title: United States – Washington Payments Regulation Monitor | World Payments Monitor canonical: https://payments.gi/jurisdictions/united-states-washington/ date_modified: 2026-10-21 publisher: Asymmetric Intelligence # United States – Washington US-WA schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-21 · 14 modules · 63 sourced findings · 138 sources in the cumulative register 14 Modules baseline.modules[] 63 Findings modules[].findings[] 111 Tier-1 sources run_metadata.t1_source_count Confidence mix (sums to 14 rendered modules; click to filter) ** United States federal law** that applies in United States – Washington is covered once, on the [United States](https://payments.gi/jurisdictions/united-states/) page. This page covers United States – Washington’s own layer: its own law, regulators and enforcement. ## Jurisdiction brief ###### Latest update · 18 October 2026 #### Lead Signal Washington State has established a new licensing regime for Earned Wage Access (EWA) providers, with the requirement taking effect 1 July 2026 under the Earned Wage Access Services Act (SSB 5328/HB 1063). The Department of Financial Institutions set an initial licensing fee of $1,500 and reports approximately 28 initial licensees under the new regime, marking the formal arrival of EWA as a DFI-supervised product category in Washington rather than an unregulated or ambiguously-regulated fintech niche. This is a structural market-access development: a product segment that previously operated without a dedicated state licensing framework now has one, with concrete fee and licensee-count figures attached. Separately, and on a different licensee segment, Washington DFI has entered a multi-state consent order with crypto-kiosk operator Coinme, Inc., requiring the firm to surrender its Washington money-transmission activity in that product line and cease crypto-kiosk operations by 1 January 2027. A parallel, still-pending Statement of Charges against Bitcoin Depot Operating LLC, entered 8 June 2026, indicates that DFI's supervisory attention to the crypto-kiosk money-transmitter segment is sustained rather than confined to a single enforcement episode. #### Other Developments **Coinme's forced exit becomes a commercial event.** Beyond its licensing implications, the Coinme settlement carries a distinct commercial dimension: the firm agreed to a $2.5 million multi-state settlement that requires winding down its crypto-kiosk product line nationwide by 1 January 2027. This is a regulatory-settlement-driven restructuring rather than a voluntary business decision, and it removes a recognised national crypto-kiosk brand from that product market within a defined, near-term window. **Bitcoin Depot matter remains open.** The parallel Statement of Charges against Bitcoin Depot Operating LLC, entered under the same Uniform Money Services Act framework that produced the Coinme order, has not yet been resolved. Its presence in DFI's enforcement register alongside the concluded Coinme matter signals continuing supervisory activity on the crypto-kiosk licensee class as a whole. #### Cross-Monitor Connections The Coinme enforcement action is a crypto-kiosk AML/BSA matter at its root, and the parallel Statement of Charges against Bitcoin Depot sits in the same enforcement register; readers tracking the illicit-finance dimension of these actions, including the alleged misappropriation of customer funds and BSA/AML program deficiencies underlying the Coinme settlement, should consult the financial-integrity monitor, where that AML-specific analysis is carried. The commercial-restructuring dimension of Coinme's forced wind-down is also tracked there as a commercial-activity finding; this brief's own treatment is confined to the market-access and commercial-intelligence lens appropriate to payments supervision. #### Outlook The Earned Wage Access licensing regime, now in its fourth month of operation as of this cycle, is the development most likely to generate further market-structure findings: whether the initial roughly 28 licensees grows, contracts, or consolidates under the new $1,500 fee structure will indicate how the EWA product category settles into Washington's regulated-market landscape. On the crypto-kiosk side, the operative date to watch is 1 January 2027, the deadline for Coinme's nationwide wind-down, alongside the still-unresolved Bitcoin Depot Statement of Charges, whose eventual disposition will clarify whether Washington's enforcement posture toward this licensee segment is converging on a standard settlement template. _5 earlier updates not shown here._ ###### Standing brief · as of 5 July 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Lead Signal Washington's Department of Financial Institutions closed two virtual-currency enforcement actions within a four-month window and co-led an $80 million multistate settlement this cycle. DFI issued a Temporary Order to Cease and Desist and a Statement of Charges against Coinme in November 2025 for allegedly claiming more than $8 million owed to consumers as income through a virtual-currency-kiosk voucher system. A Consent Order finalised 23 December 2025 required Coinme to cease the violations and segregate Washington customer assets in secure accounts. On 9 February 2026, DFI entered a further consent order against CoinZoom, Inc., barring the firm from the Washington industry for three years and imposing a $150,000 civil penalty, with $50,000 stayed to February 2029, plus a $4,170 investigation fee. Washington DFI also co-led an $80 million multistate Bank Secrecy Act and anti-money-laundering settlement against Block, Inc.'s Cash App, joining regulators from 47 states in total. The GENIUS Act, the federal payment-stablecoin statute, was enacted 18 July 2025 but remains in the rulemaking phase and is not yet operative, with an effective date set for the earlier of 18 January 2027 or 120 days after final implementing regulations. As of mid-2026 only proposed rules from the OCC, FDIC and FinCEN/OFAC have been issued, so the Act is not yet operative for issuers touching Washington. A widely circulated vendor claim attributing a Section 404 stablecoin-interest ban to Washington DFI is a misattribution, since Section 404 is in fact a provision of the pending, unenacted federal CLARITY Act rather than codified Washington law. #### Other Developments Washington regulates all non-bank money transmission, currency exchange and virtual-currency activity under one Money Transmitter/Currency Exchanger licence, with no separate EMI or PI category as found in EU and UK frameworks. Licensees must maintain tangible net worth scaled from $10,000 up to $3 million based on transmission volume, and a surety bond scaled from $10,000 up to a $550,000 ceiling. Each licensee must designate a US-based Responsible Individual accountable for compliance, transmit customer funds within ten business days of receipt, and honour refund requests within the same window under RCW 19.230.330. Seattle-headquartered Remitly operates a network spanning more than 5,100 corridors, and its fully digital transfers are exempt from the new 1% federal remittance excise tax that took effect 1 January 2026. Remitly launched a $9.99-per-month membership called Remitly One on 9 September 2025, and plans a Spring 2026 consumer line of credit delivered through bank partner Lead Bank under Visa U.S.A. licensing. Only a handful of state banks and credit unions, including O Bee, Numerica and Salal, bank most Washington cannabis retailers given marijuana's federal Schedule I status, while WAC 314-55-115 requires cannabis money-transmitter payments to be initiated within one business day of delivery and paid within five business days. A bill to ban interchange fees, SB 5070, has been dormant in committee since February 2025, and Washington has no state-specific mandatory reimbursement scheme for authorised-push-payment fraud comparable to the UK's