

Token Classification

Wyoming's approach to token classification is built around two clearly codified categories rather than a comprehensive taxonomy. The first is the utility token: a 2018 statute classifies tokens issued or sold exclusively for a consumptive purpose as exempt from state securities regulation, mirroring the licensing-side utility-token exemption tracked under Wyoming's crypto-licensing framework. This is the same underlying statutory exemption viewed through a token-classification lens rather than a licensing lens, and it is treated as confirmed and in force, subject to the same secondary-sourcing caveat noted elsewhere.

no periodic updates on record for this sub-brief

Sources and findings (3)
  1. T4 · CoinDeskCoinDesk — Tokens issued and sold exclusively for consumptive purpose (exchangeable for goods or services, not marketed as an investment) qualify for Wyoming's statutory utility-token exemption from securities regulation.retrieved M4bindingin forceour coverage gap, expected to resolve on a re-run
  2. T4 · CoinDeskCoinDesk — The Wyoming Stable Token Act authorizes the state-created Wyoming Stable Token Commission to issue a fully-reserved, U.S.-dollar-pegged stablecoin; the Frontier Stable Token (FRNT, formerly marketed as WYST) launched on mainnet across seven blockchains on August 19, 2025 as the first fully-reserved stablecoin issued by a U.S. public entity.retrieved M5bindingin force
  3. T4 · CoinDeskCoinDesk — Wyoming has not enacted a comprehensive state-level token taxonomy beyond the utility-token and stable-token categories; whether a given token is a security or other instrument under Wyoming/federal law remains a facts-and-circumstances determination.retrieved M3non-binding

#

Wyoming's most consequential on-chain-activity intervention is property-law, not licensing: the 2019 digital-asset property statute (amended effective July 1, 2021) classifies digital assets as property under the Wyoming Uniform Commercial Code, enabling perfection and priority of security interests in tokenized/digital assets and thereby facilitating on-chain tokenization of collateral. Wyoming has not enacted activity-specific licensing or prudential regimes distinct from general banking/securities law for staking, DeFi lending, DEX operation, mining, node operation, or validator activity.

Standing sub-brief320 words · last cycle 2026-08-06

On-Chain Activity Regime

Wyoming's on-chain activity regime is anchored by a single, well-developed statutory pillar and otherwise largely undeveloped. The pillar is the state's digital-asset property-law statute (Wyo. Stat. § 34-29-101 et seq.), which governs the perfection and priority of security interests in digital assets under Wyoming's UCC framework, with an amendment effective 1 July 2021. This gives Wyoming a clear, in-force legal basis for using digital assets as collateral and for establishing lien priority on tokenized assets -- a foundational piece of infrastructure predating much of the more recent legislative activity around licensing and stablecoins.

no periodic updates on record for this sub-brief

Sources and findings (2)
  1. T1 · Wyoming Division of BankingWyoming Division of Banking — Wyoming's digital-asset property law defines digital assets in conjunction with the Wyoming Uniform Commercial Code and governs perfection and priority of security interests in digital assets; the statute was amended with the amendment becoming effective July 1, 2021.retrieved M4bindingin force
  2. T1 · Wyoming Division of BankingWyoming Division of Banking — Wyoming has not enacted activity-specific licensing or prudential requirements for cryptocurrency mining, staking, validator operation, DEX operation, or DeFi lending distinct from its general money-transmission and securities frameworks.retrieved M2non-binding

#

The Wyoming Stable Token Act (enacted March 2023) created the Wyoming Stable Token Commission and authorized issuance of a state-backed, fiat-redeemable stablecoin. The resulting token — marketed variously as WYST and, at mainnet launch, as the Frontier Stable Token (FRNT) — went live on seven blockchains on August 19, 2025, over-collateralized and backed by cash, short-term U.S. Treasuries and repurchase agreements, with third-party audit/attestation and reserve-management partners engaged.

