Crypto Law Profile
Washington regulates covered virtual-currency transmission under its Uniform Money Services Act, requiring money transmitter licensing, disclosures, like-kind holdings and security controls.
Washington’s Uniform Money Services Act virtual currency regime is an operative state money-transmission framework administered by the Washington Department of Financial Institutions. The core statute is chapter 19.230 RCW, supported by chapter 208-690 WAC, and the virtual-currency amendments enacted through Substitute Senate Bill 5031 became effective on July 23, 2017. The regime treats certain virtual-currency activity as money transmission when a person receives money or equivalent value, including virtual currency, for transmission to another location.
Chapter 19.230 RCW defines money transmission to include receiving money or equivalent value for transmission, and expressly states that equivalent value includes virtual currency. It separately defines virtual currency as a digital representation of value used as a medium of exchange, unit of account, or store of value, while lacking legal tender status recognized by the United States government.
The licensing perimeter is activity-based. A person may not engage in the business of money transmission, advertise it, solicit it, or hold itself out as providing it unless the person is licensed, is an authorized delegate of a licensee, or fits an exclusion under the chapter. DFI guidance states that virtual-currency kiosks or ATMs, exchange platforms that settle transactions, hosted wallet services with transfer control, and virtual-currency payment processors generally may fall within the money transmitter framework when serving Washington residents.
Money transmitter applicants submit information about their business model, control persons, authorized delegates, financial condition, and fitness for licensure. For business models that store virtual currency on behalf of others, the statute requires a third-party security audit of electronic information and data systems acceptable to the director. The rules also require virtual-currency storage applicants to submit an information security audit report completed within one year by a credentialed company or individual acceptable to the director.
Virtual currency licensees must provide disclosures to persons seeking to use their products or services. These include a schedule of fees and charges, whether the product or service is insured or guaranteed, the irrevocability of virtual-currency transfers, and the licensee’s liability and error-resolution procedures for unauthorized, mistaken, or accidental transfers. The rules add a clear risk disclosure addressing fraud, cyberattack, and potentially irretrievable loss.
Washington’s rules and statute distinguish between ordinary permissible investments for fiat money transmission and virtual-currency obligations. A licensee transmitting virtual currency must hold like-kind virtual currency in the same volume as the virtual currency obligated to consumers. Rules also set a minimum tangible net worth of $100,000 for companies that provide virtual-currency storage and require an information security program for licensees’ electronic systems and sensitive data.
UMSA includes statutory exclusions for certain public entities, financial institutions, and other covered activities. For virtual currency, chapter 208-690 WAC excludes storage of virtual currency owned by others when the person storing it does not have unilateral ability to transmit the stored value. DFI’s 2021 guidance similarly distinguishes software-only or limited multi-signature wallet roles from hosted wallet services that interact with the payment system or have independent control over value.
Washington DFI began regulating virtual-currency businesses under UMSA before the 2017 amendments and issued interim guidance on Dec. 8, 2014. Substitute Senate Bill 5031 was introduced in January 2017, passed both chambers, was signed by Governor Jay Inslee on April 17, 2017, and became Chapter 30, Laws of 2017, with an effective date of July 23, 2017. DFI later adopted rule amendments under chapter 208-690 WAC, filed June 19, 2018 and effective Aug. 1, 2018, to further implement virtual-currency licensing, reporting, disclosure, custody, and security requirements.
As of June 9, 2026, this profile treats the Washington UMSA virtual currency regime as effective state law. Separate pending proposals may further amend kiosk-specific requirements, but they are not part of this operative profile unless enacted.
Money transmission includes receiving money or equivalent value, including virtual currency, for transmission; virtual currency is defined as digital value without U.S. legal tender status.
A person may not engage in money transmission unless licensed, acting as an authorized delegate of a licensee, or excluded under RCW 19.230.020.
DFI guidance identifies kiosks or ATMs, settling exchange platforms, hosted wallets with transfer control, and virtual-currency payment processors as generally within UMSA licensing.
Licensees must disclose fees, insurance or guarantees, transfer irrevocability, liability, error-resolution rights, and rule-based fraud and cyberattack risk notices.
A licensee transmitting virtual currency must hold like-kind virtual currency in the same volume as the virtual currency obligated to consumers.
Applicants that store virtual currency on behalf of others must provide a third-party security audit of electronic information and data systems acceptable to the director.
Rules exclude storage of another person’s virtual currency when the person storing it does not have unilateral ability to transmit the stored value.
Washington’s Uniform Money Services Act became effective as chapter 19.230 RCW.
DFI issued interim guidance explaining when virtual-currency transactions may be money transmission.
Bill first read and referred to the Senate Financial Institutions & Insurance Committee.
Signed as Chapter 30, Laws of 2017, adding virtual-currency provisions to UMSA.
The 2017 UMSA virtual-currency amendments became effective.
DFI rule amendments under chapter 208-690 WAC became effective after filing June 19, 2018.
Hosted wallet providers, Money transmitters, Virtual currency exchanges, Virtual currency kiosks, Washington Department of Financial Institutions
Virtual currency
This profile covers Washington’s operative virtual-currency treatment under the Uniform Money Services Act and implementing rules, not individualized legal or compliance advice. Monitor separate kiosk-specific bills for later amendments.