PSR rules. DFI examines money transmitter licensees on an approximately six-to-twenty-four-month risk-based cycle and requires BSA-qualifying licensees to maintain an effective anti-money-laundering programme, while a dual state and federal charter system continues to govern Washington's depository sector alongside a dense, venture-backed Seattle fintech cluster. Seattle-based OpenCFO, founded by former CrowdStrike and Bloomberg engineers, raised $2 million in seed funding announced 16 March 2026 to automate accounts-payable, accounts-receivable, and treasury functions for mid-sized companies. #### Cross-Monitor Connections The $80 million Block/Cash App settlement and the illicit-finance rulemaking accompanying GENIUS Act implementation carry anti-money-laundering significance that sits outside this monitor's scope and is flagged to the Financial Intelligence Monitor; Washington's AML/CFT module here is seeded from a single Sentinel-pending item pending full feed integration. #### Outlook Three milestones sit on the horizon: the GENIUS Act becomes operative no later than 18 January 2027, Remitly's bank-partnered consumer line of credit is expected in the second quarter of 2026, and CoinZoom's three-year Washington industry bar together with its stayed penalty contingency runs to February 2029. Taken together, Washington's payments environment this cycle reads as one of active, enforcement-led tightening around virtual-currency activity, proceeding independently of the still-pending federal stablecoin rulemaking timeline. DFI also participates in the Multistate MSB Licensing Agreement via NMLS and requires Reg E-compliant error-resolution procedures from its money transmitter licensees. trust tier: ai_unverified ###### Latest update · 18 October 2026 #### Regulatory Status Washington State's payments regulatory landscape saw two distinct developments this cycle. First, the Earned Wage Access Services Act (SSB 5328/HB 1063) brought EWA providers under a DFI licensing requirement effective 1 July 2026, with an initial licensing fee of $1,500 and approximately 28 initial licensees, establishing a new regulated product category (W1a, W9). Second, DFI entered a multi-state consent order with crypto-kiosk operator Coinme, Inc. on 7-8 October 2026, requiring the firm to cease Washington crypto-kiosk operations by 1 January 2027 as part of a $2.5 million nationwide settlement that also forces a nationwide wind-down of that product line (W1a, W13). A parallel Statement of Charges against Bitcoin Depot Operating LLC, entered 8 June 2026 under the same Uniform Money Services Act, remains pending and unresolved in DFI's enforcement register, indicating sustained supervisory attention to the crypto-kiosk money-transmitter licensee segment generally. Taken together, Washington's DFI is simultaneously expanding its regulatory perimeter to cover a previously under-regulated product category (EWA) and tightening enforcement against an existing licensee class (crypto-kiosk money transmitters) under its established Uniform Money Services Act framework. Both threads run through the same supervisory authority and reflect an active, rather than passive, state-level payments regulator in this period. #### Outlook The EWA licensee count is the figure to watch for market-development purposes going forward, while 1 January 2027 is the key compliance deadline for Coinme's nationwide crypto-kiosk wind-down. The still-unresolved Bitcoin Depot Statement of Charges is the other open item; its eventual disposition will indicate whether DFI's enforcement approach to this licensee segment is converging toward a consistent settlement template. _3 earlier updates not shown here._ ###### Standing brief · as of 5 July 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Regulatory Status Washington's Uniform Money Services Act and implementing rules at WAC 208-690 have treated virtual-currency receipt-for-transmission as money transmission since 2017 amendments, with a narrow 2018 rule carve-out for virtual-currency storage lacking unilateral transmission ability. Washington merchants may surcharge credit-card transactions subject to card-network ceilings while debit surcharging remains prohibited nationwide, and the Department of Revenue has created a dedicated Payment Card Processing business-and-occupation tax classification with interchange deductions permitted. One tracker cites 475 Seattle fintech companies with $3.43 billion raised, while a separate vendor blog claims $4.1 billion across 180-plus 2025 rounds; neither figure is independently corroborated. DFI's cannabis financial-services directory lists Aeropay, CanPay, Dutchie and Vector Payments as meeting minimum standards while stating plainly that these providers are not themselves DFI-regulated entities, and a separate November 2025 consent order fined an unnamed mortgage broker $60,000 for advertising and disclosure failures. The broadly interpreted Washington Consumer Protection Act supplies the general backstop against unfair or deceptive payments and fintech conduct where no sector-specific rule applies. Remitly One's commercial launch, DFI's cannabis-depository directory naming Sound Community Bank, Timberland Bank and Twin City Bank, and the University of Washington's CoMotion fintech incubator with Curinos round out this cycle's product and market-structure texture, the last item resting on a single, uncorroborated source. #### Outlook Washington's near-term trajectory points toward continued tightening on virtual-currency supervision, pending Sentinel.gi's full integration into the AML/CFT module and the federal GENIUS Act's rulemaking conclusion by January 2027. Absent further Sentinel or DFI disclosures, Washington's core near-term watch items remain the GENIUS Act rulemaking, the pending Remitly credit-line launch, and the expiry horizons on the Coinme and CoinZoom enforcement actions. 14 of 14 modules Signal Density Selections OR within a group, AND across groups. Press / to search. ### W1a Licensing, Authorisation & Market Access moved Confirmed confirmed 2026-07-05 Washington licenses money transmitters (including virtual-currency transmitters) under the Uniform Money Services Act (RCW 19.230 / WAC 208-690), administered by DFI; a new Earned Wage Access Services Act licensing regime under DFI commenced July 1, 2026; DFI's multi-state Coinme consent order (Oct 7-8, 2026) and a parallel Bitcoin Depot Statement of Charges materially restrict crypto-kiosk licensee market access. Movement — CHANGED tightening_Coinme consent order and Bitcoin Depot charges restrict market access for crypto-kiosk licensees._ Standing sub-brief · as of 5 July 2026 208 words · last cycle 2026-10-18 #### Licensing, Authorisation & Market Access Washington regulates all non-bank money transmission, currency exchange and virtual-currency business activity under a single Money Transmitter/Currency Exchanger licence issued under RCW 19.230 and WAC 208-690, administered through NMLS — there is no separate EMI/PI licence category as found in EU/UK regimes. Licensees must scale tangible net worth to $10,000 per $1 million of company-wide transmission volume, with a floor of $10,000 and a ceiling of $3 million (rising to a $100,000 minimum where virtual-currency storage is offered), and must post a surety bond of $10,000 per $1 million of volume, capped at $550,000. The Department of Financial Institutions participates in the Multistate MSB Licensing Agreement via NMLS; authorized delegates must be physically located in Washington absent prior director approval, and licences are perpetual subject to annual assessment and attestation. #### Outlook This single-category architecture is the foundational fact governing US market access for Washington-domiciled and Washington-serving payment firms, applying uniformly whether an applicant is a traditional remittance business or a virtual-currency platform. No legislative move