Wyoming — Bitcoin and virtual-currency law

Bitcoin Research — Law, Regulation, Markets & Origins (2026)

Legislation

2026-10-09

Document text

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.

Wyoming — Bitcoin and virtual-currency law

  • Jurisdiction: State of Wyoming (US)
  • Date checked: 2026-10-09 (all statuses below were checked on this date unless another date is given)
  • Main regulator: Wyoming Division of Banking (State Banking Commissioner); Wyoming Stable Token Commission (state-issued token)
  • Legislature: 2026 budget session ended March 2026; next general session January 2027.
  • Saved primary sources: sources/states/wy/ (see sources/states/wy/INDEX.md)

At a glance

Topic Wyoming position Key cite Status (checked 2026-10-09)
Money-transmitter licence for virtual currency Exempt. Buying, selling, issuing, holding custody of or transmitting virtual currency is outside the Wyoming Money Transmitter Act W.S. 40-22-104(a)(vi), added by 2018 HB 19 (Ch. 3) In force since 2018-03-07 [S1]
Model money-transmission laws Has not adopted the CSBS Money Transmission Modernization Act (MTMA); not shown as a Uniform Money Services Act or URVCBA state CSBS table [S14]
Digital assets as property Digital assets are property; split into digital consumer assets, digital securities and virtual currency; virtual currency "shall be considered money … only for the purposes of article 9" of the UCC (W.S. 34-29-102(a)(iii)); opt-in bank custody W.S. 34-29-101 to -105, 2019 SF 125 (Ch. 91) In force since 2019-07-01 [S4]
Crypto banks (SPDIs) Special Purpose Depository Institutions: 100%-reserve banks that may custody digital assets and may not lend customer fiat W.S. 13-12-101 to -126, 2019 HB 74 (Ch. 92); amended 2025 SF 95 (Ch. 150) In force [S3][S10][S16]
DAO LLCs / DUNAs DAO LLC supplement; Decentralized Unincorporated Nonprofit Association Act W.S. 17-31-101 et seq. (2021 SF 38); W.S. 17-32-101 to -129 (2024 SF 50) In force [S6][S8]
State stable token Wyoming Stable Token Act; Frontier Stable Token (FRNT) issued by a state commission W.S. 40-31-101 et seq. (2023 SF 127, Ch. 185); amended 2024 SF 52 and 2026 SF 21 In force; FRNT launched Aug 2025, public sale on Kraken from 2026-01-07 [S7][S11][S20]
Crypto ATMs / kiosks Operators must hold a Wyoming money-transmitter licence or be a Title 13 chartered financial institution; knowing violation is a felony W.S. 40-32-101 to -103, 2026 HB 75 (Ch. 60) Signed 2026-03-06, effective immediately [S12]
Tax No state personal or corporate income tax; virtual currency exempt from property tax 2018 SF 111 (Ch. 45) In force [S2]
Bitcoin in state funds 2025 HB 201 (invest state funds in Bitcoin) died in committee — Failed 2025-03-03 [S17]

1. Money-transmitter licensing of virtual currency

  • Exemption (2018 HB 19, Enrolled Act HEA 1, Chapter 3). Adds a definition of "virtual currency" to W.S. 40-22-102(a)(xxii) and a new exemption at W.S. 40-22-104(a)(vi): the Money Transmitter Act "shall not apply to … buying, selling, issuing, or taking custody of payment instruments or stored value in the form of virtual currency or receiving virtual currency for transmission." Signed 2018-03-07, effective on signature. Full text saved: sources/states/wy/wy-2018-hb0019-enrolled.pdf. [S1]
  • Practical effect: a pure crypto-to-crypto or crypto custody business does not need a Wyoming money-transmitter licence; a business that also moves US dollars still can. (Interpretation of the statute text; not regulator guidance.) [S1]
  • MTMA: Wyoming is listed by the Conference of State Bank Supervisors (CSBS) as not having enacted the Money Transmission Modernization Act (table dated 2026-10-08). [S14]
  • Uniform acts: Wyoming is not known to have adopted the Uniform Money Services Act or the Uniform Regulation of Virtual-Currency Businesses Act (URVCBA). The Uniform Law Commission's enactment tracker could not be read (JavaScript-only), so this is (unverified).
  • Exception — kiosks (2026): see section 3; the 2026 kiosk law requires kiosk operators to hold a money-transmitter licence even though virtual currency itself is exempt. [S12]

