Virtual Currency Business Activity (VCBA licensing information)
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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.
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Virtual Currency Business Activity
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The Virtual Currency Businesses Act (“VCBA”)
The VCBA, which was passed during the 2020 Louisiana Legislative Session, requires the licensure of entities that engage in virtual currency business activities in the State of Louisiana, as defined in LSA-RS 6:1382 (22). In accordance with Section 1394 of the VC Act, which required the promulgation of a Rule in order to implement and enforce the provisions contained therein, a Rule was published in the October 20, 2022, Edition of the Louisiana Register, in accordance with the Louisiana Administrative Procedure Act. A Declaration of Emergency amending the Rule was also adopted on October 20, 2022, and was published in the November 20, 2022, Edition of the Louisiana Register, with an effective date of July 1, 2023.
Pursuant to a Rule that was published in its final form in the February 20, 2023, Edition of the Louisiana Register, we began accepting initial applications for licensure through the Nationwide Multi-State Licensing System & Registry (“NMLS”) on January 1, 2023. After July 1, 2023, persons are no longer able to engage in VC business activities in the State of Louisiana without a license. Failure to file an application, will result in enforcement measures being taken by the Office pursuant the VC Act, and consideration of possible civil penalties pursuant to the Rule.
On June 13, 2023, Senate Bill 185, Acts 331, was enacted — providing a clear and concise regulatory structure intended to ensure compliance with the provisions of the VCBA, as enacted by Acts 341 of the 2020 Regular Session of the Louisiana Legislature.
Key provisions contained in SB 185, Acts 331, which can be found in its entirety at Louisiana Legislature Acts 331, include the following:
Provides additional terms and definitions (Section #1382)
Repeals unnecessary and/or redundant terms and definitions (Section #1382)
Provides for the approval of advanced change of control notice through the NMLS (Section #1385.1).
Provides for the approval of advanced change of responsible individual notice through the NMLS (Section #1385.2)
Reestablishes minimum surety bond and tangible net worth requirements (Section #1386)
Requires submission of audited financial statements as evidence of satisfying tangible net worth requirements (Section #1386.1)
Provides for greater protection of resident assets (Section #1386.2)
Clarifies the requirements relating to issuance, denial, and renewal of a license (Section #1387)
Requires submission of quarterly financial reports through the NMLS (Section #1388.1)
Repeals an exception to licensure relating to registrations (Formerly Section #1389)
Expands the Commissioner’s authority and flexibility relating to examinations (Section #1391)
Details the books, records, and accounts to be maintained by a licensee (Section #1391.1)
Provides for the adoption and implementation of minimum compliance policies and procedures by a licensee (Section #1391.2)
Expands the enforcement authority of the Commissioner as it relates to violations of the VCBA (Section #1392)
Requires accurate and appropriate disclosures to residents as it relates to exchanging, transferring, or storing virtual currency through a licensee (Section #1393.1)
Authorizes the adoption and implementation of emergency rules in order to prevent or terminate any condition the Commissioner reasonably considers to create an emergency relative to a particular licensee or licensees in general (Section #1394)
Key Definitions Contained in Section 1382 of the VCBA:
(17) “Person” means an individual, general partnership, limited partnership, limited liability company, corporation, trust, association, joint stock corporation, or other legal entity, or any individual or group of individuals, however organized. The term shall not include a public corporation, government, or governmental subdivision, agency, or instrumentality.
(27)(a) “Virtual currency” means a digital representation of value that is used as a medium of exchange, unit of account, or store of value, and that is not legal tender, whether or not denominated in legal tender.
(b) “Virtual currency” shall not include either of the following:
(i) A transaction in which a merchant grants, as part of an affinity or rewards program, value that cannot be taken from or exchanged with the merchant for legal tender, bank credit, or virtual currency.
(ii) A digital representation of value issued by or on behalf of a publisher and used solely within an online game, game platform, or family of games sold by the same publisher or offered on the same game platform.
(29) “Virtual currency business activity” means any of the following:
(a) Exchanging, transferring, or storing virtual currency or engaging in virtual currency administration, whether directly or through an agreement with a virtual currency control services vendor.
(b) Holding electronic precious metals or electronic certificates representing interests in precious metals on behalf of another person or issuing shares or electronic certificates representing interests in precious metals.
(c) Exchanging one or more digital representations of value used within one or more online games, game platforms, or family of games for either of the following:
(i) Virtual currency offered by or on behalf of the same publisher from which the original digital representation of value was received.
(ii) Legal tender or bank credit outside of the online game, game platform, or family of games offered by or on behalf of the same publisher from which the original digital representation of value was received.
(d) “Virtual currency business activity” shall not include any of the following:
(i) Mining.
(ii) Minting non-fungible tokens.
(iii) Blockchain activities that do not involve any exchange, holding, sale, storing, or transfer of virtual currency to, for, or on behalf of any resident.
(31) “Virtual currency kiosk” means an electronic terminal acting as a mechanical agent of the owner or operator to enable the owner or operator to facilitate the exchange of virtual currency for fiat currency or other virtual currency, including but not limited to either of the following:
(a) Connecting directly to a separate virtual currency exchanger that performs the actual virtual currency transmission.
(b) Drawing upon the virtual currency in the possession of the owner or operator of the electronic terminal.
On June 20, 2025, Governor Landry signed House Bill 483, Acts 369, which makes any person who owns, operates solicits, markets, advertises, or facilitates a virtual currency kiosk machine in the State of Louisiana subject to the provisions of the VCBA.
Key provisions contained in HB 483, Acts 369, which can be found in its entirety at Louisiana Legislature Acts 369, include the following:
Provides a $3,000 daily transactional limit for each user of a virtual currency kiosk (Section #1389(A))
Requires the owner or operator of a virtual currency kiosk to place a 72-hour hold before processing a transaction or allow the user to cancel the transaction within 72-hours and receive a refund (Section #1389(B))
Requires the posting of clear and concise disclosures (Section #1393.1(J))
Mandates the formulation and implementation of written policies and procedures that are intended to aid in fraud detection and prevention (Sections #1396&1397)
News and Information:
July 24, 2026
2026 Virtual Currency Businesses Act (VCBA) Sunset Legislation SB 163
Read More
July 24, 2026
2026 Virtual Currency Businesses Act (VCBA) Sunset Legislation SB 287
Read More
July 6, 2026
Bitcoin Depot Operating, LLC Consumer Alert
Read More
July 8, 2025
Virtual Currency Business Activity — 2025 Legislative Summary and Other Information
Read More
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