News & Analysis as of July 18, 2025

Regulatory Requirements

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Virtual Currency (aka Digital Currency or Digital Money) is a type of currency or medium of exchange that is not issued by any government nor guaranteed by a government currency. Despite lacking legal tender status, Virtual Currency is still traded and exchanged in some environments, typically online environments or communities. Bitcoin is the most well-known form of Virtual Currency. less -

Association of State Financial Regulators Issues Guidance on Virtual Currency for Licensed Money Transmitters

Wilson Sonsini Goodrich & Rosati on 7/10/2025

Recognizing the evolving landscape of digital finance, the Conference of State Bank Supervisors (CSBS), an association of state financial regulators, issued advisory guidance on the treatment of virtual currency held on a...more

CSBS Issues Guidance on Virtual Currency and Tangible Net Worth

Troutman Pepper Locke on 7/9/2025

On June 26, the Conference of State Bank Supervisors (CSBS) released new guidance regarding the treatment of virtual currency in the calculation of a licensee’s tangible net worth under the Money Transmission Modernization...more

Client Alert: California Enters the Arena of Virtual Currency Regulation

Jenner & Block on 10/25/2023

After prolonged deliberation, California has finally decided to enter the virtual currency regulatory arena by adopting two virtual currency regulatory bills into law. The California Digital Financial Assets Law (“DFAL”),...more

Wyoming, the “Equality State,” Seeks to Level the Playing Field for Digital Assets Businesses

Orrick - On the Chain on 12/4/2019

In its continued effort to establish itself as the go-to jurisdiction for digital asset businesses, Wyoming, through its Department of Audit, Division of Banking, recently published a digital asset custody regime for its...more

PA Department of Banking and Securities: Virtual Currency is not “Money”

Ballard Spahr LLP on 1/25/2019

Typical Virtual Currency Exchanges Do Not Require PA Money Transmitter Licenses - The Pennsylvania Department of Banking and Securities (“DoBS”) just released Guidance declaring that virtual currency, “including Bitcoin,”...more

Blockchain Week in Review - January 2019 #3

Perkins Coie on 1/24/2019

U.S. Developments - Flood of State Virtual Currency Legislation - Since the start of the new year there have been roughly nine virtual currency bills introduced or passed in four different states. Overall, the bills...more

State Regulations on Virtual Currency and Blockchain Technologies (Updated)

Carlton Fields on 1/9/2019

There exists no uniformity with respect to how businesses that deal in virtual currencies (also known as "cryptocurrencies") such as Bitcoin are treated among the states....more

States Race To Embrace Blockchain Technology

Robinson+Cole Data Privacy + Security Insider on 7/24/2018

Add Connecticut, Ohio and Vermont to the list of states passing legislation focused on the potential disruptive impact of blockchain – the technology underlying cryptocurrencies such as Bitcoin. ...more

A Proposed Statutory Framework for State Regulation of Virtual Currency Businesses: The Uniform Law Commission’s “Uniform...

Proskauer - Blockchain and the Law on 4/5/2018

Last July, the Uniform Law Commission completed a uniform model state law, known as the Uniform Regulation of Virtual-Currency Businesses Act (“URVCBA” or the “Act”) (Steve Weise participated in the preparation of the Act)....more

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Virtual Currency › State and Local Government › Regulatory Requirements

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