title: United States – Ohio Payments Regulation Monitor | World Payments Monitor canonical: https://payments.gi/jurisdictions/united-states-ohio/ date_modified: 2026-10-21 publisher: Asymmetric Intelligence # United States – Ohio US-OH schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-21 · 14 modules · 63 sourced findings · 121 sources in the cumulative register 14 Modules baseline.modules[] 63 Findings modules[].findings[] 48 Tier-1 sources run_metadata.t1_source_count Confidence mix (sums to 14 rendered modules; click to filter) No modules moved this cycle. ** United States federal law** that applies in United States – Ohio is covered once, on the [United States](https://payments.gi/jurisdictions/united-states/) page. This page covers United States – Ohio’s own layer: its own law, regulators and enforcement. ## Jurisdiction brief ###### Latest update · 18 October 2026 #### Lead Signal Polygon closed its acquisition of Coinme Inc. on 14 October 2026, six days after Coinme reached a 2.5 million dollar multistate settlement with thirty-four state financial regulators over BSA/AML program deficiencies. Coinme, a Seattle-based cryptocurrency money transmitter and kiosk operator, holds an Ohio money-transmitter license, and Polygon's closing means it assumes both that license and Coinme's obligation to exit the cryptocurrency kiosk business nationwide by 1 January 2027 or pay a further 4 million dollars. Deal consideration was not publicly disclosed. The timing is the structurally interesting element here: an acquirer closed a deal on a licensed payments entity days after that entity settled a regulatory enforcement matter, inheriting the settlement's unresolved remediation obligations along with the license itself. #### Other Developments No other Ohio-specific commercial-intelligence events were located this cycle; the research window surfaced this single transaction as the material signal for the jurisdiction. #### Cross-Monitor Connections This transaction is also tracked from an AML/CFT-enforcement angle by the financial-integrity monitor, which covers the underlying Coinme settlement itself in fuller detail; this brief addresses only the commercial-intelligence and market-structure dimension of the acquisition. The crypto monitor separately tracks the licensing continuity implications of the same transaction for Coinme's Ohio Money Transmitter License status. #### Outlook The near-term marker is whether Polygon meets the 1 January 2027 deadline to exit Coinme's kiosk business, or elects to pay the additional 4 million dollar penalty instead; a further marker is whether Polygon's stated intent to repurpose the assumed license for stablecoin settlement and local-currency payouts materialises into disclosed product activity in Ohio. _5 earlier updates not shown here._ ###### Standing brief · as of 8 July 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Lead Signal Global Payments completed its $24.25 billion acquisition of Cincinnati-headquartered Worldpay from FIS and GTCR on 9 January 2026, simultaneously divesting its Issuer Solutions business to FIS. The transaction re-anchors Ohio as the corporate home of one of the world's largest merchant-acquiring platforms and converts Global Payments into a pure-play merchant solutions provider, with Worldpay's headquarters remaining in Cincinnati. Before the deal closed, Worldpay ranked among the world's largest non-bank merchant acquirers, reporting $4.9 billion in 2023 revenue, 8,500 employees, and roughly $2.2 trillion processed annually. That scale traces back to Worldpay's 2023 decision to site its global headquarters in Cincinnati, a platform now processing transactions across 146 countries and 135 currencies for more than a million merchants. The completed transaction is corroborated by Global Payments' own Form 8-K filing with the Securities and Exchange Commission, the highest evidentiary standing of any item in this cycle's Ohio baseline. #### Other Developments Ohio's payments perimeter continues to rest on the state Money Transmitter Act, ORC Chapter 1315, which requires any person receiving money for transmission from a person located in Ohio to hold a licence via NMLS regardless of where the licensee itself is based. A pending bill, HB116, passed the Ohio House 68-26 in June 2025 and would exempt crypto mining, staking, and exchange activity from that licensing requirement, but it remains stalled in the Senate and is not yet operative. On the safeguarding side, licensees must hold permissible investments at least equal to their aggregate outstandings, held on statutory trust for transmission customers and shielded from other creditors even where commingled. That protection sits alongside an active enforcement record: the Department of Financial Institutions required S&P Solutions, doing business as Bitcoin of America, to render its Ohio crypto-ATM kiosks inoperable under a settlement and consent order after finding unlicensed money-transmission activity. Ohio has no enacted stablecoin-issuer regime, and a separate bill, SB57, would direct state entities receiving cryptocurrency payments to convert them to Bitcoin for a state Bitcoin Reserve Fund, though its current legislative status beyond a committee referral could not be independently verified this cycle. Meanwhile the state's Board of Deposit has already selected a vendor allowing state agencies to accept Bitcoin for taxes and registration fees, with transactions under $200 exempted from state capital-gains-tax reporting. On the federal AML/CFT track that Sentinel.gi monitors, FinCEN issued a proposed rule on 7 April 2026 that would reform Bank Secrecy Act program requirements toward an effectiveness-based, risk-focused model built on four pillars: risk assessment, independent testing, a US-based compliance officer, and ongoing training, developed in consultation with the OCC, FDIC, NCUA and Federal Reserve. That comment period remains open and the rule is not yet final. Ohio depository institutions reach Fedwire, FedACH and FedNow through the Federal Reserve Bank of Cleveland, while the Department of Financial Institutions participates in the Multistate Money Services Businesses Licensing Agreement Program that coordinates licensing for money services businesses operating across five or more states. #### Cross-Monitor Connections Ohio's AML/CFT posture is sourced this cycle from the Sentinel.gi feed rather than original World Payments Monitor analysis; illicit-finance use of any payment instrument remains a cross-monitor reference point here, not a standalone WPM conclusion. Correspondent-banking access in Ohio is fundamentally a story of two tracks: bank-chartered institutions reach national settlement rails directly through the Cleveland Fed, while non-bank money transmitters depend instead on the state's multistate licensing coordination and on their own commercial banking relationships to move funds. #### Outlook Three items carry this baseline forward into the next cycle: Ohio Senate floor action on HB116, which would activate the MTL crypto carve-out if enacted; SB57's advancement beyond committee referral, which would signal how far the state intends to go in formalising a Bitcoin reserve; and the close of FinCEN's comment period on its April 2026 proposed rule, which will determine whether Ohio-licensed money transmitters and federally chartered banks face a genuinely reformed, effectiveness-based AML/CFT standard. None of these three items had resolved as of the research date, and each is flagged for continued tracking next cycle. trust tier: ai_unverified ###### Latest update · 18 October 2026 #### Regulatory Status Ohio's payments-relevant regulatory activity this cycle is concentrated in a single commercial event rather than a licensing or conduct-rule change: Polygon's acquisition of Coinme Inc., a Seattle-based cryptocurrency money transmitter and kiosk operator holding an Ohio money-transmitter license, closed on 14 October 2026. The closing came six days after Coinme's 2.5 million dollar multistate BSA/AML settlement, meaning Polygon assumes both the Ohio license and Coinme's obligation to exit the kiosk business nationwide by 1 January 2027 or pay a further 4 million dollars. No Ohio-specific money-transmitter-licensing rule change, safeguarding development, or scheme-compliance