title: United States – Idaho Payments Regulation Monitor | World Payments Monitor canonical: https://payments.gi/jurisdictions/united-states-idaho/ date_modified: 2026-10-21 publisher: Asymmetric Intelligence # United States – Idaho US-ID schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-21 · 14 modules · 63 sourced findings · 131 sources in the cumulative register 14 Modules baseline.modules[] 63 Findings modules[].findings[] 87 Tier-1 sources run_metadata.t1_source_count Confidence mix (sums to 14 rendered modules; click to filter) No modules moved this cycle. ** United States federal law** that applies in United States – Idaho is covered once, on the [United States](https://payments.gi/jurisdictions/united-states/) page. This page covers United States – Idaho’s own layer: its own law, regulators and enforcement. ## Jurisdiction brief ###### Latest update · 11 October 2026 #### Lead Signal Idaho's payments licensing environment tightened in substance this cycle even as a new statute expanded individual rights in one adjacent area. The Idaho Department of Finance entered an Agreement and Order with Rockwallet LLC in April 2026, resolving findings that the firm had conducted unlicensed money transmission from at least April 2023 through the order date. In a separate matter, the Department denied PayKES L.L.C.'s money-transmitter licence application, dated March 25, 2026, for failing the statutory net-worth and financial-responsibility tests under Idaho Code Sections 26-2905 and 26-2910. Both actions proceed under the state's core payments statute, the Money Transmitters Act, which requires a licence for the business of money transmission absent a narrow statutory exemption. At the same time, the Legislature enacted the Distributed Ledger Technology Act, Senate Bill 1296, signed by the Governor on March 19, 2026 as Session Law Chapter 78 and effective July 1, 2026, which protects an individual's right to self-custody a software or hardware cryptocurrency wallet and to run a distributed-ledger node, without displacing the pre-existing money-transmitter licensing regime for businesses. The combined picture for market access is one of continuity and clarification rather than a wholesale regime change: the licensing gateway was already the operative control, and this cycle shows the Department exercising it against both an unlicensed incumbent and an under-capitalised new entrant, while the Legislature has separately carved out and protected a zone of individual self-custody and node-operation activity that sits outside the licensing perimeter altogether. #### Other Developments **The Money Transmitters Act's licensing requirement is unchanged and remains the operative statute for market access.** Idaho Code Section 26-2903(1) requires a licence for the business of money transmission in Idaho absent a Section 26-2904 exemption; this is standing context against which this cycle's two enforcement and licensing decisions were made, rather than a new development in itself. **The DLT Act's self-custody and node-operation protections create a carve-out that does not reach licensed money-transmission businesses.** The new statute bars state and local government from enacting rules that prohibit, restrict, or impair an individual's ability to self-custody a wallet or run a node, a protection framed around individual activity rather than commercial money-transmission services, which continue to require licensure. #### Cross-Monitor Connections The same Department of Finance orders against Rockwallet and PayKES are read in the financial-integrity monitor's output through an AML/CFT and licensing-enforcement lens, and in the crypto monitor's licensing module through a digital-asset-regime lens; all three readings rest on the identical primary-source orders. The DLT Act's self-custody protections also carry directly into the crypto monitor's on-chain-activity module, where the same statute is assessed for its node-operation and wallet-custody implications rather than its payments-market-access implications. #### Outlook Idaho's licensing gateway is likely to remain the primary lever for market access control in the near term, with the Department continuing to apply the net-worth and financial-responsibility tests that defeated the PayKES application and the unlicensed-operation standard that produced the Rockwallet order. The DLT Act's self-custody protections took effect July 1, 2026 and are now in force, establishing a durable boundary between protected individual activity and licensed commercial money transmission that future licensing decisions will need to respect. _2 earlier updates not shown here._ ###### Standing brief · as of 7 July 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Lead Signal Idaho's first full baseline cycle surfaces a sharpening contradiction at the centre of the state's payments-regulatory posture: an executive branch that vetoed a bipartisan consumer-protection bill even as its own securities regulator continues to signal accommodation for the instrument most implicated in the state's fastest-growing fraud vector. Governor Brad Little vetoed the Virtual Currency Kiosk Fraud Prevention Act (Senate Bill 1359) on April 2/3, 2026, despite passage through both the House and Senate; AARP Idaho publicly disputed the veto rationale, and sponsors indicated intent to bring revised legislation in a future session. The vetoed bill would have imposed new-customer transaction limits of $2,000 per 24 hours and $10,000 per 30 days, a 72-hour settlement delay on first transactions, mandatory fraud warnings, and fee refunds for fraud victims -- none of which are now in force. SB 1359 would also have nested crypto-kiosk oversight inside the existing Money Transmitters Act (Title 26, Chapter 29), requiring kiosk operators to hold an Idaho money-transmitter licence; that licensing extension is now stalled alongside the consumer-protection provisions. The veto lands against Attorney General data showing cryptocurrency-related consumer fraud losses rising from $19 million in 2023 to over $35 million in 2024, with seniors the largest victim group and crypto-ATM/kiosk scams a substantial driver; FBI Internet Crime Complaint Center data for 2025 puts Idaho crypto-fraud losses above $48 million. The same Idaho Department of Finance that would have gained enforcement tools under SB 1359 had already moved in a more accommodative direction eight months earlier, publishing a September 2025 Crypto ATM Framework Keys paper that frames a right-sized oversight approach intended to let crypto-ATM operators keep operating in Idaho while protecting consumers. The juxtaposition of an escalating, well-documented harm, a legislature that acted on it with bipartisan support, and an executive veto that leaves the substantive protection gap open, makes Idaho's kiosk-fraud file the most consequential single development of this baseline cycle. #### Other Developments Idaho's core non-bank payments licensing gateway is a single unified regime: the Idaho Money Transmitters Act (Idaho Code Title 26, Chapter 29), administered by the Securities Bureau of the Idaho Department of Finance, covers money transmitters, stored-value issuers/sellers, and virtual-currency exchangers alike. Minimum thresholds under the Act require net worth of at least $50,000 (rising $25,000 per branch to a $250,000 cap) and a surety bond of at least $10,000 (rising $5,000 per branch to a $500,000 cap); that same scaled bond -- formally a security device under Idaho Code 26-2908 -- doubles as the state's safeguarding mechanism for customer funds, a materially different architecture from a UK/EU-style client-money trust or segregation regime. Conduct and promotions sit outside any payments-specific regime, backstopped instead by the Idaho Consumer Protection Act (Title 48, Chapter 6) via Attorney General civil enforcement and private rights of action. Licensing enforcement is live: the Department of Finance denied Apex Capital Enterprises LLC's money-transmitter licence application for failing net-worth qualification requirements under Idaho Code 26-2916, though an independent verification challenge has flagged an unresolved discrepancy between the cited order's stated date and the Department's administrative-action page metadata, leaving the precise date -- though not the underlying denial -- unconfirmed pending re-verification. On digital money, Idaho has no enacted stablecoin-specific statute. A GENIUS-Act-aligned framework was introduced repeatedly in the 2026 session -- four bills in total (HB 586, HB 821, HB 901, and SB 1423) -- with SB 1423 passing the Senate before dying without a House hearing. A separate, already-enacted framework, Senate Bill 1296 (2024), establishes in-force rights to self-custody, Bitcoin mining, and Bitcoin node-running free of state or local