The Wisconsin Blockchain Legislative Landscape: Regulation, Innovation, and the Road Ahead

Executive Summary

It’s no exaggeration that we Wisconsinites love our charcuterie boards, in all their glory, overflowing with homegrown goods — cheese, sausages, jams, berries, honey — alongside a flight of beer from a local brewery. On a day like today, when it’s mid-eighties and sunny, and I’m gearing up to take a stroll along Lake Michigan, I can’t ignore the craving for such a spread. But unlike my backyard grazing board — where every piece is placed with intention — I don’t want the legislation for the industry I’ve spent over three years advocating for handed to us piece by piece, with no one minding how it fits together.

Right now, that’s what we’re dealing with.

Over the past two years, Wisconsin has quietly, and dare I say apprehensively, become a more active participant in one of the most consequential shifts in financial law in a generation. Our state has updated the rules that govern how money moves, acted to protect our older residents from a fast-growing form of fraud, and come close to giving one of the digital-asset economy’s core activities a clear place in state law.

Setting aside my own bias, I read these moves as reactive. When handed a national template to adopt or a documented harm to answer, Wisconsin acts decisively. When asked to decide for itself what kind of home it wants to be for this industry, it hesitates.

This briefing traces that pattern across three areas:

• Money transmission. A sensible, overdue update to Wisconsin’s decades-old money-transfer statute (Wisconsin Act 267) brought our state in line with most of the country.
• Virtual-currency kiosks. In response to a surge in scams that have cost Americans, disproportionately those over 60, hundreds of millions of dollars, Wisconsin enacted 2025 Wisconsin Act 226, requiring crypto ATMs to be licensed and adding real consumer protections.
• Digital-asset staking. Most recently, two bills, AB 471 and AB 892, that would have clarified the legal standing of staking and self-custody died with the end of the 2025–26 session. One had passed the Assembly and cleared every committee it faced.

MJ Sterling · mjsterling.org

What we’re left with is a framework built piece by piece rather than by design, and, in at least one instance, a state government working against itself. Even as the Legislature moved to declare that staking is not a security, a Wisconsin regulator continues to argue, in an active enforcement action, that it is.

Meanwhile, the national landscape is shifting. The GENIUS Act (2025) now governs stablecoins and preempts much of the state licensing that Wisconsin just modernized. In March 2026, the SEC and CFTC issued a historic joint interpretation treating staking as a service rather than a security. And a second federal bill, the CLARITY Act, could soon settle the deeper question of who regulates digital assets at all.

Wisconsin’s choices are increasingly made in a national context that the state doesn’t control. What has passed here came from an outside prompt; what has stalled was homegrown. We take such pride in our homegrown goods, but dismiss our homegrown legislation.

I write this as a call for decision and ownership, not alarm. What follows lays out what Wisconsin has done and why, what remains unresolved, and the handful of questions lawmakers will want to watch and, hopefully sooner rather than later, answer.

Introduction

Why blockchain matters to Wisconsin

Having advocated for blockchain in Wisconsin for a few years, I’m well aware of the lack of interest from most folks. Not because they don’t think it matters, but because there’s sexier emerging tech, like AI, they’d rather play with and learn about. As my colleague and fellow Wisconsinite Spencer X. Smith once told me, “If AI is candy, blockchain is vitamins.”

So, after scanning the room and seeing very few blockchain advocates in our state, I raised my hand to begin asking the questions that follow AI: the side effects of all that sugar. Who owns the data AI collects and learns from? Who is compensated for that data? How do we transparently cite the source of AI information? And those are only the first few.

Vitamins counteract some of those side effects and keep the body healthy, and blockchain does much of the same for our data. It isn’t flashy, but it’s a genuine answer to many of the concerns we’re facing with the AI boom. Blockchain is a set of tools for recording who owns what, moving value without a middleman, and cutting out the human error that manual processes invite.

