United States – Kansas

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

Last updated 2026-10-21 · 14 modules · 64 sourced findings · 146 sources in the cumulative register

14Modulesbaseline.modules[]

64Findingsmodules[].findings[]

79Tier-1 sourcesrun_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 – Kansas is covered once, on the United States page. This page covers United States – Kansas’s own layer: its own law, regulators and enforcement.

Jurisdiction brief

Latest update · 18 October 2026

Lead Signal

Kansas has extended its money-transmission licensing perimeter to virtual-currency kiosk operators, and the new perimeter has already produced its first enforcement outcome. The Virtual Currency Kiosk Consumer Protection Act, 2026 HB 2591, deems kiosk operation money transmission under K.S.A. 9-564, effective 1 July 2026, closing a prior two-party-exchange exemption that had left kiosk operators outside state licensure. Operators unlicensed as of that date had sixty days to apply, with continued operation permitted while the Office of the State Bank Commissioner reviewed a complete application. On 8 October 2026, Coinme Inc. entered a thirty-three state, 2.5 million dollar settlement with OSBC and other state regulators for Bank Secrecy Act and anti-money-laundering violations, agreeing to exit Kansas kiosk operations by 1 January 2027 or face a further four million dollar penalty. Together, the new licensing statute and its first enforcement precedent represent a tightening of Kansas's nonbank payment-institution and EMI-adjacent licensing posture that outpaces the compliance runway most kiosk operators would otherwise have expected.

Other Developments

A separate litigation matter touches the state's bespoke fiduciary charter. The Office of the State Bank Commissioner filed a cease-and-desist order against Beneficient Fiduciary Financial after it refused a consent order under the state's 2021 TEFFI charter, with an administrative law judge hearing scheduled for November 2026. The outgoing Bank Commissioner has publicly called for the Legislature to repeal the TEFFI Act. No primary cease-and-desist order text was retrieved this cycle, and confidence in the particulars is held at Probable pending primary-source retrieval.

Leadership transition at the licensing authority. Bank Commissioner David Herndon, who has served since 2019, announced his retirement effective 30 October 2026, with no successor named as of this research date, creating transition risk for both the TEFFI proceeding and continued implementation of the new kiosk-licensing regime.

Cross-Monitor Connections

The Coinme settlement is an AML/CFT and financial-crime matter as much as a licensing one; its BSA and AML violation basis connects directly to the financial-integrity monitor's enabler-jurisdiction and crypto-asset tracking for Kansas, which addresses the same settlement from an architecture-over-incident, typology-driven perspective. The underlying statute and settlement also inform the crypto monitor's licensing and consumer-protection coverage of the identical facts. These are the same underlying events read through different lenses, not independent developments.

Outlook

1 January 2027 is the operative deadline for Coinme's exit from the Kansas kiosk market. Whether other kiosk operators pursue licensure under the now-closed transitional window or themselves exit the Kansas market will determine the shape of the sector going into 2027. Separately, the administrative law judge hearing in the TEFFI/BFF cease-and-desist proceeding, scheduled for November 2026, and the as-yet-unnamed successor to the retiring Bank Commissioner, are both near-term developments that bear on the licensing authority's capacity and direction going forward.

5 earlier updates not shown here.

Standing brief · as of 24 August 2026

Written before the update above. Where they differ, the update is the more recent position.

Lead Signal

Kansas has brought virtual currency kiosk operators within its money-transmitter licensing perimeter, effective 1 July 2026, through amendments made by House Bill 2591 to the Kansas Money Transmission Act. Any person who owns, operates, solicits, markets, advertises, or facilitates a virtual currency kiosk in Kansas is now deemed to be engaged in money transmission and must hold a licence, with a 60-day cure window running from the effective date for operators not already licensed. The obligation is confirmed by the enrolled statutory text published in the Kansas Register and by the Kansas Office of the State Bank Commissioner's own implementation notice, giving this development a high evidentiary standing. This is a market-access event for the nonbank kiosk-operator population specifically: existing bank-affiliated payment rails are unaffected, and the change operates entirely within Kansas's pre-existing money-transmitter licensing category rather than creating a new licence type. This development carries the highest impact rating available in Kansas's payments tracker for the cycle, reflecting both the scale of the kiosk-operator population newly captured by the licence requirement and the elevated impact assigned to the accompanying consumer-protection provisions.

Other Developments

Conduct and disclosure obligations attach to the same statute. Kiosk operators must display on-screen fraud warnings requiring customer acknowledgment before a transaction completes, disclosing that virtual currency is not government-backed and that transactions may be irreversible. Fees on kiosk transactions are capped at the greater of five dollars or eighteen percent of the transaction amount, with a one-thousand-dollar cap on an initial transaction and a tiered transaction-limit structure beyond that. These are conduct-and-safeguarding-adjacent provisions riding on the same licensing vehicle rather than a separate financial-promotions regime, and they apply specifically to the kiosk channel rather than to virtual-currency transactions generally.

Elder-exploitation reporting authorization. The same legislative vehicle authorizes financial institutions, a bank-side rather than nonbank-side provision, to report suspected financial exploitation of adult account holders, notify a trusted contact, and place a temporary hold on suspicious transactions, with liability protection attaching to institutions that take such action. Because this provision operates on the bank side of the ledger rather than the nonbank side that dominates the rest of this cycle's Kansas development, it is a useful marker of how the same legislative vehicle can carry obligations that land differently depending on whether the affected entity is a licensed bank or a licensed nonbank payment institution.

A comparative note on the statutory bond. A single industry compliance-tracker source, of lower evidentiary tier than the primary statutory sources above, places Kansas's two-hundred-thousand-dollar baseline money-transmitter bond above thirty-seven of the fifty states that set a statutory bond. This is offered as comparative market-structure context rather than as a confirmed regulatory fact, and it did not change this cycle.

Cross-Monitor Connections

The AML/CFT and Financial Crime reading of this same Kansas kiosk statute, including its money-transmission licensing hook and its fraud-referral duty to the Attorney General and law enforcement, is tracked by the Financial Integrity Monitor. The stablecoin and digital-money reading of Kansas's broader virtual-currency posture is tracked by the Crypto monitor. This monitor's own reading is confined to the market-access, conduct, and consumer-protection dimensions of the same underlying statute. No scheme-network, correspondent-banking, or cross-border corridor signal was identified for Kansas this cycle.

Outlook

The date to watch is 1 July 2026, when the licensing requirement takes effect and the 60-day cure window opens. The practical open question for the kiosk-operator population is how many operators currently active in Kansas are not already licensed as money transmitters, and whether the compressed 60-day cure window is sufficient given typical money-transmitter licensing processing times. The consumer-protection provisions, fraud warnings, transaction and fee caps, and elder-exploitation reporting authorization, take effect on the same timeline and should be watched for early compliance patterns once the licensing population becomes visible through OSBC's administration of the new perimeter. Operators and compliance teams monitoring Kansas market access should also track whether the Office of the State Bank Commissioner issues any further implementing guidance narrowing what counts as facilitating a kiosk for licensing purposes, given the breadth of the statutory language covering ownership, operation, solicitation, marketing, advertising, and facilitation alike. No settlement-finality or safeguarded-funds insolvency question specific to Kansas kiosk operators was resolved this cycle, and remains an open gap for a future cycle.

trust tier: ai_unverified

Latest update · 18 October 2026

Regulatory Status

Kansas's payments regulatory posture tightened materially this cycle. The Virtual Currency Kiosk Consumer Protection Act, 2026 HB 2591, extended Kansas Money Transmission Act licensure to virtual-currency kiosk operators effective 1 July 2026, closing a prior two-party-exchange exemption. A sixty-day transitional application window applied to operators already active at the effective date. The first enforcement precedent under the new regime arrived on 8 October 2026: Coinme Inc. entered a thirty-three state, 2.5 million dollar Bank Secrecy Act and anti-money-laundering settlement with the Office of the State Bank Commissioner and other state regulators, agreeing to exit Kansas kiosk operations by 1 January 2027 or face a further four million dollar penalty.