toward a bank/non-bank or EMI/PI-style split is evident this cycle; the structure should be read as durable rather than transitional, and any new entrant's licensing runway should be planned around NMLS/MMLA multistate timelines rather than a Washington-specific track. Periodic update · new data 2026-10-18 #### Licensing, Authorisation & Market Access Washington's Earned Wage Access Services Act (SSB 5328/HB 1063) brought EWA providers under a DFI licensing requirement as of 1 July 2026. The Department of Financial Institutions set an initial licensing fee of $1,500 and reports approximately 28 initial licensees, establishing EWA as a formally supervised product category under state money-services law rather than an unregulated fintech niche operating outside any dedicated licensing perimeter. This is a market-access development in the most direct sense: firms wishing to offer earned-wage-access products to Washington consumers must now hold a DFI licence to do so lawfully, where previously no such dedicated requirement existed. On a separate licensee segment, Washington DFI's multi-state consent order with Coinme, Inc., entered 7-8 October 2026, has a direct market-access consequence for that firm: the order requires Coinme to surrender or cease its crypto-kiosk money-transmission activity in Washington by 1 January 2027. This is a market-access restriction imposed through enforcement rather than a change in licensing policy, but its effect is the same in practice, removing a licensed operator's ability to continue offering a specific product in the state. The parallel Statement of Charges against Bitcoin Depot Operating LLC, entered 8 June 2026 under the same Uniform Money Services Act, remains open in DFI's enforcement register. Its continuing presence alongside the now-resolved Coinme matter indicates that DFI's market-access scrutiny of the crypto-kiosk licensee class is not limited to a single firm; a second major brand in the same product category faces unresolved charges under the same statutory framework. Taken together, these two threads describe a licensing environment that is simultaneously opening a new regulated channel (EWA) and tightening an existing one (crypto-kiosk money transmission). Both developments run through the same supervisory authority, DFI, and the same general statutory architecture of money-services licensing in the state, even though the specific instruments differ: EWA licensing is product-specific statute, while the crypto-kiosk actions proceed under the Uniform Money Services Act's existing money-transmitter licensing and enforcement powers. #### Outlook For EWA, the figure to watch is the licensee count: whether the initial approximately 28 licensees grows as more providers register under the new $1,500 fee structure, or whether some exit the market rather than absorb the compliance cost, will indicate how the regime beds in over its first full year. For crypto-kiosk money transmission, the key date remains 1 January 2027, Coinme's wind-down deadline, alongside the unresolved disposition of the Bitcoin Depot Statement of Charges, which will show whether DFI's enforcement approach to this licensee class is converging toward a consistent template or will vary materially case by case. **5 earlier distinct update(s)** Periodic update · new data 2026-10-11 #### Licensing, Authorisation & Market Access Washington's market-access framework for nonbank payment and money-services firms saw its most consequential enforcement event of the year with the Washington State Department of Financial Institutions leading a 34-regulator multi-state consent order against Coinme, Inc., a crypto-kiosk operator, entered 7-8 October 2026. The order, coordinated with money-transmission regulatory agencies across thirty-one other states, requires Coinme to cease all crypto-kiosk operations nationwide before 1 January 2027, undergo an independent BSA/AML compliance review, replace compliance-responsible managers, and pay a $2.5 million penalty distributed across the settling agencies. Coinme's crypto-kiosk business falls within Washington's licensing perimeter under the Uniform Money Services Act (RCW 19.230), which treats virtual currency as money or its equivalent, bringing exchange, custody and kiosk operation within the general money-transmission licence administered by DFI -- the same statutory perimeter that governs traditional money-transmission businesses, with no separate crypto-specific licensing code. This enforcement action should be read against the backdrop of DFI's broader, routine supervisory activity: the department's public enforcement list shows numerous 2026 consent orders and statements of charges spanning mortgage, consumer-loan, check-cashing and securities licensing categories, indicating that the Coinme matter sits within an active and ongoing state-level enforcement capacity rather than representing an isolated or exceptional intervention into the crypto sector specifically. Separately, and unrelated to the Coinme enforcement action, Washington's market-access architecture for nonbank payment products also includes the Earned Wage Access Services Act, a new chapter of RCW Title 31 created by SB 5328, which took effect 1 July 2026. EWA providers must now hold a DFI licence and maintain a minimum $30,000 surety bond, with employer-integrated EWA fees capped at $10 per month. The statute expressly excludes EWA products from classification as a loan, extension of credit, or money-transmission service, meaning EWA providers sit in a distinct DFI-licensed category rather than under the money-transmitter perimeter that captures crypto-kiosk businesses. This regime was already in force before this cycle and did not change during it; it is noted here as part of the state's layered nonbank-payment licensing structure. #### Outlook The nationwide crypto-kiosk shutdown deadline of 1 January 2027 is the key date for assessing market-access continuity for Coinme and for any other crypto-kiosk operator subject to similar multi-state coordinated scrutiny. Completion of the independent BSA/AML compliance review and the replacement of compliance-responsible managers, both required by the consent order, will be the practical indicators of whether DFI treats the existing RCW 19.230 licensing perimeter as adequate for crypto-kiosk business models going forward, or whether further rulemaking specific to crypto money-transmission activity follows. Periodic update · new data 2026-09-28 #### Licensing, Authorisation & Market Access Washington regulates money transmitters, including virtual-currency businesses, under the general Uniform Money Services Act (UMSA, RCW 19.230; implementing rule WAC 208-690), with no separate crypto-specific licensing track. This is a nonbank PI/EMI-style licensing framework administered by the Washington State Department of Financial Institutions, distinct from any bank-chartering pathway, and it now shows clear signs of active, escalating enforcement specifically against digital-asset operators within that nonbank category. A February 2026 consent order against an unnamed digital-assets-focused money transmitter required cease-and-desist from UMSA violations, licence surrender within 90 days, a civil penalty of $150,000 (of which $50,000 was stayed to 2029), a $4,170 investigation fee, and a three-year industry bar. This action is corroborated by law-firm syndication reporting on what is understood to be a primary DFI order, though the order text itself was not independently retrieved this cycle. A second, larger action followed in September 2026, when DFI filed a Statement of Charges against crypto-kiosk operator CoinFlip (GPD Holdings LLC) seeking licence cancellation, an industry bar, customer refunds, and a civil penalty of $1,029,600. The action cites elder-fraud exposure at cash-to-crypto kiosks as its basis, reported currently through trade-press coverage of a pending regulatory