We like to think blockchain lives on the coasts, or in some someday. It’s already living here. Wisconsin residents hold digital assets and use them to pay and to save. Wisconsin businesses are built on this technology, though too few are Wisconsin businesses on paper. When I brought ten of our state’s blockchain and crypto founders together with the Department of Financial Institutions (DFI), every last one had incorporated elsewhere. One had gone abroad to do it. And Wisconsinites, often our elders, have lost real money to scams that run through crypto kiosks in gas stations and grocery stores. These scams are ancient; only the tools are new.

Whatever one makes of the industry, it’s no longer hypothetical in this state. It shows up in people’s savings, in their companies, and in their complaints to their government. So, time to take our vitamins.

Why state policy matters now

Those founders didn’t leave for Washington’s reasons; they left for Wisconsin’s. It’s easy to point our fingers at the Hill and twiddle our thumbs while the big decisions get made — but a great deal of what governs digital assets is, and will remain, state law. States have always answered how a security is defined, how commercial transactions are recorded, how custodians are chartered, and how consumers are protected. Blockchain doesn’t change that. And neither does Washington: even the GENIUS Act, the biggest federal move yet, preempts only a narrow slice — stablecoin licensing — and leaves the rest right where it’s always been.

The timing is what makes this moment count. Wisconsin has just enacted two significant laws and just watched two more die. Congress has passed its first major digital-asset statute and is weighing a second. And when the Legislature returns in 2027, it will face a landscape meaningfully different from the one these bills were written for. Wisconsin will answer these questions, whether it means to or not. The only choice is whether it answers them on purpose.

Purpose of the briefing

This document is a map, not a pitch — setting out, in plain terms, what Wisconsin has done in three areas: money transmission, virtual-currency kiosks, and digital-asset staking — and, for each, why it happened, what it means in practice, and what questions remain. It closes by looking ahead: to the federal developments reshaping the field, to how Wisconsin compares with peer states, and to the questions lawmakers will likely meet next session. The goal is to allow anyone, regardless of their feelings about digital assets, to understand where Wisconsin stands and reason clearly about where it should go next.

Money Transmission Modernization

What changed

Starting with the least glamorous of the three: the plumbing. In Wisconsin, if you want to move other people’s money by selling money orders, running a payment app, or wiring funds across a border, you need a license. For decades, you got that license under a law written for a world of paper checks. As of last year, that’s no longer true.

In 2023 Wisconsin Act 267, our state tossed out its old “Sellers of Checks” statute and rebuilt the rulebook from scratch: a new Chapter 217, now called, plainly enough, “Money Transmitters.”¹ Wisconsin didn’t write it alone. In fact, we adopted a national model law, the Money Transmission Modernization Act, written by the Conference of State Bank Supervisors, the association of state banking regulators, to give every state the same rulebook. We were the twentieth state to sign on, and by this year, thirty-one had.²

Why it changed

In all fairness, this change was overdue, not brave. As a thirty-year-old “Zillennial” who dutifully balanced a fake checkbook back in fourth grade, I haven’t bought one in over a decade. Money stopped moving by paper check long before Wisconsin’s statute noticed. The model law was already written and vetted by regulators across the country, and every year we held out, our rules drifted further from the states where our own companies also operate. Adopting this change was the sensible thing and a reactive decision on Wisconsin’s part to avoid being the odd one out. Not a decision about where Wisconsin wants to go, let alone lead.

There’s a federal backdrop, too. Since 2013, federal guidance has treated many virtual-currency businesses, the exchanges that convert crypto to dollars and back, as money transmitters, subject to anti-money-laundering rules.³ So modernizing this law wasn’t merely housekeeping; it was also, implicitly, about how Wisconsin’s licensing regime would meet an industry that federal regulators had already folded into the money-transmission world.

Practical implications

For the businesses doing the moving, this is mostly good news: clearer rules and a license that travels within a national system rather than a Wisconsin-only one. For the rest of us, the protection is real even if we never see it. A licensed transmitter needs to hold enough safe, liquid money to cover what its customers have handed over; that rule is what stands between a customer and a failed company.

But the most telling part of Act 267 is something our state chose not to do. The national model law comes with an optional section dedicated to virtual currency. Wisconsin didn’t adopt it. As a result, Wisconsin’s money-transmission law is, for the most part, silent on crypto: defining “money” as the government-issued kind and asking nothing of a business whose whole job is holding digital assets for someone else. A crypto custodian generally falls outside this chapter, not by a considered decision that they shouldn’t be covered, but because the question was left unanswered.

