US-IN v13.3.0
content: ai_generated 132 sources retrieved model claude-sonnet-5 · 2026-07-05

United States – Indiana

US-IN schema world-payments-v1 trajectory: not yet assessed

Last updated · 14 modules · 60 sourced findings · 204 sources in the cumulative register

14Modulesbaseline.modules[]
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United States federal law that applies in United States – Indiana is covered once, on the United States page. This page covers United States – Indiana’s own layer: its own law, regulators and enforcement.

Jurisdiction brief

Latest update · 28 September 2026

Lead Signal

Indiana's money-transmission regime for crypto-fiat businesses has clarified its scope boundary this period. The Indiana Money Transmission Modernization Act (SEA 458, codified at IC 28-8-4.1), signed by Governor Holcomb on 4 May 2023 and administered by the Department of Financial Institutions through NMLS, repealed and replaced the state's prior money-transmitter statute and broadened its definition to reach business-purpose activity in addition to consumer transactions. What makes this period's picture material is not the licensing requirement itself, which has been in place since the 2023 signing, but the DFI's own confirmation of where the licensing perimeter actually sits for crypto businesses: Indiana did not adopt the virtual-currency transmission portion of the CSBS Model Money Transmission Modernization Act, and the state's regulation does not bring virtual-currency transmission itself within the licensable activity definition.

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Indiana's core payments licensing backbone remains the general Money Transmission Modernization Act (IC 28-8-4.1), administered by DFI; this cycle adds a statutory carve-out clarifying non-custodial digital-asset software is not money transmission, and HEA 1116 bans virtual-currency kiosks outright rather than licensing them.

Movement — NEWIC 24-4.4/24-4.5 recodified to IC 37, effective 2026-07-01.Backfill item not previously logged.
Standing sub-brief · as of 5 July 2026211 words · last cycle 2026-10-04

Licensing, Authorisation & Market Access

Indiana's money transmission licensing regime is administered by the Department of Financial Institutions (DFI) under the Money Transmission Modernization Act (MTMA, SEA 458), effective 2024-01-01, which replaced the legacy IC 28-8-4 statute. Two Tier-1 DFI documents — the SEA-458 guidance and the MTMA licensing guidance — corroborate both the regime replacement and its effective date. Within the MTMA's scope, DFI guidance is explicit that virtual currency transmission was not adopted into the money-transmission definition under IC 28-8-4.1-201(19); however, fiat legs of a virtual-currency business may still trigger licensure, preserving a partial regulatory hook over crypto-adjacent payment flows even absent a dedicated virtual-currency licence. On prudential standards, industry commentary (a single Tier-3 source, treated as Assessed pending primary-source corroboration) describes money transmitter licence applicants as needing to maintain a minimum net worth of $600,000, a surety bond of $200,000-$300,000, and errors-and-omissions insurance of at least $300,000, administered through NMLS with annual December 31 expiry.

Periodic update · new data 2026-09-28

Licensing, Authorisation & Market Access

Indiana's licensing framework for money transmission, including crypto-fiat businesses, runs through the Money Transmission Modernization Act (SEA 458, codified at IC 28-8-4.1), signed by Governor Holcomb on 4 May 2023. The Act repealed and replaced the state's prior money-transmitter law and broadened the definition of covered activity to include business-purpose transactions in addition to consumer transactions, with licensing administered by the Department of Financial Institutions through the Nationwide Multistate Licensing System. This places Indiana's crypto-adjacent licensing regime squarely within the nonbank payment-institution/e-money-institution category rather than the bank-charter track: a crypto exchange or transmitter operating in Indiana is licensed and supervised as a nonbank money transmitter, not as a depository institution, and is subject to the state licensing perimeter rather than federal bank prudential regulation.

The material clarification this period concerns where that perimeter actually sits for crypto businesses specifically. The Department of Financial Institutions has confirmed, in updated licensing guidance, that Indiana did not adopt the virtual-currency transmission portion of the CSBS Model Money Transmission Modernization Act on which SEA 458 was based, and that Indiana's regulation does not bring the transmission of virtual currency itself within the definition of licensable activity. The practical consequence is a fiat-transmission trigger: DFI guidance states that a fiat or virtual-currency exchange does not require an Indiana money-transmitter licence where the consumer strictly buys or sells currency and cannot use the platform to send fiat currency to another consumer. A pure buy/sell crypto exchange model, in other words, sits outside the licensing perimeter entirely, while any crypto business whose product allows a consumer to transmit fiat to a third party crosses into licensable activity regardless of the presence of a crypto leg in the transaction.

This distinction matters for market access planning because it means the licensing question for a crypto business entering Indiana turns entirely on the fiat-transmission function of the product, not on whether the product involves virtual currency as such. A business modelling its Indiana market-access pathway needs to assess specifically whether its product design permits person-to-person fiat transmission, since that is the single determinative factor DFI guidance identifies for whether MTL licensure under IC 28-8-4.1 is required.