Separately, the state's licensing authority filed a cease-and-desist order against Beneficient Fiduciary Financial under Kansas's bespoke 2021 TEFFI fiduciary charter, with an administrative law judge hearing scheduled for November 2026; the Bank Commissioner has publicly called for the Legislature to repeal the TEFFI Act. That same Commissioner, David Herndon, announced retirement effective 30 October 2026, with no successor named as of this research date.

Outlook

1 January 2027 is the operative deadline for Coinme's Kansas market exit. The November 2026 administrative law judge hearing in the TEFFI/BFF matter, and the naming of a successor Bank Commissioner, are the near-term developments to watch for Kansas's payments regulatory authority going forward.

5 earlier updates not shown here.

Standing brief · as of 24 August 2026

Written before the update above. Where they differ, the update is the more recent position.

Regulatory Status

Kansas has extended its money-transmitter licensing perimeter to virtual currency kiosk operators through House Bill 2591's amendment of the Kansas Money Transmission Act, effective 1 July 2026, with a 60-day cure window for operators not already licensed. The same statute imposes fee caps (the greater of five dollars or eighteen percent of the transaction amount), a one-thousand-dollar cap on an initial transaction, mandatory on-screen fraud warnings, and, through a companion provision, authorizes financial institutions to report suspected elder financial exploitation and place temporary transaction holds with liability protection. Kansas's baseline statutory money-transmitter bond of two hundred thousand dollars is, per a single lower-tier comparative source, above thirty-seven of the fifty states that set a statutory bond, though this did not change this cycle.

Outlook

The 1 July 2026 effective date and the 60-day cure window are the near-term milestones. Watch for OSBC implementing guidance on the scope of facilitating a kiosk for licensing purposes, the compliance posture of the newly captured kiosk-operator population, and any early reporting-volume signal from the bank-side elder-exploitation authorization.

14 of 14 modules

Signal

Density

Selections OR within a group, AND across groups. Press / to search.

#

Kansas money-transmission licensing now expressly reaches virtual-currency kiosk operators following enactment of the Virtual Currency Kiosk Consumer Protection Act (HB 2591), in force 2026-07-01, administered by OSBC via NMLS.

Horizon · 2026-07-01 (±quarter)Kansas Virtual Currency Kiosk Consumer Protection Act (HB 2591) licensure requirement in forcein_force · TT1

Standing sub-brief · as of 24 August 2026361 words · last cycle 2026-10-18

Licensing, Authorisation & Market Access

Kansas has extended its money-transmitter licensing perimeter to cover virtual currency kiosk operation for the first time, through House Bill 2591's amendment of the Kansas Money Transmission Act. Any person who owns, operates, solicits, markets, advertises, or facilitates a virtual currency kiosk in the state is now deemed to be engaged in money transmission and must hold a licence, with the obligation taking effect 1 July 2026. Operators not already licensed as of that date have a 60-day window from the effective date in which to submit a licence application, a compressed timeline relative to the processing periods typically associated with money-transmitter licensing generally. The finding is corroborated by two sources: the enrolled statutory text published in the Kansas Register, and the Kansas Office of the State Bank Commissioner's own implementation guidance confirming the effective date and the licensing mechanism.

Periodic update · new data 2026-10-18

Licensing, Authorisation & Market Access

Kansas extended its money-transmission licensing perimeter to virtual-currency kiosk operators this cycle. The Virtual Currency Kiosk Consumer Protection Act, 2026 HB 2591, deems kiosk operation money transmission under K.S.A. 9-564, effective 1 July 2026, closing a prior two-party-exchange exemption that had left kiosk operators outside the Kansas Money Transmission Act's licensure requirement. A transitional provision gave operators unlicensed as of the effective date sixty days to apply for licensure, with continued operation permitted while the Office of the State Bank Commissioner reviewed a complete application, avoiding an abrupt market-access disruption at the point of transition. The licence type required is a money transmitter licence, with no exemption category remaining for kiosk operators after the Act's passage.

The new licensing gateway produced its first enforcement test within months. On 8 October 2026, Coinme Inc. entered a thirty-three state, 2.5 million dollar settlement with OSBC and other state regulators for Bank Secrecy Act and anti-money-laundering violations, agreeing to exit Kansas kiosk operations by 1 January 2027 or face a further four million dollar penalty. This settlement is a nonbank payment-institution and EMI-adjacent market-access event: a kiosk operator's continued presence in the Kansas market is now directly contingent on resolving an enforcement matter arising under the same licensing regime that created the market-access gateway in the first place.

A separate development affecting the licensing authority itself: Bank Commissioner David Herndon, who has served since 2019, announced his retirement effective 30 October 2026, with no successor named as of this research date. This creates near-term leadership-transition risk for the authority responsible for reviewing kiosk-licence applications under the still-new regime.

Outlook

The transitional sixty-day licensure window has closed, and the practical shape of the Kansas kiosk sector going into 2027 will depend on how many operators secure licensure under the new regime versus following Coinme's path of settlement and exit. The naming of a successor Bank Commissioner is a related near-term development to watch, given that office's responsibility for ongoing licence-application review.

5 earlier distinct update(s)

Periodic update · new data 2026-10-11

Licensing, Authorisation & Market Access

Kansas's Virtual Currency Kiosk Consumer Protection Act (HB 2591) extends the Kansas Money Transmission Act licensing perimeter to cover virtual-currency kiosks. Owning, operating, soliciting, marketing, advertising or facilitating a virtual-currency kiosk in the state is deemed money transmission, requiring licensure under K.S.A. 2025 Supp. 9-564. This closes a structural gap in oversight of crypto-ATM infrastructure by routing it through the state's existing non-bank money-transmitter licensing gateway rather than establishing a parallel crypto-specific licence category, a pattern consistent with how other states have addressed similar kiosk proliferation. Unlicensed incumbent operators are required to apply for licensure, and a 60-day post-effective-date application window gives Kansas a faster phase-in than many comparable state kiosk-licensing regimes elsewhere.

Outlook

The marker to track is completion of the 60-day incumbent-operator licensing window following the 1 July 2026 effective date, and whether the Office of the State Bank Commissioner takes visible licensing or enforcement action against operators that did not apply within that window.

Periodic update · new data 2026-09-28

Licensing, Authorisation & Market Access

Kansas has expanded its money-transmitter licensing perimeter to explicitly cover virtual currency kiosk (crypto ATM) operators. 2026 House Bill 2591 created the Virtual Currency Kiosk Consumer Protection Act (VCKCPA) as new sections of the Kansas Money Transmission Act, requiring kiosk operators to hold a money-transmitter licence, effective July 1, 2026. This is a nonbank-PI/EMI-type market-access change: kiosk operators, a category of nonbank payment-adjacent business not previously subject to a distinct statutory licensing requirement, are now brought within the same money-transmitter authorisation framework that already governs other nonbank money-services businesses operating in Kansas. The change does not alter licensing conditions for bank-provided payment services, which remain governed by separate banking-law frameworks; the tightening is specific to the nonbank kiosk-operator category.

Outlook

Whether Kansas extends comparable licensing requirements to other nonbank payment-adjacent business models beyond virtual currency kiosks is not addressed by this cycle's evidence.

Periodic update · new data 2026-09-22

Licensing, Authorisation & Market Access

Kansas amended the Kansas Money Transmission Act via HB 2591, effective July 1, 2026, to explicitly bring virtual-currency kiosk operators within its money-transmitter licensing perimeter. Any person owning, operating, soliciting, marketing, advertising, or facilitating virtual-currency kiosks in Kansas is now deemed engaged in money transmission and must obtain licensure from the Kansas Office of the State Bank Commissioner. This is a confirmed, Tier-1-sourced development, drawn directly from the Kansas Register's enrolled bill text and independently corroborated by OSBC's own regulatory notice, which confirms the same July 1, 2026 effective date.