2. Virtual-currency-specific statutes and regulator guidance

Law What it does Status / date Source
2018 HB 70 (Ch. 44) "Open blockchain tokens — exemptions" A developer or seller of an "open blockchain token" (a consumptive/utility token meeting listed conditions, with a notice filed with the Secretary of State) is not treated as a securities issuer (new W.S. 17-4-206); also amends the money-transmitter exemptions (40-22-104) and definitions Signed 2018-03-10 [S19]
2019 SF 125 (Ch. 91) "Digital assets — existing law" Creates W.S. 34-29-101 to -105: defines digital asset, digital consumer asset, digital security, virtual currency; classifies them as property under the UCC; lets banks opt in to digital-asset custody; Wyoming courts' jurisdiction Signed 2019-02-26, effective 2019-07-01 [S4]
2019 HB 74 (Ch. 92) "Special purpose depository institutions" Creates W.S. 13-12-101 to -126. SPDIs must hold unencumbered liquid assets of at least 100% of deposits (13-12-105), may not lend customer fiat deposits, need at least $5 million initial capital (13-12-110, later amended), may obtain FDIC insurance but are not required to Signed 2019-02-26, effective 2019-10-01 [S3]
2021 SF 38 (Ch. 162) "Decentralized autonomous organizations" DAO supplement to the LLC Act (W.S. 17-31-101 et seq.): a DAO may organize as a Wyoming LLC, managed algorithmically or by members Signed 2021-04-21, effective 2021-07-01; amended 2022 SF 68 (Ch. 36) and 2023 SF 75 (Ch. 108) [S6][S18]
2023 HB 86 (Ch. 66) "Disclosure of private cryptographic keys" Limits compelled disclosure of a private key Signed 2023-02-21 [S9]
2023 SF 127 (Ch. 185) "Wyoming Stable Token Act" Creates the Wyoming Stable Token Commission and authorizes a state-issued, fully reserved dollar token (W.S. 40-31-101 et seq.). A 2022 version (SF 106) was vetoed by Gov. Gordon. Signed 2023-03-17 [S7][S18]
2024 SF 50 (Ch. 50) "Unincorporated nonprofit DAO's" Wyoming Decentralized Unincorporated Nonprofit Association (DUNA) Act, W.S. 17-32-101 to -129 Signed 2024-03-07, effective 2024-07-01 [S8]
2024 SF 52 (Ch. 92) Stable Token Act amendments (investments in cash and government securities; different token types) Signed 2024-03-18 [S18][N2]
2024 SF 96 (Ch. 80) Trusts and bank assets in bankruptcy; amends requirements for banks giving digital-asset custody Signed 2024-03-15, effective 2024-07-01 [S18][N2]
2025 SF 95 (Ch. 150) "Special purpose depository institution — amendments" Lets an SPDI convert to a public trust company (new W.S. 13-5-523); changes start-up capital; repeals the rule that SPDI depositors must be legal entities; repeals the digital-asset custody supervision fee Signed 2025-03-17, effective 2025-07-01 [S10]
2025 HB 264 (Ch. 47) No state agency may require payment in a central bank digital currency or spend public funds on testing or adopting one (W.S. 9-14-601) Governor signed 2025-02-27 [S15]
2026 SF 21 (Ch. 55) "Wyoming stable token — amendments" Allows gifts and bequests into the stable-token trust account; reserve investments limited to cash, Treasuries of 365 days or less, Treasury repos of 30 days or less or 2a-7 money-market funds; reserve requirement changed from 102% to 100% of outstanding tokens; creates a liquidity account; lets the commission make agreements with other states Signed 2026-03-06 [S11]
2026 SF 22 (Ch. 25) DUNAs may automatically convert to ordinary unincorporated nonprofit associations Signed 2026-03-03, effective 2026-07-01 [S18][N1]

SPDIs actually chartered. The Division of Banking says the Banking Board "has approved four SPDI charters thus far" but does not list them on that page. [S16] Two are widely reported: Kraken Financial and Custodia Bank (formerly Avanti). The other two are not named in a source read for this note (unverified).

