Money Transmitter page (virtual currency and kiosk statements)

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Research, not advice. Part of the Bitcoin research archive (October 2026). Claims labelled unverified, contested or fringe are reported, not endorsed; statuses of bills and rules are as of the date checked. Government, court and patent records are public domain; the research notes are CC BY 4.0.

DFI

            Money Transmitter

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                            Money Transmitter

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Licensed under chapter 217 of the Wisconsin Statutes, money transmitters engage in the business of transmitting money and/or selling or issuing checks, including money orders, traveler's checks and prepaid cards.

2023 WI Act 267 & the Money Transmitter Modernization ActWI Act 267 was signed by Governor Evers on April 4, 2024, and became effective on January 1, 2025.  The Act repealed Chapter 217 of the Wisconsin Statutes, which was known as the Seller of Checks law, and replaced it with the Model Money Transmission Modernization law.  

More information about the Model Money Transmission Law is found here.

​Virtual Currency Kiosk OperatorsVirtual currency kiosk operators must be licensed under the state’s money transmission law, which includes several provisions specifically addressing kiosk operations.  See 2025 Wisconsin Act 226. 

Notice to Customers:  If you were induced to engage in a virtual currency kiosk transaction in connection with a fraud or scam, you should immediately report the fraud to (1) the kiosk operator and (2) the DFI or your local law enforcement agency.  Reporting is important to protect others, and if the fraud is reported to both the kiosk operator and to law enforcement within 30 days of the transaction, you may be eligible for a refund under state law. 

Frequent Links
Applications - Licenses must be applied for through the Nationwide Multistate Licensing System & Registry (NMLS). Links to NMLS resources are found below.  Questions pertaining to Wisconsin licensing requirements should be directed to [email protected].  Questions pertaining to NMLS account creation and the completion of NMLS forms can be directed to the NMLS Resource Center at 1-855-665-7123 (Monday - Friday, 8:00 AM to 8:00 PM Central Time). 
Creating an NMLS Account 
Company Licensing Guide
Licensing Checklists, Requirements, and Fees 
Licensee Search 
Frequently Asked Questions
State Statutes 
Wis. Stat. ch. 217 - Money Transmitter Statute
Wis. Admin. Code ch. DFI-Bkg 79 - Money Transmitter Administrative Rules
Wis. Stat. s. 224.35 - Annual Reports, Financial Statements, and Use of NMLS
License Amendment Instructions - Refer to the applicable Wisconsin NMLS Amendment Checklist for instructions on how notify the Division of Banking about changes to:
Direct Owners, Indirect Owners, Affiliates or Subsidiaries
Executive Officers or other Control Persons
Addresses 
Legal Names or Trade Names
Legal Status
Disclosure Question and Answers

License Surrender Instructions - Refer to the applicable Wisconsin NMLS Surrender Checklist.

Helpful Information
Annual Filing: Due Dates
Virtual Currency:  Companies engaged in the business of virtual currency transactions may be subject to Wisconsin’s money transmission law, depending on the nature of the transactions and whether fiat currency is involved.  For example, a company may enable a customer to use fiat currency to purchase virtual currency for delivery to a specific wallet or address.  If the wallet or address belongs to a third party, then the operator has engaged in money transmission.  Therefore, in situations where companies are unable to feasibly ensure that their transactions do not involve money transmission (which requires more definitive verification than their customers’ mere assurances that they own or control the wallet), the Division has required licensure. Because of the wide variation in business models and fact patterns in this evolving area, however, the Division is unable to provide company-specific “safe harbor” or “no action” letters relating to these activities.  You may wish to consult with legal counsel, and to seek licensure if your company’s activities in this state could be reasonably construed as involving money transmission that is not exempt under Wis. Stat. s. 217.03.

Financial Statement Requirements: The licensed legal entity's audited fiscal year-end financial statements must be uploaded to NMLS within 90 days after the completion of each fiscal year. Licensees must maintain at all times a tangible net worth in excess of the greater of $100,000 or the sum of the following: 3% of the licensee’s first $100,000,000 in total assets, plus 2 percent of any additional assets up to $1,000,000,000, plus 0.5% of any additional assets over $1,000,000,000. 
Financial statements must be prepared in accordance with U.S. generally accepted accounting principles.
"Tangible net worth" means the aggregate assets of a licensee excluding all intangible assets, less liabilities, as determined in accordance with U.S. generally accepted accounting principles.
Cybersecurity Resources:
Cybersecurity 101 – a resource developed by the Conference of State Bank Supervisors intended to be an easily-digestible, non-technical reference guide to help executives develop a comprehensive, responsive cybersecurity program in line with best practices.
Ransomware Self-Assessment Tool – a resource updated October 15, 2024, and ​developed by the Conference of State Bank Supervisors in conjunction with state bank examiners, the Bankers Electronic Crimes Taskforce, and the United States Secret Service which contains important controls that all types of companies should use to assess their efforts to mitigate risks associated with ransomware and to identify opportunities for increasing security​.
Federal Trade Commission's Cybersecurity for Small Business Resources – a set of cybersecurity resources developed in partnership with the National Institute of Standards and Technology, the U.S. Small Business Administration, and the Department of Homeland Security.

Contact Us

Phone: (608) 261-7578
Email: [email protected]​

Virtual currency kiosk operators must be licensed under the state’s money transmission law, which includes several provisions specifically addressing kiosk operations.  See Wis. Stat. s. 217.12. 

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