This is a nonbank-PI/EMI licensing action specifically: it extends an existing non-bank money-transmitter licensing framework to a previously undefined product category, unattended virtual-currency kiosks, rather than altering any bank-provided payment-services requirement. The licensing regime kiosk operators now enter is not a light-touch registration: Kansas's statutory surety-bond requirement for money transmitters is $200,000, reportedly higher than 37 of the 50 bonding states per a secondary licensing-compliance source, a Probable-confidence, Tier-3-sourced comparative claim that nonetheless signals a materially stringent bonding bar relative to other US states for any new entrant, including newly-captured kiosk operators.

The market-access effect is a narrowing of previously ambiguous or unlicensed operating space for kiosk operators specifically, while leaving Kansas's broader money-transmission licensing perimeter for other payment-services categories unchanged this cycle.

Outlook

The clearest near-term marker for market access is whether OSBC's public licensee registry begins listing kiosk operators as licensed money transmitters, confirming that the new statutory requirement has produced actual licensing activity. Whether the $200,000 bonding requirement, now applicable to newly-captured kiosk operators, proves a material barrier to entry for smaller kiosk operators is a second market-access question to track into the next cycle.

Periodic update · new data 2026-09-14

Licensing, Authorisation & Market Access

Kansas enacted HB 2591, the Virtual Currency Kiosk Consumer Protection Act, requiring virtual currency kiosk operators to be licensed as money transmitters under the Kansas Money Transmission Act as amended, effective July 1, 2026. This is a Confirmed development corroborated by two Tier-1 sources, the Kansas Register statutory publication and OSBC guidance, and it represents Kansas closing a market-access gap for a specific nonbank product category — virtual-currency kiosks — by folding it into the existing money-transmitter licensing perimeter rather than creating a bespoke licence type. This is the carry-the-distinction moment for the bank-PSP versus nonbank-PI/EMI split that structures this module: kiosk operators, like other money transmitters in Kansas, are nonbank payment-institution-equivalent entities subject to state licensure rather than federally chartered banks, and HB 2591 simply extends that same nonbank licensing track to cover the kiosk business model specifically.

Notably, the existing prudential backbone of that licensing track is unchanged: the surety-bond requirement — the greater of $200,000 or 100 percent of the licensee's average daily money-transmission liability, capped at $1,000,000 — continues to apply without modification for the newly covered kiosk-operator category. This confirms Kansas's approach is one of extension rather than redesign, though this specific bond-continuity finding rests on a single Tier-3 source rather than direct Tier-1 confirmation of the bond schedule's application to kiosks specifically.

The practical market-access effect is that any entity wishing to operate virtual-currency kiosks in Kansas after July 1, 2026 must clear the same money-transmitter licensure bar — including the surety-bond requirement — that applies to other nonbank money-transmission businesses in the state, closing what had functioned as a licensing gap for this specific product category.

Outlook

The effective date of July 1, 2026 is the key market-access marker: whether existing Kansas-licensed money transmitters extend their licences to cover kiosk operation, or whether a distinct population of kiosk-specific new entrants seeks licensure, will define how this market-access change plays out in practice over coming cycles.

Periodic update · new data 2026-09-08

Licensing, Authorisation & Market Access

Kansas House Bill 2591 extends the Kansas Money Transmission Act to explicitly cover virtual-currency kiosk operators, effective July 1, 2026. Any operator who owns, operates, solicits, markets, advertises, or facilitates virtual-currency kiosks in the state is now deemed to be engaged in money transmission and must hold a Kansas money transmitter licence. This is a non-bank payment-institution and e-money-institution licensing action: the obligation attaches to the kiosk-operator category rather than to any bank partner, and it closes a market-access gap that previously allowed kiosk operators to function without a state licensing touchpoint specific to their activity.

The statute includes a transitional provision material to market access: unlicensed operators active in Kansas as of the July 1, 2026 effective date have 60 days to apply for licensure, and may continue operating during the Commissioner's review of that application. A denied applicant, however, must cease operations. This creates a defined compliance runway rather than an abrupt market exit requirement, softening the transition for incumbent non-bank kiosk operators while still establishing a hard endpoint for those unable or unwilling to obtain licensure.

Comparative positioning matters here: Kansas's approach, licensing plus consumer protection, mirrors Kentucky's model and stands in contrast to the outright prohibition on VC kiosks adopted in Minnesota, Indiana, and Tennessee. This is a probable rather than confirmed characterization drawn from specialist legal commentary rather than primary statutory text, but it usefully situates Kansas within the broader landscape of state approaches to kiosk regulation. For non-bank payment institutions and e-money-institution-adjacent kiosk operators specifically, Kansas has chosen market access conditioned on licensure over exclusion, which is the more commercially favourable of the two dominant state regulatory postures for this sub-sector.

Outlook

The defining near-term event is the close of the 60-day licence-application window, expected around late August 2026. The proportion of Kansas's existing kiosk-operator base that successfully licenses within that window, versus exits the market, will be the clearest signal of how burdensome the new market-access conditions prove in practice for non-bank operators in this specific product category.

1 further periodic run re-emitted the standing brief unchanged and is not shown.

Sources and findings (6)

T1https://osbckansas.gov/legal/kmta_2025.pdfretrieved 2026-07-05
T1https://klrd.gov/2024/12/18/definition-of-money-and-money-transmitters/retrieved 2026-07-05
T1https://ksrevisor.gov/statutes/chapters/ch09/009_005_0055.html
T3https://moneytransmitterlaw.com/state-laws/kansas/retrieved 2026-07-05
T1https://sos.ks.gov/publications/Register/Volume-45/Issues/Issue-18/04-30-26-54119.htmlretrieved 2026-07-05
T3https://www.pillsburylaw.com/en/news-and-insights/starting-july-1-kansas-money-transmitter-act-requires-licensure.htmlretrieved 2026-07-05

#

Kansas ties licensee conduct to permissible-investment/trust safeguarding of outstanding transmission liability, a dedicated information-security statute mirroring the federal GLBA Safeguards Rule, a 2024 Earned Wage Access conduct regime under OSBC, and a 2025 surcharge-disclosure regime governing card-payment promotions/pricing, all backstopped by the Kansas Consumer Protection Act.

Horizon · 2026-07-01 (±quarter)Kansas EWA Act information-security amendment (HB 2591) in forcein_force · TT1

Standing sub-brief · as of 24 August 2026281 words · last cycle 2026-10-11

Conduct, Safeguarding & Financial Promotions

The same Kansas statute that extends money-transmitter licensure to virtual currency kiosk operators, House Bill 2591, layers a set of conduct and disclosure obligations directly onto the kiosk transaction itself. Kiosk operators must display an on-screen fraud warning requiring customer acknowledgment before a transaction completes, disclosing that virtual currency is not government-backed, that its value is volatile, and that completed transactions may be irreversible. This operates as a point-of-transaction disclosure control specific to the kiosk channel, rather than a general financial-promotions regime applicable to virtual-currency marketing across all channels.

Periodic update · new data 2026-10-11

Conduct, Safeguarding & Financial Promotions

Alongside the new licensing requirement, the Virtual Currency Kiosk Consumer Protection Act imposes a conduct-layer cap on kiosk transaction charges: fees are capped at the greater of $5 or 18% of the full money-transmission amount. This fee-cap provision sits within the same enacted instrument as the licensing extension, meaning kiosk operators face both a market-access gate and a conduct-level pricing constraint simultaneously, rather than the two obligations arriving on separate regulatory timelines as is sometimes the case in other states. This is a meaningful consumer-facing conduct standard specific to the kiosk channel, distinct from and narrower than the general conduct obligations applicable to bank or non-bank payment institutions operating other product types in Kansas.