movement was identified for the jurisdiction this cycle. #### Outlook The 1 January 2027 kiosk-exit deadline, now a Polygon obligation attached to the Ohio-licensed entity, is the clearest dated marker for this jurisdiction going forward. _4 earlier updates not shown here._ ###### Standing brief · as of 8 July 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Regulatory Status Ohio's payments regulatory architecture rests almost entirely on a single state statute, the Money Transmitter Act (ORC Chapter 1315), which licenses non-bank money transmission, mandates permissible-investments trust safeguarding, and equips the Superintendent with cease-and-desist, suspension, and civil-penalty powers exercised against unlicensed crypto-ATM activity in the Bitcoin of America consent order. Two crypto-related bills, HB116 (Blockchain Basics Act) and SB57 (Bitcoin Reserve Fund), remain pending in the legislature and are treated as proposed rather than operative, since their current committee or floor status could not be independently re-verified this cycle, while the state's own Board of Deposit already accepts Bitcoin for taxes and fees through a selected vendor. Ohio's commercial-structure profile was reshaped this cycle by Global Payments' completed $24.25 billion acquisition of Cincinnati-headquartered Worldpay from FIS and GTCR, effective 9 January 2026, which converts Global Payments into a pure-play merchant solutions provider while keeping the jurisdiction's largest payments employer anchored in Cincinnati, alongside a Columbus-centred venture cluster led by Drive Capital. #### Outlook The jurisdiction's near-term regulatory trajectory hinges on three unresolved threads: whether the Ohio Senate advances HB116's crypto carve-out, whether SB57's Bitcoin Reserve Fund proposal moves beyond committee, and how the federal FinCEN AML/CFT reform proposal - which Ohio-licensed money transmitters and federally chartered banks would ultimately have to follow - resolves once its comment period closes; absent movement on any of these, Ohio's risk profile remains low-to-moderate and its regulatory direction stable. 14 of 14 modules Signal Density Selections OR within a group, AND across groups. Press / to search. ### W1a Licensing, Authorisation & Market Access Confirmed confirmed 2026-07-05 Ohio regulates money transmission under the state Money Transmitters Act (ORC Chapter 1315), administered by the Division of Financial Institutions (DFI) via NMLS. Licensure is required of any person receiving money for transmission from a person located in Ohio regardless of the licensee's own location, subject to bank/credit-union and other statutory exemptions. Minimum net worth of $500,000 and a security device (surety bond) of $300,000-$2,000,000 are standing capital/security requirements. HB 116 (Ohio Blockchain Basics Act) is in the General Assembly review stage and would exempt pure crypto mining/staking/exchange activity from MTL requirement. Standing sub-brief · as of 8 July 2026 183 words · last cycle 2026-10-11 #### Licensing, Authorisation & Market Access Ohio's sole payments licensing perimeter is the state Money Transmitter Act, ORC Chapter 1315, which requires any person receiving money for transmission from a person located in Ohio to hold a licence through NMLS, regardless of where the licensee itself is domiciled, subject to bank, credit-union, and other statutory exemptions. Licensees must also maintain a minimum net worth of $500,000 and a surety bond ranging from $300,000 to $2,000,000, calibrated at the Superintendent's discretion to reflect transaction volume. A pending bill, HB116 (the Blockchain Basics Act), passed the Ohio House 68-26 in June 2025 and would carve crypto mining, staking, and exchange activity out of the MTL requirement, but it remains stalled in the Senate; the carve-out is not yet operative and its current committee status was not independently re-verified this cycle. #### Outlook The determinative near-term event for this module is Ohio Senate floor action on HB116: enactment would activate the crypto carve-out and meaningfully narrow the MTL perimeter, while continued inaction preserves the current blanket licensing requirement for any crypto-asset activity that meets the statute's money-transmission definition. Periodic update · new data 2026-10-11 #### Licensing, Authorisation & Market Access Ohio's licensing position for digital-asset business is anchored, this cycle, by the continued operation of the general money-transmitter licence under Revised Code Chapter 1315. The 2023 Division of Financial Institutions consent order against Metallicus, Inc. confirmed that this general licensure test, under R.C. 1315.02(A), applies to virtual-currency exchange activity, establishing that no crypto-specific carve-out is needed for the existing licence to bind a virtual-currency business operating from, into, or through Ohio; the statute itself provides that it applies regardless of the location of the person, its facilities, or its agents. This standing architecture has not changed this cycle, and it remains the default market-access gateway for virtual-currency businesses absent further legislative action. That legislative action is in motion but not yet complete. House Bill 648, the ELDER Act, introduced February 5, 2026, would extend the general money-transmitter licence explicitly to digital-asset kiosk operators, deeming them engaged in money transmission under Chapter 1315 and adding kiosk-specific disclosure, transaction-hold, and senior-verification duties for customers aged 60 and above. The bill has been pending in the House Financial Institutions Committee since a third hearing on May 20, 2026, and its status as reported out of committee is unconfirmed as of this cycle. For a digital-asset kiosk operator assessing Ohio market access today, the practical position is that the general MTL licence already applies by extension of the existing statutory test, with HB 648 poised to make that application explicit and to layer additional kiosk-specific consumer-facing duties on top of it once and if enacted. #### Outlook Whether HB 648 is reported out of the House Financial Institutions Committee following its May 2026 hearing is the principal near-term market-access question for digital-asset kiosk operators in Ohio. Enactment would formalise kiosk-operator licensure under the existing MTL framework and add senior-protection controls; non-enactment leaves the current general-licensure test, as applied in the Metallicus precedent, as the operative standard. **3 earlier distinct update(s)** Periodic update · new data 2026-09-29 #### Licensing, Authorisation & Market Access Ohio's money-transmitter regime, administered by the Department of Commerce's Division of Financial Institutions under the state's general licensing statute, registered two developments this cycle. First, OwlTing Group (NASDAQ: OWLS), a payments company, obtained an Ohio money-transmitter licence, which per the company's own announcement extends its US multistate licensing coverage to 42 states. This is a routine addition to the licensee roster under the existing non-bank payment-institution licensing track rather than a change to the licensing framework itself. Second, and more structurally significant, is Ohio HB 648, sometimes referenced as the ELDER Act, which would require owners and operators of digital-asset kiosks to register as money transmitters under the same statutory framework, ORC Chapter 1315, coupled with mandatory risk and fee disclosures and new transaction limits specific to kiosk transactions. The bill had its first committee hearing on 18 March 2026 and remains pending, not yet enacted. If passed, it would extend Ohio's existing non-bank money-transmitter licensing perimeter to explicitly name a device-based channel -- digital-asset kiosks -- that is not separately named in the current statute, addressing a gap that has drawn legislative attention in connection with elder-fraud risk. Both developments sit within the non-bank payment-institution/EMI licensing track; neither touches bank-chartered payment activity in the state. #### Outlook HB 648's progression is the item to track for this module, with an expected further-development window in the first quarter of 2027 per the regulatory horizon record. Passage would