Remaining questions

That silence is the open question. It’s fine right up until it isn’t. It works cleanly for a business that only holds crypto, but gets far murkier for the many that do more than one thing — hold digital assets and move dollars — and could be swept into licensing through the dollar side of their operation. Where exactly that line sits, the statute doesn’t say.

The tell that this matters: the Legislature nearly answered this question itself. One of the digital-asset bills I’ll get into shortly would have written a plain exemption into Chapter 217 by spelling out that running a node or trading one digital asset for another doesn’t make you a money transmitter. The people closest to this wanted the ambiguity cleared up. The bill died. The ambiguity didn’t.

Virtual Currency Kiosks

The legislative response

If the money-transmission rewrite was Wisconsin falling in line with the national standard, this one was Wisconsin answering a call it couldn’t let ring. The problem was too close to home and too ugly to leave unattended.

In 2025 Wisconsin Act 226, signed this past April, our state did something it had never done before: it put rules around virtual-currency kiosks, the crypto ATMs that have inconspicuously appeared in gas stations, convenience stores, and strip malls across Wisconsin.⁴ The new law, section 217.12, lays down one foundational thing and several protective ones. The foundation is simple: you can’t run one of these machines here without a license. From there, it builds a set of consumer safeguards around them.

Consumer protection

Here’s why the Legislature bothered.

These kiosks had become a favorite tool for a particularly cruel kind of scam, and it tends to go the same way every time. Someone calls — pretending to be the IRS, or Microsoft tech support, or a grandchild in trouble — and talks a frightened person into pulling cash out of the bank, driving to a crypto kiosk, and feeding the bills in. The machine turns the cash into digital currency on the spot, and the moment it does, the money is gone.

The people this happens to are, by and large, older — our parents and grandparents. The federal numbers are hard to read and harder to look away from. The FTC found that Americans lost more than $65 million at Bitcoin ATMs in just the first half of 2024, at a median loss of ten thousand dollars a person — and that people over 60 were more than three times as likely to be taken, accounting for roughly seven of every ten dollars lost at these machines.⁵ The FBI’s count for the full year came to nearly $247 million.⁶ AARP Wisconsin backed the bill, and it isn’t hard to see why.

MJ Sterling · mjsterling.org

What’s new is the technology, and it cuts both ways. On one hand, AI can take a few seconds of someone’s kid or grandkid speaking, clone the voice, and put a terrifying script in their mouth, enough to fool even the tech-savvy. On the other, the traceability of blockchain enables recoveries cash never could. With cash, once it’s gone, it’s gone.

That’s the hard irony here: the very thing that makes these scams work, that the money moves as crypto, is also the thing cash never offered law enforcement: a permanent, public trail. It’s how the FBI recovered most of the Colonial Pipeline bitcoin, and how the Justice Department clawed back $3.6 billion from a hack that was years cold.⁷ An envelope of cash handed to a stranger, or a wire sent to an overseas prince, leaves nothing to follow; cryptocurrency leaves nothing but a trail.

I’ve seen the cash version with my own two eyes. As a teller at a large bank, I watched a woman wire her savings to exactly that kind of overseas prince — and despite raising every alarm and working with my manager to convince her it was a scam, we couldn’t stop her. That doesn’t mean the woman at the kiosk gets her money back either — most individual victims don’t — but it does mean the case doesn’t have to go cold the way it would have a decade ago.

Act 226 answers with a handful of concrete guardrails. It caps what a customer can move through one operator’s kiosks at $1,000 in a single day, a limit built to break up exactly the big, panicked, one-time transfer these scams run on. It forces an operator to refund a defrauded customer in full, fees and all, as long as the customer reports it within 30 days to both the operator and law enforcement. That refund is Wisconsin’s answer to those grim odds: it doesn’t make a victim chase the blockchain trail; it puts the money back from the operator’s pocket. And it adds the ordinary scaffolding of consumer protection: ID checks, fraud warnings on the screen, and a real receipt.