Outlook

The item to watch is whether Kansas kiosk operators' pricing practices are found compliant with the fee cap once the Office of the State Bank Commissioner's licensing review of incumbent applicants concludes, and whether any further conduct or promotional restrictions are added to the kiosk-specific regime.

1 further periodic run re-emitted the standing brief unchanged and is not shown.

Sources and findings (5)

T1https://osbckansas.gov/legal/kmta_2025.pdfretrieved 2026-07-05
T3https://www.consumerfinancemonitor.com/2023/05/22/kansas-passes-an-act-requiring-mortgage-companies-supervised-lender-and-money-transmitters-to-create-information-security-standards-consistent-with-glbas-consumer-information-safeguard-rule/retrieved 2026-07-05
T1https://www.osbckansas.gov/kansas-earned-wage-access-legislation/retrieved 2026-07-05
T1https://www.ksrevisor.gov/statutes/chapters/ch16a/016a_002_0403.htmlretrieved 2026-07-05
T3https://legalclarity.org/kansas-attorney-general-consumer-protection-what-you-need-to-know/retrieved 2026-07-05

#

Kansas does not treat cryptocurrency as "money" under the KMTA, so pure crypto-to-crypto transfers fall outside state money-transmission licensing, while crypto-fiat exchange through a third party generally does trigger it; a dedicated Kansas fiduciary charter (TEFFI) exists for digital-asset trust institutions, and the 2026 Virtual Currency Kiosk Act plus the federal GENIUS Act now layer additional stablecoin/crypto-kiosk requirements onto the state regime.

Horizon · 2026-07-18 (±quarter)OCC GENIUS Act implementing-rulemaking one-year statutory deadlineconsultation · TT1

Horizon · 2027-01-18 (±quarter)GENIUS Act full implementation deadline (federal stablecoin framework)adopted · TT1

Standing sub-brief · as of 5 July 2026207 words · last cycle 2026-07-05

Stablecoins & Digital Money

Because cryptocurrencies are not "money" or "monetary value" under the KMTA, an entity engaged solely in transmitting decentralized virtual currency is not required to obtain a Kansas money-transmission license; exchange of cryptocurrency for sovereign currency through a third party is generally treated as money transmission. HB 2591 amends Kansas's Technology-Enabled Fiduciary Financial Institution (TEFFI) framework to prohibit OSBC or any other state agency from acting as receiver for a TEFFI that becomes insolvent or declares bankruptcy. The federal GENIUS Act, enacted July 18, 2025, establishes a national payment-stablecoin regulatory framework with parallel OCC (federal) and State qualified-issuer tracks; most implementing rulemakings are due within one year of enactment (by July 18, 2026), and full implementation takes effect at the earlier of final rules or January 18, 2027. It interacts with KMTA's K.S.A. 9-561 provision that federal law controls where inconsistent with the state Act. Taken together, Kansas's crypto-scoping guidance, its TEFFI fiduciary charter and the incoming federal stablecoin regime form a layered - if not fully reconciled - digital-money framework.

no periodic updates on record for this sub-brief

Sources and findings (5)

T1https://www.osbckansas.gov/cml/mt_2014_01.pdfretrieved 2026-07-05
T1https://sos.ks.gov/publications/Register/Volume-45/Issues/Issue-18/04-30-26-54119.htmlretrieved 2026-07-05
T1https://www.governor.ks.gov/Home/Components/News/News/1012/56retrieved 2026-07-05
T1https://www.congress.gov/119/plaws/publ27/PLAW-119publ27.pdfretrieved 2026-07-05
T1https://www.federalregister.gov/documents/2026/03/02/2026-04089/implementing-the-guiding-and-establishing-national-innovation-for-us-stablecoins-act-for-theretrieved 2026-07-05

#

Kansas layers a GLBA-equivalent information-security statute onto covered financial institutions (including money transmitters), a state security-breach notification law with tight timing obligations, and a distinct public-sector cybersecurity incident-reporting regime, while the Federal Reserve Bank of Kansas City provides the regional payment-system-risk and account-management infrastructure for Kansas depository institutions.

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 2026116 words · last cycle 2026-10-11

Operational Resilience & Critical Infrastructure

HB 2019 requires public entities to notify the Kansas Information Security Office within 12 hours of discovering a significant cybersecurity incident, and government contractors to notify within 72 hours of reasonably believing an incident occurred. The Federal Reserve Bank of Kansas City supplies Kansas depository institutions with account management, Payment System Risk policy resources, and financial-condition/compliance evaluation, forming the regional operational-resilience backbone for Kansas banks. These federal and state-level resilience layers sit alongside SB44's GLBA-equivalent information-security obligations covered under Conduct, Safeguarding & Financial Promotions, giving Kansas payments infrastructure overlapping public- and private-sector reporting channels.

Periodic update · new data 2026-10-11

Operational Resilience & Critical Infrastructure

Enacted alongside the kiosk Act, a new provision under the Technology-Enabled Fiduciary Financial Institutions Act bars the Office of the State Bank Commissioner or any other Kansas state agency from acting as receiver for an insolvent or bankrupt Technology-Enabled Fiduciary Financial Institution (TEFFI). This materially affects resolution planning for Kansas-chartered technology-enabled fiduciary trust companies, since the usual state-agency receivership backstop available for other regulated financial institutions is expressly unavailable for this category. Market participants relying on a TEFFI charter for custodial or fiduciary digital-asset infrastructure in Kansas should treat insolvency resolution as a matter requiring alternative contractual or structural planning, since no state-agency receiver will step in.

Outlook

The item to watch is how TEFFI-chartered institutions and their counterparties structure resolution and continuity arrangements in the absence of a state-agency receivership backstop, and whether any Kansas-chartered TEFFI tests this provision in practice.

Sources and findings (4)

T3https://www.consumerfinancemonitor.com/2023/05/22/kansas-passes-an-act-requiring-mortgage-companies-supervised-lender-and-money-transmitters-to-create-information-security-standards-consistent-with-glbas-consumer-information-safeguard-rule/retrieved 2026-07-05
T1https://www.ksrevisor.gov/statutes/chapters/ch50/050_007a_0001.htmlretrieved 2026-07-05
T1https://sos.ks.gov/publications/sessionlaws/2023/Chapter-75-HB-2019.htmlretrieved 2026-07-05
T1https://www.kansascityfed.org/banking/retrieved 2026-07-05

#

Kansas lifted a decades-old ban on credit-card surcharging (HB 2247, effective January 1, 2025) after a federal court found the prior ban unconstitutional, replacing it with a disclosure-based regime that operates alongside federal Durbin Amendment debit-interchange caps and card-network (Visa/Mastercard) surcharge notice and percentage-cap rules.

Standing sub-brief · as of 5 July 2026132 words · last cycle 2026-07-05

Scheme & Network Compliance

Effective January 1, 2025, Kansas permits a credit-card surcharge only where the retailer discloses the amount via clear and conspicuous notice at the point of entry or sale in advance of the transaction, following a federal court ruling that the prior no-surcharge ban was unconstitutional. Kansas merchants implementing surcharge programs under the amended state law must separately comply with Visa's scheme rule requiring 30 days' advance written notice to the network and a surcharge cap of 3%, layering scheme-level compliance atop the state disclosure statute. The result is a two-tier compliance stack: a state disclosure mandate and a card-network notice-and-cap regime that merchants must satisfy simultaneously.

no periodic updates on record for this sub-brief

Sources and findings (3)

T1https://www.ksrevisor.gov/statutes/chapters/ch16a/016a_002_0403.htmlretrieved 2026-07-05
T3https://intellipay.com/surcharge-interchange-fee-legislation-2026/retrieved 2026-07-05
T3https://merchantcostconsulting.com/lower-credit-card-processing-fees/kansas-surcharge-laws/retrieved 2026-07-05

#

Kansas hosts an outsized correspondent-banking wire corridor through a small rural bank (CBW Bank), sits within the Federal Reserve Bank of Kansas City's settlement infrastructure, and shows growing but still-partial community-bank participation in the domestic FedNow instant-payments rail; the state's rural banks remain materially dependent on correspondent-bank credit lines for cross-border wire settlement.

