Crypto Law Profile

Nevada Virtual Currency Money Transmission Regime

Nevada regulates virtual-currency transmission through NRS Chapter 671 and FID determinations. Licensing may apply to money transmission, stored value, fiat/digital currency transmission, or custody models.

Nevada, U.S. Effective Agency guidance Jul 1, 2023

At a glance

Status Effective; crypto coverage remains business-model specific.
Regulator Nevada Financial Institutions Division administers money transmitter licensing.
License Trigger Licensure may apply to receiving money or credits for transmission or stored value.
Custody Overlay Digital-currency custody may be reviewed under Nevada trust-company law.

Bill details

Bill number
AB 21
Session
82nd Legislature (2023)
Chamber
Assembly
Legislative stage
Enacted

Action

Last action
AB 21 approved as Chapter 23, modernizing NRS Chapter 671 money transmission provisions.
Last action date
May 24, 2023

Sponsor

Primary sponsor
Assembly Committee on Commerce and Labor
Sponsor party
Unknown

Source

Source provider
State legislature
Source ID
Chapter 23, Statutes of Nevada 2023
State legislature
Official bill page

Overview

As of June 9, 2026, Nevada’s virtual currency money transmission profile is best understood as a state money-transmission regime under Nevada Revised Statutes Chapter 671, administered by the Nevada Financial Institutions Division. The regime is not a standalone crypto license. Instead, virtual-currency activity may fall within money transmission, authorized-delegate, or trust-company oversight depending on the flow of funds, custody function, and business model.

How Nevada treats virtual currency under money transmission law

NRS Chapter 671 requires a person to hold a money transmission license, or act as an authorized delegate of a licensee, before engaging in or holding out as providing money transmission in Nevada. The licensing trigger applies regardless of whether the activity is conducted through a physical office, kiosk, internet platform, mobile device, telecommunications system, or other networked means.

The statute defines money transmission around three core activities: selling or issuing payment instruments to a person located in Nevada, selling or issuing stored value to a person located in Nevada, and receiving money or credits for transmission from a person located in Nevada. Chapter 671 also defines monetary value as a medium of exchange, whether or not redeemable in money, and defines stored value as monetary value evidenced by an electronic or digital record.

For crypto activity, the Nevada Financial Institutions Division has historically framed coverage as fact-specific. Its 2014 virtual-currency guidance warned that companies offering to exchange, administer, or maintain virtual currencies may be subject to state and federal regulation. A later FID cryptocurrency statement directed entities that facilitate transmission of, or hold, fiat or digital currency through brick-and-mortar, kiosk, mobile, internet, or other channels to seek a licensure determination. The same statement indicated that a digital custodian may be reviewed under Nevada trust-company law.

Key provisions for virtual currency businesses

  • Licensing trigger: A person engaged in covered money transmission must be licensed or operate as an authorized delegate within the scope of a written contract.
  • Covered value: The definitions of monetary value and stored value are broad enough to require analysis of some digital-value products, even though Chapter 671 does not operate as a crypto-only statute.
  • Business-model review: Virtual-currency exchanges, kiosks, hosted wallets, fiat on/off ramps, and custodial models may receive different treatment depending on who receives value, who owes the customer, and whether transmission or custody is occurring.
  • Safeguards: Licensees are subject to surety bond, tangible net worth, permissible investment, reporting, examination, and enforcement provisions under Chapter 671.
  • AML reporting: Licensees and authorized delegates must file reports required by the Bank Secrecy Act and other federal or state laws relating to money laundering.

Status and timeline

Nevada modernized Chapter 671 through AB 21, approved as Chapter 23 of the 2023 Statutes of Nevada and effective July 1, 2023. Those amendments aligned Nevada’s money-transmission framework with the Money Transmission Modernization Act model and added several current definitions, prudential standards, multistate supervision tools, and enforcement provisions.

A later 2025 amendment, AB 430, removed payroll processing services from the definition of money transmission and became effective October 1, 2025. That change is not a virtual-currency rule, but it matters for current Chapter 671 status because older summaries may still describe payroll processing as included. NRS 671.020 also has a future applicability version effective January 1, 2030, which editors should re-check during future updates.

Practical scope and limitations

This profile does not determine whether any particular crypto business needs a Nevada license. The key editorial point is that Nevada uses a functional money-transmission and custody analysis rather than a single crypto-specific license label. Firms handling customer fiat, credits, stored value, or digital currency for transfer or custody should treat Nevada coverage as a regulator-facing determination question, not a purely asset-label question.

Key provisions

Money transmission license trigger

NRS 671.040 bars engaging in or holding out as providing money transmission unless licensed or acting within a licensee’s authorized-delegate contract.

Licensing Jul 1, 2023 Source

Covered transmission activities

Money transmission covers payment instruments, stored value, and receiving money or credits for transmission from a person located in Nevada.

Payments Jul 1, 2023 Source

Monetary value and stored value

Chapter 671 defines monetary value as a medium of exchange and stored value as monetary value evidenced by an electronic or digital record.

Definitions Jul 1, 2023 Source

Virtual-currency determinations

FID guidance indicates virtual-currency exchanges, administrators, maintainers, custodians, or transmitters may need licensing depending on the model.

Regulator review Source

Bond, net worth, and investments

Licensees must maintain bond coverage, tangible net worth, and permissible investments tied to outstanding money transmission obligations.

Prudential Jul 1, 2023 Source

BSA and AML reporting

Licensees and authorized delegates must file required federal currency, recordkeeping, suspicious activity, and money-laundering reports.

AML/CFT Jul 1, 2023 Source

Timeline

  1. FID virtual-currency guidance issued

    Nevada FID warned that virtual-currency businesses may be subject to state and federal regulation and licensing.

    Enacted Source
  2. FID cryptocurrency statement

    FID statement directed fiat or digital currency transmitters and custodians to seek a licensure determination.

    Enacted Source
  3. AB 21 approved

    Nevada approved Chapter 23, revising Chapter 671 money-transmission licensing and regulation.

    Enacted Source
  4. AB 21 effective

    Modernized NRS Chapter 671 money-transmission framework became operative.

    Effective Source
  5. AB 430 payroll amendment effective

    Nevada removed payroll processing services from Chapter 671 money-transmission coverage.

    Effective Source

Who it affects

Actors

Commissioner of Financial Institutions, Money transmitters, Nevada Financial Institutions Division

Asset classes

Cryptocurrency, Digital assets, Virtual currency

Official sources

Editorial note

This profile treats Nevada’s virtual-currency coverage as a business-model-dependent overlay to the state money-transmission regime. It is not legal advice and should be reviewed against current FID determinations.