filing rather than a document independently retrieved this cycle. The licensing pathway for nonbank crypto money transmitters in Washington therefore remains open and functioning as a matter of statute, but the two actions taken within roughly seven months indicate materially elevated market-access risk for any nonbank PI/EMI-class operator judged non-compliant with UMSA's licensing conditions. The absence of a bespoke crypto statute means this risk sits entirely within the general money-transmitter licensing regime rather than a separately calibrated crypto framework. #### Outlook The disposition of the CoinFlip Statement of Charges, whether by settlement, contested hearing, or default, is the clearest near-term signal for how Washington intends to apply its licensing-enforcement authority against nonbank digital-asset money transmitters going forward, with direct implications for market-access conditions in this segment. Periodic update · new data 2026-09-08 #### Licensing, Authorisation & Market Access Washington's Department of Financial Institutions entered a $150,000 consent order against a digital-assets-focused money transmitter this cycle, requiring licence surrender within 90 days for violations of the Uniform Money Services Act spanning net-worth requirements, recordkeeping accuracy, and regulatory filing timeliness. This action confirms that DFI is willing to enforce the full UMSA licensing regime, including its net-worth and reporting provisions, against digital-asset-focused business models with the same rigor applied to traditional money transmitters. Corroborating this, virtual currency is expressly captured as 'equivalent value' for money-transmission licensing purposes under RCW 19.230, meaning that crypto exchange, custody, and money-transmission activity fall within Washington's existing Money Transmitter Licence regime rather than requiring, or benefiting from, a bespoke crypto licence. There is no exemption category currently available to crypto MSBs under this framework. The structural safeguarding backstop for this licensing regime is the surety-bond mechanism under RCW 19.230 and its implementing rule WAC 208-690: bond levels scale from a $10,000 minimum to a $550,000 maximum according to a licensee's prior-year money-transmission dollar volume, with mandatory annual updates by 1 July. This bond runs to the benefit of the state and of any person who suffers loss by reason of a licensee's violation, functioning as Washington's principal consumer-protection mechanism for nonbank payment institutions and electronic-money issuers operating without bank-grade prudential capital requirements. This is squarely a nonbank_pi_emi regime: bank-affiliated money transmission does not depend on this bond mechanism in the same structural way, and the bank-PSP versus nonbank-PI/EMI distinction is the analytical spine of how this licensing framework actually bites on different entity types. Taken together, this cycle's single enforcement action, combined with the confirmed regulatory scope-capture of virtual currency, evidences a tightening trajectory in Washington's licensing and market-access posture toward crypto-adjacent money-services businesses, achieved entirely through active enforcement of an existing general statute rather than through any new legislative instrument. #### Outlook Whether DFI's UMSA enforcement extends to further crypto MSBs in coming cycles will determine whether this reflects a durable tightening trajectory in market-access conditions for nonbank crypto payment institutions in Washington, or an isolated action. The identity of the money transmitter named in the February 2026 consent order was not disclosed in sources retrieved this cycle, which limits how precisely the affected segment of the licensed population can be characterised. Periodic update · new data 2026-08-26 #### Licensing, Authorisation & Market Access Washington's W1a domain recorded two developments this cycle moving in opposite directions. The Washington State Earned Wage Access Services Act establishes a new Department of Financial Institutions licence requirement for Earned Wage Access providers, effective July 1, 2026, with background-check and a minimum thirty-thousand-dollar surety-bond requirements attached. This licence sits under the nonbank_pi_emi classification, extending the state's existing bank-PSP versus non-bank-PI/EMI distinction to a product category not previously subject to a dedicated licensing regime. Separately, on February 9, 2026, the Department of Financial Institutions issued a $150,000 consent order and licence-surrender directive against a digital-assets-focused money transmitter for Uniform Money Services Act violations spanning net-worth, recordkeeping, and adverse-action reporting failures; that licensee is also classified under the nonbank_pi_emi distinction. The consent order rests on a single Tier-3 secondary source this cycle, with no independent Tier-1-or-higher corroboration located, a gap carried forward rather than resolved. This cycle's key judgment, assigned an elevated impact rating, reads the two developments together as evidence that Washington's non-bank payments licensing perimeter is simultaneously expanding, through the new Earned Wage Access category, and tightening, through active supervisory enforcement against an existing digital-asset money-transmission licensee. #### Outlook The Earned Wage Access licensing regime's July 1, 2026 effective date, tracked on the regulatory horizon within a quarter-band uncertainty window, is the principal near-term item to watch, alongside whether in-scope providers complete their background-check and surety-bond obligations ahead of that date. The digital-asset money transmitter's licence-surrender process should also be watched for completion, and a primary Washington DFI document corroborating this cycle's secondary reporting would strengthen the evidentiary basis of that finding in a future cycle. Periodic update · new data 2026-08-11 #### Licensing, Authorisation & Market Access Washington's Department of Financial Institutions treats crypto and virtual-currency businesses as fully within money-transmission licensing scope under the state's Uniform Money Services Act (RCW 19.230, WAC 208-690), not as a regulatory gray area, and this cycle produced two enforcement actions that operationalise that standing position. DFI's consent order against CoinZoom, Inc., effective February 9, 2026, requires the firm to cease its UMSA violations and surrender its Washington money-transmitter licence within ninety days, following an alleged tangible-net-worth deficiency. Separately, a Temporary Cease and Desist Order against Coinme, dated December 1, 2025, halts the firm's money-transmission activity and orders refund of more than eight million dollars in unredeemed Bitcoin-ATM voucher balances, alleging a tangible-net-worth failure spanning 2020 through 2025; this finding currently rests on a single Tier-4 source and has not yet attracted Tier-1 or Tier-2 corroboration this cycle. Both firms fall into the non-bank payment-institution and e-money-institution licensee category rather than the bank-affiliated payment-services channel, and neither could avail itself of an identified exemption pathway from full UMSA licensing once DFI determined a violation. The safeguarding basis in both matters rests on tangible-net-worth and bonding requirements under UMSA, an other-categorised safeguarding mechanism distinct from a codified customer-fund-segregation regime; the Coinme matter in particular alleges that unredeemed Bitcoin-ATM voucher balances were treated as company revenue rather than as customer funds requiring segregation, a safeguarding-architecture gap specific to the crypto cash-in and cash-out layer. Separately, Washington's money transmitters and currency exchangers, including crypto-focused licensees, faced a standing Online Annual Assessment