Outlook

The fiat-transmission-trigger boundary DFI guidance has drawn is likely to remain the operative test for licensing determinations absent a future legislative move to add virtual-currency transmission language to IC 28-8-4.1. No such legislative move has been identified this period; the current gap between what the CSBS Model Act contemplates and what Indiana actually adopted appears to be a durable feature of the state's regime rather than a transitional one, and businesses should plan market access around the fiat-transmission test rather than anticipating imminent expansion of the licensable-activity definition to cover virtual-currency-only transmission.

2 earlier distinct update(s)
Periodic update · new data 2026-09-14

Licensing, Authorisation & Market Access

Indiana's non-bank market-access perimeter for digital-asset activity shifted at two distinct points this cycle without any change to the underlying licensing backbone itself. House Enrolled Act 1042 clarifies that developing or using software for non-custodial digital-asset transfers does not, by itself, constitute money transmission under Indiana law. This is a definitional carve-out, not the creation of a new licence class or exemption category with its own application process; its effect is to confirm that a category of non-custodial software activity sits outside the money-transmission perimeter entirely, rather than requiring an affirmative licence or registration to operate within it.

At the same time, House Enrolled Act 1116 closed off market access for a different, custodial-adjacent activity: the statewide operation of virtual-currency kiosks is now banned outright, a legislative outcome that supersedes an earlier draft which would instead have required money-transmitter licensure for kiosk operators. The choice to prohibit rather than license this specific channel is itself a market-access decision distinct from the general licensing backbone: it removes kiosk operation as an available business model in Indiana altogether, rather than gating it behind a licence application. Enforcement of the ban sits with the Attorney General under the Deceptive Consumer Sales Act, a bank/non-bank-relevant distinction in itself, since this enforcement track runs entirely outside the Department of Financial Institutions' money-transmitter licensing and supervision apparatus that governs other non-bank payment activity in the state.

The general money-transmitter licensing backbone itself, under the Money Transmission Modernization Act (IC 28-8-4.1), is unchanged this cycle: a flat three hundred thousand dollar surety bond requirement, administered by the Department of Financial Institutions and processed through the Nationwide Multistate Licensing System, continues to govern non-bank payment-company market access in Indiana. Virtual-currency transmission was never separately adopted into the state's implementation of that Act, a standing structural feature that predates and is unaffected by either of this cycle's two developments.

Outlook

Watch for whether the Department of Financial Institutions issues implementing guidance further clarifying the boundary HEA 1042 has drawn between protected non-custodial software activity and licensable money transmission, a boundary that has not yet been tested by DFI guidance as of this cycle. Watch also for confirmation of HEA 1116's exact statutory effective date, which has not been independently confirmed beyond bill text and secondary commentary this cycle.

Periodic update · new data 2026-08-25

Licensing, Authorisation & Market Access

Indiana's money transmission licensing regime was rebuilt from the ground up by Senate Enrolled Act 458 in 2023, which repealed the state's prior money transmission statute (Indiana Code 28-8-4-1 through -61 as they previously stood) and replaced it with the Conference of State Bank Supervisors' Model Money Transmission Modernization Act framework, with licensure taking effect January 1, 2024. This places Indiana among the cohort of states that have adopted the CSBS model law wholesale as part of the broader interstate money-transmission licensing-harmonization effort, a status independently confirmed by the CSBS's own nationwide tracking of state MTMA adoption. The licensing regime applies to both bank and nonbank money transmitters conducting fiat-denominated money transmission business in or into Indiana, requiring authorisation from the Indiana Department of Financial Institutions.

The defining feature of Indiana's adoption, however, is a deliberate scope exclusion rather than a scope expansion: Indiana Department of Financial Institutions guidance confirms that the state did not adopt the CSBS model law's virtual-currency-transmission title. The practical effect is that virtual-currency-only transmission -- transmission of value denominated purely in virtual currency with no fiat leg -- falls entirely outside Indiana's money-transmission licensing perimeter. An operator transmitting only virtual currency in Indiana therefore has no state money-transmission licence to obtain, because the activity is not captured by the statute at all, rather than being captured and then exempted. This is a structural market-access fact with direct consequences for nonbank payment-institution and e-money-institution-style operators whose business model is virtual-currency-native: such operators face a licensing vacuum in Indiana specifically for the virtual-currency leg of their business, even as their fiat-transmission activities, if any, remain fully licensable under the same statute. Bank-chartered entities engaging in virtual-currency activity typically sit under separate federal or trust-charter supervision rather than the state money-transmission licence regime in the first instance, so the practical weight of this exclusion falls disproportionately on the nonbank payment-institution and e-money-institution segment of the market rather than on bank-affiliated participants.

This scope choice distinguishes Indiana from full-adoption peer states that incorporated the model law's virtual-currency-transmission title in its entirety, and it is corroborated across two independent, high-tier sources: the Department of Financial Institutions' own licensing guidance and the Conference of State Bank Supervisors' national tracker of state MTMA adoption status, both assessed at High confidence. For market-access purposes, an operator evaluating Indiana as a licensing jurisdiction for a purely virtual-currency-denominated product should not expect the state money transmission licensing framework to apply, and should evaluate whether any other Indiana or federal authorisation regime might reach the activity instead.