mark the first Ohio instrument to name digital-asset kiosks specifically within the money-transmitter licensing and disclosure framework. Continued OMTA licensing activity among multistate payment companies, of the kind evidenced by OwlTing's addition, is expected to continue as a routine, non-material feature of the licensing environment absent further legislative change. Periodic update · new data 2026-09-08 #### Licensing, Authorisation & Market Access Ohio's baseline money-transmission licensing framework already covers crypto-adjacent activity: the Division of Financial Institutions' Money Transmitters Section regulates money transmitters doing business in Ohio, including businesses that buy or sell cryptocurrency. This is confirmed, established regulatory ground administered under the state's general money-transmitter licence category, and it sits within a much larger nonbank licensing apparatus, the Division administers twelve distinct consumer-finance licensing regimes and held over 28,000 licenses as of the most recent count, indicating that money transmission is one of several licensing lines the same regulator manages at scale. Applications for the Ohio money-transmitter licence are accepted exclusively through the Nationwide Multistate Licensing System, the shared multistate application channel used by most U.S. states, meaning entrants seeking Ohio authorization already interact with a familiar, standardized process rather than a bespoke state-specific portal. The cycle's substantive development is Ohio House Bill 648, which would extend a specific registration obligation to owners and operators of digital-asset kiosks, requiring them to register as money transmitters and to provide mandatory pre-transaction risk disclosures. The stated rationale is elder-fraud prevention, reflecting documented concern about the use of unattended crypto kiosks to defraud vulnerable consumers. The bill is currently pending in the House Financial Institutions Committee and has not been enacted. Because HB648 operates as an extension of the existing general money-transmitter licence category rather than the creation of a wholly new licence type, its effect, if enacted, would be to close a device-specific gap in the current perimeter rather than to restructure Ohio's money-transmission licensing regime as a whole. The distinction carries through the bank-versus-nonbank frame that structures this module: kiosk operators captured by HB648 would fall within the nonbank_pi_emi category already used for general money-transmitter licensees, with no separate bank-channel implication evidenced this cycle. #### Outlook HB648's progress through the House Financial Institutions Committee is the item to watch, with an estimated resolution window as far out as 2027 Q1 and a correspondingly wide, year-scale uncertainty band reflecting the bill's early legislative stage. Passage would formalize kiosk-specific money-transmitter registration as a distinct sub-category of Ohio's existing licensing perimeter; continued pendency would leave kiosk operators subject only to whatever general money-transmitter obligations already apply to them under current law. Periodic update · new data 2026-08-25 #### Licensing, Authorisation & Market Access Ohio's money-transmitter licensing regime already operates on a receipt-based extraterritorial trigger: any person receiving money for transmission from a person located in Ohio must be licensed under the Ohio Money Transmitters Act, regardless of where the transmitting entity itself is domiciled. This structural feature means the licensing perimeter already reaches non-bank payment institutions and e-money issuers transacting into Ohio from outside the state, not only Ohio-domiciled firms. Applicants face a five-thousand-dollar new-licence application fee and a twenty-five-hundred-dollar change-of-control application fee, and licensees are expected to register federally with FinCEN as money-services businesses and to screen counterparties against the OFAC Specially Designated Nationals list. This cycle's material development is Ohio House Bill 648, which would extend this same non-bank licensing perimeter to a category not currently captured by it: owners, operators, and facilitators of digital-asset kiosks. Under the proposal, kiosk operators would need money-transmitter licensure plus mandatory KYC, consumer disclosures, and elder-focused transaction-approval holds. The bill has not been enacted and remains before the House Financial Institutions Committee; its introduction follows the bankruptcy and cessation of operations of a nationwide crypto-ATM kiosk operator, which exposed the absence of a distinct licensed category for the kiosk channel under the existing statute. This extraterritorial trigger and the pending kiosk extension are both coded at an elevated impact level in this cycle's tracking, reflecting the potential breadth of firms brought within scope: the extraterritorial receipt-based rule already has broad application to any entity receiving Ohio-originated funds for transmission, and the kiosk extension would materially widen the population of digital-asset intermediaries subject to state licensure. The DFI's fee schedule and federal-registration expectations, by contrast, are tracked at a monitored rather than elevated level, reflecting their status as standing operational requirements rather than a new source of regulatory change this cycle. All of this activity sits within the non-bank PI/EMI segment specifically — bank-chartered payment providers' Ohio market access runs through separate banking-law channels untouched by this cycle's developments. #### Outlook HB648's expected resolution window is 2026 Q4, carrying a half-year uncertainty band, and its committee trajectory is not yet determinable from current sourcing. If enacted, kiosk operators would become the newest addition to Ohio's non-bank money-transmitter population, subject to the same fee schedule and federal MSB-registration and OFAC-screening expectations already borne by existing licensees. Market entrants and existing licensees operating adjacent digital-asset infrastructure in Ohio should treat the bill's committee progress as the clearest near-term signal of whether the state's licensing perimeter formally captures the kiosk channel. **Sources and findings (7)** 1. T1 [https://com.ohio.gov/divisions-and-programs/financial-institutions/money-transmitters/money-transmitters](https://com.ohio.gov/divisions-and-programs/financial-institutions/money-transmitters/money-transmitters) retrieved 2026-07-05 2. T1 [https://codes.ohio.gov/ohio-revised-code/chapter-1315](https://codes.ohio.gov/ohio-revised-code/chapter-1315) retrieved 2026-07-05 3. T3 [https://www.bondexchange.com/ohio-money-transmitter-bond-a-comprehensive-guide/](https://www.bondexchange.com/ohio-money-transmitter-bond-a-comprehensive-guide/) retrieved 2026-07-05 4. T1 [http://archives.legislature.state.oh.us/analysis.cfm?ID=126_HB_454](http://archives.legislature.state.oh.us/analysis.cfm?ID=126_HB_454) 5. T3 [https://cryptoslate.com/ohio-passes-blockchain-bill-allowing-200-tax-free-bitcoin-payments/](https://cryptoslate.com/ohio-passes-blockchain-bill-allowing-200-tax-free-bitcoin-payments/) retrieved 2026-07-05 6. T3 [https://www.chaincatcher.com/en/article/2169351](https://www.chaincatcher.com/en/article/2169351) retrieved 2026-07-05 7. T3 [https://moneytransmitterlaw.com/state-laws/ohio/](https://moneytransmitterlaw.com/state-laws/ohio/) retrieved 2026-07-05 ### W1b Conduct, Safeguarding & Promotions Confirmed confirmed 2026-07-05 Safeguarding of customer funds under the Ohio MTL regime rests on the permissible-investments/trust mechanism (ORC 1315.06) plus the security device (ORC 1315.07), with continuing licensee duties under ORC 1315.05. The Superintendent holds graduated enforcement powers (cease-and-desist, suspension/revocation, civil penalties) used against unlicensed or non-compliant conduct, as demonstrated by the 2022-23 Bitcoin of America consent order. Standing sub-brief · as of 8 July 2026 144 words · last cycle 2026-08-05 #### Conduct, Safeguarding & Financial Promotions Ohio's core customer-protection mechanism is the permissible-investments trust under ORC 1315.06: licensees must hold permissible investments at least equal to aggregate outstandings, and