Report filing deadline of July 1, 2026, with late filing risking licence suspension and late fees; this is a durable, standing-brief-tier compliance-calendar obligation rather than a crypto-specific development in itself. #### Outlook The items to watch next cycle are whether CoinZoom completes its ninety-day licence-surrender process on schedule, and whether the Coinme cease-and-desist matter attracts Tier-1 or Tier-2 corroboration beyond its current single Tier-4 source. Washington DFI's willingness to apply full UMSA net-worth, bonding, and safeguarding standards to crypto-focused non-bank money transmitters, evidenced by two enforcement actions within an eight-month window, signals continued tightening of state-level market-access conditions for this licensee category, independent of any federal-level digital-asset regulatory development. **Sources and findings (6)** 1. T1 [https://app.leg.wa.gov/rcw/default.aspx?Cite=19.230&full=true](https://app.leg.wa.gov/rcw/default.aspx?Cite=19.230&full=true) retrieved 2026-07-05 2. T1 [https://dfi.wa.gov/money-services/money-transmitter-and-currency-exchange-licensing](https://dfi.wa.gov/money-services/money-transmitter-and-currency-exchange-licensing) retrieved 2026-07-05 3. T1 [https://app.leg.wa.gov/Wac/default.aspx?cite=208-690-060](https://app.leg.wa.gov/Wac/default.aspx?cite=208-690-060) retrieved 2026-07-05 4. T1 [https://app.leg.wa.gov/wac/default.aspx?cite=208-690-040](https://app.leg.wa.gov/wac/default.aspx?cite=208-690-040) retrieved 2026-07-05 5. T2 [https://www.dwt.com/blogs/financial-services-law-advisor/2018/07/washington-state-updates-money-services-rules](https://www.dwt.com/blogs/financial-services-law-advisor/2018/07/washington-state-updates-money-services-rules) retrieved 2026-07-05 6. T1 [https://dfi.wa.gov/money-services/licensing-frequently-asked-questions](https://dfi.wa.gov/money-services/licensing-frequently-asked-questions) retrieved 2026-07-05 ### W1b Conduct, Safeguarding & Promotions Confirmed confirmed 2026-07-05 Washington's conduct regime centres on a named Responsible Individual per licensee, mandatory permissible-investment/safeguarding of customer funds, a statutory refund right, and federal Regulation E remittance-transfer disclosure obligations layered on top of the state licence. DFI enforces these conduct standards actively via examinations and administrative actions. Standing sub-brief · as of 5 July 2026 169 words · last cycle 2026-09-05 #### Conduct, Safeguarding & Financial Promotions Each Washington money transmitter licensee must designate a Responsible Individual — a US citizen or lawfully authorised worker employed as a W-2 employee — who is accountable for state and federal compliance under WAC 208-690-014(2). Licensees are further bound by a statutory duty to transmit customer funds within ten business days of receipt and to refund all monies within ten days of a written refund request under RCW 19.230.330; this operates alongside permissible-investment and segregation duties rather than through a discrete named safeguarding-fund mechanism. Layered atop the state regime, licensees must also satisfy federal Regulation E pre-payment disclosure, error-resolution and cancellation/refund obligations for remittance transfers. #### Outlook The conduct backbone here is a compliance stack rather than a single instrument: a named accountable individual, a hard statutory refund clock, and federal Reg E obligations operating concurrently. Firms should expect DFI examinations to test all three layers together, and the absence of a discrete safeguarding-fund label should not be read as an absence of segregation expectations. Periodic update · new data 2026-09-08 #### Conduct, Safeguarding & Financial Promotions A Temporary Cease and Desist Order issued by Washington's DFI against Coinme, a Bitcoin-ATM and kiosk operator, directs repayment of more than $8 million in customer voucher balances that were allegedly treated as company revenue rather than as safeguarded consumer funds. This is a conduct and safeguarding finding, distinct from the separate licensing-scope enforcement action tracked under W1a: the substantive issue here is how a nonbank payment institution characterised and held customer-facing balances within a kiosk-based cash-to-crypto model, not whether it held a valid licence. The safeguarding mechanism implicated is described in general terms as 'other' rather than a formal ring-fencing or trust-account arrangement, and the alleged misclassification of unredeemed voucher balances as revenue points to a gap in how customer funds were segregated from operational funds in this business model. Confidence on this specific finding is held at Probable, reflecting reliance on a single tier-4 aggregator source without independent primary-source corroboration this cycle; this should be read as a real, if not yet fully corroborated, conduct-supervision signal rather than a settled finding. The elevated-impact rating attached to this development reflects the scale of customer funds involved (over $8 million) relative to the safeguarding-conduct gap alleged, even though the confidence tier remains at Probable pending stronger sourcing. The broader safeguarding backstop available to Washington nonbank payment institutions generally, the RCW 19.230 surety-bond mechanism scaling from $10,000 to $550,000 by transaction volume, exists as a structural remedy of last resort for exactly this kind of consumer-funds shortfall, running to the benefit of any person who suffers loss from a licensee's violation. Whether that bond mechanism is sufficient to make whole the more than $8 million at issue in the Coinme matter is not established by evidence retrieved this cycle. #### Outlook Independent corroboration of the Coinme cease-and-desist order from a higher-tier source would materially strengthen confidence in this conduct-supervision finding. The broader question worth tracking is whether DFI's conduct-supervision attention to kiosk-based cash-to-crypto safeguarding practices extends beyond this single operator to the wider Washington-licensed Bitcoin-ATM sector. **Sources and findings (5)** 1. T1 [https://dfi.wa.gov/sites/default/files/documents/money-transmitters/summary-mt-regulation.pdf](https://dfi.wa.gov/sites/default/files/documents/money-transmitters/summary-mt-regulation.pdf) retrieved 2026-07-05 2. T1 [https://law.justia.com/codes/washington/title-19/chapter-19-230/section-19-230-330/](https://law.justia.com/codes/washington/title-19/chapter-19-230/section-19-230-330/) retrieved 2026-07-05 3. T1 [https://dfi.wa.gov/money-services/examinations](https://dfi.wa.gov/money-services/examinations) retrieved 2026-07-05 4. T1 [https://dfi.wa.gov/money-services/examinations](https://dfi.wa.gov/money-services/examinations) retrieved 2026-07-05 5. T2 [https://www.dwt.com/blogs/financial-services-law-advisor/2018/07/washington-state-updates-money-services-rules](https://www.dwt.com/blogs/financial-services-law-advisor/2018/07/washington-state-updates-money-services-rules) retrieved 2026-07-05 ### W2 Stablecoins & Digital Money Probable confirmed 2026-07-05 Washington treats virtual currency (including stablecoins) as money transmission under 2017 RCW 19.230 amendments, layering a state licensing/custody regime atop the federal GENIUS Act (enacted 18 Jul 2025 but NOT YET OPERATIVE pending final implementing regulations, expected no later than 18 Jan 2027). A vendor claim attributing a 'Section 404' stablecoin-interest ban to Washington DFI is a misattribution; Section 404 is a provision of the pending, unenacted federal CLARITY Act. DFI has taken high-profile enforcement action (Coinme, CoinZoom) against non-compliant virtual-currency MSBs. Horizon · 2027-01-18 (±year) GENIUS Act stablecoin framework becomes operative_in_force_pending · TT1_ Horizon · 2027-01-18 (±year) GENIUS Act stablecoin framework becomes operative_in_force_pending · TT1_ Standing