restriction, functioning as the state's only enacted digital-money-adjacent statute even as the stablecoin track remains unresolved. Operational resilience relies entirely on the federal examination stack: Idaho-chartered banks and credit unions are examined for IT/cyber risk through the interagency InTREx programme (FDIC/CSBS/Federal Reserve) rather than any state-specific resilience statute, and the FFIEC's Cybersecurity Assessment Tool sunset on August 31, 2025, redirecting institutions toward the NIST Cybersecurity Framework 2.0 and sector tools such as the Cyber Risk Institute Profile. Scheme and network compliance remains permissive: Idaho merchants may surcharge subject only to federal card-network caps (Visa 3%/Mastercard 4% or actual cost, whichever is lower), with no state-specific surcharge statute. A second consecutive attempt to restrict interchange scope, Senate Bill 1055 (2025), which would have barred processors from charging interchange on the tax or gratuity portion of a transaction, failed to pass, following a near-identical failed 2023 bill (SB 1066). Corridor dynamics are shaped by a single load-bearing precedent: the U.S. District Court for the District of Idaho held, in PayServices Bank v. Federal Reserve Bank of San Francisco, that FRBSF properly exercised discretion under 12 U.S.C. 342 to deny a master-account application, dismissing APA, Mandamus Act, and Due Process claims on March 30, 2024. That ruling confirms Federal Reserve Banks' near-unfettered discretion over direct settlement-rail access nationally, and it is the reason Idaho community banks access Fed rails predominantly via correspondent relationships -- such as with Bankers' Bank of the West, which also supports FedNow onboarding -- rather than direct master accounts. The Idaho Bank Act reinforces that federal integration by permitting the Director of the Department of Finance to rely on federal examination reports (Federal Reserve, OCC, FDIC) in lieu of independent state holding-company examination. The Money Transmitters Act separately licenses money transmission both within the United States and to locations outside the United States, bringing outbound cross-border remittance corridors within the state's licensing scope even though no state-run corridor or rail exists. Industry structure shows a consolidating, competitively tense picture: Idaho Central Credit Union, with approximately $10 billion in assets, ranks among the top 20 U.S. credit unions and is a structurally significant nonbank deposit/payments competitor to community banks, while the Idaho Bankers Association actively contests the credit-union tax-exempt model as a competitive-structure issue. Community-bank consolidation continued with Glacier Bancorp's completed acquisition of Bank of Idaho Holding Co. for $245.4 million, adding roughly $1.3 billion in assets and 15 locations across Eastern Idaho, Boise, and Eastern Washington -- Glacier's 26th bank acquisition since 2000. On merchant acquiring, Idaho has no dedicated acquiring statute; Idaho Central Credit Union delivers merchant-acquiring services through a partnership with Fiserv/Clover, with high-risk-MCC treatment governed by processor and network policy rather than state law. On product innovation, credit-union vendor partnerships are the dominant pattern: alongside the Department of Finance's accommodative Crypto ATM Framework Keys paper, Idaho Central Credit Union has deployed Zest AI for automated credit underwriting, reporting a 30%+ increase in loan approvals across auto, personal, and credit-card lending with bias testing built into the model. On the AML/CFT overlay, Idaho-licensed money transmitters must register with FinCEN as Money Services Businesses on Form 107, renewing every two years, maintaining a written BSA/AML compliance programme with a designated compliance officer, and filing Suspicious Activity Reports for transactions of $2,000 or more that are known or suspected to be suspicious; this module carries only the Sentinel.gi payments-context AML posture, since direct Sentinel.gi feed content for US-ID was not accessible this cycle. Commercial activity in the baseline window is dominated by product and partnership events rather than fresh deal-making: Alkami Technology deployed its ORB digital-banking platform at Idaho Central Credit Union, integrating with ICCU's Fiserv DNA core to add ACH and wire capabilities, and Upstart partnered with ICCU to expand personal-loan origination across Idaho, Washington, and eastern Oregon via its AI lending marketplace. Separately, World Liberty Financial disclosed lobbying spend of roughly $18,000 in travel and lodging plus $450-900 in meals for a Mar-a-Lago dinner hosting three Idaho legislators between February and April 2026, in support of the stablecoin bills. #### Cross-Monitor Connections The kiosk-fraud and AML findings in this cycle carry significance beyond WPM's consumer-protection and licensing framing. Idaho's crypto-ATM/kiosk fraud losses -- Attorney General data showing a rise from $19 million to over $35 million between 2023 and 2024, and FBI IC3 data placing 2025 losses above $48 million -- together with a pending 2026 FinCEN AML/CFT programme-modernisation rulemaking, carry illicit-finance and AML significance that sits outside this monitor's remit. This module (W11) carries only the Sentinel.gi-sourced payments-context AML posture rather than original illicit-finance analysis; readers seeking the illicit-finance dimension of Idaho's crypto-kiosk fraud problem should consult the Financial Intelligence Monitor. #### Outlook Idaho's payments-regulatory trajectory into the next cycle is defined by three open questions rather than settled positions. First, the stablecoin track: four consecutive legislative attempts have failed to produce an enacted GENIUS-Act-aligned framework, and whether a fifth attempt emerges -- amid continuing lobbying activity such as World Liberty Financial's -- will determine whether Idaho joins the ranks of states with a codified stablecoin regime or remains reliant on the 2024 digital-asset-rights statute alone. Second, the kiosk-fraud gap: sponsors of the vetoed SB 1359 have indicated intent to bring revised legislation in a future session, and continuing AG- and FBI-reported loss escalation makes some legislative or administrative response likely, though the accommodative posture in the Department of Finance's Crypto ATM Framework Keys paper suggests any future fix may arrive through guidance rather than statute. Third, the master-account precedent: PayServices Bank v. FRBSF stands as settled law shaping correspondent-dependency for Idaho's community banks, and no countervailing litigation or federal rulemaking is currently in view that would loosen Federal Reserve discretion over direct settlement-rail access. Verification of the Apex Capital Enterprises order date remains an open item for the next cycle. trust tier: ai_unverified ###### Latest update · 28 September 2026 #### Regulatory Status Idaho's payments regulatory posture this cycle is defined by a single proposed measure that did not advance: Senate Bill 1440, which would have imposed an excise tax on international money-transmission transactions -- a flat $5 fee under $500 and a 4% tax above that threshold, collected by licensed transmitters and remitted quarterly to the Idaho State Tax Commission. The bill was referred to the Senate Local Government & Taxation Committee on March 27, 2026, and saw no further action before the session adjourned on April 2, 2026, leaving it stalled rather than defeated. Beneath this proposal, the underlying licensing framework -- money-transmitter licensing under the Idaho Money Transmitters Act, administered by the Idaho Department of Finance's Securities Bureau, with a surety bond scaling from $10,000 to $500,000 and a minimum net-worth requirement -- remains unchanged and structurally stable. #### Outlook Idaho's payments regime should be read as stable at the licensing-and-bonding level, with one live watch item: whether S1440's excise-tax structure is reintroduced in a future session. Because the bill stalled procedurally at committee referral rather than being voted down, the same or a similar transaction-tax mechanism targeting international money transmissions remains available to be brought back, and firms with Idaho-licensed transmission operations touching cross-border transfers should monitor the next legislative session for its reappearance. _1 earlier update not shown here._ ###### Standing brief · as of 7 July 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Regulatory Status Idaho's payments-regulatory architecture, established as a full baseline in this cycle, rests on a single non-bank licensing gateway -- the Idaho Money Transmitters Act (Title 26, Chapter 29), administered by the Securities Bureau