those assets are impressed with a statutory trust for transmission customers, shielded from other creditors even where commingled with the licensee's general funds. That statutory protection has an active enforcement backstop: the Department of Financial Institutions required S&P Solutions, doing business as Bitcoin of America, to render its Ohio crypto-ATM kiosks inoperable under a Settlement and Consent Order after finding unlicensed three-party money-transmission activity, with a civil penalty suspended pending compliance. #### Outlook Absent new legislation, Ohio's safeguarding regime will continue to rest on the trust mechanism rather than a segregation-and-audit model, and the Bitcoin of America precedent signals that DFI is prepared to use its administrative toolkit against unlicensed nonbank payment activity, including crypto-adjacent kiosk operators. Periodic update · new data 2026-08-11 #### Conduct, Safeguarding & Financial Promotions Ohio's money-transmission conduct framework tightened on the crypto-kiosk front this cycle. The Division of Financial Institutions' governing position, per Interpretive Guidance 2022-01 (effective August 31, 2022), treats cryptocurrencies as money or its equivalent, meaning crypto buy/sell businesses, including kiosks and bitcoin teller machines, generally require an Ohio money transmitter licence under the Ohio Money Transmitter Act. This licensing position is not new, but it is the direct predicate for House Bill 648, introduced in the 136th General Assembly, which would go further by requiring digital-asset kiosk owners and operators to comply explicitly with OMTA licensure and to make material-risk disclosures to consumers. The underlying OMTA scope itself is broad and extraterritorial in application: any person receiving money or its equivalent for transmission from someone located in Ohio must hold a money transmitter licence, regardless of where that person, its facilities, or its agents are physically located. Read together, the interpretive guidance and the pending bill point toward a state regulatory perimeter that already captures crypto-kiosk intermediation as a licensing matter and is moving toward codifying consumer-facing risk-disclosure obligations specific to that channel. #### Outlook House Bill 648 remains at the introduced-bill stage in the 136th General Assembly, with no confirmed passage timeline in the record this cycle. Its principal effect, if enacted, would be to convert the Division's existing interpretive position on crypto-kiosk licensure into express statutory licensure and disclosure requirements. Watch for committee movement on the bill alongside any further OMTA licensing actions affecting nonbank crypto intermediaries in the state. **Sources and findings (5)** 1. T1 [http://codes.ohio.gov/orc/1315.06v1](http://codes.ohio.gov/orc/1315.06v1) retrieved 2026-07-05 2. T1 [https://codes.ohio.gov/orc/1315.15](https://codes.ohio.gov/orc/1315.15) retrieved 2026-07-05 3. T1 [http://archives.legislature.state.oh.us/analysis.cfm?ID=126_HB_454](http://archives.legislature.state.oh.us/analysis.cfm?ID=126_HB_454) 4. T1 [https://dam.assets.ohio.gov/image/upload/com.ohio.gov/documents/fiin_Enf2023_SandP%20Solutions%20dba%20Bitcoin%20of%20America.pdf](https://dam.assets.ohio.gov/image/upload/com.ohio.gov/documents/fiin_Enf2023_SandP%20Solutions%20dba%20Bitcoin%20of%20America.pdf) retrieved 2026-07-05 5. T1 [https://law.justia.com/codes/ohio/2016/title-13/chapter-1315/](https://law.justia.com/codes/ohio/2016/title-13/chapter-1315/) retrieved 2026-07-05 ### W2 Stablecoins & Digital Money Probable confirmed 2026-07-05 Ohio has no bespoke stablecoin-issuer licensing regime; digital assets are addressed indirectly through money-transmitter interpretive guidance and a cluster of pending legislation (HB 116 Blockchain Basics Act; SB 57/HB 18 Bitcoin Reserve bills) that would carve out mining/staking/exchange activity from MTL scope and create a state Bitcoin reserve, alongside an operational state-payments initiative allowing Bitcoin for tax and fee payments via a third-party processor. Standing sub-brief · as of 8 July 2026 178 words · last cycle 2026-07-08 #### Stablecoins & Digital Money Ohio has no enacted stablecoin-issuer or virtual-currency licensing statute; the underlying MTL law does not define 'money' or 'payment instrument', and industry guidance simply assumes virtual currencies fall within MTL scope pending clarifying legislation such as HB116. A separate bill, SB57, would require state entities receiving cryptocurrency payments to convert them to Bitcoin and transfer the proceeds into a state Bitcoin Reserve Fund, with security and reporting standards to follow; the bill remains pending and its current committee or floor status could not be independently verified this cycle. Separately, Ohio's State Board of Deposit has already selected a vendor enabling state agencies to accept Bitcoin for tax and registration-fee payments, exempting transactions under $200 from state capital-gains-tax reporting - an operational payments initiative that sits outside any licensing regime. #### Outlook The determinative gap in this module is enacted legislation: if HB116 or SB57 advance and pass, Ohio would move from an ambiguous, guidance-based approach to virtual currency toward an explicit statutory framework, but until then the state's digital-money posture remains interpretive rather than codified. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T1 [https://www.legislature.ohio.gov/download?key=24536](https://www.legislature.ohio.gov/download?key=24536) retrieved 2026-07-05 2. T3 [https://cointelegraph.com/news/ohio-bill-tax-free-crypto-payments-passses-house](https://cointelegraph.com/news/ohio-bill-tax-free-crypto-payments-passses-house) retrieved 2026-07-05 3. T3 [https://coincentral.com/ohio-approves-bitcoin-payments-for-state-servicesohio/](https://coincentral.com/ohio-approves-bitcoin-payments-for-state-servicesohio/) retrieved 2026-07-05 4. T3 [https://moneytransmitterlaw.com/cryptocurrency-state-laws/ohio/](https://moneytransmitterlaw.com/cryptocurrency-state-laws/ohio/) retrieved 2026-07-05 5. T1 [https://dam.assets.ohio.gov/image/upload/com.ohio.gov/documents/fiin_Enf2023_SandP%20Solutions%20dba%20Bitcoin%20of%20America.pdf](https://dam.assets.ohio.gov/image/upload/com.ohio.gov/documents/fiin_Enf2023_SandP%20Solutions%20dba%20Bitcoin%20of%20America.pdf) retrieved 2026-07-05 ### W3 Operational Resilience & Critical Infra Probable confirmed 2026-07-05 Ohio has no bespoke state operational-resilience statute for payments; resilience obligations for MTL licensees flow through ORC 1315.081 (mandatory written reporting of specified events within 15 business days) and DFI examination powers, layered on top of the federal FFIEC/prudential-regulator operational-resilience framework applicable to bank-charter payment providers headquartered in Ohio. Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. [Open its jurisdiction pages on Dataprotection.gi →](https://dataprotection.gi/jurisdictions/) Standing sub-brief · as of 8 July 2026 97 words · last cycle 2026-07-08 #### Operational Resilience & Critical Infrastructure Ohio has no bespoke operational-resilience or critical-third-party-outsourcing statute for money transmitters; the closest analogues are ORC 1315.081, which requires licensees to file a written report with the Superintendent within 15 business days of specified events, and ORC 1315.12, which authorises the Superintendent or engaged examiners to inspect licensee records and affairs as often as considered necessary. #### Outlook Because examination cadence is discretionary rather than fixed by statute, resilience oversight for Ohio's nonbank money transmitters will likely continue to track federal FFIEC expectations for bank-charter-linked exposures rather than any bespoke state operational-resilience rulemaking. no periodic updates on record for this sub-brief ** Sources and findings (3)** 1. T1 [https://law.onecle.com/ohio/title-13/chapter-1315/index.html](https://law.onecle.com/ohio/title-13/chapter-1315/index.html) retrieved 2026-07-05 2. T1 [https://law.onecle.com/ohio/title-13/chapter-1315/index.html](https://law.onecle.com/ohio/title-13/chapter-1315/index.html) retrieved 2026-07-05 3. T1 [https://com.ohio.gov/divisions-and-programs/financial-institutions/money-transmitters/money-transmitters](https://com.ohio.gov/divisions-and-programs/financial-institutions/money-transmitters/money-transmitters) retrieved 2026-07-05 ### W4 Scheme & Network Compliance Probable confirmed 2026-07-05 Ohio imposes no state-level interchange or scheme-technical-standard regulation; card-network (Visa/Mastercard) surcharge caps and PCI DSS obligations apply to Ohio merchants as private scheme rules layered over a permissive state surcharging/convenience-fee framework, with debit-card surcharging separately barred nationwide by the federal Durbin Amendment. Standing sub-brief · as of 8 July 2026 155 words · last cycle 2026-07-08 #### Scheme & Network Compliance Ohio imposes no state-level cap on credit-card surcharging, but Visa's scheme rules cap surcharges at 3% - tighter than the federal 4% ceiling - with penalties ranging from $50,000 to $1,000,000 for violations, making the network rule the binding constraint for Ohio merchants. Debit-card surcharging is separately prohibited nationwide under the federal Durbin Amendment, a rule that applies in Ohio irrespective of any state-law position. For public-sector transactions, ORC 113.40 requires state elected officials and entities imposing a surcharge or convenience fee for financial-transaction-device payments to notify payers, specifying the exact charge in dollars and cents or as a percentage - a disclosure duty distinct from private merchant surcharging. #### Outlook With no state interchange-fee rulemaking on the horizon, the compliance stack for Ohio card-present merchants will remain layered: federal debit-surcharge prohibition, Visa/Mastercard scheme caps tighter than the federal credit ceiling, and public-sector-specific disclosure duties, rather than a unified state surcharge code. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T3 [https://www.getnickel.com/surcharge-laws/ohio](https://www.getnickel.com/surcharge-laws/ohio) retrieved 2026-07-05 2. T3 [https://merchantcostconsulting.com/lower-credit-card-processing-fees/ohio-surcharge-laws/](https://merchantcostconsulting.com/lower-credit-card-processing-fees/ohio-surcharge-laws/) retrieved 2026-07-05 3. T3 [https://www.getflexpoint.com/credit-card-surcharging-us-states/ohio](https://www.getflexpoint.com/credit-card-surcharging-us-states/ohio) retrieved 2026-07-05 4. T3 [https://www.wkyc.com/article/life/legally-speaking/surcharge-fees-convenience-fees-debit-card-credit-card-transactions-federal-law-ohio-law-legally-speaking/95-fcb0c6e1-ae31-4b19-8563-fca41aca029a](https://www.wkyc.com/article/life/legally-speaking/surcharge-fees-convenience-fees-debit-card-credit-card-transactions-federal-law-ohio-law-legally-speaking/95-fcb0c6e1-ae31-4b19-8563-fca41aca029a) retrieved 2026-07-05 5. T1 [https://codes.ohio.gov/ohio-revised-code/section-113.40](https://codes.ohio.gov/ohio-revised-code/section-113.40) retrieved 2026-07-05 ### W5 Payment Corridor Dynamics Probable confirmed 2026-07-05 Ohio is not a border/remittance-corridor jurisdiction in the traditional sense, but hosts the global corporate headquarters of Worldpay (now part of Global Payments), giving the state an outsized structural role in cross-border card-acquiring corridors spanning ~146 countries and 135 currencies, reinforced by direct international air connectivity (CVG-London) cited as a locational driver. Standing sub-brief · as of 8 July 2026 144 words · last cycle 2026-07-08 #### Payment Corridor Dynamics Ohio is not a traditional cross-border remittance corridor, but Cincinnati's status as Worldpay's global headquarters gives the state outsized structural weight in cross-border acquiring: the platform processes transactions across 146 countries and 135 currencies for more than one million merchants. That structural role sits atop the Federal Reserve Bank of Cleveland's role as the Fourth District's settlement gateway, providing Ohio depository institutions interbank settlement and instant-payments corridor access, including FedNow. Local reporting attributes part of the Cincinnati HQ decision to talent access and a direct CVG-London flight cited by Worldpay's incoming chief executive, though the route's launch date and the underlying statement's context were not independently verified this cycle. #### Outlook Worldpay's continued Cincinnati anchoring under new Global Payments ownership, combined with Cleveland Fed settlement access, keeps Ohio positioned as a structurally significant node in both cross-border acquiring and domestic instant-payments corridors. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T2 [https://www.jobsohio.com/newsroom/news-press/governor-dewine-lt-governor-husted-announce-worldpay-locating-corporate-headquarters-in-cincinnati](https://www.jobsohio.com/newsroom/news-press/governor-dewine-lt-governor-husted-announce-worldpay-locating-corporate-headquarters-in-cincinnati) retrieved 2026-07-05 2. T3 [https://www.wcpo.com/news/local-news/hamilton-county/cincinnati/worldpay-one-of-the-largest-payment-processors-in-the-world-making-cincinnati-its-global-headquarters](https://www.wcpo.com/news/local-news/hamilton-county/cincinnati/worldpay-one-of-the-largest-payment-processors-in-the-world-making-cincinnati-its-global-headquarters) retrieved 2026-07-05 3. T3 [https://www.zoominfo.com/c/worldpay-llc/346258911](https://www.zoominfo.com/c/worldpay-llc/346258911) retrieved 2026-07-05 4. T1 [https://www.clevelandfed.org/collections/speeches/2023/sp-20230712-update-on-the-federal-reserves-instant-payments-service](https://www.clevelandfed.org/collections/speeches/2023/sp-20230712-update-on-the-federal-reserves-instant-payments-service) retrieved 2026-07-05 ### W6 Industry Structure & Commercial Probable confirmed 2026-07-05 Ohio hosts the fifth-largest state financial-services sector in the US, anchored by Fortune 500 banks (Huntington, Fifth Third, KeyBank) and insurers (Nationwide, Progressive), a major JPMorgan Chase technology/operations presence, and - since the Worldpay HQ relocation and its January 2026 acquisition by Global Payments - one of the largest global non-bank merchant acquirers. Columbus/Cincinnati/Cleveland ('the three C's') form a growing fintech-venture cluster led by Drive Capital. Standing sub-brief · as of 8 July 2026 159 words · last cycle 2026-07-08 #### Industry Structure & Commercial Dynamics Ohio hosts the fifth-largest state financial-services sector in the United States, anchored by Huntington, Fifth Third, KeyBank, Nationwide, Progressive, and a major JPMorgan Chase operations presence. The dominant commercial event for this module is Global Payments' completed $24.25 billion acquisition of Cincinnati-headquartered Worldpay from FIS and GTCR on 9 January 2026, executed simultaneously with the divestiture of Global Payments' Issuer Solutions business to FIS - a restructuring that leaves Global Payments a pure-play merchant solutions provider while keeping Worldpay's headquarters in Cincinnati. That reshaping sits alongside a growing venture ecosystem: Drive Capital, the largest non-coastal US venture fund with $1.2 billion across five funds, anchors a Columbus-centred fintech and insurtech cluster distinct from the Worldpay-driven acquiring story. #### Outlook With the acquisition now closed, the near-term watch item shifts from deal completion to integration: how Global Payments consolidates Worldpay's Cincinnati operations, and whether the Columbus venture cluster produces a comparable landmark event in coming cycles. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T3 [https://fintech.cioreview.com/cxoinsight/banking-on-ohio-as-a-fintech-leader-nid-28630-cid-189.html](https://fintech.cioreview.com/cxoinsight/banking-on-ohio-as-a-fintech-leader-nid-28630-cid-189.html) retrieved 2026-07-05 2. T3 [https://en.wikipedia.org/wiki/Worldpay,_Inc.](https://en.wikipedia.org/wiki/Worldpay,_Inc.) retrieved 2026-07-05 3. T3 [https://columbusregion.com/content-hub-article/the-columbus-finance-hub-the-columbus-region/](https://columbusregion.com/content-hub-article/the-columbus-finance-hub-the-columbus-region/) retrieved 2026-07-05 4. T3 [https://www.ohiotechnews.com/how-ohio-is-winning-in-fintech-2024/](https://www.ohiotechnews.com/how-ohio-is-winning-in-fintech-2024/) retrieved 2026-07-05 ### W7 Legal & Litigation Confirmed confirmed 2026-07-05 Ohio's principal payments-adjacent legal enforcement instrument is the DFI's administrative enforcement toolkit (ORC 1315.15/.151/.152/.153) rather than court litigation; the clearest applied example is the 2022-23 consent order against an unlicensed cryptocurrency-kiosk operator. Consumer-facing UDAP litigation authority sits with the Ohio Attorney General's Consumer Protection Section under ORC 1345.02. Standing sub-brief · as of 8 July 2026 128 words · last cycle 2026-10-11 #### Legal & Litigation Ohio's principal payments enforcement instrument is administrative rather than judicial: under ORC 1315.15 and related sections, the Superintendent may issue cease-and-desist notices, suspend or revoke licences, and assess civil penalties, a toolkit applied directly in the Bitcoin of America consent order, with judicial review available through the Franklin County Court of Common Pleas. That administrative track sits alongside the Ohio Attorney General's Consumer Protection Section, which investigates and pursues unfair-and-deceptive-practices violations under ORC 1345.02, providing the litigation backbone for payments-adjacent consumer-harm claims even though its authority is general rather than payments-specific. #### Outlook No landmark court ruling reshaping Ohio's payments regime has emerged this cycle, so the practical enforcement risk for licensees remains concentrated in DFI's administrative process and AG-led UDAP actions rather than precedent-setting litigation. Periodic update · new data 2026-10-11 #### Legal & Litigation Ohio enacted a durable change to its commercial-law infrastructure for digital assets this cycle. House Bill 195 amended the Ohio Uniform Commercial Code to add Article 12, effective October 6, 2026, establishing controllable electronic records as a defined property classification for cryptocurrency, NFTs and similar digital assets. The instrument is modeled on the 2022 amendments to the UCC adopted by the Uniform Law Commission and the American Law Institute, and its core legal effect is to enable perfection of security interests in digital assets by control: a secured party that has control over a controllable electronic record can perfect its interest without the filing and possession mechanics that otherwise complicate digital-asset collateral. This is a structural legal-infrastructure development, independent of, and unaffected by, the separate licensing questions raised by House Bill 648's pending extension of money-transmitter registration to digital-asset kiosk operators. For payments and lending counterparties operating in Ohio, the practical consequence is that digital-asset collateral arrangements now have a settled commercial-law footing that did not previously exist at the state level. This matters for secured lending structures, custodial arrangements that rely on establishing control for perfection purposes, and dispute resolution involving competing claims to digital-asset collateral, since Article 12 now supplies Ohio courts with a defined statutory framework rather than requiring analogy to pre-digital commercial-law categories. #### Outlook No further legislative action on UCC Article 12 itself is indicated this cycle; the instrument is now in force as of October 6, 2026. The item to watch on the adjacent licensing track remains House Bill 648's status in the House Financial Institutions Committee, which would affect money-transmission licensing for kiosk operators but does not bear on the Article 12 commercial-law framework itself. **Sources and findings (4)** 1. T1 [https://dam.assets.ohio.gov/image/upload/com.ohio.gov/documents/fiin_Enf2023_SandP%20Solutions%20dba%20Bitcoin%20of%20America.pdf](https://dam.assets.ohio.gov/image/upload/com.ohio.gov/documents/fiin_Enf2023_SandP%20Solutions%20dba%20Bitcoin%20of%20America.pdf) retrieved 2026-07-05 2. T1 [https://codes.ohio.gov/orc/1315.15](https://codes.ohio.gov/orc/1315.15) retrieved 2026-07-05 3. T4 [https://www.kohlcook.com/how-does-the-state-attorney-general-aid-in-consumer-protection-laws/](https://www.kohlcook.com/how-does-the-state-attorney-general-aid-in-consumer-protection-laws/) retrieved 2026-07-05 4. T1 [https://www.ohioattorneygeneral.gov/consumerlaws](https://www.ohioattorneygeneral.gov/consumerlaws) retrieved 2026-07-05 ### W8 Merchant Acquiring & Risk Probable confirmed 2026-07-05 Ohio hosts one of the world's largest non-bank merchant acquirers (Worldpay, now part of Global Payments) headquartered in Cincinnati, while the state's own merchant-facing legal framework is permissive: credit-card surcharging is broadly allowed with minimal state-specific disclosure mandates, layered under card-network compliance requirements, and debit surcharging remains federally prohibited. Standing sub-brief · as of 8 July 2026 118 words · last cycle 2026-08-05 #### Merchant Acquiring & Risk Ohio hosts one of the world's largest non-bank merchant acquirers in Worldpay, which reported $4.9 billion in 2023 revenue, 8,500 employees, and roughly $2.2 trillion processed annually from its Cincinnati base, now under Global Payments ownership. State merchant law is permissive on surcharging, imposing minimal Ohio-specific disclosure mandates beyond card-network requirements such as the 30-day advance notice merchants must give card companies before surcharging, leaving scheme rules as the primary compliance layer. #### Outlook Under Global Payments' ownership, Ohio's acquiring franchise inherits both the scale and the risk profile of a top-tier global processor, meaning merchant-risk oversight will increasingly be shaped by the combined entity's enterprise-wide compliance posture rather than by any Ohio-specific acquiring rule. Periodic update · new data 2026-08-11 #### Merchant Acquiring & Risk The Ohio Casino Control Commission's draft amendment to Sports Gaming Rule 3775-16-03 would remove credit cards as a permitted funding method for deposit-enabled online sports-betting and iGaming accounts. The rule's public comment period closed on May 15, 2026, and it is now proceeding through public hearing, business-impact analysis, and Joint Committee on Agency Rule Review. Debit cards remain fully permitted, and wire transfers or other electronic payment methods are expected to remain available, so the restriction is confined to a single card-network funding rail rather than a broader tightening of merchant-acquiring arrangements for regulated sports-betting deposits. If JCARR raises no objection, the restriction could take effect by the end of summer 2026. From a merchant-acquiring perspective, the rule's effect is narrow but direct: it removes one card-based funding rail from a regulated deposit-taking flow, with the consumer-protection rationale, addressing bettors funding losses with borrowed money, driving a change that acquirers and payment facilitators serving Ohio-licensed sports-betting operators will need to accommodate on the funding-method side rather than the settlement side. #### Outlook The rule's progression through business-impact analysis and JCARR review is the marker to watch this cycle; a clean pass through JCARR would bring the restriction into force by the end of summer 2026 on the timeline currently in the record. No primary OCCC docket text for the rule was directly retrieved this cycle, so confirmation of the exact in-force date should be treated as provisional pending the formal filing. **Sources and findings (4)** 1. T3 [https://en.wikipedia.org/wiki/Worldpay,_Inc.](https://en.wikipedia.org/wiki/Worldpay,_Inc.) retrieved 2026-07-05 2. T3 [https://merchantcostconsulting.com/lower-credit-card-processing-fees/ohio-surcharge-laws/](https://merchantcostconsulting.com/lower-credit-card-processing-fees/ohio-surcharge-laws/) retrieved 2026-07-05 3. T4 [https://www.walterhav.com/transaction-fees-service-fees-and-the-ftcs-proposed-ban-on-junk-fees/](https://www.walterhav.com/transaction-fees-service-fees-and-the-ftcs-proposed-ban-on-junk-fees/) retrieved 2026-07-05 4. T1 [https://www.sec.gov/Archives/edgar/data/0000035527/000119312504186328/dex991.htm](https://www.sec.gov/Archives/edgar/data/0000035527/000119312504186328/dex991.htm) retrieved 2026-07-05 ### W9 Product Innovation & Market Development Probable confirmed 2026-07-05 Ohio product innovation activity centres on state-government crypto-payment acceptance (Bitcoin for taxes/fees