Compliance implications

For the companies running these machines, the ground shifts. They need a license now, with the paperwork and oversight that comes with it. The daily cap changes the math on their most profitable transactions. And the refund rule moves the cost of fraud onto the party actually positioned to build defenses against it, which is the whole point.

It’s a good law, and I want to be clear about that. But it’s worth seeing it for what it is, and isn’t.

It regulates a machine, not a market. It answers one specific, documented harm, and says nothing about how Wisconsin means to treat digital assets more broadly. It’s a well-placed patch on a single leak.

And like most patches, it leaves a few seams. The $1,000 cap is per operator, which means a determined scammer can still walk a victim to a second company’s machine down the street. How hard the licensing rule actually gets enforced is an open question. And whether DFI puts out clear guidance for operators to follow is, so far, unanswered. Good law tends to surface the next problem. This one already has.

Digital Asset Staking Legislation

What the legislation proposes

The first two laws in this briefing passed. The most ambitious thing Wisconsin tried this session didn’t — and how it failed is more revealing than the fact that it didn’t.

Walk with me now.

First, what we’re talking about. “Staking” sounds like jargon, and the mechanics really are technical — but the idea underneath is simple, and it comes in two parts. The process: you “lock” your crypto coins in the blockchain network, which helps it stay safe and fast. The reward: the network pays you new coins as a thank-you. That’s it. It’s how a lot of newer blockchains keep themselves secure without the enormous electricity use of Bitcoin-style mining, and for the person doing it, it lands closer to earning interest on money you’ve parked than to buying a lottery ticket. All of which makes the legal question it raises strangely large: when you earn those rewards, are you making an investment — which would make staking a security, with all the registration that implies — or are you just being paid for a service?

Two bills tried to answer, from opposite ends of the ambition scale.

AB 471 was the swing-for-the-fences version, a broad “regulation of digital assets” bill. It would have protected a Wisconsinite’s right to hold their own crypto without a middleman, to run the computers (“nodes”) that keep a blockchain running, and to stake. It would have barred both state agencies and local governments from banning those activities. And it would have carved staking, mining, and node-running out of two regulatory buckets at once — money-transmitter licensing and securities law. It was introduced in September 2025, got a hearing, and then quietly died in committee without ever reaching a floor vote.⁸

AB 892 was the surgical version. It did one thing: amended Wisconsin’s securities law to define staking and “staking as a service,” and to say plainly that neither one is a security under state law. Just that. And it very nearly made it: cleared its committee, passed the full Assembly in February, cleared a Senate committee in March, and then the session ran out before the full Senate ever voted. It didn’t lose. The clock beat it.⁹

I testified in favor of both bills — as an entrepreneur and an artist, not a financier — so take my read for what it’s worth. But the shape of the opposition is telling on its own. At both hearings, it came from a single quarter: the banking industry. The Wisconsin Bankers Association testified against each bill, raising a general consumer-protection concern about treating digital assets differently from ordinary currency. Pressed for specifics, though, it didn’t develop the arguments much further.¹⁰ That doesn’t mean the banks have no case; it means it wasn’t made here. These bills didn’t die because someone argued them down. They died because the session ended.

Why it matters

Two dead bills earn a section of their own for one reason: at the very moment the Legislature was moving to say staking is not a security, another arm of Wisconsin’s own government was formally arguing the opposite.

Back in 2023, Wisconsin joined a coalition of ten states that brought enforcement actions against Coinbase, one of the country’s largest crypto exchanges, claiming its staking program was an unregistered security.¹¹ Then the ground moved. In early 2025, federal securities regulators dropped their own parallel case against Coinbase. Five of the ten states followed and withdrew theirs. And in March 2026 — right in the middle of AB 892’s run through the Legislature — the SEC and CFTC went further still. Within a single week, the two agencies signed a formal harmonization pact and issued a joint interpretation that treats staking rewards as payment for a service, not the return on an investment — more or less exactly what AB 892 was trying to write into our state law. The SEC’s own chairman, Paul Atkins, declared that “the regrettable era of duplicative enforcement actions … for the same conduct is over.”¹³

Wisconsin has not withdrawn.