of the Idaho Department of Finance -- that covers money transmitters, stored-value issuers/sellers, and virtual-currency exchangers (W1a), backstopped by a scaled bond/security-device safeguarding model under Idaho Code 26-2908 rather than a UK/EU-style trust regime, with conduct and promotions governed generically by the Idaho Consumer Protection Act (W1b). Digital-money regulation is unsettled: no stablecoin-specific statute has been enacted despite four legislative attempts in the 2026 session alone (HB 586, HB 821, HB 901, SB 1423), while a 2024 digital-asset-rights statute (SB 1296) covering self-custody and Bitcoin mining/node-running is in force (W2). Operational resilience and merchant acquiring both rely on federal/network frameworks rather than state-specific statute -- InTREx/FFIEC examination for resilience (W3) and processor/network policy for acquiring (W8) -- while scheme and network compliance remains permissive, with two consecutive legislative attempts to restrict interchange on tax/gratuity having failed (W4). Corridor and correspondent dynamics are shaped by a single load-bearing federal-court precedent, PayServices Bank v. Federal Reserve Bank of San Francisco, decided in the District of Idaho, which confirms broad Federal Reserve discretion over master-account access and explains why Idaho community banks remain correspondent-dependent (via relationships such as Bankers' Bank of the West) rather than holding direct Fed master accounts (W5/W12); the Idaho Bank Act reinforces this federal integration by permitting reliance on federal examination reports in lieu of independent state holding-company examination (W12). Industry structure shows a fast-growing, structurally significant credit-union sector (Idaho Central Credit Union, ~$10 billion in assets) alongside consolidating community banks (Glacier Bancorp's $245.4 million acquisition of Bank of Idaho), against a backdrop of bank-versus-credit-union tax-exemption tension voiced by the Idaho Bankers Association (W6). The state's litigation and enforcement register combines the PayServices Bank precedent, an MTL licence denial (Apex Capital Enterprises, order date under re-verification), and the 2026 gubernatorial veto of bipartisan crypto-kiosk fraud legislation (W7). Product innovation runs through regulatory accommodation for crypto ATMs (the Department of Finance's September 2025 Crypto ATM Framework Keys paper) and credit-union AI/digital-banking vendor deployments including Zest AI, Alkami's ORB platform, and Upstart (W9/W13). AML/CFT posture layers the federal BSA/FinCEN Money Services Business framework onto state MTL licensing, carried here via Sentinel.gi payments-context sourcing rather than original illicit-finance analysis (W11). The most acute consumer-harm vector is cryptocurrency-related fraud: Attorney General data shows losses rising from $19 million (2023) to over $35 million (2024), with FBI IC3 data placing 2025 losses above $48 million, concentrated among senior victims of crypto-ATM/kiosk scams. A bipartisan bill (SB 1359) that would have addressed both the consumer-protection gap and nested kiosk licensing within the MTL regime passed both chambers but was vetoed by Governor Brad Little in April 2026, leaving the gap open (W10/W1a/W7). #### Outlook Idaho's overall regulatory trajectory combines a stable, long-established core (the MTL licensing/safeguarding regime, the federal-reliant resilience and correspondent-banking postures, the permissive scheme/surcharge regime) with three areas of active volatility: the unresolved stablecoin legislative track, the vetoed and potentially revived crypto-kiosk consumer-protection and licensing package, and continuing industry consolidation and credit-union/bank competitive tension. The jurisdiction's risk profile is assessed as elevated, with an uncertain regulatory direction driven primarily by the stablecoin (W2), licensing (W1a), litigation (W7), and consumer-protection (W10) modules. Verification of the Apex Capital Enterprises order date is an open item for the next cycle, as is direct Sentinel.gi feed integration for W11 and confirmation of any in-window Idaho fintech funding activity for W13. 14 of 14 modules Signal Density Selections OR within a group, AND across groups. Press / to search. ### W1a Licensing, Authorisation & Market Access Confirmed confirmed 2026-07-05 Virtual-currency kiosk/exchange activity in Idaho continues to be governed solely by the generic Idaho Money Transmitters Act (Idaho Code § 26-2901 et seq.), administered by the Securities Bureau, Idaho Department of Finance. A 2026 attempt to layer kiosk-specific licensing/AML obligations (SB1359a) passed the legislature but was vetoed by Gov. Little on April 8-9, 2026, preserving the status quo. Standing sub-brief · as of 7 July 2026 325 words · last cycle 2026-10-11 #### Licensing, Authorisation & Market Access Idaho's non-bank payments licensing gateway is unified under the Idaho Money Transmitters Act (Idaho Code Title 26, Chapter 29), administered by the Securities Bureau of the Idaho Department of Finance. The Act covers non-bank money transmitters, stored-value issuers/sellers, and virtual-currency exchangers, requiring each to hold an Idaho Money Transmitter Licence. Minimum capitalisation and bonding thresholds require net worth of at least $50,000, rising $25,000 per branch to a maximum of $250,000, alongside a surety bond of at least $10,000, rising $5,000 per branch to a maximum of $500,000. Enforcement of this gateway is active rather than merely nominal: the Department of Finance denied Apex Capital Enterprises LLC's licence application for failing the Act's net-worth qualification requirements under Idaho Code 26-2916. An independent baseline-research verification challenge dated 2026-07-05 flagged that the cited order PDF's stated date (2025-12-02) may not match the Department's administrative-action page metadata, which reportedly shows a last-update of 2025-08-22; the precise order date is therefore treated as unconfirmed pending re-verification, though the underlying enforcement fact -- a denial for net-worth failure -- is not itself disputed. The licensing perimeter nearly extended to virtual-currency kiosks in 2026. Senate Bill 1359 would have nested crypto-kiosk oversight inside the existing MTL regime, requiring kiosk operators to hold an Idaho money-transmitter licence. The bill passed both chambers but was subsequently vetoed by Governor Brad Little (see W7/W10), leaving kiosk operators outside the state's core non-bank licensing gateway for now. #### Outlook The MTL regime itself is stable and unlikely to change in its core contours; the open question is scope, not architecture. Whether a revived kiosk-licensing bill in a future session succeeds in bringing virtual-currency kiosk operators inside Chapter 29 -- as SB 1359 attempted -- will be the key licensing-perimeter development to track. Separately, the unresolved date discrepancy on the Apex Capital Enterprises denial order should be treated as an open verification item rather than a substantive challenge to the enforcement outcome. Periodic update · new data 2026-10-11 #### Licensing, Authorisation & Market Access Idaho's market-access framework for payment and money-transmission businesses is anchored in the Money Transmitters Act, Idaho Code Section 26-2901 et seq., which requires any person engaging in the business of money transmission in Idaho, absent a narrow exemption under Idaho Code Section 26-2904, to hold a state licence. This statute is unchanged this cycle but forms the necessary backdrop to two fresh Department of Finance decisions that show the licensing gateway in active operation. First, the Department entered an Agreement and Order with Rockwallet LLC in April 2026, resolving findings that the firm had engaged in the business of money transmission in Idaho without a licence from at least April 2023 through the date of the order. No monetary penalty was disclosed as part of the resolution. Second, and separately, the Department denied a money-transmitter licence application submitted by PayKES L.L.C., dated March 25, 2026, on the ground that the applicant failed to meet the statutory net-worth and financial-responsibility requirements set out in Idaho Code Sections 26-2905 and 26-2910. Together these two decisions illustrate both ends of the licensing gateway's function: enforcement against an entity that operated without ever obtaining a licence, and gatekeeping against an applicant that sought a licence but could not meet the capital-adequacy bar. Alongside this enforcement and licensing activity, the Idaho Legislature enacted the Distributed Ledger Technology Act, Senate Bill 1296, signed by the Governor on March 19, 2026, designated Session Law Chapter 78, and effective July 1, 2026. The Act establishes a right