Standing sub-brief506 words · last cycle 2026-09-21

Stablecoin Regime

Wyoming's stablecoin regime is the most operationally developed and, this cycle, the most evidentially contested part of its crypto framework. The Wyoming Stable Token Act (2023) authorizes the Wyoming Stable Token Commission to research, develop and issue a state-backed stablecoin, and that authorization has moved from statute to a live product: the Frontier Stable Token (FRNT, formerly branded WYST) launched on mainnet across seven blockchains on 19 August 2025. Reported operational architecture around FRNT is substantial. The token is described as maintaining an over-collateralized reserve -- reported at roughly 102 percent -- composed of cash and short-term U.S. Treasury securities, managed by Franklin Advisers. It is described as redeemable at a fixed 1:1 U.S.-dollar value, with issuance proceeds placed in a trust invested in cash and Treasury securities to support that redemption right. And the Commission is reported to have engaged a supporting vendor ecosystem: The Network Firm for audits and monthly attestations of FRNT, Inca Digital for surveillance and analytics, and Fireblocks and LayerZero for underlying infrastructure.

Periodic update · new data 2026-09-22

Stablecoin Regime

Wyoming's Frontier Stable Token, trading as FRNT/WYST, became publicly purchasable via Kraken, a Wyoming-domiciled cryptocurrency exchange, on January 7, 2026, under the Wyoming Stable Token Act (W.S. 40-31-101 et seq.), issued by the Wyoming Stable Token Commission. It is the first fiat-backed, fully-reserved stable token issued by a US public entity. The Act imposes a statutory capitalization requirement of not less than 102 percent, meaning reserves must exceed the circulating token value by at least two percent, held in USD and short-duration Treasuries managed by Franklin Templeton and custodied by Fiduciary Trust Company International.

On September 2, 2026, the Commission adopted Chainlink Proof of Reserve, enabling real-time on-chain verification of reserve backing. This followed an earlier migration from LayerZero/Stargate cross-chain infrastructure to Chainlink's CCIP in August 2026, and it supplements the token's existing daily attestation practice with continuous, cryptographically verifiable on-chain disclosure. This represents an escalation in the state's public-stable-token disclosure infrastructure: the token's reserve backing can now be checked on-chain in near real time rather than relying solely on periodic attestation reports, positioning Wyoming's instrument ahead of most peer state-issued stable-token programs in transparency tooling.

Whether FRNT/WYST's circulation is subject to a statutory cap, or whether any observed circulation ceiling reflects a self-imposed operational choice by the Commission, was not fully resolved this cycle and remains an open question for future verification.

Outlook

Watch for further on-chain disclosure enhancements and for clarification of whether circulation limits are statutory or operational. The Commission's rapid infrastructure iteration -- moving from LayerZero/Stargate to Chainlink CCIP and then to Chainlink Proof of Reserve within roughly a month -- suggests continued near-term technical development of the program's verification tooling is likely.

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

Stablecoin Regime

The Frontier Stable Token, described as the first fiat-backed, fully-reserved stable token issued by a public entity in the United States, is now publicly available for purchase via Kraken. Wyoming stable tokens are fully backed by U.S. dollars and short-duration U.S. Treasuries, with interest income earned on the reserve returned to the State rather than retained by a private issuer. This reserve structure is the defining feature distinguishing Wyoming's public-instrumentality stable-token model from privately issued stablecoins that dominate the broader market.

FRNT's transition to public-purchase availability marks a genuine advance from program development to live retail distribution. The token is distributed through Kraken, a Wyoming-chartered exchange, giving the state's stable-token programme a distribution channel within the same state-level regulatory ecosystem that created the token itself.

Outlook

Watch for the token's transaction volume and reserve-balance reporting now that public purchase is available, and for whether additional Wyoming-chartered exchanges are added as distribution channels.