Outlook

Watch for whether Indiana's legislature or Department of Financial Institutions moves in a future session to close the virtual-currency-transmission gap by belatedly adopting the CSBS model law's virtual-currency title, a change that would bring Indiana into alignment with full-adoption peer states and would materially alter market access for virtual-currency-native nonbank operators. Absent such a change, the exclusion remains a durable structural feature of Indiana's payments licensing landscape rather than a transitional gap expected to close on its own.

Sources and findings (7)
  1. T1https://law.justia.com/codes/indiana/2010/title28/ar8/ch4.htmlretrieved
  2. T1https://www.in.gov/dfi/files/SEA-458-Guidance.pdfretrieved
  3. T1https://www.in.gov/dfi/files/MTMA-Licensing-Guidance-Updated.pdfretrieved
  4. T3https://www.bondexchange.com/indiana-money-transmitter-bond-a-comprehensive-guide/retrieved
  5. T1https://cdn.cocodoc.com/cocodoc-form-pdf/pdf/121832-48009-MONEY-TRANSMITTER-LICENSE-APPLICATION-State--Indiana--in.pdfretrieved
  6. T2https://www.alstonconsumerfinance.com/new-indiana-money-transmission-license-requirements-impact-business-purpose-activities/retrieved
  7. T1https://www.in.gov/dfi/licensing-and-applications/consumer-credit-licensing/retrieved

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Conduct/safeguarding obligations sit in the MTMA plus the new Indiana Earned Wage Access Act (EWAA), effective 2026-01-01.

Standing sub-brief · as of 5 July 2026172 words · last cycle 2026-07-05

Conduct, Safeguarding & Financial Promotions

Indiana's conduct and safeguarding layer has been reshaped by the Earned Wage Access Act (EWAA, HB1125), which requires most earned-wage-access providers to hold a DFI licence effective 2026-01-01; NMLS applications were accepted from 2025-10-01, with a grace period running to 2026-04-30. Enacted EWAA provisions, per bill-tracker records, set a surety-bond range of $100,000-$250,000, require a no-cost access option within one business day, cap optional fees at $5 or 5% of the amount accessed, mandate disclosed and voluntary tipping, and empower DFI to levy civil penalties of up to $10,000 per violation. Separately, money transmitter licensees carry forward a legacy safeguarding requirement from IC 28-8-4-33(b) into the MTMA regime: criminal-dishonesty insurance equal to the required surety bond's principal sum.

no periodic updates on record for this sub-brief

Sources and findings (6)
  1. T1https://www.in.gov/dfi/files/EWALicensingGuidance.pdfretrieved
  2. T2https://www.thewbkfirm.com/industry/indiana-enacts-earned-wage-access-lawretrieved
  3. T2https://www.billtrack50.com/billdetail/1766852retrieved
  4. T3https://vensure.com/employment-law-updates/indiana-enacts-earned-wage-access-act/retrieved
  5. T1https://www.in.gov/dfi/files/SEA-458-Guidance.pdfretrieved
  6. T2https://www.goodwinlaw.com/en/insights/publications/2025/05/alerts-practices-fs-indiana-enacts-law-regulating-earned-wageretrieved

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Indiana has no standalone stablecoin-issuer regime; governed by the federal GENIUS Act; no state certification filing identified.

Standing sub-brief · as of 5 July 2026170 words · last cycle 2026-07-05

Stablecoins & Digital Money

Indiana has no standalone stablecoin-issuer licensing regime; DFI guidance confirms virtual currency was not adopted into the MTMA money-transmission definition, leaving stablecoin issuance entirely outside state-specific licensure. Instead, Indiana's stablecoin posture is deferential to the federal GENIUS Act (12 U.S.C. 5901 et seq.), enacted 2025-07-18, which establishes a federal framework for 'payment stablecoins'; the OCC issued a notice of proposed rulemaking on 2026-03-02 to implement licensing, custody, and reserve requirements for permitted issuers. Treasury's April 2026 GENIUS Act NPRM proposes principles under which state-chartered nonbank issuers with up to $10bn outstanding could operate under state oversight via a 'substantially similar' regime certification; no Indiana-specific filing for such certification has been identified this cycle, a genuine gap pending horizon resolution rather than a settled state position.

no periodic updates on record for this sub-brief

Sources and findings (4)
  1. T1https://www.in.gov/dfi/files/MTMA-Licensing-Guidance-Updated.pdfretrieved
  2. T1https://www.federalregister.gov/documents/2026/03/02/2026-04089/implementing-the-guiding-and-establishing-national-innovation-for-us-stablecoins-act-for-theretrieved
  3. T2https://www.consumerfinancialservicelawmonitor.com/2026/04/treasury-proposes-genius-act-principles-for-acceptable-state-stablecoin-regimes/
  4. T3https://www.mayerbrown.com/en/insights/events/2025/11/understanding-when-and-how-the-genius-act-preempts-state-lawretrieved

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DFI supervises IT/operational risk via FFIEC-aligned advisory letters, transitioning to NIST CSF 2.0.