for individuals to self-custody software or hardware cryptocurrency wallets and to operate distributed-ledger technology nodes, and bars state or local governing bodies from enacting an ordinance, resolution, or rule that would prohibit, restrict, or otherwise impair those activities. Critically, this protection is framed around individual activity, not commercial money-transmission services, and the Act sits alongside the pre-existing Money Transmitters Act licensing regime without displacing or narrowing it. A business conducting money transmission, including a virtual-currency exchange or custodial service, continues to require a licence under the existing statute regardless of the DLT Act's individual-rights protections. The net effect for market participants is a bifurcated but coherent structure: individuals retain a newly-codified right to self-custody and run nodes without governmental interference, while commercial money-transmission activity, whether fiat or virtual-currency denominated, remains subject to the Money Transmitters Act's licensing, net-worth, and bonding requirements, which the Department has shown this cycle it continues to enforce both against unlicensed incumbents and against under-capitalised applicants. #### Outlook The Department of Finance's enforcement posture toward unlicensed virtual-currency money transmission, evidenced by the Rockwallet order, and its gatekeeping posture toward under-capitalised licence applicants, evidenced by the PayKES denial, both point toward continued active administration of the existing statutory licensing gateway rather than any near-term change to the underlying legal standard. The DLT Act's self-custody and node-operation protections, now in force since July 1, 2026, establish a durable individual-rights boundary that licensing decisions and any future legislative activity will need to respect, without altering the licensing obligations that apply to commercial money-transmission businesses operating in the state. **2 earlier distinct update(s)** Periodic update · new data 2026-09-28 #### Licensing, Authorisation & Market Access Idaho's money-transmitter licensing framework, administered by the Idaho Department of Finance's Securities Bureau under the Idaho Money Transmitters Act (Idaho Code §26-2901 et seq.), remains the operative gateway for non-bank payment institutions in the state, requiring a surety bond scaling from $10,000 to $500,000 depending on transaction volume plus a minimum net-worth threshold. No change to those bonding or net-worth figures was reported this cycle; the framework's structural stability is the backdrop against which this cycle's one material development occurred. That development is Idaho Senate Bill 1440, introduced in the 2026 session, which would have imposed a new excise tax on international money-transmission transactions: a flat $5 fee on transfers under $500, and a 4% tax on the portion of any transaction exceeding $500, collected at the point of transaction by the licensed transmitter and remitted quarterly to the Idaho State Tax Commission. The bill would not have altered who needs a license or the terms of licensure -- it targets the transaction itself, layering a new state revenue mechanism on top of the existing licensing perimeter rather than touching the perimeter itself. This is a nonbank_pi_emi-facing measure: it speaks to licensed money transmitters specifically, the category under which non-bank payment institutions and e-money-adjacent transmitters in Idaho operate, and does not engage bank-channel payment activity. Procedurally, S1440 was referred to the Senate Local Government & Taxation Committee on March 27, 2026, and received no further recorded floor action before the 2026 session adjourned on April 2, 2026. The bill is therefore stalled rather than rejected: it did not receive a committee vote that killed it outright, nor did it reach the floor for a vote that failed. That distinction matters for how the finding should be read going into future sessions -- a bill that dies in adjournment without a negative committee vote is procedurally live to be reintroduced with the same or similar text in a subsequent session, whereas an outright floor defeat would signal a harder political ceiling. #### Outlook The licensing and bonding framework itself shows no sign of near-term change and should be treated as stable. The excise-tax proposal is the item to track: its structure -- transmitter-collected, transaction-tiered, remitted quarterly -- is a template that could be reintroduced largely intact in a future Idaho legislative session, and the committee-stage stall (rather than a decisive defeat) leaves that reintroduction path open. Firms holding or seeking Idaho money-transmitter licenses with material international-transfer volume should treat this as a watch item for the next session rather than a resolved question. Periodic update · new data 2026-09-22 #### Licensing, Authorisation & Market Access Idaho SB1359a, the Virtual Currency Kiosk Fraud Prevention Act, was vetoed by Governor Little on April 8-9, 2026. The bill would have created a new Chapter 54 under Title 28 of the Idaho Code, imposing kiosk-specific licensing conditions on top of the existing money-transmitter framework: mandatory blockchain-analytics and tracing software, capped new-customer transactions, a delayed first-transaction settlement window, and fraud-related fee refunds. Following the veto, virtual-currency kiosk and exchange operators in Idaho continue to access the market through the same non-bank money-transmitter licensing pathway, Idaho Code § 26-2901 et seq., administered by the Securities Bureau of the Idaho Department of Finance, carrying no exemption and no kiosk-specific authorization tier. This is explicitly a non-bank market-access story: the licensing lane in question is the nonbank payment-institution and e-money-institution lane, not a bank charter, and the veto leaves that lane's contours unchanged. No new capital, bonding, or conduct-of-business condition attaches to kiosk operation as a result of this cycle's development; the market-access bar for entering Idaho's virtual-currency kiosk business remains exactly what it was before the bill was introduced. #### Outlook A redrafted Virtual Currency Kiosk Fraud Prevention Act addressing the Governor's stated drafting deficiencies could reach the Idaho Legislature in the 2027 session. If enacted, it would introduce Idaho's first kiosk-specific licensing overlay on the non-bank money-transmitter regime. Until then, market access for virtual-currency kiosk operators in Idaho remains governed by the generic framework alone. **Sources and findings (6)** 1. T1 [https://www.finance.idaho.gov/securities-bureau/money-transmitters/](https://www.finance.idaho.gov/securities-bureau/money-transmitters/) retrieved 2026-07-05 2. T1 [https://www.finance.idaho.gov/wp-content/uploads/legal/statutes-rules/documents/Money%20Transmitters%20Act.pdf](https://www.finance.idaho.gov/wp-content/uploads/legal/statutes-rules/documents/Money%20Transmitters%20Act.pdf) retrieved 2026-07-05 3. T3 [https://www.bondexchange.com/idaho-money-transmitter-bond-a-comprehensive-guide/](https://www.bondexchange.com/idaho-money-transmitter-bond-a-comprehensive-guide/) retrieved 2026-07-05 4. T1 [https://www.finance.idaho.gov/wp-content/uploads/2023/09/2025-12-02-Apex-Order-of-Denial.pdf](https://www.finance.idaho.gov/wp-content/uploads/2023/09/2025-12-02-Apex-Order-of-Denial.pdf) retrieved 2026-07-05 5. T2 [https://www.billtrack50.com/billdetail/1983173](https://www.billtrack50.com/billdetail/1983173) retrieved 2026-07-05 6. T1 [https://www.finance.idaho.gov/securities-bureau/money-transmitters/](https://www.finance.idaho.gov/securities-bureau/money-transmitters/) retrieved 2026-07-05 ### W1b Conduct, Safeguarding & Promotions Confirmed confirmed 2026-07-05 Idaho's safeguarding mechanism for money transmitters is a scaled security device (surety bond, irrevocable letter of credit, or similar), not a UK/EU-style client-money segregation or trust regime. Conduct/promotions are governed generically by the Idaho Consumer Protection Act, enforced by the Attorney General. Standing sub-brief · as of 7 July 2026 204 words · last cycle 2026-07-05 #### Conduct, Safeguarding & Promotions Idaho money transmitters must furnish a safeguarding security device of at least $10,000, increasing $5,000 per branch to a maximum of $500,000, running to the state for the benefit of claimants against the licensee under Idaho Code 26-2908. This is a bond/security-device model, not a UK/EU-style client-money trust or segregation regime -- a materially different consumer-protection architecture from jurisdictions that mandate ring-fenced safeguarding accounts. There is no dedicated payments financial-promotions regime in Idaho; conduct and promotional practices are instead governed generically by the Idaho Consumer Protection Act (Title 48, Chapter 6), enforced through Attorney General Consumer Protection Division civil enforcement and private rights of action for unfair or deceptive acts or practices. #### Outlook Barring a change to the Money Transmitters Act itself, the scaled-bond safeguarding model is a stable, structural feature of Idaho's regime rather than a live legislative question. The absence of a payments-specific promotions regime means conduct issues -- including those arising from the crypto-kiosk fraud pattern tracked in W10 -- will continue to be addressed, if at all, through the Attorney General's general consumer-protection authority rather than a targeted payments rulebook, unless a revived version of the vetoed SB 1359 changes that calculus in a future session. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T1 [https://www.finance.idaho.gov/wp-content/uploads/legal/statutes-rules/documents/Money%20Transmitters%20Act.pdf](https://www.finance.idaho.gov/wp-content/uploads/legal/statutes-rules/documents/Money%20Transmitters%20Act.pdf) retrieved 2026-07-05 2. T3 [https://idaholegalservicesauthority.com/idaho-consumer-protection-law](https://idaholegalservicesauthority.com/idaho-consumer-protection-law) retrieved 2026-07-05 3. T1 [https://www.ag.idaho.gov/consumer-protection/](https://www.ag.idaho.gov/consumer-protection/) retrieved 2026-07-05 4. T1 [https://www.finance.idaho.gov/wp-content/uploads/legal/statutes-rules/documents/Money%20Transmitters%20Act.pdf](https://www.finance.idaho.gov/wp-content/uploads/legal/statutes-rules/documents/Money%20Transmitters%20Act.pdf) retrieved 2026-07-05 5. T2 [https://www.billtrack50.com/billdetail/1983173](https://www.billtrack50.com/billdetail/1983173) retrieved 2026-07-05 ### W2 Stablecoins & Digital Money Probable confirmed 2026-07-05 Idaho has no enacted stablecoin-specific statute as of the baseline date. A GENIUS Act-aligned framework was introduced repeatedly in the 2026 session (HB586/821/901, SB1423) but none enacted. A separate Bitcoin/digital-asset rights framework (SB1296, 2024) is in force. Standing sub-brief · as of 7 July 2026 224 words · last cycle 2026-07-05 #### Stablecoins & Digital Money Idaho has no enacted stablecoin-specific statute as of the baseline date. The 2026 legislative session saw four separate bills addressing stablecoins introduced -- HB 586, HB 821, HB 901, and Senate Bill 1423 (the FAST Act) -- continuing a pattern of repeated but unsuccessful attempts to legislate a GENIUS-Act-aligned state framework. SB 1423 passed the Senate but died without a House hearing, leaving Idaho without an enacted framework. Lobbying around the stablecoin push was active: World Liberty Financial disclosed hosting Idaho legislators (see W13). Separately, and already in force since 2024, Senate Bill 1296 establishes rights to self-custody, Bitcoin mining, and Bitcoin node-running without state or local government restriction, added as a new chapter under Title 28 of the Idaho Code. This digital-asset-rights layer is distinct from, and predates, the still-pending stablecoin framework, and functions as the state's only enacted digital-money-adjacent statute. #### Outlook The stablecoin track is escalating in legislative attention but unresolved in outcome: four bills in a single session is a marked increase in activity relative to prior years, yet none has been enacted. Continued lobbying activity suggests a fifth attempt is plausible in a future session; whether it succeeds will determine whether Idaho aligns its state framework with the federal GENIUS Act baseline or continues to rely solely on the 2024 digital-asset-rights statute for its digital-money posture. no periodic updates on record for this sub-brief ** Sources and findings (6)** 1. T3 [https://www.eastidahonews.com/2026/04/trump-family-crypto-venture-lobbied-for-stablecoin-bill-hosted-idaho-legislators-at-mar-a-lago/](https://www.eastidahonews.com/2026/04/trump-family-crypto-venture-lobbied-for-stablecoin-bill-hosted-idaho-legislators-at-mar-a-lago/) retrieved 2026-07-05 2. T2 [https://idahofreedom.org/house-bill-821-fast-act-stablecoins/](https://idahofreedom.org/house-bill-821-fast-act-stablecoins/) retrieved 2026-07-05 3. T3 [https://idahocapitalsun.com/2026/04/21/trump-family-crypto-venture-lobbied-for-stablecoin-bill-hosted-idaho-legislators-at-mar-a-lago/](https://idahocapitalsun.com/2026/04/21/trump-family-crypto-venture-lobbied-for-stablecoin-bill-hosted-idaho-legislators-at-mar-a-lago/) retrieved 2026-07-05 4. T1 [https://www.finance.idaho.gov/wp-content/uploads/2025/09/Crypto-ATM-Framework-Final.pdf](https://www.finance.idaho.gov/wp-content/uploads/2025/09/Crypto-ATM-Framework-Final.pdf) retrieved 2026-07-05 5. T1 [https://legislature.idaho.gov/wp-content/uploads/sessioninfo/2024/legislation/S1296.pdf](https://legislature.idaho.gov/wp-content/uploads/sessioninfo/2024/legislation/S1296.pdf) retrieved 2026-07-05 6. T1 [https://www.finance.idaho.gov/securities-bureau/money-transmitters/](https://www.finance.idaho.gov/securities-bureau/money-transmitters/) retrieved 2026-07-05 ### W3 Operational Resilience & Critical Infrastructure Probable confirmed 2026-07-05 Idaho has no state-specific operational-resilience statute for payments; state-chartered banks/credit unions are examined under the federal/CSBS InTREx framework and FFIEC guidance. Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. [Open its jurisdiction pages on Dataprotection.gi →](https://dataprotection.gi/jurisdictions/) Standing sub-brief · as of 7 July 2026 131 words · last cycle 2026-07-05 #### Operational Resilience & Critical Infrastructure Idaho has no state-specific operational-resilience statute for payments equivalent to a DORA- or PS21/3-style regime. Idaho-chartered banks and credit unions instead undergo IT/cyber-risk examination through the interagency InTREx programme (FDIC/CSBS/Federal Reserve), relying entirely on the federal examination stack rather than any state rule. That federal stack itself shifted during the baseline period: the FFIEC's Cybersecurity Assessment Tool sunset on August 31, 2025, redirecting Idaho-chartered institutions toward the NIST Cybersecurity Framework 2.0 and sector tools such as the Cyber Risk Institute Profile. #### Outlook Absent any signal of a forthcoming Idaho-specific resilience statute, this module's trajectory is stable federal reliance. The practical development to track is adoption pace among Idaho-chartered institutions of NIST CSF 2.0 and CRI Profile tooling following the CAT sunset, rather than any state rulemaking. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://www.finance.idaho.gov/consumer-education-r/cybersecurity-and-identity-theft-prevention/](https://www.finance.idaho.gov/consumer-education-r/cybersecurity-and-identity-theft-prevention/) retrieved 2026-07-05 2. T1 [https://oig.federalreserve.gov/reports/board-cybersecurity-community-banking-may2025.pdf](https://oig.federalreserve.gov/reports/board-cybersecurity-community-banking-may2025.pdf) retrieved 2026-07-05 3. T3 [https://www.bdo.com/insights/assurance/what-the-sunset-of-ffeics-cybersecurity-assessment-tool-means-for-financial-institutions](https://www.bdo.com/insights/assurance/what-the-sunset-of-ffeics-cybersecurity-assessment-tool-means-for-financial-institutions) retrieved 2026-07-05 4. T3 [https://its.idaho.gov/opportunities-initiatives/](https://its.idaho.gov/opportunities-initiatives/) retrieved 2026-07-05 ### W4 Scheme & Network Compliance Probable confirmed 2026-07-05 Idaho imposes no state-specific card-scheme or interchange regulation; surcharging is legal statewide subject only to federal card-brand caps. Repeated attempts (2023, 2025) to bar interchange on the tax/gratuity portion have failed. Standing sub-brief · as of 7 July 2026 140 words · last cycle 2026-07-05 #### Scheme & Network Compliance Idaho merchants operate under a permissive surcharge regime, subject only to federal card-network caps -- Visa's 3% cap and Mastercard's 4% cap, or actual cost if lower -- with no state-specific surcharge statute. This permissive posture is consistent with the state's own use of card fees, including in courts and the Tax Commission. A second consecutive attempt to restrict interchange scope, Senate Bill 1055 (2025), which would have prohibited card processors from charging interchange on the tax or gratuity portion of a transaction under a proposed new Idaho Code 63-3643, failed to pass, following a near-identical failed 2023 bill (SB 1066). #### Outlook With two consecutive legislative attempts to restrict interchange scope having failed, Idaho's scheme and network compliance posture is likely to remain stable and permissive absent a materially different legislative strategy in a future session. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://codes.findlaw.com/id/title-31-counties-and-county-law/id-st-sect-31-3221](https://codes.findlaw.com/id/title-31-counties-and-county-law/id-st-sect-31-3221) retrieved 2026-07-05 2. T3 [https://merchantcostconsulting.com/lower-credit-card-processing-fees/idaho-surcharge-laws/](https://merchantcostconsulting.com/lower-credit-card-processing-fees/idaho-surcharge-laws/) retrieved 2026-07-05 3. T2 [https://idahofreedom.org/senate-bill-1055-electronic-payments-taxes-fees/](https://idahofreedom.org/senate-bill-1055-electronic-payments-taxes-fees/) retrieved 2026-07-05 4. T1 [https://www.sco.idaho.gov/LivePages/fiscal-policies-credit-card-fees.aspx](https://www.sco.idaho.gov/LivePages/fiscal-policies-credit-card-fees.aspx) retrieved 2026-07-05 ### W5 Payment Corridor Dynamics Probable confirmed 2026-07-05 Idaho has no state-run payment corridor or rail; cross-border/interstate settlement flows through federal rails and correspondents. The 2024 D. Idaho PayServices Bank ruling confirms Fed discretion over master-account access. Standing sub-brief · as of 7 July 2026 173 words · last cycle 2026-07-05 #### Payment Corridor Dynamics Idaho has no state-run payment corridor or rail; cross-border and interstate settlement flows through federal rails -- Fedwire, FedNow, and ACH -- and correspondent banking relationships. The Idaho Money Transmitters Act nonetheless brings outbound cross-border remittance corridors within the state's licensing scope, since it licenses money transmission both within the United States and to locations outside the United States. The corridor-access landscape nationally is shaped by a precedent that originated in Idaho's federal district: the U.S. District Court for the District of Idaho held, in PayServices Bank v. Federal Reserve Bank of San Francisco, that FRBSF had discretion under 12 U.S.C. 342 to deny a master-account request, confirming Federal Reserve Banks' near-unfettered discretion over direct settlement-rail access nationally. #### Outlook The PayServices Bank precedent is now settled law (see W7) and is unlikely to be disturbed absent new litigation or federal rulemaking; its practical effect is to keep Idaho's community banks and money transmitters routing cross-border and settlement flows through federal rails and correspondents rather than direct Fed access (see W12). no periodic updates on record for this sub-brief ** Sources and findings (3)** 1. T1 [https://www.consumerfinancemonitor.com/2024/04/30/districts-of-wyoming-and-idaho-affirm-broad-fed-powers-over-master-accounts/](https://www.consumerfinancemonitor.com/2024/04/30/districts-of-wyoming-and-idaho-affirm-broad-fed-powers-over-master-accounts/) retrieved 2026-07-05 2. T1 [https://www.finance.idaho.gov/securities-bureau/money-transmitters/](https://www.finance.idaho.gov/securities-bureau/money-transmitters/) retrieved 2026-07-05 3. T1 [https://www.consumerfinancemonitor.com/2024/04/30/districts-of-wyoming-and-idaho-affirm-broad-fed-powers-over-master-accounts/](https://www.consumerfinancemonitor.com/2024/04/30/districts-of-wyoming-and-idaho-affirm-broad-fed-powers-over-master-accounts/) retrieved 2026-07-05 ### W6 Industry Structure & Commercial Probable confirmed 2026-07-05 Idaho's payments-relevant financial industry is dominated by a fast-growing credit-union sector (ICCU) alongside consolidating community banks, most visibly Glacier Bancorp's 2025 acquisition of Bank of Idaho. Standing sub-brief · as of 7 July 2026 163 words · last cycle 2026-07-05 #### Industry Structure & Commercial Dynamics Idaho's payments-relevant financial-industry structure is defined by a fast-growing credit-union sector alongside consolidating community banks. Idaho Central Credit Union, the largest state-chartered credit union in Idaho, holds approximately $10 billion in assets, ranking in the top 20 U.S. credit unions and functioning as a structurally significant nonbank deposit/payments competitor to community banks. This scale sits within an ongoing structural tension: the Idaho Bankers Association actively contests the credit-union model's tax-exempt status as a competitive-structure issue vis-a-vis taxed community banks. Community-bank consolidation continued in parallel, with Glacier Bancorp's acquisition of Bank of Idaho Holding Co. (see W13) adding to the state's competitive landscape. #### Outlook The bank-versus-credit-union structural tension is a persistent, multi-year feature of Idaho's industry structure rather than a single-cycle event, and is likely to continue generating trade-association commentary and periodic legislative attention regardless of individual M&A outcomes. Continued credit-union scale growth and community-bank consolidation both bear watching as they reshape competitive dynamics for payments and acquiring partnerships. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://www.sec.gov/Archives/edgar/data/0000868671/000086867125000063/pressreleasedatedmay1202.htm](https://www.sec.gov/Archives/edgar/data/0000868671/000086867125000063/pressreleasedatedmay1202.htm) retrieved 2026-07-05 2. T4 [https://www.temenos.com/success-story/iccu-success-story/](https://www.temenos.com/success-story/iccu-success-story/) retrieved 2026-07-05 3. T2 [https://www.creditunionsonline.com/idaho-credit-unions.html](https://www.creditunionsonline.com/idaho-credit-unions.html) retrieved 2026-07-05 4. T3 [https://idahobankers.org/community-banking/](https://idahobankers.org/community-banking/) retrieved 2026-07-05 ### W7 Legal & Litigation Confirmed confirmed 2026-07-05 Idaho's litigation/enforcement register centres on the federal Fed master-account discretion precedent, DoF administrative MTL denials, and the 2026 veto of bipartisan crypto-kiosk fraud legislation. Standing sub-brief · as of 7 July 2026 256 words · last cycle 2026-07-05 #### Legal & Litigation Idaho's litigation and enforcement register for the baseline period centres on three developments. First, the District of Idaho held in PayServices Bank v. Federal Reserve Bank of San Francisco that FRBSF properly exercised discretion to deny a master-account application, dismissing APA, Mandamus Act, and Due Process claims on March 30, 2024 -- a binding precedent on payment-rail access litigated in Idaho's federal court, with a national reach on Federal Reserve master-account discretion (see W5/W12). Second, the Idaho Department of Finance denied Apex Capital Enterprises LLC's money-transmitter licence application for failing net-worth qualification requirements under Idaho Code 26-2916; an independent baseline-research verification challenge (2026-07-05) flagged that the order PDF's stated date (2025-12-02) may not match the Department's administrative-action page metadata, which reportedly shows a last-update of 2025-08-22, so the precise order date is treated as unconfirmed pending re-verification, though the underlying denial itself is not disputed. Third, Governor Brad Little vetoed the bipartisan Virtual Currency Kiosk Fraud Prevention Act (SB 1359) on April 2/3, 2026, despite its passage through both the House and Senate; AARP Idaho publicly disputed the veto rationale, and sponsors indicated intent to bring revised legislation in a future session (see W1a/W10). #### Outlook Of the three items on this register, the master-account precedent is settled and stable, the Apex Capital denial's date requires re-verification but its substance is not contested, and the SB 1359 veto is the most consequential open item -- its reversal or replacement in a future session would materially change both the licensing (W1a) and consumer-protection (W10) registers. no periodic updates on record for this sub-brief ** Sources and findings (3)** 1. T1 [https://www.consumerfinancemonitor.com/2024/04/30/districts-of-wyoming-and-idaho-affirm-broad-fed-powers-over-master-accounts/](https://www.consumerfinancemonitor.com/2024/04/30/districts-of-wyoming-and-idaho-affirm-broad-fed-powers-over-master-accounts/) retrieved 2026-07-05 2. T1 [https://www.finance.idaho.gov/wp-content/uploads/2023/09/2025-12-02-Apex-Order-of-Denial.pdf](https://www.finance.idaho.gov/wp-content/uploads/2023/09/2025-12-02-Apex-Order-of-Denial.pdf) retrieved 2026-07-05 3. T3 [https://www.idahopress.com/news/sen-ruchti-aarp-disappointed-in-veto-of-legislation-addressing-virtual-currency-kiosk-fraud/article_409b6089-36cd-4589-a3e6-db0d49bac826.html](https://www.idahopress.com/news/sen-ruchti-aarp-disappointed-in-veto-of-legislation-addressing-virtual-currency-kiosk-fraud/article_409b6089-36cd-4589-a3e6-db0d49bac826.html) retrieved 2026-07-05 ### W8 Merchant Acquiring & Risk Probable confirmed 2026-07-05 Idaho has no dedicated merchant-acquiring statute; acquiring is delivered through bank/credit-union partnerships with national processors under general federal card-network rules. Standing sub-brief · as of 