Sources and findings (4)
  1. T4 · The BlockThe Block — The Wyoming Stable Token Act, passed in March 2023, authorizes the Wyoming Stable Token Commission to research, develop and issue a state-backed stablecoin.retrieved M5bindingin forceour coverage gap, expected to resolve on a re-run
  2. T4 · The BlockThe Block — The Frontier Stable Token (FRNT) is designed to be over-collateralized, holding a minimum reserve ratio (reported at approximately 102%) of cash and short-term U.S. Treasurys managed by Franklin Advisers.retrieved M4bindingin force
  3. T4 · The BlockThe Block — Wyoming's state-issued stable token is designed to be redeemable at a fixed 1:1 U.S.-dollar value, with issuance proceeds placed into a trust invested in cash and U.S. Treasury securities.retrieved M4bindingin forceour coverage gap, expected to resolve on a re-run
  4. T4 · CoinDeskCoinDesk — The Wyoming Stable Token Commission engaged The Network Firm to conduct audits and monthly attestations for the Frontier Stable Token, alongside Inca Digital for surveillance/analytics and Fireblocks/LayerZero for infrastructure.retrieved M3bindingin force

#

Consumer protection for digital-asset customers in Wyoming is delivered principally through SPDI prudential rules (100% fiat-deposit backing, prohibition on lending customer deposits) rather than a dedicated crypto-consumer-protection statute. A 2020 Division of Banking no-action letter recognized a Wyoming-chartered public trust company as a 'qualified custodian' for digital assets under the Advisers Act Custody Rule, but the SEC subsequently withdrew its own staff statement acknowledging that letter, introducing uncertainty about federal recognition of the state custody framework.

Standing sub-brief320 words · last cycle 2026-08-25

Consumer Protection

Wyoming's consumer-protection framework for crypto activity centers on custody and segregation rules for SPDI-chartered institutions, which are clear, specific, and in force. SPDIs are required to maintain customer fiat deposits backed 100 percent or more by unencumbered liquid assets, and are affirmatively prohibited from lending customer fiat deposits. This is a meaningfully stronger segregation standard than a typical money-transmitter bonding requirement, reflecting the SPDI charter's origin as a bank-grade custody vehicle.

Periodic update · new data 2026-08-26

Consumer Protection

HB0075 attaches two new consumer-protection mechanisms directly to virtual-currency kiosk transactions. First, kiosk transactions are now subject to a mandatory waiting period, 48 hours for new users and 24 hours for existing users, during which a user may cancel the transaction. Second, unlicensed operation of a virtual currency kiosk in Wyoming now carries felony charges, prison sentences of at least three years, and fines of at least $10,000.

Together these two mechanisms give Wyoming's kiosk consumer-protection regime independent levers at two different points in the fraud lifecycle: the cooling-off window gives a user time to reconsider and cancel a transaction already underway, while the felony-level penalty is designed to deter unlicensed operators from entering the kiosk market at all.

Outlook

Watch for whether the felony-penalty structure produces an early enforcement action or prosecution, and for reported fraud-loss data in subsequent cycles as an indicator of the cooling-off window's effectiveness.

Sources and findings (2)
  1. T1 · Wyoming Division of BankingWyoming Division of Banking — As fully-reserved banks, Wyoming SPDIs are prohibited from making loans with customer fiat deposits and must maintain customer fiat deposits backed 100% or more by unencumbered liquid assets at all times.retrieved M4bindingin forceour coverage gap, expected to resolve on a re-run
  2. T1 · U.S. Securities and Exchange CommissionU.S. Securities and Exchange Commission — The SEC has withdrawn its staff statement that had acknowledged a Wyoming Division of Banking no-action letter recognizing a state-chartered trust company as a 'qualified custodian' for digital assets, creating uncertainty about federal recognition of Wyoming's state-level custody framework.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run

#

Wyoming levies no state personal or corporate income tax, so crypto-related income and gains follow federal tax treatment only (property characterization per IRS guidance). Separately, Wyoming has enacted a state property-tax exemption for virtual currencies, removing crypto holdings from ad valorem taxation. There is no Wyoming-specific crypto tax reporting regime beyond federal obligations.