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 →

Standing sub-brief · as of 5 July 2026141 words · last cycle 2026-07-05

Operational Resilience & Critical Infrastructure

DFI's Depository Division supervises operational and IT risk at Indiana-chartered institutions through a series of advisory instruments: Advisory Letter 2025-03 on URSIT ratings implementation, Advisory Letter 2025-01 on Cyber Hygiene Awareness, and a Ransomware Self-Assessment Tool (R-SAT v2.0) made available to supervised institutions. This state-level supervisory activity sits against a federal backdrop in which the FFIEC Cybersecurity Assessment Tool was retired on 2025-08-31 in favor of the NIST Cybersecurity Framework 2.0, and OCC Bulletin 2025-24, effective 2026-01-01, shifted federal IT examinations toward a risk-proportionate model — a transition that ripples into DFI-coordinated examinations of Indiana-chartered institutions, per a single Tier-3 vendor source on the CAT-retirement/NIST-CSF-2.0 transition.

no periodic updates on record for this sub-brief

Sources and findings (5)
  1. T1https://www.in.gov/dfi/general-information/policies-and-guidance/retrieved
  2. T3https://www.myabt.com/blog/ffiec-it-examination-readiness-financial-institutionsretrieved
  3. T1https://ithandbook.ffiec.gov/retrieved
  4. T1https://www.in.gov/cybersecurity/retrieved
  5. T3https://en.wikipedia.org/wiki/Federal_Financial_Institutions_Examination_Councilretrieved

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No Indiana-specific surcharge cap; permissive credit-card surcharging bounded by card-network limits and federal Durbin debit-surcharge ban.

Standing sub-brief · as of 5 July 2026103 words · last cycle 2026-07-05

Scheme & Network Compliance

Credit-card surcharging is permitted in Indiana subject only to card-network limits — Visa caps at 3%, while Mastercard, American Express, and Discover permit up to 4% — with no Indiana-specific statutory ban or cap on the practice. Debit-card surcharging, however, remains prohibited nationwide, including in Indiana, under the Durbin Amendment (15 U.S.C. 1693o-2), the federal interchange-fee regulation regime overseen by the Federal Reserve Board.

no periodic updates on record for this sub-brief

Sources and findings (4)
  1. T4https://ebizcharge.com/blog/credit-card-surcharging-a-state-by-state-legal-analysis/retrieved
  2. T1https://uscode.house.gov/view.xhtml?req=%28title%3A15+section%3A1693o-2+edition%3Aprelim%29retrieved
  3. T4https://merchantcostconsulting.com/lower-credit-card-processing-fees/indiana-surcharge-laws/retrieved
  4. T1https://law.justia.com/codes/indiana/title-7-1/article-3/chapter-1/section-7-1-3-1-13-5/retrieved

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Indiana's corridor position is dominated by domestic instant-payments rail build-out via correspondent channels rather than a distinct international corridor regime.

Standing sub-brief · as of 5 July 202670 words · last cycle 2026-07-05

Payment Corridor Dynamics

Indiana's corridor dynamics are dominated by domestic instant-payments rail build-out rather than a distinct cross-border regime. Pidgin, operating via the Independent Correspondent Bankers' Bank (ICBB) network, has extended real-time payments rail access to Indiana community banks through a partnership in place since October 2023.

Outlook

No dedicated Indiana cross-border payment-corridor statute has been located; this module will remain dashboard-tier pending any emergence of a distinct corridor regime.

no periodic updates on record for this sub-brief

Sources and findings (2)
  1. T3https://www.cbinsights.com/company/independent-correspondent-bankers-bankretrieved
  2. T1https://www.fdic.gov/household-surveyretrieved

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Consolidating community-bank sector (First Merchants) combined with a growing Indianapolis fintech/payments startup cluster.

Standing sub-brief · as of 5 July 2026106 words · last cycle 2026-07-05

Industry Structure & Commercial Dynamics

First Merchants Corporation completed its legal closing of a merger with First Savings Financial Group on 2026-02-01, creating a combined entity with approximately $21.4bn in assets and making First Merchants the second-largest Indiana-headquartered financial holding company. This consolidation, together with the correspondent-banking network anchored by ICBB and FHLBank Indianapolis, and the domestic instant-payments partnership via Pidgin, reflects a bank-led rather than non-bank-led market structure for settlement and payments-access in Indiana.

no periodic updates on record for this sub-brief

Sources and findings (4)
  1. T1https://ir.firstmerchants.com/news-releases/news-release-details/first-merchants-corporation-completes-legal-closing-firstretrieved
  2. T3https://www.privsource.com/acquisitions/payments-fintech/state/indianaretrieved
  3. T4https://angelmatch.io/publication/top-startup-investors-in-indiana-who-fund-fintech-startupsretrieved
  4. T1https://www.federalreserve.gov/newsevents/speech/bowman20250227a.htmretrieved

Indiana has no state-specific stablecoin statute; Indiana-domiciled entities fall under the federal GENIUS Act framework, which entered active multi-agency rulemaking in 2026 (OCC, FDIC, Treasury FinCEN/OFAC).