Standing sub-brief · as of 5 July 2026144 words · last cycle 2026-07-05

Payment Corridor Dynamics

CBW Bank ran a multibillion-dollar international money-transfer business (correspondent services to ~30 foreign banks and six MSBs, ~$27 billion in wires in 2018) between 2018 and 2020; the bank shut down its correspondent-banking and MSB wire business in 2020 under an FDIC consent order, and a subsequent $20M FDIC civil penalty (assessed 2024) concerns that 2018-2020 conduct, not current operations. Multiple Kansas-chartered community banks - including Bank of Tescott, CBW Bank, Central National Bank, Conway Bank, Denison State Bank, Farmers State Bank, Goppert State Service Bank, INTRUST Bank N.A. and Union State Bank - have joined the Federal Reserve's FedNow instant-payments network. The corridor picture is therefore one of a closed historical foreign-wire channel alongside a still-emerging domestic real-time-payments footprint.

no periodic updates on record for this sub-brief

Sources and findings (4)

T2https://www.bankingdive.com/news/cbw-bank-kansas-20m-fdic-penalty-aml-suspicious-activity-lawsuit/736422/retrieved 2026-07-05
T3https://www.nerdwallet.com/banking/learn/banks-that-use-fednowretrieved 2026-07-05
T1https://www.kansascityfed.org/banking/retrieved 2026-07-05
T3https://www.americanbanker.com/news/failed-kansas-bank-rapidly-borrowed-21-million-from-fhlb-systemretrieved 2026-07-05

#

Kansas's payments-adjacent industry structure is dominated by an actively-consolidating community-bank sector led by Wichita-based Equity Bancshares, a large Lenexa-headquartered credit union pursuing scale mergers, several Wichita community-bank brands, and a globally-recognized homegrown fintech (C2FO); a fintech-sponsor-bank model also exists in the state (Small Business Bank) alongside a newly announced major fintech-employer entrant (Fiserv) in Overland Park.

Standing sub-brief · as of 5 July 2026136 words · last cycle 2026-07-05

Industry Structure & Commercial Dynamics

Wichita-headquartered Equity Bancshares has completed 26 strategic transactions since 2002, including 14 whole-bank acquisitions in the past decade, positioning it as Kansas's most acquisitive community-banking franchise, with total assets expected to reach $7.9 billion after its pending Frontier Holdings merger. Small Business Bank operates as a fintech-sponsor bank planning digital-asset services but has drawn a third Federal Reserve enforcement action since 2023 - most recently a prompt-corrective-action order for being significantly undercapitalized - highlighting supervisory risk within Kansas's bank/fintech-sponsorship niche. These two data points bookend Kansas's industry structure: an acquisitive, well-capitalised community-bank consolidator on one side and a stressed fintech-sponsor bank on the other.

no periodic updates on record for this sub-brief

Sources and findings (6)

T1https://s203.q4cdn.com/843919082/files/doc_downloads/2025/09/6b78ce64-69c3-45b1-b05d-d6ca569fc4ad.pdfretrieved 2026-07-05
T3https://www.bankingdive.com/news/equity-bank-frontier-kansas-nebraska-122-million-merger/759140/retrieved 2026-07-05
T3https://www.americanbanker.com/news/five-trends-that-shaped-the-credit-union-industry-in-2025retrieved 2026-07-05
T3https://en.wikipedia.org/wiki/C2FOretrieved 2026-07-05
T2https://www.americanbanker.com/news/fed-warns-that-kansas-bank-significantly-undercapitalizedretrieved 2026-07-05
T1https://www.kansascommerce.gov/2025/04/governor-kelly-announces-fiserv-to-open-regional-fintech-hub-in-kansas/retrieved 2026-07-05

#

Kansas's payments litigation and enforcement landscape is anchored by the CardX v. Schmidt First Amendment ruling that dismantled the state's surcharge ban, a $20 million FDIC BSA/AML penalty against a Kansas-domiciled correspondent bank (whose challenge to that penalty was dismissed for lack of subject-matter jurisdiction in March 2025), Kansas's participation in a nationwide $80 million Cash App settlement, repeated Federal Reserve enforcement against a Lenexa fintech-sponsor bank, and a federal criminal case tied to the 2023 failure of a rural Kansas bank.

Standing sub-brief · as of 5 July 2026185 words · last cycle 2026-10-18

Legal & Litigation

A federal district court ruled Kansas's no-surcharge statute an unconstitutional restriction on commercial speech, finding the state could not show the ban was tailored to a substantial interest in lowering credit-card debt, directly triggering the legislature's 2024 repeal-and-replace of the surcharge prohibition (HB 2247). The FDIC assessed a ~$20 million penalty against CBW Bank of Weir, Kansas, alleging failure to maintain an AML/CFT program matching the risk of its (since-discontinued) correspondent/MSB wire-transfer business, including failure to file hundreds of SARs; CBW's federal lawsuit challenging the penalty was dismissed for lack of subject-matter jurisdiction on March 3, 2025. Kansas joined 47 other state financial regulatory agencies in an $80 million multistate enforcement action against Block, Inc.'s Cash App for BSA/AML compliance failures. The CardX ruling and the CBW dismissal are the state's two defining payments-litigation data points this cycle, one liberalising merchant pricing and one closing out a legacy AML enforcement dispute.

Periodic update · new data 2026-10-18

Legal & Litigation

Kansas's Office of the State Bank Commissioner filed a cease-and-desist order against Beneficient Fiduciary Financial (BFF) after the company refused a consent order under the state's 2021 TEFFI (Technology-Enabled Fiduciary Financial Institution) charter. An administrative law judge hearing on the order is scheduled for November 2026. In an unusual posture for a supervisor toward the instrument creating the charter class it oversees, the Bank Commissioner has publicly called for the Kansas Legislature to repeal the TEFFI Act itself, rather than simply seeking stronger enforcement tools within the existing statute.

This litigation matter is analytically distinct from, though temporally coincident with, a leadership transition at the same agency: the Commissioner who filed the cease-and-desist order and called for TEFFI's repeal, David Herndon, has himself announced retirement effective 30 October 2026, with no successor named as of this research date. The administrative law judge hearing will therefore proceed, and any subsequent appeal or legislative response will be managed, under conditions of leadership transition at the supervising agency.

No primary cease-and-desist order text was retrieved this cycle; the characterisation here rests on investigative reporting that quotes the regulator directly, and confidence is accordingly held at Probable pending primary-source retrieval of the order itself.

Outlook

The administrative law judge hearing scheduled for November 2026 is the near-term litigation event to watch. Separately, whether the Kansas Legislature takes up the Commissioner's call to repeal the TEFFI Act in a future session would be the clearest indicator of whether this dispute produces a durable change to the charter framework rather than remaining confined to the individual enforcement proceeding.

Sources and findings (5)

T1https://www.ksrevisor.gov/statutes/chapters/ch16a/016a_002_0403.htmlretrieved 2026-07-05
T2https://www.bankingdive.com/news/cbw-bank-kansas-20m-fdic-penalty-aml-suspicious-activity-lawsuit/736422/retrieved 2026-07-05
T1https://osbckansas.gov/kansas-joins-80-million-enforcement-action-against-block-inc-cash-app-for-bsa-aml-violations/retrieved 2026-07-05
T2https://www.americanbanker.com/news/fed-warns-that-kansas-bank-significantly-undercapitalizedretrieved 2026-07-05
T3https://www.americanbanker.com/news/why-kansas-bank-failure-did-not-raise-alarms-for-industryretrieved 2026-07-05

#

Kansas merchants gained the legal ability to add credit-card surcharges from January 1, 2025 subject to clear point-of-sale disclosure, operating alongside continued federal debit no-surcharge/interchange-cap rules and card-network-imposed surcharge percentage caps and notice requirements; local district attorney consumer-protection units actively police merchant compliance with the new disclosure regime.