7 July 2026 85 words · last cycle 2026-07-05 #### Merchant Acquiring & Risk Idaho has no dedicated merchant-acquiring statute; high-risk-MCC treatment is governed by processor and network policy rather than state law. Idaho Central Credit Union delivers merchant-acquiring services to Idaho businesses through a partnership with Fiserv/Clover, illustrating the credit-union/bank-partnership delivery model that substitutes for a dedicated state acquiring framework. #### Outlook Absent any signal of a forthcoming state acquiring statute, this module's posture is stable: acquiring and high-risk-merchant treatment will continue to be set by national processor and card-network policy rather than Idaho-specific rulemaking. no periodic updates on record for this sub-brief ** Sources and findings (3)** 1. T4 [https://www.iccu.com/business/services/merchant-services/](https://www.iccu.com/business/services/merchant-services/) retrieved 2026-07-05 2. T3 [https://merchantcostconsulting.com/lower-credit-card-processing-fees/idaho-surcharge-laws/](https://merchantcostconsulting.com/lower-credit-card-processing-fees/idaho-surcharge-laws/) retrieved 2026-07-05 3. T1 [https://www.finance.idaho.gov/securities-bureau/money-transmitters/](https://www.finance.idaho.gov/securities-bureau/money-transmitters/) retrieved 2026-07-05 ### W9 Product Innovation & Market Development Probable confirmed 2026-07-05 Product innovation in Idaho payments concentrates in credit-union/fintech vendor partnerships and the pending stablecoin/digital-asset legislative track; no state sandbox or open-banking mandate exists. Standing sub-brief · as of 7 July 2026 172 words · last cycle 2026-07-05 #### Product Innovation & Market Development Product innovation in Idaho's payments space in the baseline period runs through two channels: regulatory accommodation and credit-union vendor partnerships. The Idaho Department of Finance signalled regulatory accommodation for crypto-ATM businesses via its September 2025 Crypto ATM Framework Keys paper, framing a right-sized oversight approach intended to let crypto-ATM operators keep operating in Idaho while protecting consumers -- non-statutory guidance that precedes any enacted kiosk statute. On the vendor-deployment side, Idaho Central Credit Union deployed Zest AI for AI-automated credit underwriting, reporting a 30%+ increase in loan approvals across auto, personal, and credit-card lending with bias testing built into the model. #### Outlook The accommodative regulatory posture toward crypto ATMs sits in tension with the escalating fraud data tracked in W10 and the vetoed SB 1359 (W7); how the Department of Finance reconciles guidance-based accommodation with rising consumer harm is the key product-innovation question for the next cycle. Separately, continued credit-union vendor deployment (AI underwriting, digital-banking platforms -- see W13) is likely to continue as a steady-state trend. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T4 [https://www.zest.ai/learn/success_stories/idaho-central-credit-union/](https://www.zest.ai/learn/success_stories/idaho-central-credit-union/) retrieved 2026-07-05 2. T4 [https://www.fintechfutures.com/press-releases/idaho-central-credit-union-selects-upstart-for-personal-lending](https://www.fintechfutures.com/press-releases/idaho-central-credit-union-selects-upstart-for-personal-lending) retrieved 2026-07-05 3. T4 [https://www.fintechfutures.com/credit-unions-building-societies/idaho-central-credit-union-opts-for-alkami-orb-platform](https://www.fintechfutures.com/credit-unions-building-societies/idaho-central-credit-union-opts-for-alkami-orb-platform) retrieved 2026-07-05 4. T1 [https://www.finance.idaho.gov/wp-content/uploads/2025/09/Crypto-ATM-Framework-Final.pdf](https://www.finance.idaho.gov/wp-content/uploads/2025/09/Crypto-ATM-Framework-Final.pdf) retrieved 2026-07-05 ### W10 Consumer Protection & APP Fraud Confirmed confirmed 2026-07-05 Idaho's most acute payments consumer-harm vector is APP-style fraud via crypto kiosks targeting seniors; a 2026 bill to address it passed both chambers but was vetoed. Standing sub-brief · as of 7 July 2026 197 words · last cycle 2026-07-05 #### Consumer Protection & APP Fraud Idaho's most acute and fastest-growing payments consumer-harm vector is cryptocurrency-related fraud. The Idaho Attorney General reported cryptocurrency-related consumer fraud losses rising from $19 million in 2023 to over $35 million in 2024, with seniors the largest victim group, driven substantially by crypto-ATM/kiosk scams; FBI Internet Crime Complaint Center 2025 data puts Idaho crypto-fraud losses above $48 million. A legislative response was mounted in 2026: Senate Bill 1359 would have imposed new-customer transaction limits of $2,000 per 24 hours and $10,000 per 30 days, a 72-hour settlement delay on first transactions, mandatory fraud warnings, and fee refunds for fraud victims. None of these protections are in force following Governor Brad Little's veto of the bill (see W7/W1a) despite its passage through both chambers. #### Outlook The substantive consumer-protection gap that SB 1359 targeted remains open, and the underlying harm trend -- AG-reported losses nearly doubling year-on-year and FBI IC3 data showing continued escalation -- makes some future legislative or administrative response likely. Whether that response arrives as revived statute (per sponsors' stated intent) or as continued reliance on the Department of Finance's guidance-based Crypto ATM Framework Keys approach (W9) is the key open question. no periodic updates on record for this sub-brief ** Sources and findings (6)** 1. T1 [https://www.ag.idaho.gov/newsroom/attorney-general-labrador-warns-idahoans-about-cryptocurrency-atm-scams/](https://www.ag.idaho.gov/newsroom/attorney-general-labrador-warns-idahoans-about-cryptocurrency-atm-scams/) retrieved 2026-07-05 2. T3 [https://www.idahopress.com/news/sen-ruchti-aarp-disappointed-in-veto-of-legislation-addressing-virtual-currency-kiosk-fraud/article_409b6089-36cd-4589-a3e6-db0d49bac826.html](https://www.idahopress.com/news/sen-ruchti-aarp-disappointed-in-veto-of-legislation-addressing-virtual-currency-kiosk-fraud/article_409b6089-36cd-4589-a3e6-db0d49bac826.html) retrieved 2026-07-05 3. T3 [https://www.aarp.org/states/idaho/protecting-your-money-from-crypto-kiosk-fraud/](https://www.aarp.org/states/idaho/protecting-your-money-from-crypto-kiosk-fraud/) retrieved 2026-07-05 4. T2 [https://www.billtrack50.com/billdetail/1983173](https://www.billtrack50.com/billdetail/1983173) retrieved 2026-07-05 5. T3 [https://idaholegalservicesauthority.com/idaho-consumer-protection-law](https://idaholegalservicesauthority.com/idaho-consumer-protection-law) retrieved 2026-07-05 6. T1 [https://www.finance.idaho.gov/wp-content/uploads/2025/09/SFFEP-Crypto-ATM-Final-Approved.pdf](https://www.finance.idaho.gov/wp-content/uploads/2025/09/SFFEP-Crypto-ATM-Final-Approved.pdf) retrieved 2026-07-05 ### W11 AML/CFT & Financial Crime [Sourced from Sentinel.gi ↗](https://sentinel.gi/jurisdictions/united-states-idaho/#sec-dom-D7) Probable confirmed 2026-07-05 Idaho's payments AML/CFT posture rests on the federal BSA/FinCEN MSB framework layered onto state MTL licensing; no original illicit-finance analysis performed in this module. Standing sub-brief · as of 7 July 2026 161 words · last cycle 2026-07-05 #### AML/CFT & Financial Crime This module carries the Sentinel.gi payments-context AML posture only; no original illicit-finance analysis is performed here, consistent with WPM's scope guardrail treating illicit-finance use of any instrument as a cross-reference to the Financial Intelligence Monitor rather than a WPM conclusion. Direct Sentinel.gi feed content for US-ID was recorded as absent this cycle and has been substituted with public federal sourcing: Idaho-licensed money transmitters must register with FinCEN as Money Services Businesses on Form 107, renewing every two years, maintaining a written BSA/AML compliance programme with a designated compliance officer, and filing Suspicious Activity Reports for transactions of $2,000 or more that are known or suspected to be suspicious. #### Outlook This module's federal BSA/FinCEN overlay on state MTL licensing is a stable structural baseline. Direct Sentinel.gi feed integration for US-ID remains an open item for future cycles; readers should consult the Financial Intelligence Monitor for the illicit-finance dimension of Idaho's crypto-kiosk fraud pattern (see W10 and Cross-Monitor Connections). no periodic updates on record for this sub-brief ** Sources and findings (6)** 1. T1 [https://www.federalregister.gov/documents/2026/04/10/2026-07033/anti-money-laundering-and-countering-the-financing-of-terrorism-programs](https://www.federalregister.gov/documents/2026/04/10/2026-07033/anti-money-laundering-and-countering-the-financing-of-terrorism-programs) retrieved 2026-07-05 2. T? FIM (sentinel.gi) per-JID baseline profile — United States — Idaho — Idaho operates under the federal BSA/AML framework (FinCEN, OFAC) with state-level money transmitter licensing administered by the Idaho Department of Finance. No Idaho-specific BO registry exists; the state relies on the federal CTA regime, now sharply narrowed. State AML supervisory capacity is modest relative to crypto-enabled fraud exposure. 3. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: sourcing-thinness 4. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: enforcement-absence 5. T3 FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-001) — Sanctions: OFAC listing 6. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: regulatory-failure ### W12 Correspondent Banking, Settlement & Access Confirmed confirmed 2026-07-05 Idaho community banks/credit unions access settlement rails predominantly through correspondent relationships rather than direct Fed master accounts, reflecting the discretionary access regime confirmed in D. Idaho. Standing sub-brief · as of 7 July 2026 184 words · last cycle 2026-07-05 #### Correspondent Banking, Settlement & Access Idaho community banks access Fed settlement rails predominantly via correspondent banking relationships -- for example, with Bankers' Bank of the West, which includes FedNow onboarding support -- rather than direct Fed master accounts. This pattern reflects the discretionary master-account regime confirmed in PayServices Bank v. Federal Reserve Bank of San Francisco (see W5/W7), under which Federal Reserve Banks retain broad discretion over direct settlement-rail access -- an asymmetry that compounds further for non-bank money transmitters (W1a), which have no comparable statutory path to direct settlement-rail access at all. The Idaho Bank Act reinforces the integration of state and federal oversight in this space, permitting the Director of the Department of Finance to rely on federal examination reports from the Federal Reserve, OCC, and FDIC in lieu of independent state holding-company examination. #### Outlook The bank-versus-non-bank access asymmetry that is this module's analytical spine is unlikely to shift absent a change to the master-account discretion confirmed in PayServices Bank; Idaho's community banks will remain correspondent-dependent for the foreseeable future, while state supervisory oversight continues to lean on the federal examination stack. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://www.consumerfinancemonitor.com/2024/04/30/districts-of-wyoming-and-idaho-affirm-broad-fed-powers-over-master-accounts/](https://www.consumerfinancemonitor.com/2024/04/30/districts-of-wyoming-and-idaho-affirm-broad-fed-powers-over-master-accounts/) retrieved 2026-07-05 2. T4 [https://www.bbwest.com/idaho-contacts](https://www.bbwest.com/idaho-contacts) retrieved 2026-07-05 3. T1 [https://www.finance.idaho.gov/wp-content/uploads/legal/statutes-rules/documents/2022-Idaho-Bank-Act.pdf](https://www.finance.idaho.gov/wp-content/uploads/legal/statutes-rules/documents/2022-Idaho-Bank-Act.pdf) retrieved 2026-07-05 4. T1 [https://www.federalreserve.gov/newsevents/speech/bowman20250227a.htm](https://www.federalreserve.gov/newsevents/speech/bowman20250227a.htm) retrieved 2026-07-05 ### W13 Commercial Intelligence (M&A, Investment & Product) Probable confirmed 2026-07-05 Idaho's payments-adjacent commercial activity in the baseline window is dominated by regulatory/legislative product events rather than confirmed new M&A; the state's marquee bank M&A event (Glacier/Bank of Idaho) closed just outside the strict 12-month window. Standing sub-brief · as of 7 July 2026 256 words · last cycle 2026-07-05 #### Commercial Intelligence (M&A, Investment & Product) Glacier Bancorp, Inc. completed its acquisition of Bank of Idaho Holding Co. on May 1, 2025, for $245.4 million (announced January 13, 2025), adding approximately $1.3 billion in assets and 15 locations across Eastern Idaho, Boise, and Eastern Washington -- Glacier's 26th bank acquisition since 2000. On the product side, Alkami Technology deployed its ORB digital-banking platform at Idaho Central Credit Union, integrating with ICCU's Fiserv DNA core to add ACH and wire capabilities to its digital-banking product suite; the deal value was not publicly disclosed. Separately, Upstart partnered with Idaho Central Credit Union to expand personal-loan origination across Idaho, Washington, and eastern Oregon via its AI lending marketplace (the Upstart Referral Network); this deal value was also not publicly disclosed. On the legislative-commercial interface, World Liberty Financial lobbied Idaho legislators in support of stablecoin legislation, disclosing approximately $18,000 in travel and lodging plus roughly $450-900 in meals for a Mar-a-Lago dinner hosting three Idaho senators and representatives between February and April 2026, in support of HB 586, HB 821, HB 901, and SB 1423 (see W2). #### Outlook Idaho's commercial-events register in this baseline window is dominated by product/partnership activity and legislative lobbying rather than confirmed new M&A or funding rounds within the strict trailing-12-month window; the state's marquee bank deal (Glacier/Bank of Idaho) closed just outside that window but is retained for continuity. No confirmed Idaho-headquartered payments/fintech funding round was identified this cycle, though this may reflect coverage limits (deal-database sources were not directly queried) rather than confirmed non-existence. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T1 [https://www.finance.idaho.gov/wp-content/uploads/2025/09/Crypto-ATM-Framework-Final.pdf](https://www.finance.idaho.gov/wp-content/uploads/2025/09/Crypto-ATM-Framework-Final.pdf) retrieved 2026-07-05 2. T3 [https://idahocapitalsun.com/2026/04/21/trump-family-crypto-venture-lobbied-for-stablecoin-bill-hosted-idaho-legislators-at-mar-a-lago/](https://idahocapitalsun.com/2026/04/21/trump-family-crypto-venture-lobbied-for-stablecoin-bill-hosted-idaho-legislators-at-mar-a-lago/) retrieved 2026-07-05 3. T3 [https://www.idahopress.com/news/sen-ruchti-aarp-disappointed-in-veto-of-legislation-addressing-virtual-currency-kiosk-fraud/article_409b6089-36cd-4589-a3e6-db0d49bac826.html](https://www.idahopress.com/news/sen-ruchti-aarp-disappointed-in-veto-of-legislation-addressing-virtual-currency-kiosk-fraud/article_409b6089-36cd-4589-a3e6-db0d49bac826.html) retrieved 2026-07-05 4. T4 [https://www.zest.ai/learn/success_stories/idaho-central-credit-union/](https://www.zest.ai/learn/success_stories/idaho-central-credit-union/) retrieved 2026-07-05 5. T1 [https://www.sec.gov/Archives/edgar/data/0000868671/000086867125000063/pressreleasedatedmay1202.htm](https://www.sec.gov/Archives/edgar/data/0000868671/000086867125000063/pressreleasedatedmay1202.htm) retrieved 2026-07-05 ** No modules match.** Filters combine as OR inside a group and AND across groups. ## Editorial metadata Provenance only. Nothing below gates publication or affects the render. Editorial metadata for United States – Idaho| Field | Value | |---|---| | `trust.lawyer_review.status` | never_reviewed | | `trust.lawyer_review.reviewer` | no reviewer on record | | ` trust.content_source` | ai_generated | ## Provenance and declared absence **Disclosure model:** module cards load OPEN; standing positions render in full; sub-briefs and jurisdiction briefs load as a clamped teaser with an explicit “read full” control carrying the true word count; earlier updates stay collapsed behind a counted summary. No text is hidden without disclosing how much of it there is. **Sentinel-fed modules** receive no special rendering treatment. `sentinel_feed` is an attribution chip only: it does not suppress content, does not generate an absence reason code, and does not exclude the module from any count, filter, search index or export on this page. **Family taxonomy** is renderer-level presentation config, not a JID field. Colour is always duplicated in text and is never the sole carrier of meaning. **Suppressed by doctrine:** derived risk score; per-module RAG traffic light; `derived_scores` = `{"legal_accessibility": {"per_product": {"account_to_account": "regulated", "cards": "regulated", "prepaid_emoney": "licensed-emi", "stablecoin": "emerging-regime"}}}`. **Band honesty:** uncertainty bands are computed against a frozen build clock of 2026-10-21. A year-precision row is never promoted into a tighter band. **Orphan deltas:** 2 cycle_delta row(s) target non-module objects and are listed in the rail rather than attached to a card. **Envelope:** baseline resolved at `jurisdiction_json.baseline`; 14 module(s), 63 finding(s), 131 source(s) in the cumulative register. Think something on this page is wrong? [Report an error](https://payments.gi/legal/#contact).