Standing sub-brief · as of 5 July 202676 words · last cycle 2026-08-05

Legal & Litigation

The Indiana Attorney General joined a 52-state coalition in a $700m national Google Play antitrust and in-app-payment settlement, with Indiana consumers receiving approximately $10.5m and the state a penalty share of roughly $1.4m. No Indiana-specific payments court ruling was identified this cycle; multistate attorney-general enforcement is the principal legal signal.

Outlook

Absent an Indiana-specific ruling, expect continued reliance on multistate AG settlement mechanisms as the primary legal-enforcement channel touching payments and platform conduct.

Periodic update · new data 2026-08-11

Legal & Litigation

GENIUS Act implementation entered an active, multi-agency rulemaking phase this cycle, generating three concurrent legal instruments relevant to payment-stablecoin issuers and their counterparties. The OCC issued a notice of proposed rulemaking on February 25, 2026, implementing the Act for national banks, federal savings associations, and qualified nonbank or state stablecoin issuers under a federal_qualified_issuer licensing pathway; its comment period closed May 1, 2026. The FDIC board approved a parallel proposal on April 7, 2026, establishing reserve-asset, capital, risk-management, and two-business-day redemption standards for insured depository institutions issuing payment stablecoins, including pass-through insurance treatment considerations for reserve assets. A joint proposed rule from Treasury, FinCEN, and OFAC followed on April 8, 2026, implementing the Act's AML and sanctions-compliance program requirements specifically for payment-stablecoin issuers, applicable to both bank and nonbank issuers. Taken together, the three proposals represent the most substantial federal legal development for payment-stablecoin issuers since the GENIUS Act's enactment, and their eventual final form will define the operative legal perimeter for the industry nationwide.

All three rulemaking actions are corroborated by independent Tier-1 federal-regulator primary sources, supporting High confidence that a coordinated federal legal architecture for payment stablecoins is taking shape ahead of the Act's statutory effective-date backstop. That backstop is set for the earlier of January 18, 2027, eighteen months after enactment, or 120 days after final implementing regulations are issued, whichever occurs first; this specific date rests on a single Tier-4 secondary source this cycle but is broadly consistent with the timing implied by the federal-regulator NPRM schedule itself.

For Indiana-domiciled banks and nonbank payment-services providers specifically, this rulemaking package is legally significant because it is arriving through the federal channel rather than through any parallel state-level instrument. Indiana's own Money Transmitter Modernization Act framework does not extend its licensing perimeter to pure virtual-currency transmission, meaning that, for the moment, the federal GENIUS Act rulemaking track is the primary legal reference point for any Indiana entity contemplating payment-stablecoin issuance, custody, or distribution activity. This is a structural point rather than an incidental one: it means Indiana-domiciled entities' stablecoin-related legal obligations will be defined by the OCC, FDIC, and joint Treasury/FinCEN/OFAC rules directly, without an intervening state-level layer specific to stablecoins.

The three rulemaking tracks also differ in scope in ways that matter for legal risk assessment. The OCC's proposal is the broadest in reach, covering national banks, federal savings associations, and qualified nonbank or state stablecoin issuers together. The FDIC's proposal is narrower, applying specifically to insured depository institutions, and is the most prescriptive on redemption-timing mechanics, requiring redemption within two business days. The joint Treasury, FinCEN, and OFAC proposal is the broadest in firm-type reach on the AML dimension, applying to both bank and nonbank issuers, and is the instrument most directly relevant to sanctions-screening and AML-program legal-compliance obligations, an area this jurisdiction cross-references to standing AML/CFT and financial-crime coverage rather than analyzing in full here. The bank-versus-nonbank distinction running through all three proposals is itself a live legal question: the OCC and joint Treasury/FinCEN/OFAC tracks explicitly extend to nonbank and state-qualified issuers, while the FDIC's standards are framed around insured depository institutions specifically. This means a nonbank payment-services provider domiciled in Indiana and a national bank subsidiary domiciled in Indiana will, on the current NPRM text, face materially different combinations of these three rulemaking tracks. The comment period closing on the OCC's proposal on May 1, 2026 is itself a legally significant date: it marks the point at which industry and public comment on the broadest of the three proposed rules concluded, after which the OCC may move toward a final rule text that could differ from the February 2026 proposal in response to that comment record. No enforcement action, litigation, or adjudicated legal dispute tied to the GENIUS Act rulemaking was identified in this cycle's research; the legal developments captured here are exclusively at the rulemaking and comment-period stage, with no adjudicated outcome yet to report.