Standing sub-brief · as of 5 July 2026123 words · last cycle 2026-07-05

Merchant Acquiring & Risk

Kansas merchants may impose a credit-card surcharge only with clear and conspicuous advance disclosure at the point of entry or sale; the statute distinguishes lawful cash discounts from surcharges and flags manipulation of that distinction as a potential KCPA deceptive trade practice. The Sedgwick County District Attorney's Consumer Protection Division publicly flagged the January 2025 surcharge-law change to residents, noting Kansas has no state-set surcharge cap, leaving the card-network 4% ceiling as the practical maximum - reflecting active local enforcement outreach on merchant payment-acceptance practices. Merchant-acquiring risk in Kansas is therefore concentrated in surcharge-disclosure compliance, policed at both the state and county level.

no periodic updates on record for this sub-brief

Sources and findings (4)

T1https://www.ksrevisor.gov/statutes/chapters/ch16a/016a_002_0403.htmlretrieved 2026-07-05
T3https://merchantcostconsulting.com/lower-credit-card-processing-fees/kansas-surcharge-laws/retrieved 2026-07-05
T3https://intellipay.com/surcharge-interchange-fee-legislation-2026/retrieved 2026-07-05
T3https://www.kake.com/home/change-in-kansas-state-law-allows-merchants-to-add-surcharge-to-credit-card-transactions/article_d5e9ab0e-d204-11ef-a55c-df5bcfaae0d6.htmlretrieved 2026-07-05

#

Kansas product innovation spans early community-bank FedNow instant-payments adoption, a formalized 2024 Earned Wage Access product category, a 2026 crypto-kiosk consumer-protection layer, a Kansas-originated global working-capital fintech (C2FO), and a major new fintech-processing employment hub (Fiserv, Overland Park) - though the state has no dedicated open-banking mandate or CBDC pilot of its own.

Standing sub-brief · as of 5 July 2026104 words · last cycle 2026-09-21

Product Innovation & Market Development

HB 2560 formally regulates Earned Wage Access as a distinct fintech product category under OSBC registration, examination and enforcement, positioning Kansas among the states codifying EWA product rules. Kansas's 2026 kiosk act layers blockchain-analytics fraud screening, live customer service and refund-rights requirements onto crypto-kiosk products, a novel state-level product-safety innovation for an emerging payments channel. Kansas has no dedicated open-banking mandate or CBDC pilot; its product-innovation posture instead runs through targeted product-category regulation of EWA and crypto kiosks.

Periodic update · new data 2026-09-22

Product Innovation & Market Development

Virtual-currency kiosks are now the first payment product category in Kansas to receive a dedicated statutory consumer-protection and disclosure regime, introduced via HB 2591 and effective July 1, 2026. This development narrows, for kiosks specifically, the Kansas Office of the State Bank Commissioner's standing 2014 interpretive guidance, which holds that exchange of one cryptocurrency for another is not money transmission under the state's statutory framework. That standing exemption remains fully intact for other product models: peer-to-peer transfer of decentralized cryptocurrency alone, with no fiat leg and no kiosk involvement, continues to fall outside Kansas money-transmission licensure. This is a confirmed, Tier-1-sourced finding for both the kiosk-specific narrowing and the persistence of the broader exemption.

The product-development significance here is structural rather than incremental: Kansas has created a dedicated regulatory lane for one specific hardware-based payment product, unattended virtual-currency kiosks, distinct from its treatment of software-only or peer-to-peer crypto-transmission products. This is a meaningful divergence within a single jurisdiction's regulatory treatment of functionally related but operationally distinct crypto-payment products, and it illustrates how product form, kiosk versus peer-to-peer, rather than the underlying asset class alone, is now driving Kansas's licensing determinations.

Outlook

Whether Kansas extends comparable dedicated statutory treatment to other emerging payment-product categories, such as crypto-linked prepaid instruments or other hardware-based crypto-payment access points, is the structural question to track. Whether the kiosk-specific carve-out prompts operators to restructure kiosk offerings to fall within the standing decentralized-crypto exemption, for instance by removing any fiat conversion leg, is a second product-innovation dynamic worth monitoring.

2 earlier distinct update(s)

Periodic update · new data 2026-09-14

Product Innovation & Market Development

Virtual currency kiosks — a nonbank payment product category built around physical terminals converting cash to and from cryptocurrency — are now subject to a dedicated regulatory overlay in Kansas under HB 2591, the Virtual Currency Kiosk Consumer Protection Act, effective July 1, 2026. This is a Confirmed, Tier-1-sourced development. Beyond the money-transmitter licensing requirement addressed under Licensing, Authorisation & Market Access, kiosk operators must display on-screen fraud warnings requiring a clicked pre-transaction acknowledgment, disclose that virtual currency transactions may be irreversible, provide live customer service during operating hours, and maintain a written anti-fraud and enhanced-due-diligence policy.

This is a specific, targeted regulatory response to a product-innovation category associated nationally with elevated consumer-fraud risk, and it places kiosk operators under conduct obligations that go materially beyond the baseline requirements applicable to other money-transmission products in Kansas. The product-specific nature of this overlay — rather than a general update to money-transmission conduct rules — signals that Kansas's regulator is treating virtual-currency kiosks as a distinct product-innovation surface requiring its own tailored consumer-facing controls, even while housing the underlying licensing mechanic within the existing general money-transmission framework.

Outlook

As the July 1, 2026 effective date approaches, the practical test for this product category will be whether the mandated fraud-warning acknowledgment and live customer-service requirements measurably affect kiosk-linked fraud complaint volumes in Kansas, and whether other product-innovation categories in the payments space attract similarly tailored overlays in future cycles.

Periodic update · new data 2026-09-08

Product Innovation & Market Development

Two distinct product-development signals surface in Kansas this cycle. First, HB 2591 caps virtual-currency kiosk transaction fees at the greater of five dollars or eighteen percent of the transaction amount, with a tiered transaction-limit structure. This is a direct constraint on kiosk-operator unit economics, introduced alongside the new licensing requirement discussed under market access. The fee cap is likely to compress margins for kiosk operators relative to the prior unregulated-fee baseline that prevailed before HB 2591, and a plausible secondary effect is a slowdown in new-kiosk deployment growth within Kansas as operators reassess the economics of expanding into a fee-capped, licensed environment.

Second, and at a considerably earlier and more uncertain stage, Kansas Senate Bill 352 proposes a state-managed Bitcoin and digital-assets reserve, to be funded via unclaimed property and overseen by the state treasurer. The bill was introduced in January 2026 and advanced through committee on January 23, 2026, but its status beyond that point in the 2026 session is not confirmed by available sources. If enacted, a state-level digital-asset reserve would be a notable public-sector product-adoption signal with implications for how state governments engage with digital-asset market infrastructure, though the uncertain confidence rating on this claim reflects the genuinely unresolved legislative status rather than any doubt about the bill's content as introduced.

These two developments should be read as operating on different timelines and with different certainty levels: the fee-cap and licensing changes under HB 2591 are confirmed and imminent, while the SB 352 reserve proposal remains a watch item rather than a settled product-development fact.

Outlook

The fee-cap's effect on kiosk-operator deployment economics should become observable within the next one to two cycles as operators respond to the new margin structure. SB 352's committee trajectory beyond January 23, 2026 is the more open question, and any further legislative movement, in either direction, would be the key signal to capture in a subsequent cycle.