Kraken Financial and the Fed. Kraken Financial (a Wyoming SPDI) was reported on 2026-03-04 to have obtained a Federal Reserve master account, described as the first for a crypto-native firm; the account was reported not to pay interest on reserves. [N3] A later report said US Rep. Maxine Waters pressed the Kansas City Fed over the approval (summary only; not read in full). [N4]

FRNT (Frontier Stable Token). First launched in August 2025; available for public purchase on Kraken from 2026-01-07; issued on Arbitrum, Avalanche, Base, Ethereum, Optimism, Polygon and Solana; reserves in cash and short-dated US Treasuries, with interest going to Wyoming's School Foundation fund (GovTech, 2026-01-14). [N5] In August 2026 the commission was reported to have moved its cross-chain infrastructure from LayerZero to Chainlink CCIP (Crowdfund Insider headline; page returned 403, details unverified). [N6]

3. Crypto ATM / kiosk law

  • 2026 HB 75, Enrolled Act HEA 19, Chapter 60 — "Virtual currency kiosks." Sponsor Rep. Clouston. Creates W.S. 40-32-101 to -103. [S12]
  • No person may own, operate or manage a virtual-currency kiosk in Wyoming unless it holds a licence under the Wyoming Money Transmitters Act (W.S. 40-22-101 to -129) or is a financial institution chartered under Title 13.
  • A knowing violation is a felony: imprisonment of not less than three years, a fine of not less than $10,000, or both (as the enrolled text reads).
  • The banking commissioner must adopt rules for kiosk operation; kiosk records given to the commissioner are confidential, with sharing allowed to other regulators and prosecutors.
  • Existing operators had to comply from the effective date.
  • House passed 56-5 on 2026-02-21; signed 2026-03-06, effective immediately. [S12]
  • The statute itself sets no daily limits, fee caps or refund rules; those would come in the commissioner's rules (not found in this check — gap).

4. Tax treatment

  • Wyoming has no state personal income tax and no corporate income tax, so gains on Bitcoin carry no state income tax (general knowledge of Wyoming's tax system; not re-verified against a Department of Revenue page in this check).
  • 2018 SF 111 (Ch. 45) "Property taxation — digital currencies": exempts virtual currency from property taxation. Signed 2018-03-10. Full text: sources/states/wy/wy-2018-sf0111-enrolled.pdf. [S2]

5. Notable enforcement and court cases

Custodia Bank v. Federal Reserve Board of Governors and Federal Reserve Bank of Kansas City