via a state-selected processor), pending Blockchain Basics/Bitcoin Reserve legislation, and participation of Ohio-based/chartered institutions in the Federal Reserve's national FedNow instant-payments infrastructure, alongside Worldpay's product build-out (tap-to-pay, Solana-based platform) from its Ohio HQ. Standing sub-brief · as of 8 July 2026 162 words · last cycle 2026-07-08 #### Product Innovation & Market Development Nationally, the Federal Reserve's FedNow Service reached more than 1,400 participating banks and credit unions two years after launch, with growing use cases including instant payroll, auto-loan disbursement, wallet defunding, and request-for-payment, and Ohio depository institutions are eligible participants via the Cleveland Fed. At the state level, Ohio's State Board of Deposit selected its first vendor to process cryptocurrency payments for state taxes and fees, a government product-innovation initiative distinct from any licensing reform. On the private side, Worldpay's Ohio-headquartered product organisation has built out a Solana-based platform, a 'Know Your Agent' AI-verification framework, and an iPhone tap-to-pay feature supporting contactless cards and Apple Pay, though these product claims rest on a single secondary vendor-profile source not independently corroborated this cycle. #### Outlook Product-innovation signals in Ohio therefore split cleanly between a verified public-sector crypto-payments pilot, a well-documented national instant-payments infrastructure, and vendor-sourced claims about Worldpay's product roadmap that warrant independent confirmation before being treated as settled fact. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T3 [https://coincentral.com/ohio-approves-bitcoin-payments-for-state-servicesohio/](https://coincentral.com/ohio-approves-bitcoin-payments-for-state-servicesohio/) retrieved 2026-07-05 2. T1 [https://www.frbservices.org/news/fed360/issues/071625/fednow-service-two-years-growth-innovation](https://www.frbservices.org/news/fed360/issues/071625/fednow-service-two-years-growth-innovation) retrieved 2026-07-05 3. T3 [https://www.zoominfo.com/c/worldpay-llc/346258911](https://www.zoominfo.com/c/worldpay-llc/346258911) retrieved 2026-07-05 4. T3 [https://en.wikipedia.org/wiki/Worldpay,_Inc.](https://en.wikipedia.org/wiki/Worldpay,_Inc.) retrieved 2026-07-05 ### W10 Consumer Protection & APP Fraud Probable confirmed 2026-07-05 Consumer payments protection in Ohio rests on the general UDAP statute (ORC 1345.02) enforced by the Attorney General's Consumer Protection Section, plus fee-disclosure rules for government financial-transaction-device payments (ORC 113.40). The AG's office actively issues investment/cryptocurrency scam warnings, an APP-fraud-adjacent consumer-protection function, though Ohio has no dedicated APP-fraud reimbursement mandate comparable to the UK's. Standing sub-brief · as of 8 July 2026 122 words · last cycle 2026-07-08 #### Consumer Protection & APP Fraud Ohio has no dedicated authorised-push-payment fraud reimbursement mandate comparable to the UK's Payment Systems Regulator regime; the operative consumer-protection baseline is the general unfair-and-deceptive-acts-and-practices statute, ORC 1345.02, enforced by the Attorney General's Consumer Protection Section. That statutory baseline is supplemented by an active consumer-advocate function: the Attorney General's office regularly issues public warnings on investment and cryptocurrency scams and impostor payment-fraud schemes, an APP-fraud-adjacent protection role that nonetheless stops short of a formal reimbursement mandate. #### Outlook Absent new state legislation mirroring the UK's reimbursement model, Ohio consumers harmed by authorised-push-payment fraud will continue to rely on general UDAP remedies and AG advocacy rather than a sector-specific right of redress, a gap worth monitoring as instant-payments volumes grow. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T4 [https://www.kohlcook.com/how-does-the-state-attorney-general-aid-in-consumer-protection-laws/](https://www.kohlcook.com/how-does-the-state-attorney-general-aid-in-consumer-protection-laws/) retrieved 2026-07-05 2. T1 [https://www.ohioattorneygeneral.gov/consumeradvocate](https://www.ohioattorneygeneral.gov/consumeradvocate) retrieved 2026-07-05 3. T1 [https://codes.ohio.gov/ohio-revised-code/section-113.40](https://codes.ohio.gov/ohio-revised-code/section-113.40) retrieved 2026-07-05 4. T1 [https://www.ohioattorneygeneral.gov/about-ag/service-divisions/consumer-protection](https://www.ohioattorneygeneral.gov/about-ag/service-divisions/consumer-protection) retrieved 2026-07-05 ### W11 AML/CFT & Financial Crime (Sentinel.gi-fed) [Sourced from Sentinel.gi ↗](https://sentinel.gi/jurisdictions/united-states-ohio/#sec-dom-D7) Confirmed confirmed 2026-07-05 sentinel.Ohio money transmitter licensees operate under the federal BSA/AML framework administered by FinCEN (MSB registration, SAR filing, written AML/BSA/OFAC/PATRIOT Act policy required as part of MTL applications), overlaid on Ohio DFI licensing. FinCEN's April 2026 proposed rule would reform AML/CFT program requirements toward an effectiveness-based, risk-focused model, directly shaping the federal posture Ohio-licensed and federally chartered institutions must follow. Standing sub-brief · as of 8 July 2026 180 words · last cycle 2026-07-08 #### AML/CFT & Financial Crime (Sentinel.gi-fed) Per Sentinel.gi's feed, all money services businesses, including Ohio-licensed money transmitters, must register with FinCEN using Form 107 and implement a Bank-Secrecy-Act anti-money-laundering compliance programme to guard against money-laundering and terrorist-financing misuse; this baseline federal obligation sits atop, and is not re-analysed independently of, Ohio's own DFI licensing regime. Sentinel.gi flags that on 7 April 2026 FinCEN issued a Notice of Proposed Rulemaking reforming BSA AML/CFT programme requirements toward an effectiveness-based, risk-focused model built on four pillars - policies and risk assessment, independent testing, a US-based compliance officer, and ongoing training - prepared in consultation with the OCC, FDIC, NCUA, and the Federal Reserve; the comment period remains open and no final rule text exists yet. #### Outlook Sentinel.gi's tracker (WT1) flags this NPRM as escalating; the determinative event for the next cycle is the comment-period close and any resulting final rule text, which would reshape effectiveness-based AML/CFT expectations for Ohio's federally chartered banks and DFI-licensed money transmitters alike - a development this brief will continue to source from the Sentinel feed rather than analyse independently. no periodic updates on record for this sub-brief ** Sources and findings (6)** 1. T3 [https://moneytransmitterlaw.com/state-laws/ohio/](https://moneytransmitterlaw.com/state-laws/ohio/) retrieved 2026-07-05 2. T? FIM (sentinel.gi) per-JID baseline profile — United States — Ohio — Ohio has no state-level AML/BO regime distinct from federal BSA/CTA framework; state financial institutions and MSBs are supervised by the Ohio Division of Financial Institutions alongside federal regulators (FinCEN, OCC, Fed, FDIC). Federal 2025 CTA rollback exempted Ohio-formed LLCs from BOI reporting, widening opacity around the state's large small-business/shell-formation base. Active federal prosecutorial engagement (USAO-NDOH/SDOH) on crypto fraud forfeitures partly offsets state-level regulatory gaps, especially around unregulated crypto ATM kiosks. 3. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: sourcing-thinness 4. T3 FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-004) — Enforcement: DOJ Scam Center Strike Force / OFAC / State Department — Southeast Asian scam-compound financial networks (typology matching NDOH pig-butchering victims) 5. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: regulatory-failure 6. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: legal-gap ### W12 Correspondent Banking, Settlement & Access Confirmed confirmed 2026-07-05 Ohio depository institutions access national settlement infrastructure through the Federal Reserve Bank of Cleveland (Fourth District), including Fedwire, FedACH, and FedNow, while the DFI participates in the Multistate Money Services Businesses Licensing Agreement Program to streamline multi-state correspondent/agency relationships for licensed money transmitters. Standing sub-brief · as of 8 July 2026 131 words · last cycle 2026-07-08 #### Correspondent Banking, Settlement & Access The module's analytical spine is the asymmetry between bank and non-bank access to national settlement infrastructure: Ohio depository institutions reach Fedwire, FedACH, and FedNow directly through the Federal Reserve Bank of Cleveland, the Fourth District's settlement gateway. That settlement backbone sits alongside a coordination layer for non-bank licensees: Ohio's Department of Financial Institutions participates in the Multistate Money Services Businesses Licensing Agreement Program, which streamlines licence coordination for money services businesses operating across five or more states. #### Outlook As Global Payments' newly enlarged acquiring footprint layers atop this settlement structure, correspondent-access dynamics in Ohio will likely continue to bifurcate along the bank/non-bank line, with chartered institutions leaning on Federal Reserve rails and non-bank money transmitters continuing to depend on multistate licensing coordination and private banking relationships. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://www.clevelandfed.org/collections/speeches/2023/sp-20230712-update-on-the-federal-reserves-instant-payments-service](https://www.clevelandfed.org/collections/speeches/2023/sp-20230712-update-on-the-federal-reserves-instant-payments-service) retrieved 2026-07-05 2. T1 [https://www.federalreserve.gov/paymentsystems/fednow_about.htm](https://www.federalreserve.gov/paymentsystems/fednow_about.htm) retrieved 2026-07-05 3. T3 [https://jetsurety.com/ohio/money-transmitter-bond](https://jetsurety.com/ohio/money-transmitter-bond) retrieved 2026-07-05 4. T1 [https://www.frbservices.org/financial-services/fednow/organizations](https://www.frbservices.org/financial-services/fednow/organizations) retrieved 2026-07-05 ### W13 Commercial Intelligence (M&A, Investment & Product) limited signal Probable confirmed 2026-07-05 The dominant Ohio commercial-intelligence event in the trailing 12 months is Global Payments' completed $24.25 billion acquisition of Cincinnati-headquartered Worldpay from GTCR/FIS in January 2026, alongside continued Ohio venture-funding momentum in fintech/insurtech centred on Columbus. Standing sub-brief · as of 8 July 2026 136 words · last cycle 2026-10-18 #### Commercial Intelligence (M&A, Investment & Product) The lead commercial event this cycle is Global Payments' completed $24.25 billion acquisition of Cincinnati-headquartered Worldpay from FIS and GTCR, effective 9 January 2026, structured with a simultaneous divestiture of Global Payments' Issuer Solutions business to FIS; the deal's rationale, per the parties' own filing, is to transform Global Payments into a pure-play merchant solutions provider. In a separate episode, UnionPay International announced in November 2025 a ten-year partnership extension with Worldpay featuring UnionPay 3D Secure and ExpressPay solutions, with the deal's value not publicly disclosed. #### Outlook With the Worldpay acquisition now completed and the UnionPay extension running through the next decade, the near-term watch is whether Global Payments announces further Ohio-linked commercial activity - additional partnerships, product launches, or portfolio moves - building on its newly consolidated Cincinnati-anchored platform. Periodic update · new data 2026-10-18 #### Commercial Intelligence & Fintech The material commercial event for Ohio this cycle is Polygon's completed acquisition of Coinme Inc., closed 14 October 2026. Coinme is a Seattle-based cryptocurrency money transmitter and kiosk operator holding an Ohio money-transmitter license. The acquisition closed six days after Coinme reached a 2.5 million dollar settlement with thirty-four state financial regulatory agencies over BSA/AML program deficiencies, a settlement that requires Coinme to exit the cryptocurrency kiosk business nationwide by 1 January 2027 or pay an additional 4 million dollars. Deal consideration was not publicly disclosed in the sources reviewed. By closing after the settlement rather than before it, Polygon assumes not just the Ohio license but the unresolved remediation and exit obligations that attach to it, a structurally distinct position from acquiring a payments entity with a clean compliance record. No parties, amount, or further transaction terms beyond those noted were disclosed this cycle. #### Outlook Watch for whether Polygon meets the 1 January 2027 deadline to exit the kiosk business or instead pays the additional penalty, and whether it discloses how it intends to use the assumed Ohio license, reportedly including plans for stablecoin settlement and local-currency payout functionality for business customers. **2 earlier distinct update(s)** Periodic update · new data 2026-08-25 #### Commercial Intelligence & Fintech A nationwide crypto-ATM kiosk operator, Bitcoin Depot Inc., filed for bankruptcy and ceased operations this cycle, prompting the Ohio Division of Financial Institutions to issue a consumer alert to affected Ohio users. The amount of any affected customer funds was not publicly disclosed in the sourcing available this cycle. This is a discrete commercial event rather than a structural market-wide trend, and it sits upstream of this cycle's Licensing, Authorisation & Market Access signal: the same kiosk-operator failure is the commercial backdrop against which Ohio House Bill 648's proposed kiosk money-transmitter licensing extension is being considered by the legislature. #### Outlook Watch for whether other crypto-ATM kiosk operators active in Ohio disclose similar operational or financial distress, and for whether the Division of Financial Institutions issues further consumer alerts tied to the kiosk channel. The kiosk operator's failure is likely to remain a reference point as HB648 moves through committee, given its direct relevance to the policy case for extending money-transmitter licensure to kiosk operators. Periodic update · new data 2026-08-11 #### Commercial Intelligence & Fintech OwlTing Group (NASDAQ: OWLS) secured an Ohio money transmitter licence on June 3, 2026, extending its OwlPay subsidiary's United States coverage to 42 states. The development was reported via company press release; no independent Tier 1 confirmation of the specific Ohio licensure record was retrieved this cycle, so the finding is carried at Assessed confidence on a Tier 4 company-disclosure basis. The filing is a discrete commercial-licensing event rather than a structural market-entry trend, and it illustrates the OMTA licensing pathway continuing to serve as the entry mechanism for nonbank cross-border payments infrastructure expanding into large state economies. #### Outlook Watch for independent confirmation of OwlTing's Ohio licensure status via the Division of Financial Institutions' own licensee record, and for any further nonbank money-transmitter licensing filings in Ohio that would corroborate a broader pattern of cross-border payments-infrastructure expansion into the state. **Sources and findings (4)** 1. T3 [https://en.wikipedia.org/wiki/Worldpay,_Inc.](https://en.wikipedia.org/wiki/Worldpay,_Inc.) retrieved 2026-07-05 2. T3 [https://local12.com/news/local/cincinnati-large-company-acquired-24-billion-dollars-worldpay-acquisition-global-payments-symmes-township-fidelity-national-information-services](https://local12.com/news/local/cincinnati-large-company-acquired-24-billion-dollars-worldpay-acquisition-global-payments-symmes-township-fidelity-national-information-services) retrieved 2026-07-05 3. T3 [https://news.crunchbase.com/startups/ohio-venture-funding-startups-ai-supergiant/](https://news.crunchbase.com/startups/ohio-venture-funding-startups-ai-supergiant/) retrieved 2026-07-05 4. T3 [https://www.zoominfo.com/c/worldpay-llc/346258911](https://www.zoominfo.com/c/worldpay-llc/346258911) 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 – Ohio| 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` = `{}`. **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), 63 finding(s), 121 source(s) in the cumulative register. Think something on this page is wrong? [Report an error](https://payments.gi/legal/#contact).