Sources and findings (5)

T3https://www.nerdwallet.com/banking/learn/banks-that-use-fednowretrieved 2026-07-05
T1https://www.kslegislature.gov/li_2024/b2023_24/measures/documents/summary_hb_2560_2024retrieved 2026-07-05
T1https://sos.ks.gov/publications/Register/Volume-45/Issues/Issue-18/04-30-26-54119.htmlretrieved 2026-07-05
T3https://c2fo.com/newsroom/record-breaking-year-for-c2fo-marks-shift-in-trade-finance-landscape/retrieved 2026-07-05
T1https://www.kansascommerce.gov/2025/04/governor-kelly-announces-fiserv-to-open-regional-fintech-hub-in-kansas/retrieved 2026-07-05

#

HB 2591 (2026) creates the Virtual Currency Kiosk Consumer Protection Act, layering fraud-warning disclosures, live customer service, a $1,000 initial-transaction cap, fee caps (greater of $5 or 18%), and refund/fraud-hold procedures onto kiosk transactions; the same act separately authorizes financial institutions to report and act on suspected elder financial exploitation.

Standing sub-brief · as of 24 August 2026274 words · last cycle 2026-10-11

Consumer Protection & APP Fraud

Kansas's Virtual Currency Kiosk Consumer Protection Act, enacted as part of House Bill 2591, is squarely a consumer-protection and fraud-mitigation statute layered onto the kiosk-specific money-transmission licensing extension. Its central consumer-facing controls are a fee cap set at the greater of five dollars or eighteen percent of the transaction amount, a one-thousand-dollar cap on an initial kiosk transaction, and a mandatory on-screen fraud warning requiring customer acknowledgment before a transaction completes, disclosing that virtual currency is not government-backed and that transactions may be irreversible. These controls target the fraud typology most associated with unattended, high-friction cash-to-crypto kiosks: pressured, often scam-induced cash-outs, frequently involving elderly or otherwise vulnerable victims.

Periodic update · new data 2026-10-11

Consumer Protection & APP Fraud

Enacted alongside the kiosk Act, a new elder financial-exploitation reporting framework permits a Kansas financial institution to report, in good faith and with reasonable cause, suspected financial exploitation of an adult account holder to law enforcement or the Kansas Department for Children and Families, and to separately notify a designated trusted contact, without displacing existing elder-abuse reporting duties. This is a fraud-adjacent consumer-protection development distinct from the kiosk-specific fee-cap and disclosure provisions, giving Kansas financial institutions an additional, protected channel to intervene when an account holder is suspected to be the target of financial exploitation, a pattern relevant to authorised-push-payment and elder-fraud typologies more broadly.

Outlook

The item to watch is uptake of the trusted-contact notification mechanism by Kansas financial institutions, and whether reporting activity under this new gateway becomes visible in subsequent regulatory or industry reporting.

1 earlier distinct update(s)

Periodic update · new data 2026-09-28

Consumer Protection & APP Fraud

The Virtual Currency Kiosk Consumer Protection Act imposes new disclosure and refund obligations on virtual currency kiosk operators, a fraud-mitigation-driven consumer-protection package layered onto the licensing requirement described in the Licensing, Authorisation & Market Access module. Conference Committee materials on HB 2591 cite national fraud-loss estimates exceeding $12 billion annually in support of these provisions, indicating the Kansas legislature explicitly framed the new disclosure and refund duties as a response to fraud risk associated with virtual-currency-kiosk transactions specifically, rather than a general consumer-protection measure applicable across all payment channels.

Outlook

Whether kiosk-specific fraud-loss data for Kansas itself, as distinct from the national estimate cited in support of the legislation, will be tracked or reported in future cycles is not addressed by this cycle's evidence.

1 further periodic run re-emitted the standing brief unchanged and is not shown.

Sources and findings (4)

T3https://legalclarity.org/kansas-attorney-general-consumer-protection-what-you-need-to-know/retrieved 2026-07-05
T1https://sos.ks.gov/publications/Register/Volume-45/Issues/Issue-18/04-30-26-54119.htmlretrieved 2026-07-05
T1https://www.ag.ks.gov/divisions/public-protectionretrieved 2026-07-05
T1https://www.ksrevisor.gov/statutes/chapters/ch50/050_007a_0001.htmlretrieved 2026-07-05

#

W11 carries the Sentinel.gi payments-context AML/CFT position only, not original illicit-finance analysis. The federal FinCEN/BSA framework governs Kansas money transmitters and banks; Kansas's OSBC participates directly in national multistate BSA/AML supervisory and enforcement coordination, and a Kansas-domiciled bank has been a notable BSA/AML enforcement data point within that national posture.

Standing sub-brief · as of 5 July 2026132 words · last cycle 2026-10-18

AML/CFT & Financial Crime (Sentinel.gi-fed)

This module's intelligence is sourced from the Sentinel.gi feed; illicit-finance analysis proper is carried in the Financial Intelligence Monitor and is not re-analysed here. FinCEN administers the federal Bank Secrecy Act/AML framework applicable to Kansas money transmitters and banks, serving as the U.S. FIU within the Egmont Group and setting SAR, CTR and beneficial-ownership reporting obligations binding on Kansas-licensed and Kansas-chartered entities. Kansas's OSBC participated directly in a coordinated 47-state BSA/AML enforcement action against Block, Inc.'s Cash App, reflecting the state supervisory layer feeding into the national multistate AML coordination the Sentinel feed tracks.

Periodic update · new data 2026-10-18

AML/CFT & Financial Crime

Kansas's AML/CFT posture for virtual-currency kiosks tightened materially this cycle following the entry into force of the Virtual Currency Kiosk Consumer Protection Act on 1 July 2026, which brought kiosk operators under Kansas money-transmitter licensure and closed a prior exemption. The first enforcement precedent under the new regime followed on 8 October 2026: Coinme Inc. entered a thirty-three state, 2.5 million dollar settlement with the Office of the State Bank Commissioner and other state regulators for Bank Secrecy Act and anti-money-laundering violations. As part of the settlement, Coinme agreed to exit Kansas kiosk operations by 1 January 2027 or face a further four million dollar penalty.

This settlement is the first visible enforcement outcome combining the new state money-transmission licensing layer with the pre-existing federal Bank Secrecy Act and FinCEN money-services-business framework that already applied to kiosk operators. The practical effect for any nonbank payment institution or EMI-adjacent entity operating a kiosk channel in Kansas is a dual compliance obligation: continued federal BSA reporting and recordkeeping duties, now layered under a state licensing condition carrying its own enforcement consequence, demonstrated here to be swift and financially substantial.

Outlook

Whether additional kiosk operators in Kansas face similar multistate AML enforcement action, or instead achieve licensure and compliance under the new regime without incident, is the principal AML/CFT question for this module going into 2027. The 1 January 2027 exit deadline for Coinme is the specific date to track.

Sources and findings (6)

T2https://www.bankingdive.com/news/cbw-bank-kansas-20m-fdic-penalty-aml-suspicious-activity-lawsuit/736422/retrieved 2026-07-05
T?FIM (sentinel.gi) per-JID baseline profile — United States — Kansas — Kansas AML/CFT architecture operates almost entirely through the federal BSA regime, overlaid by the Kansas Office of the State Bank Commissioner (OSBC), which charters/examines state banks and licenses money transmitters under the Kansas Uniform Money Services Act. Kansas has no independent beneficial-ownership registry and no distinct virtual-asset licensing regime; it relies on federal FinCEN/CTA infrastructure, which was substantially narrowed in March 2025.
T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: sourcing-thinness
T2FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-002) — Sanctions: OFAC listing
T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-004) — Gap: enforcement-absence
T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: regulatory-failure

#

Kansas presents an outsized correspondent-banking access story: a small rural Kansas bank built a global correspondent wire business (wound down in 2020 under an FDIC consent order) now subject to AML enforcement, another rural Kansas bank's 2023 failure exposed dependence on correspondent credit lines for settlement, and the Federal Reserve Bank of Kansas City anchors the state's Fed-account settlement access amid a national de-risking backdrop affecting small and foreign-facing institutions.