  • District court: D. Wyo. No. 1:22-cv-00125-SWS, reported at 728 F. Supp. 3d 1227 (D. Wyo. 2024): Custodia's summary-judgment motion denied and the Kansas City Fed's cross-motion granted, disposing of all claims. [S13a]
  • Underlying denials: on 2023-01-27 the Fed Board denied Custodia's application for Fed membership, citing "significant safety and soundness risks" from its "novel and untested crypto activities"; the Kansas City Fed denied the master account the same day. [S21] (The panel dissent's background passage says "January 27, 2024"; the Fed's own press release is dated 2023-01-27, so the dissent's year appears to be a typo.)
  • Tenth Circuit panel, No. 24-8024, decided 2025-10-31 (published). Before Tymkovich, Ebel and Rossman. Opinion by Judge Ebel: affirmed for the Fed on all claims, holding that Reserve Banks have discretion to deny master-account applications by non-member depository institutions. Judge Tymkovich dissented. Amici included the State of Wyoming, the Wyoming Secretary of State, Sen. Cynthia Lummis, Sen. Steve Daines, Rep. Warren Davidson, former Sen. Pat Toomey, the Blockchain Association and The Digital Chamber (for Custodia), and the American Bankers Association, Bank Policy Institute, The Clearing House, ICBA, Consumer Bankers Association, Wyoming Bankers Association and the Federal Reserve Banks (for the Fed). Full opinion saved: sources/states/wy/custodia-v-fed-10th-cir-24-8024-2025-10-31-opinion.pdf. [S13a]
  • Rehearing en banc denied, 2026-03-13. Judges Hartz, Tymkovich and Eid voted to rehear; Judge Tymkovich wrote a dissent from denial, joined by Judge Eid. Full order saved: sources/states/wy/custodia-v-fed-10th-cir-24-8024-2026-03-13-en-banc-denial.pdf. [S13b] (A news report described the vote as 7-3. [N7])
  • Supreme Court: Justice Gorsuch extended the time to file a certiorari petition to 2026-07-11 (application No. 25A1320). [N7] Custodia then petitioned; the Blockchain Association filed an amicus brief in support; as of 2026-08-18 the Court had not agreed to hear the case. [N8][N9] Current cert status as of 2026-10-09 not confirmed (gap).

Other

  • Wyoming's money-transmitter exemption means there is little state money-transmission enforcement against crypto firms; no notable Wyoming state enforcement action against a Bitcoin business was found in this check (gap).

6. Pending and recently failed bills

Bill Subject Status (checked 2026-10-09) Source
2025 HB 201 Invest state funds and permanent funds in Bitcoin Died in committee 2025-03-03 [S17]
2025 HB 308 "Cryptographic Frontiers Act" AG to investigate federal overreach involving blockchain Not considered for introduction 2025-02-03 [S17]
2026 HB 160 "Digital Taxonomy Act" Classification of digital assets ("sealed tokens") Died in committee 2026-03-03 [S17]
2022 SF 106 "Wyoming stable token act" First version of the stable token Vetoed by the governor (2022) [S18]

No Wyoming bill is pending now: the 2026 session has adjourned and the next general session starts January 2027.

7. Contested and fringe claims (flagged, not endorsed)

  • "Debanking" / "Operation Choke Point 2.0." Custodia, its founder Caitlin Long, and supporters including Sen. Lummis (as amicus) argue that the Fed's master-account denial was political and that federal agencies worked to cut crypto firms off from banking. The Fed and the bank trade groups (ABA, BPI, The Clearing House) argue that the Fed has discretion and that a full-reserve crypto bank without federal supervision carries risks. The Tenth Circuit majority sided with the Fed; Judge Tymkovich's dissents side with Custodia's reading of the statute. [S13a][S13b] Contested; the "coordinated campaign" claim is the advocates' characterization, not a court finding.
  • Claims that Wyoming is "the" crypto-law state. Promoters describe Wyoming's 2018–2026 laws as the most complete state framework in the US. The counter-point visible in the record is that Custodia, the SPDI that fought hardest for Fed access, lost in court, while Kraken Financial got an account by a different route. [S13a][N3] Advocacy claim — reported here as a claim, not a finding. (The "most complete" claim and any count of operating SPDIs are unverified.)
  • Kraken master account criticism. Rep. Maxine Waters questioned the Kansas City Fed's approval of Kraken's account (report summarized from a headline only). [N4] Political dispute; facts of the approval itself are from [N3].
  • State stable token. Supporters call FRNT a safe, public dollar token whose interest funds schools; critics ask why a state should issue a payments token at all and whether it competes with private stablecoins. [N5] Policy dispute.

Sources

Saved full copies are in sources/states/wy/. News and secondary items are summaries only, with links.