Outlook

The near-term legal-process test is whether the three rulemaking tracks converge on final rules well ahead of the January 18, 2027 statutory backstop, or whether the alternative 120-days-post-final-rule trigger becomes operative instead, which would compress the implementation runway for payment-stablecoin issuers, including any Indiana-domiciled institutions entering the space. A second test is how the finalized federal rules will interface with state-level money-transmission frameworks such as Indiana's Money Transmitter Modernization Act, an intersection this cycle's research does not yet resolve. Legal and compliance functions supporting Indiana-domiciled institutions considering stablecoin activity should treat the current NPRM stage as the operative reference point while recognizing that specific provisions, including the reserve-asset and redemption-timing standards, remain subject to change before finalization.

Sources and findings (3)
  1. T2https://www.21alivenews.com/2025/12/22/indiana-attorney-general-shares-how-access-funds-10m-google-settlement/retrieved
  2. T2https://www.recordinglaw.com/us-laws/data-privacy-laws/indiana-data-privacy-laws/data-breach-notification/retrieved
  3. T2https://www.goodwinlaw.com/en/insights/publications/2026/03/insights-finance-cfs-yir-fintechretrieved

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Permissive surcharging framework layered on an ISO market consolidating into national acquirers.

Standing sub-brief · as of 5 July 202667 words · last cycle 2026-07-05

Merchant Acquiring & Risk

Payroc WorldAccess acquired Retriever Merchant Solutions (Select Merchant Services, Inc.), a Munster, Indiana-based independent sales organisation serving approximately 30,000 merchants and roughly $5bn in annual payment volume, illustrating the consolidation of Indiana-headquartered ISOs into national acquirers. This sits alongside the state's permissive card-surcharging framework described in W4.

Outlook

Continued ISO consolidation into national acquiring platforms is the base-case trajectory for Indiana's merchant-acquiring landscape.

no periodic updates on record for this sub-brief

Sources and findings (3)
  1. T4https://merchantcostconsulting.com/lower-credit-card-processing-fees/credit-card-surcharge-laws-by-state/retrieved
  2. T3https://mergr.com/transaction/payroc-acquires-select-merchant-servicesretrieved
  3. T1https://uscode.house.gov/view.xhtml?req=%28title%3A15+section%3A1693o-2+edition%3Aprelim%29retrieved

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Licensed EWA product category created effective 2026-01-01; instant-payments product access extended via fintech partnerships.

Movement — NEWEarned Wage Access Act licensing regime, effective 2026-01-01.Standing-position fact newly confirmed this cycle.
Standing sub-brief · as of 5 July 202678 words · last cycle 2026-09-21

Product Innovation & Market Development

The Earned Wage Access Act (EWAA) creates a licensed on-demand pay product category in Indiana, distinguishing employer-integrated and consumer-directed models, effective 2026-01-01 — the most significant Indiana product-innovation development identified this baseline. Separately, instant-payments product access for community banks continues to expand via the Pidgin/ICBB fintech partnership.

Outlook

Watch for how the licensed EWA category interacts with employer-integrated payroll products as the April 2026 grace period closes and licensing enforcement begins in earnest.

Periodic update · new data 2026-09-22

Product Innovation & Market Development

Indiana produced two distinct product-innovation and market-access developments this cycle, both arising from the same 2026 legislative session but pulling in different directions. First, HEA 1116 makes operating a virtual-currency kiosk unlawful statewide -- the first such absolute ban among US states -- displacing the licence-plus-disclosure model that remains under active consideration in peer jurisdictions. Enforcement rests with the Indiana Attorney General under existing consumer-protection statutes rather than through the Department of Financial Institutions' ordinary money-services supervisory channel, reflecting the ban's grounding in consumer-protection concerns about crypto-ATM-facilitated scam losses rather than in prudential money-transmission regulation. Second, and moving in the opposite regulatory direction, HEA 1042 (P.L. 49-2026, effective July 1, 2026) requires defined-contribution retirement plans for Indiana legislators, public employees, and teachers to offer a self-directed brokerage account with at least one cryptocurrency investment option by July 1, 2027. This is a distinctive development in the payments-and-market-development landscape: rather than merely permitting or cautiously restricting retail crypto access, Indiana is mandating crypto-investment availability within a regulated, institutional retirement product. The same enactment also creates a state Blockchain and Digital Assets Task Force, which will presumably serve as an ongoing reference point for further digital-asset market-development policy in the state. Read together, these two developments reflect a bifurcated posture at the product level: prohibition at the retail, fraud-exposed edge (kiosks), and mandated access at the institutional, retirement-product edge (pension crypto options).

Outlook

The July 1, 2027 deadline for Indiana's public retirement plans to implement the cryptocurrency investment-option requirement is the clearest near-term product-development milestone to track, since it will produce the state's first mandated institutional-scale crypto-investment product rollout. Separately, watch whether other states follow Indiana's kiosk-ban approach or continue developing licence-plus-disclosure alternatives, since Indiana's choice now represents a meaningful divergence point in US state-level crypto-kiosk policy.