Standing sub-brief · as of 5 July 2026162 words · last cycle 2026-07-05

Correspondent Banking, Settlement & Access

The module's spine in Kansas is the asymmetry between bank-chartered correspondent access and the absence of any equivalent direct settlement channel for non-bank payment institutions, illustrated here through two rural-bank case studies. CBW Bank of Weir, Kansas provided correspondent banking/wire-transfer access to roughly 30 foreign banks and six MSBs across Central/South America, Europe, Africa and the Middle East between 2018 and 2020 (~$27B in wires in 2018 alone), before shutting down that correspondent/MSB business in 2020 under an FDIC consent order - a legacy access case study rather than a live exposure. Heartland Tri-State Bank had nearly exhausted a correspondent bank's line of credit used to process its wire transfers just before its July 2023 failure, having drawn down roughly $24 million of that line, illustrating rural Kansas banks' structural reliance on correspondent-provided wire-settlement access.

no periodic updates on record for this sub-brief

Sources and findings (4)

T2https://www.bankingdive.com/news/cbw-bank-kansas-20m-fdic-penalty-aml-suspicious-activity-lawsuit/736422/retrieved 2026-07-05
T3https://www.americanbanker.com/news/failed-kansas-bank-rapidly-borrowed-21-million-from-fhlb-systemretrieved 2026-07-05
T1https://www.kansascityfed.org/banking/retrieved 2026-07-05
T1https://home.treasury.gov/system/files/136/Treasury_AMLA_23_508.pdfretrieved 2026-07-05

#

Within the trailing 12 months, Kansas commercial activity is dominated by continued bank/credit-union consolidation centered on Wichita's Equity Bancshares and Lenexa's CommunityAmerica Credit Union, alongside a major new fintech-employer entrant (Fiserv) establishing a large-scale processing hub in Overland Park.

Standing sub-brief · as of 5 July 2026171 words · last cycle 2026-09-05

Commercial Intelligence (M&A, Investment & Product)

On September 2, 2025, Wichita-based Equity Bancshares announced a $122.8 million cash-and-stock merger with Omaha-based Frontier Holdings, adding seven locations and $1.4 billion in assets and expanding into Nebraska for the first time. Lenexa, Kansas-based CommunityAmerica Credit Union ($5.3B assets) merged with Texas's Unify Financial Credit Union ($3.4B assets); the deal closed in November 2025, creating a combined $9 billion-asset institution. The transaction's amount was not publicly disclosed. Fiserv announced (April 2025) plans to open a strategic fintech hub at the Aspiria campus in Overland Park, Kansas, expected to create approximately 2,000 jobs across two phases beginning in 2026. The capital investment figure was not publicly disclosed. Together these three events - one announced bank M&A deal, one completed credit-union merger, and one major new fintech-employer entrant - mark Kansas's most active commercial-intelligence cycle in this dataset.

Periodic update · new data 2026-09-08

Commercial Intelligence & Fintech

The discrete commercial event this cycle is Kansas Senate Bill 352, introduced in January 2026, which would establish a state-managed Bitcoin and digital-assets reserve funded via unclaimed property and overseen by the state treasurer. The bill advanced through committee on January 23, 2026. This is a specific, discrete legislative proposal rather than a structural market-wide trend, which places it properly within commercial intelligence rather than within the broader industry-structure lens. No funding amount or valuation is attached to this proposal, as it concerns state-treasury allocation of unclaimed property rather than a disclosed private-sector transaction; there is accordingly no amount to flag as not publicly disclosed, since the proposal's fiscal mechanism, sourcing from unclaimed property, is itself the disclosed detail.

The bill's confidence rating is uncertain, reflecting that its status beyond the January 23, 2026 committee action within the 2026 legislative session has not been independently confirmed by available sources. If it advances and is enacted, it would represent a notable public-sector digital-asset adoption event, positioning Kansas among a small group of US states exploring state-held Bitcoin reserves, a development with commercial relevance to digital-asset custody providers, treasury-management vendors, and market infrastructure providers that serve public-sector clients.

Outlook

The item to track is whether SB 352 receives further committee or floor action in a subsequent legislative session; its current status as introduced-and-advanced-through-committee-only means it should continue to be treated as an early-stage, unconfirmed signal rather than an enacted commercial development until further legislative record becomes available.

Sources and findings (3)

T3https://www.bankingdive.com/news/equity-bank-frontier-kansas-nebraska-122-million-merger/759140/retrieved 2026-07-05
T3https://www.americanbanker.com/news/five-trends-that-shaped-the-credit-union-industry-in-2025retrieved 2026-07-05
T1https://www.kansascommerce.gov/2025/04/governor-kelly-announces-fiserv-to-open-regional-fintech-hub-in-kansas/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 – Kansas
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", "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: 1 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), 64 finding(s), 146 source(s) in the cumulative register.

Think something on this page is wrong? Report an error.

United States – Kansas

Jurisdiction brief

Latest update · 18 October 2026

Lead Signal

Other Developments

Cross-Monitor Connections

Outlook

Standing brief · as of 24 August 2026

Lead Signal

Other Developments

Cross-Monitor Connections

Outlook

Latest update · 18 October 2026

Regulatory Status

Outlook

Standing brief · as of 24 August 2026

Regulatory Status

Outlook

W1aLicensing, Authorisation & Market AccessConfirmedconfirmed 2026-07-05▾#

Licensing, Authorisation & Market Access

Outlook

Licensing, Authorisation & Market Access

Outlook

Licensing, Authorisation & Market Access

Outlook

Licensing, Authorisation & Market Access

Outlook

Licensing, Authorisation & Market Access

Outlook

Licensing, Authorisation & Market Access

Outlook

Licensing, Authorisation & Market Access

Outlook

W1bConduct, Safeguarding & PromotionsConfirmedconfirmed 2026-07-05▾#

Conduct, Safeguarding & Financial Promotions

Outlook

Conduct, Safeguarding & Financial Promotions

Outlook

W2Stablecoins & Digital MoneyConfirmedconfirmed 2026-07-05▾#

Stablecoins & Digital Money

Outlook

W3Operational Resilience & Critical InfrastructureConfirmedconfirmed 2026-07-05▾#

Operational Resilience & Critical Infrastructure

Outlook

Operational Resilience & Critical Infrastructure

Outlook

W4Scheme & Network ComplianceConfirmedconfirmed 2026-07-05▾#

Scheme & Network Compliance

Outlook

W5Payment Corridor DynamicsProbableconfirmed 2026-07-05▾#

Payment Corridor Dynamics

Outlook

W6Industry Structure & CommercialProbableconfirmed 2026-07-05▾#

Industry Structure & Commercial Dynamics

Outlook

W7Legal & LitigationConfirmedconfirmed 2026-07-05▾#

Legal & Litigation

Outlook

Legal & Litigation

Outlook

W8Merchant Acquiring & RiskProbableconfirmed 2026-07-05▾#

Merchant Acquiring & Risk

Outlook

W9Product Innovation & Market DevelopmentProbableconfirmed 2026-07-05▾#

Product Innovation & Market Development

Outlook

Product Innovation & Market Development

Outlook

Product Innovation & Market Development

Outlook

Product Innovation & Market Development

Outlook

W10Consumer Protection & APP Fraudlimited signalConfirmedconfirmed 2026-07-05▾#

Consumer Protection & APP Fraud

Outlook

Consumer Protection & APP Fraud

Outlook

Consumer Protection & APP Fraud

Outlook

W11AML/CFT & Financial Crime (Sentinel.gi-fed)Sourced from Sentinel.gi ↗Probableconfirmed 2026-07-05▾#

#

#

#

#

#

#

#

#

#

#

#

#

#

#