  • [S1] Wyoming Legislature, 2018 HB 19, Enrolled Act HEA 1 (Ch. 3), "Wyoming Money Transmitter Act — virtual currency exemption." https://wyoleg.gov/2018/Enroll/HB0019.pdf — retrieved 2026-10-09 — saved wy-2018-hb0019-enrolled.pdf. Status from LSO API https://wyoleg.gov/LsoService/api/BillInformation/2018/HB0019
  • [S2] Wyoming Legislature, 2018 SF 111 (Ch. 45), "Property taxation — digital currencies." https://wyoleg.gov/2018/Enroll/SF0111.pdf — saved wy-2018-sf0111-enrolled.pdf
  • [S3] Wyoming Legislature, 2019 HB 74 (Ch. 92), "Special purpose depository institutions." https://wyoleg.gov/2019/Enroll/HB0074.pdf — saved wy-2019-hb0074-enrolled.pdf
  • [S4] Wyoming Legislature, 2019 SF 125 (Ch. 91), "Digital assets — existing law." https://wyoleg.gov/2019/Enroll/SF0125.pdf — saved wy-2019-sf0125-enrolled.pdf
  • [S6] Wyoming Legislature, 2021 SF 38 (Ch. 162), "Decentralized autonomous organizations." https://wyoleg.gov/2021/Enroll/SF0038.pdf — saved wy-2021-sf0038-enrolled.pdf
  • [S7] Wyoming Legislature, 2023 SF 127 (Ch. 185), "Wyoming Stable Token Act." https://wyoleg.gov/2023/Enroll/SF0127.pdf — saved wy-2023-sf0127-enrolled.pdf
  • [S8] Wyoming Legislature, 2024 SF 50 (Ch. 50), DUNA Act. https://wyoleg.gov/2024/Enroll/SF0050.pdf — saved wy-2024-sf0050-enrolled.pdf
  • [S9] Wyoming Legislature, 2023 HB 86 (Ch. 66), "Disclosure of private cryptographic keys." https://wyoleg.gov/2023/Enroll/HB0086.pdf — saved wy-2023-hb0086-enrolled.pdf
  • [S10] Wyoming Legislature, 2025 SF 95 (Ch. 150), SPDI amendments. https://wyoleg.gov/2025/Enroll/SF0095.pdf — saved wy-2025-sf0095-enrolled.pdf
  • [S11] Wyoming Legislature, 2026 SF 21 (Ch. 55), stable token amendments. https://wyoleg.gov/2026/Enroll/SF0021.pdf — saved wy-2026-sf0021-enrolled.pdf
  • [S12] Wyoming Legislature, 2026 HB 75 (HEA 19, Ch. 60), "Virtual currency kiosks." https://wyoleg.gov/2026/Enroll/HB0075.pdf — saved wy-2026-hb0075-enrolled.pdf; actions from https://wyoleg.gov/LsoService/api/BillInformation/2026/HB0075
  • [S13a] US Court of Appeals for the Tenth Circuit, Custodia Bank, Inc. v. Federal Reserve Board of Governors, No. 24-8024, opinion filed 2025-10-31. https://www.ca10.uscourts.gov/sites/ca10/files/opinions/010111327582.pdf — saved custodia-v-fed-10th-cir-24-8024-2025-10-31-opinion.pdf
  • [S13b] Tenth Circuit, same case, order denying rehearing en banc with dissent, filed 2026-03-13. https://www.ca10.uscourts.gov/sites/ca10/files/opinions/010111400884.pdf — saved custodia-v-fed-10th-cir-24-8024-2026-03-13-en-banc-denial.pdf
  • [S21] Board of Governors of the Federal Reserve System, press release "Federal Reserve Board announces denial of application by Custodia Bank, Inc. to become a member of the Federal Reserve System," 2023-01-27. https://www.federalreserve.gov/newsevents/pressreleases/orders20230127a.htm — retrieved 2026-10-09 — saved frb-2023-01-27-custodia-membership-denial-press-release.html
  • [S14] Conference of State Bank Supervisors, "MTMA State Enactments" table (PDF dated 2026-10-08). https://www.csbs.org/sites/default/files/external-link-files/10.8.26%20MTMA%20State%20Enactments.pdf — read 2026-10-09 (summary only; CSBS is a non-government association)