1 earlier distinct update(s)
Periodic update · new data 2026-09-14

Product Innovation & Market Development

Indiana's statutory ban on virtual-currency kiosks under House Enrolled Act 1116 removes an entire product channel from the state's market this cycle rather than modifying the terms under which it may operate. The measure supersedes an earlier legislative draft that would have brought kiosk operators under money-transmitter licensure, meaning Indiana's final policy choice moved from a regulate-and-permit model toward a prohibit-and-close model for this specific cash-to-crypto conversion product. This is a tightening development for the product-innovation and market-development dimension specifically: a previously viable, if lightly regulated, retail product channel is no longer available to operators in Indiana at all, regardless of how that operator might otherwise be structured or licensed.

The comparative context matters for reading the significance of this move. Trade press characterizes Indiana's approach as an outright ban, contrasted explicitly with Wisconsin, Virginia, Wyoming, and South Dakota, each of which chose in 2026 to regulate the same kiosk product channel rather than prohibit it outright. This places Indiana at the most restrictive end of the current multi-state spectrum of policy responses to the same underlying product category, a spectrum that otherwise clusters around a licensing-with-conditions model in most of the peer states named.

The product-development consequence for operators is straightforward: any product roadmap that depended on physical kiosk deployment as an Indiana market-entry or expansion channel is no longer viable under current law, and the enforcement mechanism, Attorney General action under the Deceptive Consumer Sales Act, signals that the state intends this closure to be treated as a consumer-protection matter rather than a licensing-compliance matter subject to potential future licensing pathways.

Outlook

Watch for whether other states in the 2026 wave of kiosk legislation move toward Indiana's prohibition model rather than the regulate-with-limits model chosen by Wisconsin, Virginia, Wyoming, and South Dakota, and for confirmation of the exact statutory effective date of Indiana's ban, which remains unconfirmed beyond bill text and secondary legal commentary as of this cycle.

Sources and findings (4)
  1. T1https://www.in.gov/dfi/files/EWALicensingGuidance.pdfretrieved
  2. T3https://www.cbinsights.com/company/independent-correspondent-bankers-bankretrieved
  3. T3https://www.privsource.com/acquisitions/payments-fintech/state/indianaretrieved
  4. T3https://www.ibj.com/articles/indianapolis-fintech-startup-habits-lands-1-1m-investmentretrieved

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Security-breach statute since 2006 plus new comprehensive ICDPA effective 2026-01-01 and EWA-specific safeguards; no APP fraud reimbursement regime.

Standing sub-brief · as of 5 July 2026134 words · last cycle 2026-07-05

Consumer Protection & APP Fraud

The Indiana Consumer Data Protection Act (ICDPA, IC 24-15) took effect 2026-01-01, applying to entities processing personal data of at least 100,000 Indiana residents annually, or 25,000 residents where more than half of revenue derives from data sales; enforcement is Attorney-General-only, with a 30-day cure notice and penalties of up to $7,500 per violation. This sits alongside EWAA-specific consumer safeguards, including the $100,000-$250,000 surety bond and fee caps described in W1b. No dedicated authorised-push-payment (APP) fraud reimbursement mandate exists in Indiana, consistent with the broader US federal and state landscape.

no periodic updates on record for this sub-brief

Sources and findings (5)
  1. T1https://www.in.gov/attorneygeneral/consumer-protection-division/id-theft-prevention/security-breaches/security-breach-faqs-and-notification-form-for-businesses/retrieved
  2. T3https://multilaw.com/Multilaw/Multilaw/Data_Protection_Laws_Guide/DataProtection_Guide_USA_Indiana.aspxretrieved
  3. T3https://www.kriegdevault.com/insights/businesses-prepare-now-for-indianas-new-data-privacy-law-effective-january-1-2026retrieved
  4. T2https://www.insideprivacy.com/state-privacy/indiana-attorney-general-releases-data-consumer-bill-of-rights/retrieved
  5. T3https://vensure.com/employment-law-updates/indiana-enacts-earned-wage-access-act/retrieved

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W11 content intended to be Sentinel.gi-fed; direct feed not accessible this cycle, only supervisory backdrop captured.

Standing sub-brief · as of 5 July 2026142 words · last cycle 2026-07-05

AML/CFT & Financial Crime

This module is sourced from the Sentinel.gi feed. A direct Sentinel.gi feed for US-IN was not accessible this cycle; in its place, only backdrop supervisory-cooperation context has been captured: DFI maintains a Letter Agreement with FinCEN for confidential supervisory information sharing and an MOU with the IRS on MSB oversight, and FinCEN supervises Indiana-licensed money transmitters and MSBs via the Bank Secrecy Act framework (31 U.S.C. 310, 31 CFR Chapter X), with an FY2026 budget request of approximately $300m and roughly 609 staff. Full illicit-finance analysis for Indiana MSBs, including any bank-versus-non-bank supervision-gap assessment, has been routed to the FIM monitor and is not re-analysed here; readers should consult the Sentinel.gi feed directly once integrated.