As of this writing, it remains one of only a handful of states still pressing its Coinbase action, and its order still bars the company from offering staking to new Wisconsin customers.¹² So we’ve landed somewhere genuinely strange: our state’s legislature reaching for one answer, with our state’s regulator defending the other, and the federal consensus drifting toward the legislature’s side. That is not a stable place to stand. It’s the clearest example in this whole briefing of what “piecemeal” actually costs — not merely gaps, but a government at odds with itself.

MJ Sterling · mjsterling.org

One caution: even if AB 892 had passed, it would only have settled the question under state law. It would not have bound the SEC, whose authority over what counts as a security runs on federal law, independent of anything Wisconsin says. So the bill was never a shield against Washington. It was something smaller, and honestly more useful: a clear signal to businesses and residents about how Wisconsin itself intends to treat the activity. Its champions sometimes oversold it, and its skeptics undersold it. In the end, it was a modest thing worth doing.

Economic implications

None of this is abstract. Staking is real economic activity. Validators run real infrastructure, companies build real businesses providing staking services, and ordinary Wisconsinites earn real rewards on assets they already own, or would, if they could. Right now, because of the cease-and-desist, Wisconsin residents are locked out of staking through our country’s biggest exchange. Supporters put a number on it: at the AB 892 hearings, Coinbase’s U.S. policy director, Robin Cook, testified that Wisconsinites had already missed more than $4 million in staking rewards — money “directly taken out of people’s pockets,” and income the state never got to tax.¹⁴ It’s an industry estimate, and should be read as one. But the meter is still running.

For a business deciding where to plant a staking operation, the calculation is simple and unsentimental. Is the law here clear? Are the regulators here welcoming, or are they the ones still litigating? Wisconsin’s answer, at the moment, is a shrug and a lawsuit: an unsettled statute pointing one way, an active enforcement action pointing the other. That’s exactly the kind of mixed signal that sends founders like the ten I sat with to incorporate elsewhere.

Both bills are dead for now, but not buried. They can return in 2027, and given how close AB 892 came, I’d wager at least one does. The real question isn’t whether Wisconsin revisits this. It’s whether, next time, the state’s left hand and right hand can agree on what they’re reaching for.

Looking Ahead

Everything above is Wisconsin looking at its own feet. This last stretch is about looking up, because whatever our state decides next, it will decide inside a national picture that’s filling in fast, and that Wisconsin doesn’t control.

The federal picture

Start with what’s already law. The GENIUS Act, passed in 2025, built the first federal framework for stablecoins, the dollar-pegged tokens meant to move value the way cash does. For Wisconsin, the relevant part is quiet but real: GENIUS preempts state money-transmitter licensing for compliant stablecoin issuers. Part of the very regime Wisconsin modernized in Act 267 has, in effect, already been lifted up to Washington.¹⁵

Then there’s the coordination. That same SEC–CFTC harmonization from a moment ago — the memorandum of understanding, the shared “no more duplicative enforcement” posture — is the two federal market regulators deciding to speak with one voice on digital assets after years of speaking over each other. That matters to every state, because it narrows the room a state regulator has to strike out on its own.

And then there’s the piece that isn’t finished. The CLARITY Act, a market-structure bill that would finally settle which federal agency governs which digital asset, passed the U.S. House in 2025 and, as of this writing, sits before the Senate with a narrow window to act before the chamber breaks.¹⁶ If it passes, it would give the field the one thing it has never had: a durable, statutory answer to “who’s in charge,” instead of guidance the next administration can rewrite. If it stalls, states keep filling the gap themselves, one bill at a time — which is exactly the pattern this briefing has traced. It is one of the most consequential things Congress will decide this year, and it deserves more attention than it’s getting.