Standing sub-brief282 words · last cycle 2026-08-06

Tax Treatment

Wyoming's tax treatment of crypto activity is structurally favorable on the facts available, though the evidentiary base behind that favorable picture is thinner than for most other modules in this baseline. Two structural features stand out. First, Wyoming imposes no state corporate or personal income tax at all, meaning crypto income and gains realized by Wyoming taxpayers are subject only to federal income tax treatment, under the IRS's existing property-characterization approach. Second, and more crypto-specific, Wyoming exempts virtual currencies from the state's ad valorem property tax, a targeted exemption rather than a byproduct of the general no-income-tax structure.

no periodic updates on record for this sub-brief

Sources and findings (3)
  1. T4 · CoinDeskCoinDesk — Wyoming law exempts virtual currencies from the state's ad valorem property tax, removing crypto asset holdings from that state-level tax base.retrieved M3bindingin forceour coverage gap, expected to resolve on a re-run
  2. T4 · CoinDeskCoinDesk — Wyoming imposes no state corporate or personal income tax, so income or gains from crypto activity are subject only to federal income tax treatment (virtual currency treated as property per IRS guidance).retrieved M4bindingin forcea fact about the regime
  3. T4 · CoinDeskCoinDesk — Wyoming has no state-specific crypto tax reporting regime; reporting obligations for Wyoming taxpayers holding or transacting in crypto derive solely from federal (IRS) reporting requirements.retrieved M2non-binding

#

Wyoming state law does not impose any distinct cross-border restriction, sanctions nexus, or reporting-threshold regime on cryptocurrency transfers; cross-border movement of digital assets by Wyoming-domiciled entities is governed by federal law (FinCEN, OFAC) rather than any state-level instrument, consistent with the general preemption pattern for cross-border payments regulation in the U.S. state system.

Standing sub-brief159 words · last cycle 2026-08-06

Cross-Border Transfer

Wyoming imposes no state-level restriction on cross-border cryptocurrency transfers. To the extent cross-border crypto transfers are regulated at all, that regulation occurs exclusively at the federal level, through FinCEN and OFAC frameworks, rather than through any Wyoming-specific statute or Division of Banking rule. This finding is treated as a legitimate negative finding rather than a research gap, though it is rated Probable confidence and rests on a single Wyoming Division of Banking source addressing money-transmission law generally rather than cross-border transfer specifically. This module is thin across the estate generally, and Wyoming's finding here is consistent with that broader pattern.

no periodic updates on record for this sub-brief

Sources and findings (1)
  1. T1 · Wyoming Division of BankingWyoming Division of Banking — Wyoming imposes no state-level restriction on cross-border cryptocurrency transfers; such transfers are governed exclusively by federal law (FinCEN/OFAC), not by any Wyoming statute or Division of Banking rule.retrieved M2non-bindinga fact about the regime

#

Crypto AML/CFT obligations for this JID are covered under the fleet's Financial Integrity Module (FIM) aml_ctf subscription and are intentionally out of scope for this baseline per the module-subscription rule. Context only: Wyoming SPDI examinations reference a dedicated 'Wyoming SPDI BSA/AML and OFAC examination manual,' and Wyoming Stable Token Commission has engaged a third-party analytics vendor (Inca Digital) for stablecoin-related monitoring — both are disambiguation context, not baseline AML 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

No categories match.

Filters combine as OR inside a group and AND across groups.

Publication gate

Blocking. 2 failing check(s).

schema_validFAIL
min_quoted_text_presentwaived — floor 0%
egress_verifiedpass
every_practical_object_has_source_idn/a — no subject in this jurisdiction
source_tier_integrity_okFAIL
jurisdiction_source_floor_metpass
tier_a_b_national_primary_pct19.23
aggregator_only_jurisdiction_count0
manual_override

Editorial metadata

Provenance only. Nothing below gates publication or affects the render.

Editorial metadata for Wyoming, USA
FieldValue
trust.lawyer_review.statusnever_reviewed
trust.lawyer_review.reviewerno reviewer on record
trust.content_sourceai_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.

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

Band honesty: uncertainty bands are computed against a frozen build clock of 2026-09-27. A year-precision row is never promoted into a tighter band.

Orphan deltas: 0 cycle_delta row(s) target non-module objects and are listed in the rail rather than attached to a card.

Envelope: baseline resolved at jurisdiction_json.baseline; 8 module(s), 19 finding(s), 18 source(s) in the cumulative register.

Think something on this page is wrong? Report an error.