no periodic updates on record for this sub-brief

Sources and findings (7)
  1. T3https://indianagovinfo.org/2025/10/02/financial-crimes-enforcement-network/retrieved
  2. T?FIM (sentinel.gi) per-JID baseline profile — United States — Indiana — Indiana operates under the federal Bank Secrecy Act/AML framework administered by FinCEN and OFAC, supplemented by state money-transmitter licensing under the Indiana Uniform Money Services Act (Indiana Department of Financial Institutions). Since March 2025, domestically-formed Indiana entities are exempt from federal beneficial ownership reporting, and no Indiana-specific virtual-currency-kiosk consumer-protection statute has been confirmed, leaving state-level AML/CFT capacity thin relative to federal architecture.
  3. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: sourcing-thinness
  4. T1FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-003) — Sanctions: OFAC listing
  5. T1FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-002) — Enforcement: OFAC — Zedcex Exchange, Ltd. and Zedxion Exchange, Ltd.
  6. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: capacity-deficit
  7. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: regulatory-failure

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Community-bank sector accesses wholesale settlement via FHLBank Indianapolis and correspondent banks' banks (ICBB) amid rural branch-consolidation trend.

Standing sub-brief · as of 5 July 2026159 words · last cycle 2026-08-21

Correspondent Banking, Settlement & Access

Indiana's correspondent-banking landscape illustrates a structural bank-versus-non-bank access asymmetry: community banks reach wholesale settlement and instant-payments rails through correspondent channels — the Pidgin/ICBB partnership and FHLBank Indianapolis's Elevate Grant cooperative, which supports member institutions' capital-expenditure and workforce-development needs while functioning as a wholesale funding and settlement anchor — whereas non-bank payment providers have no equivalent institutional access point identified in this baseline. This state-level access structure sits against a national trend the Federal Reserve Board has documented: over half of analyzed US counties lost bank branches between 2012 and 2017, and more than 100 banking markets lost their last local bank headquarters, a rural correspondent-banking access-risk trend directly relevant to rural Indiana counties.

Periodic update · new data 2026-08-25

Correspondent Banking, Settlement & Access

The Indiana-specific development in this module this cycle is narrow and sectoral: Senate Enrolled Act 243 (2026) directs the Indiana Department of Revenue to require income-tax withholding on riverboat and casino slot-machine and keno winnings of $2,000 or more, implemented through the Department's Departmental Notice #16, at a withholding rate of 2.95 percent for 2026 stepping down to 2.9 percent for 2027 and later. This is a settlement-and-withholding change applied at the point of payout within the gaming vertical rather than a change to correspondent-banking access, bank-to-bank settlement rails, or cross-border payment corridors, and it is sourced to a single T3 trade-press account this cycle rather than to primary Departmental text directly reviewed here. Because this module's analytical spine is the structural asymmetry between bank and nonbank access to correspondent banking relationships, this finding is flagged as a dated, sector-specific entry rather than elevated to full standing-brief treatment; no bank-versus-nonbank correspondent-access dynamic is implicated by this particular withholding change.

Outlook

Watch for whether the Indiana Department of Revenue issues further guidance clarifying how gaming operators should integrate the new withholding requirement into existing settlement and reporting workflows, and whether any correspondent-banking-relevant consequence emerges from gaming-sector payment processors adjusting to the new withholding obligation.

Sources and findings (4)
  1. T3https://www.cbinsights.com/company/independent-correspondent-bankers-bankretrieved
  2. T3https://www.cbinsights.com/company/independent-correspondent-bankers-bankretrieved
  3. T1https://www.federalreserve.gov/publications/november-2019-bank-branch-access-in-rural-communities.htmretrieved
  4. T1https://www.sec.gov/Archives/edgar/data/0000712534/000119312525268801/d828300d424b3.htmretrieved

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Trailing-12-month activity anchored by the First Merchants/First Savings merger and continued Allied Payment Network growth-capital investment.

Standing sub-brief · as of 5 July 2026115 words · last cycle 2026-07-05

Commercial Intelligence

First Merchants Corporation's acquisition of First Savings Financial Group, an all-stock merger signed 2025-09-24 and valued at approximately $241.3m, reached legal closing on 2026-02-01, per SEC EDGAR filing — the deal's rationale was to expand Indiana community-bank scale to approximately $21.4bn in combined assets. Separately, Allied Payment Network received additional strategic growth-capital investment from RF Investment Partners, with Plymouth Growth co-investing, intended to fund next-generation payments infrastructure and product development; the transaction amount was not publicly disclosed.

no periodic updates on record for this sub-brief

Sources and findings (2)
  1. T1https://www.sec.gov/Archives/edgar/data/0000712534/000119312525216440/d83219dex991.htmretrieved
  2. T3https://www.privsource.com/acquisitions/payments-fintech/state/indianaretrieved
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Editorial metadata for United States – Indiana
FieldValue
trust.lawyer_review.statusnever_reviewed
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trust.content_sourceai_generated

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