Where Wisconsin stands

Against that backdrop, let’s name Wisconsin’s competitive position plainly, because it isn’t flattering. Wyoming built a special kind of bank: a chartered institution designed to hold digital assets for customers under strict, fully reserved rules.¹⁷ Wisconsin has nothing like it. Mention Wisconsin blockchain policy in this world, and a good number of people hear Wyoming. The two W-states blur; Wyoming’s the one that’s supposed to be there, and Wisconsin isn’t even a guess. A majority of states have adopted the 2022 updates to the Uniform Commercial Code, which provide digital assets with clear, predictable treatment in ordinary commercial transactions. Wisconsin hasn’t even introduced them.¹⁸ These aren’t the things that make headlines. They’re the quiet infrastructure that tells a serious company whether a state has thought about this at all — and, true to the pattern this briefing has traced, ours reads as though it hasn’t.

MJ Sterling · mjsterling.org

The questions that follow

Which leaves the questions Wisconsin will actually have to answer. Will it come back in 2027 with an agenda of its own, or keep legislating only when prompted? Will it build the custody and commercial-law scaffolding its neighbors already have, or keep watching its founders set up shop elsewhere? And what about the things that tend to follow clear law: the jobs in validation, compliance, and financial services that locate where the rules are settled, and the larger institutions that, with a federal framework finally taking shape, are only now stepping into this space in earnest? None of these has an answer yet. All of them are live. That’s the good news, actually: what comes next isn’t decided. The canvas isn’t totally blank; Wisconsin’s already made its first marks — but what they add up to is still ours to compose.

Conclusion

Here, we’ve set the whole record side by side to see a shape emerging. Wisconsin modernized its money-transmission law when the country handed it a template. It protected its residents from kiosk fraud when the harm got too loud to ignore. It nearly clarified staking, only to run out the clock — and it still hasn’t reconciled a legislature and a regulator pulling in opposite directions. None of these was the wrong thing to do. Most were sensible. But almost none of them started as Wisconsin’s own idea.

That’s the point, and it’s worth saying plainly: the trouble isn’t what our state has done. It’s that Wisconsin has done it piece by piece, in response to whatever landed on the doorstep, without ever stepping back to ask what it wants the pieces to add up to. That’s a forgivable way to legislate. It’s also a costly one, and the cost climbs as the field settles, federally and in the choices other states keep making while ours waits to be prompted.

Here’s what we love about a good charcuterie board: the pieces only work because someone arranged them. Left to themselves, they’re a pile of odds and ends. Wisconsin has the pieces: real laws, real talents, real founders who want to build here. What it hasn’t done is decide what they’re meant to make together.

None of this asks Wisconsin to love the digital-asset economy, or to fear it. It asks the state to choose, on purpose and with its eyes open, what kind of participant it intends to be. The 2027 session is the next chance to do exactly that. We need fewer reactions and more compositions. The board is ours. It’s time we arrange it.