  • [S15] Wyoming Legislature, 2025 HB 264 (Ch. 47), CBDC prohibition. https://wyoleg.gov/2025/Enroll/HB0264.pdf — saved wy-2025-hb0264-enrolled.pdf
  • [S16] Wyoming Division of Banking, "Special Purpose Depository Institutions" page. https://wyomingbankingdivision.wyo.gov/banks-and-trust-companies/special-purpose-depository-institutions — read 2026-10-09
  • [S17] Wyoming LSO bill-information API for 2025 HB 201, 2025 HB 308, 2026 HB 160 (status lines). https://wyoleg.gov/LsoService/api/BillInformation/2025/HB0201 (and /2025/HB0308, /2026/HB0160) — read 2026-10-09
  • [S18] Wyoming LSO bill-information API for 2022 SF 106 (vetoed), 2022 SF 68, 2023 SF 75, 2023 SF 127, 2024 SF 52, 2024 SF 96, 2026 SF 22. https://wyoleg.gov/LsoService/api/BillInformation/2022/SF0106 (etc.) — read 2026-10-09
  • [S19] Wyoming Legislature, 2018 HB 70 (Ch. 44), "Open blockchain tokens — exemptions." https://wyoleg.gov/2018/Enroll/HB0070.pdf — saved wy-2018-hb0070-enrolled.pdf
  • [S20] NCSL, "Cryptocurrency, Digital or Virtual Currency and Digital Assets 2024 / 2025 / 2026 Legislation" (2026 page updated 2026-03-25). https://www.ncsl.org/financial-services/cryptocurrency-digital-or-virtual-currency-and-digital-assets-2026-legislation — read 2026-10-09
  • [N1] NCSL 2026 page (as [S20]) — SF 22 summary.
  • [N2] NCSL 2024 page — SF 52, SF 96 summaries. https://www.ncsl.org/financial-services/cryptocurrency-digital-or-virtual-currency-and-digital-assets-2024-legislation
  • [N3] Yahoo Finance, "Kraken Wins Fed Master Account, in First for Crypto-Native Firm," 2026-03-04. https://finance.yahoo.com/news/kraken-wins-fed-master-account-171352496.html — summary only
  • [N4] Yahoo Finance, "Rep. Waters Presses Kansas City Fed Over Kraken Master Account Approval" (headline seen in search results; article not read). https://finance.yahoo.com/markets/crypto/articles/rep-waters-presses-kansas-city-102435442.html — (unverified beyond headline)
  • [N5] GovTech, "Now Available for Purchase: Wyoming's Frontier Stable Token," 2026-01-14. https://www.govtech.com/budget-finance/now-available-for-purchase-wyomings-frontier-stable-token — summary only
  • [N6] Crowdfund Insider, "Wyoming Stable Token Commission Migrates from LayerZero to Chainlink," August 2026 (403 on fetch; headline only). https://www.crowdfundinsider.com/2026/08/298928-wyoming-stable-token-commission-migrates-from-layerzero-to-chainlink
  • [N7] Yahoo Finance, "Custodia Bank Takes Fed Master Account Fight Toward Supreme Court," 2026-05-30. https://finance.yahoo.com/markets/crypto/articles/custodia-bank-takes-fed-master-132906359.html — summary only
  • [N8] PYMNTS, "Crypto Trade Group Backs Custodia's Supreme Court Bid," 2026-08-18. https://www.pymnts.com/cryptocurrency/2026/blockchain-group-asks-supreme-court-review-federal-reserve-denial-crypto-bank-bid-master-account — summary only
  • [N9] Law360, "Custodia Urges Justices To Take Up Fed Master Account Fight," 2026-07-13 (paywalled; headline and date only). https://www.law360.com/articles/2500317/custodia-urges-justices-to-take-up-fed-master-account-fight