Sources

1. 2023 Wisconsin Act 267 & Chapter 217. Wis. Stat. ch. 217; 2023 Wisconsin Act 267; Wisconsin Dept. of Financial Institutions, Money Transmitter Modernization Act.
2. Money Transmission Modernization Act (MTMA). Conference of State Bank Supervisors, MTMA overview and state-adoption tracker.
3. Federal treatment of virtual-currency businesses. FinCEN, Guidance FIN-2013-G001 (Mar. 18, 2013).
4. 2025 Wisconsin Act 226 (virtual-currency kiosks). 2025 Wisconsin Act 226; Wis. Stat. § 217.12.
5. Bitcoin-ATM scam losses. Federal Trade Commission, “Bitcoin ATMs: A payment portal for scammers” (Sept. 2024).
6. Crypto-kiosk fraud, 2024. FBI Internet Crime Complaint Center (IC3), 2024 annual report; see also FinCEN, Notice FIN-2025-NTC1 (Aug. 2025).
7. Law-enforcement crypto recoveries. U.S. Dept. of Justice, Colonial Pipeline ransom recovery (June 7, 2021) and Bitfinex-hack seizure (Feb. 8, 2022).
8. 2025 Assembly Bill 471. 2025 AB 471, “relating to: the regulation of digital assets” (bill text and history).
9. 2025 Assembly Bill 892. 2025 AB 892, “relating to: digital asset staking and the state’s securities laws” (bill text and history).
10. Committee-hearing testimony. AB 471 and AB 892 public-hearing records, Wisconsin State Legislature; coverage, Wisconsin Public Radio and WisPolitics.
11. Multistate staking actions against Coinbase (2023). Wisconsin DFI, news release (June 9, 2023); New Jersey Bureau of Securities.
12. SEC dismissal, state withdrawals, remaining holdouts. SEC dismissal of its Coinbase staking matter (Feb. 2025); Coinbase, “Staking action dismissals”; and CoinDesk/Politico reporting.
13. SEC–CFTC harmonization. SEC, memorandum of understanding (Mar. 11, 2026) and joint interpretation (Mar. 17, 2026), incl. Chairman Atkins’s statement.
14. Missed staking rewards ($4M). Testimony of Coinbase U.S. policy director Robin Cook at the AB 892 hearing, per WisPolitics.
15. GENIUS Act. S. 1582, Guiding and Establishing National Innovation for U.S. Stablecoins Act, 119th Cong. (signed July 18, 2025).
16. CLARITY Act. H.R. 3633, Digital Asset Market Clarity Act, 119th Cong. (passed the House July 2025; pending in the Senate).
17. Wyoming special-purpose depository institutions. Wyoming Division of Banking, SPDIs.
18. UCC Article 12 (2022 amendments). Uniform Law Commission, 2022 UCC Amendments (new Article 12; enactment tracker).
19. Great Lakes scorecard. Money transmission: CSBS MTMA tracker (incl. Illinois S.B. 3412). Kiosks: Minnesota Dept. of Commerce (2024 law), Illinois S.B. 2319, Michigan H.B. 4511 / H.B. 5469 (introduced). UCC Article 12: Uniform Law Commission (Illinois and Minnesota enacted). Custody: Wyoming; Nebraska Financial Innovation Act.

Common questions

What did Wisconsin’s Act 267 change?

2023 Wisconsin Act 267 replaced the state’s decades-old “Sellers of Checks” law with a modern money-transmitter statute (a new Chapter 217). It adopts the Money Transmission Modernization Act, a national model law from the Conference of State Bank Supervisors, so states share one rulebook. In plain terms, it updated the license you need to move other people’s money for a digital age. Wisconsin was the 20th state to sign on.

What is Wisconsin’s Act 226, and why did it pass?

2025 Wisconsin Act 226 regulates virtual-currency kiosks — the “Bitcoin ATMs” in gas stations and grocery stores — by requiring operators to be licensed and adding consumer protections. It answered a fast-growing scam: the FTC reported Americans lost more than $65 million at Bitcoin ATMs in just the first half of 2024, with people over 60 accounting for roughly seven of every ten dollars lost. (The FBI’s full-year 2024 count reached nearly $247 million.)

Does Wisconsin cap crypto-kiosk (ATM) transactions?

Yes. Act 226 caps what one customer can move through a single operator’s kiosks at $1,000 in a single day — a limit built to break up exactly the big, panicked, one-time transfer these scams run on. It also forces an operator to refund a defrauded customer in full, fees and all, if they report within 30 days to both the operator and law enforcement. The cap is per operator, though, which means a determined scammer can still walk a victim to a second company’s machine down the street.

What happened to Wisconsin’s digital-asset staking bills?

AB 471 and AB 892 would have clarified the legal standing of staking and self-custody. Both died at the end of the 2025–26 session — one after passing the Assembly and clearing every committee. They were Wisconsin’s own initiatives, and their failure is the clearest sign of the state hesitating to set its own course.

Is staking a security in Wisconsin?

It’s unsettled, and Wisconsin has been on both sides. The Legislature moved to declare staking is not a security, while a state regulator argues in an active enforcement action that it is. Federally, the SEC and CFTC issued a March 2026 joint interpretation treating staking as a service, not a security, lining up with the Legislature’s view.

How does the federal GENIUS Act affect Wisconsin’s new laws?

The GENIUS Act (2025) set the first national stablecoin rules and preempts state licensing for stablecoin issuers — a narrow slice of the money-transmission framework Wisconsin just modernized. Most digital-asset law is still state law: how a security is defined, how custodians are chartered, how consumers are protected. Washington changed one lane, not the whole road.