sub-brief · as of 5 July 2026 241 words · last cycle 2026-07-05 #### Stablecoins & Digital Money Washington has treated virtual currency, including stablecoins, as money transmission since 2017 amendments to RCW 19.230 brought virtual-currency receipt-for-transmission within the statutory definition, with 2018 rule amendments exempting 'virtual currency storage' from licensing where the storer lacks unilateral transmission ability. The federal GENIUS Act was enacted on 18 July 2025 but remains not yet operative — its effective date is the earlier of eighteen months post-enactment (18 January 2027) or 120 days after final implementing regulations, and only proposed rules from the OCC, FDIC and FinCEN/OFAC have issued as of mid-2026. A vendor claim attributing a Washington-specific 'Section 404' stablecoin-interest ban to DFI is a misattribution: Section 404 is a provision of the pending, unenacted federal CLARITY Act, not codified Washington policy, and no primary DFI source corroborates related vendor claims of mandated staking opt-in or universal proof-of-reserves requirements. DFI's November 2025 enforcement action against Coinme, resolved via a 23 December 2025 Consent Order, required cessation of violations and segregation of Washington customer assets in secure accounts. #### Outlook The operative gap between GENIUS Act enactment and its actual effective date is the single most consequential fact for any Washington-touching stablecoin issuer to track through the remainder of 2026; treating the Act as currently binding materially overstates present obligations. The corrected record on 'Section 404' should also be carried forward: it is federal and pending, not Washington law, and should not be cited as a state compliance requirement. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T2 [https://cryptoslate.com/crypto-laws/washington-uniform-money-services-act-virtual-currency-regime/](https://cryptoslate.com/crypto-laws/washington-uniform-money-services-act-virtual-currency-regime/) retrieved 2026-07-05 2. T2 [https://www.dwt.com/blogs/financial-services-law-advisor/2018/07/washington-state-updates-money-services-rules](https://www.dwt.com/blogs/financial-services-law-advisor/2018/07/washington-state-updates-money-services-rules) retrieved 2026-07-05 3. T1 [https://www.federalregister.gov/documents/2026/03/02/2026-04089/implementing-the-guiding-and-establishing-national-innovation-for-us-stablecoins-act-for-the](https://www.federalregister.gov/documents/2026/03/02/2026-04089/implementing-the-guiding-and-establishing-national-innovation-for-us-stablecoins-act-for-the) retrieved 2026-07-05 4. T3 [https://www.bitget.com/academy/coinbase-restrictions-washington-state-2026-comprehensive-america-guide](https://www.bitget.com/academy/coinbase-restrictions-washington-state-2026-comprehensive-america-guide) retrieved 2026-07-05 5. T1 [https://dfi.wa.gov/news/press/washington-state-dfi-takes-action-against-coinme-halt-all-money-transfers-washington-due](https://dfi.wa.gov/news/press/washington-state-dfi-takes-action-against-coinme-halt-all-money-transfers-washington-due) retrieved 2026-07-05 ### W3 Operational Resilience & Critical Infrastructure Probable confirmed 2026-07-05 Operational resilience obligations for Washington money transmitters are embedded in WAC 208-690 rather than a standalone resilience statute: cybersecurity, business-continuity, recordkeeping and third-party/agent oversight duties are examination-enforced by DFI on a risk-based cycle. 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 5 July 2026 98 words · last cycle 2026-07-05 #### Operational Resilience & Critical Infrastructure WAC 208-690 imposes cybersecurity, business-continuity and five-year recordkeeping expectations — transaction logs, customer communications and audit trails — enforced through periodic DFI examination on a risk-based cycle of roughly six to twenty-four months, alongside a requirement that BSA-qualifying licensees maintain an effective anti-money-laundering program and records under 31 CFR Part 103. #### Outlook The risk-based examination cadence means resilience posture is tested unevenly across the licensee population; firms nearer the more frequent end of the six-to-twenty-four-month cycle should expect closer scrutiny of recordkeeping and continuity documentation, particularly where virtual-currency activity is also in scope. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T3 [https://www.innreg.com/blog/washington-money-transmitter-license-guide](https://www.innreg.com/blog/washington-money-transmitter-license-guide) retrieved 2026-07-05 2. T1 [https://dfi.wa.gov/money-services/examinations](https://dfi.wa.gov/money-services/examinations) retrieved 2026-07-05 3. T1 [https://dfi.wa.gov/money-services](https://dfi.wa.gov/money-services) retrieved 2026-07-05 4. T1 [https://dfi.wa.gov/sites/default/files/documents/money-transmitters/summary-mt-regulation.pdf](https://dfi.wa.gov/sites/default/files/documents/money-transmitters/summary-mt-regulation.pdf) retrieved 2026-07-05 ### W4 Scheme & Network Compliance Probable confirmed 2026-07-05 Washington imposes no state-specific cap on credit-card surcharging beyond the federal/card-network ceiling, but a state-level interchange-fee ban bill (SB 5070) has been actively debated in the legislature, and the state Department of Revenue has created a distinct B&O tax classification for payment-card processing/acquiring activity. Standing sub-brief · as of 5 July 2026 137 words · last cycle 2026-07-05 #### Scheme & Network Compliance Washington imposes no state-specific surcharge cap beyond federal and card-network rules: credit-card surcharging is legal subject to Visa, Mastercard, Amex and Discover ceilings, while debit-card surcharging remains illegal nationwide under the Durbin Amendment. SB 5070, which would ban interchange/swipe fees outright, has taken no action since a February 2025 executive-session slot and remains dormant in committee with no confirmed forward date. Separately, the Department of Revenue has created a dedicated Payment Card Processing B&O tax classification covering acquiring, processing, routing, issuing and network services, with interchange and network-fee deductions permitted. #### Outlook With SB 5070 dormant and no confirmed forward legislative date, Washington's scheme-compliance posture is best read as stable rather than reform-bound this cycle; the more immediate operative reality for card-processing entities is the new B&O tax classification rather than any interchange-ban prospect. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T3 [https://merchantcostconsulting.com/lower-credit-card-processing-fees/washington-surcharge-laws/](https://merchantcostconsulting.com/lower-credit-card-processing-fees/washington-surcharge-laws/) retrieved 2026-07-05 2. T3 [https://www.nbcrightnow.com/legislature/servers-in-washington-state-hoping-for-reprieve-from-credit-card-fees/article_fa5b9b46-d867-11ef-a91c-bfcf55753fb1.html](https://www.nbcrightnow.com/legislature/servers-in-washington-state-hoping-for-reprieve-from-credit-card-fees/article_fa5b9b46-d867-11ef-a91c-bfcf55753fb1.html) retrieved 2026-07-05 3. T1 [https://dor.wa.gov/forms-publications/publications-subject/special-notices/new-tax-rate-and-classification-payment-card-processing-activities](https://dor.wa.gov/forms-publications/publications-subject/special-notices/new-tax-rate-and-classification-payment-card-processing-activities) retrieved 2026-07-05 4. T2 [https://mrsc.org/explore-topics/finance/accounting/credit-card-acceptance](https://mrsc.org/explore-topics/finance/accounting/credit-card-acceptance) retrieved 2026-07-05 ### W5 Payment Corridor Dynamics Probable confirmed 2026-07-05 Washington (via Seattle-headquartered Remitly) is a globally significant node for US outbound remittance corridors, with the state's digital remittance leader benefiting from a federal carve-out on the new 2026 remittance excise tax for electronically funded transfers. Standing sub-brief · as of 5 July 2026 137 words · last cycle 2026-07-05 #### Payment Corridor Dynamics Seattle-headquartered Remitly Global, Inc. operates a global remittance network completing transfers across more than 5,100 corridors without local operations in each destination, per its own SEC 10-K disclosure. A 1% federal remittance excise tax took effect 1 January 2026 on cash-funded international transfers, but Remitly's fully digital, electronically-funded transfers are exempt under the law's carve-out. Illustrative corridor detail remains thin in this pass, limited chiefly to the founding US-Philippines corridor and an expanding US-Kenya mobile-money interoperability link via M-Pesa. #### Outlook The remittance-tax exemption for digital transfers is a structural advantage for Washington's largest homegrown remittance platform relative to cash-based competitors, and should be read as a durable feature of the post-1-January-2026 landscape rather than a transitional one. Emerging-market rail coverage for Washington-originated flows remains under-surveyed and is flagged as a gap for future cycles. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://ir.remitly.com/static-files/d82354f4-cfc3-453c-b3cd-a68f0e31a47c](https://ir.remitly.com/static-files/d82354f4-cfc3-453c-b3cd-a68f0e31a47c) retrieved 2026-07-05 2. T3 [https://www.fintechfutures.com/remittances/how-remitly-marries-remittances-with-financial-inclusion](https://www.fintechfutures.com/remittances/how-remitly-marries-remittances-with-financial-inclusion) retrieved 2026-07-05 3. T3 [https://www.remitly.com/blog/money-transfer/federal-remittance-tax-guide/](https://www.remitly.com/blog/money-transfer/federal-remittance-tax-guide/) retrieved 2026-07-05 4. T3 [https://moneytransfers.com/companies/remitly](https://moneytransfers.com/companies/remitly) retrieved 2026-07-05 ### W6 Industry Structure & Commercial Probable confirmed 2026-07-05 Washington's payments industry structure is bifurcated between DFI-supervised depository institutions (state-chartered banks and credit unions under a dual state/federal charter system) and a dense non-bank fintech/payments cluster headquartered in Seattle, anchored by Remitly, Coinbase-licensed activity, Block/Square, and a wider venture-backed B2B payments and banking-as-a-service scene. Standing sub-brief · as of 5 July 2026 117 words · last cycle 2026-10-04 #### Industry Structure & Commercial Dynamics Washington operates a genuine dual state/federal bank-charter system: DFI's Division of Banks supervises state-chartered commercial and savings banks and trust companies, while its Division of Credit Unions supervises state-chartered credit unions alongside NCUA federal oversight. Separately, Seattle's fintech cluster is described by one tracker as comprising 475 companies with $3.43 billion raised, and by another vendor source as having raised $4.1 billion across 180-plus rounds in 2025; neither figure is independently corroborated by a primary data provider. #### Outlook The dual-charter structure is a stable, long-standing feature unlikely to shift in the near term. The venture-funding figures for the Seattle fintech cluster should be treated as directional rather than precise pending independent corroboration. Periodic update · new data 2026-09-28 #### Industry Structure & Commercial Dynamics Washington's crypto-kiosk operator CoinFlip (GPD Holdings LLC) faces acute regulatory-capital and licence-continuity risk following the Washington State Department of Financial Institutions' September 2026 Statement of Charges, which seeks licence cancellation, an industry bar, customer refunds, and a civil penalty of $1,029,600. For a kiosk-model operator, licence cancellation in a single state represents a direct threat to that state's revenue base and, depending on the multi-state licensing footprint typical of such operators, could carry reputational spillover into other jurisdictions' licensing reviews. This sits alongside a separate February 2026 action against an unnamed digital-assets-focused money transmitter, which resulted in licence surrender within 90 days and a $150,000 penalty, illustrating that Washington's enforcement posture toward the nonbank digital-asset money-transmission segment has now produced two commercially consequential outcomes within roughly seven months. For the broader nonbank crypto-kiosk and money-transmission industry structure in Washington, this signals a tightening operating environment in which regulatory-capital exposure (potential penalties, licence-continuity costs, and remediation obligations such as customer refunds) is becoming a live commercial consideration, not merely a compliance-department concern. #### Outlook Whether CoinFlip's Statement of Charges results in settlement, a negotiated licence continuation, or full licence cancellation will be a significant marker for the commercial viability of the cash-to-crypto kiosk business model in Washington specifically, and may influence how other multi-state kiosk operators assess their regulatory-capital exposure in this state going forward. **Sources and findings (5)** 1. T1 [https://dfi.wa.gov/banks](https://dfi.wa.gov/banks) retrieved 2026-07-05 2. T1 [https://dfi.wa.gov/credit-unions/dual-charter](https://dfi.wa.gov/credit-unions/dual-charter) retrieved 2026-07-05 3. T3 [https://tracxn.com/d/explore/fintech-startups-in-seattle-united-states/hIA6ahe_JjGiPf2h9u82FtFyhb-EOobZ96Go0J4W2CQ](https://tracxn.com/d/explore/fintech-startups-in-seattle-united-states/hIA6ahe_JjGiPf2h9u82FtFyhb-EOobZ96Go0J4W2CQ) retrieved 2026-07-05 4. T3 [https://www.ellty.com/blog/seattle-fintech-investors](https://www.ellty.com/blog/seattle-fintech-investors) retrieved 2026-07-05 5. T4 [https://www.dnb.com/business-directory/company-profiles.amazon_payments_inc.d4807d8e003930eaa963fb06eedfbe76.html](https://www.dnb.com/business-directory/company-profiles.amazon_payments_inc.d4807d8e003930eaa963fb06eedfbe76.html) retrieved 2026-07-05 ### W7 Legal & Litigation Confirmed confirmed 2026-07-05 DFI has been an active enforcer against non-compliant money transmitters, with two major virtual-currency-kiosk/MSB enforcement actions resolved late 2025/early 2026 (Coinme, CoinZoom) and a January 2025 multistate $80m BSA/AML settlement with Block, Inc./Cash App co-led by Washington, alongside routine mortgage-sector consent orders. Horizon · 2029-02-09 (±quarter) CoinZoom 3-year WA industry ban / stayed penalty contingency expires_in_force · TT1_ Horizon · 2029-02-09 (±quarter) CoinZoom 3-year WA industry ban / stayed penalty contingency expires_in_force · TT1_ Standing sub-brief · as of 5 July 2026 201 words · last cycle 2026-07-05 #### Legal & Litigation Washington's Department of Financial Institutions closed two virtual-currency money-transmitter enforcement actions within a four-month window: a Temporary Order to Cease and Desist and 23 December 2025 Consent Order against Coinme over more than $8 million allegedly improperly claimed as income from consumers via a kiosk voucher system, and a 9 February 2026 consent order against CoinZoom, Inc. requiring surrender of its licence and a three-year industry bar with a $150,000 civil penalty, of which $50,000 is stayed to February 2029 contingent on compliance. DFI also co-led, alongside regulators in Arkansas, California, Florida, Maine, Massachusetts, Texas and 47 states in total, an $80 million multistate BSA/AML settlement against Block, Inc. over Cash App, with a nine-month compliance-reporting deadline and twelve months to remediate underlying findings. A separate 5 November 2025 consent order addressed Mortgage Broker Practices Act and Consumer Loan Act violations at a Washington mortgage broker, with a $60,000 civil penalty. #### Outlook Three enforcement actions concentrated in roughly a twelve-month window mark a distinct escalation in DFI's posture toward virtual-currency MSBs specifically, rather than routine baseline enforcement texture; expect continued scrutiny of the sector through the Block remediation window and the CoinZoom compliance-contingency period running to February 2029. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://dfi.wa.gov/news/press/washington-state-dfi-takes-action-against-coinme-halt-all-money-transfers-washington-due](https://dfi.wa.gov/news/press/washington-state-dfi-takes-action-against-coinme-halt-all-money-transfers-washington-due) retrieved 2026-07-05 2. T2 [https://natlawreview.com/article/washington-dfi-enters-consent-order-digital-assets-focused-money-transmitter](https://natlawreview.com/article/washington-dfi-enters-consent-order-digital-assets-focused-money-transmitter) retrieved 2026-07-05 3. T1 [https://www.einpresswire.com/article/777029125/washington-dfi-jointly-leads-80-million-multistate-enforcement-action-against-block-inc-cash-app](https://www.einpresswire.com/article/777029125/washington-dfi-jointly-leads-80-million-multistate-enforcement-action-against-block-inc-cash-app) retrieved 2026-07-05 4. T2 [https://www.consumerfinanceandfintechblog.com/2025/11/washington-dfi-finalizes-60000-consent-order-addressing-alleged-advertising-disclosure-and-reporting-failures/](https://www.consumerfinanceandfintechblog.com/2025/11/washington-dfi-finalizes-60000-consent-order-addressing-alleged-advertising-disclosure-and-reporting-failures/) retrieved 2026-07-05 ### W8 Merchant Acquiring & Risk Probable confirmed 2026-07-05 Merchant acquiring in Washington follows the standard US card-network model with DOR B&O tax carve-outs for acquirers/processors; the highest-risk merchant segment DFI actively tracks is cannabis retail, for which the state has codified specific settlement-timing rules for money-transmitter, card and check payment methods given federal banking access constraints. Standing sub-brief · as of 5 July 2026 112 words · last cycle 2026-07-05 #### Merchant Acquiring & Risk Cannabis-sector money-transmitter transactions are subject to codified settlement-timing rules under WAC 314-55-115, requiring initiation no later than the first business day following delivery and payment within five business days, with the transmitter licensed and in good standing with DFI. DFI's own cannabis-financial-services directory lists high-risk payment providers such as Aeropay, CanPay, Dutchie and Vector Payments that meet minimum DFI standards, while explicitly stating that these providers are not themselves DFI-regulated entities. #### Outlook The curated-but-unregulated status of the cannabis payment-provider directory is a structural feature worth tracking: DFI's endorsement is limited to minimum-standards screening, not full regulatory oversight, leaving a residual due-diligence burden on cannabis retailers selecting a provider. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://app.leg.wa.gov/wac/default.aspx?cite=314-55-115](https://app.leg.wa.gov/wac/default.aspx?cite=314-55-115) retrieved 2026-07-05 2. T1 [https://dfi.wa.gov/cannabis/financial-services](https://dfi.wa.gov/cannabis/financial-services) retrieved 2026-07-05 3. T1 [https://dor.wa.gov/forms-publications/publications-subject/special-notices/new-tax-rate-and-classification-payment-card-processing-activities](https://dor.wa.gov/forms-publications/publications-subject/special-notices/new-tax-rate-and-classification-payment-card-processing-activities) retrieved 2026-07-05 4. T3 [https://merchantcostconsulting.com/lower-credit-card-processing-fees/washington-surcharge-laws/](https://merchantcostconsulting.com/lower-credit-card-processing-fees/washington-surcharge-laws/) retrieved 2026-07-05 ### W9 Product Innovation & Market Development Probable confirmed 2026-07-05 Seattle-based Remitly is the state's flagship payments product innovator, having launched a subscription membership (Remitly One), a bank-partnered debit/wallet product, and a forthcoming consumer line of credit in 2025-2026; the University of Washington's CoMotion innovation arm has also stood up a dedicated fintech incubator. Horizon · 2026-Q2 (±quarter) Remitly consumer line-of-credit launch_proposed · TT1_ Standing sub-brief · as of 5 July 2026 134 words · last cycle 2026-10-18 #### Product Innovation & Market Development Remitly launched a $9.99-per-month 'Remitly One' membership on 9 September 2025, bundling its Flex, Wallet and Card offerings for US customers, and plans to add a consumer line of credit reported to a US credit bureau beginning spring 2026, with banking services and its debit card provided by partner Lead Bank under Visa U.S.A. licensing. The University of Washington's CoMotion innovation arm has also announced a fintech-incubator partnership with data-intelligence company Curinos, though this remains a single-source, uncorroborated report. #### Outlook Remitly's trajectory — membership subscription now, bank-partnered consumer credit in spring 2026 — is the clearest evidence in this cycle of a Washington-based nonbank money transmitter using a bank-partner model to expand beyond core remittance into adjacent consumer financial products, a pattern now typical of large US money-transmitter platforms. Periodic update · new data 2026-10-18 #### Product Innovation & Market Development The commencement of Washington's Earned Wage Access Services Act licensing requirement on 1 July 2026 is the principal product-innovation development in this cycle. Earned wage access, a product category that allows employees to access a portion of already-earned but not yet paid wages ahead of a standard payroll cycle, has operated in a regulatory grey zone in many US states for several years, with providers often structuring offerings to avoid classification as consumer lending. Washington's dedicated licensing statute resolves that ambiguity for the state by creating a specific regulatory home for the product under DFI supervision, with an initial licensing fee of $1,500 and approximately 28 providers registered under the new regime as of this cycle. The establishment of a dedicated licensing pathway, rather than folding EWA into an existing consumer-lending or money-transmitter framework, is itself a product-development signal: it indicates the state legislature and DFI judged EWA to be sufficiently distinct from both traditional short-term credit and traditional money transmission to warrant its own statutory category. For product teams building or scaling EWA offerings, Washington's approach now functions as one of a growing number of state-specific licensing regimes that must be navigated separately as EWA providers expand their market footprint across US states with increasingly divergent approaches to the product. The roughly 28 initial licensees gives an early indication of the size of the regulated EWA market in Washington specifically; whether that number represents close to full market coverage of EWA providers already operating in the state, or whether it reflects only the subset that moved quickly to register ahead of or at the 1 July 2026 effective date, is not resolved by the evidence available this cycle. A fuller picture of market compliance, including whether any unlicensed EWA activity continues to operate in the state despite the new requirement, would require further monitoring in subsequent cycles. #### Outlook The product-development question worth tracking is whether Washington's licensee count stabilises near its current level, grows as the product category expands, or produces consolidation among EWA providers unable to absorb the compliance cost of state-by-state licensing. More broadly, Washington's approach joins a wider pattern of state-level EWA regulation forming piecemeal across the US, and whether other states adopt a comparable dedicated-licensing model, rather than folding EWA into existing lending or money-transmission frameworks, remains an open product-development question beyond this jurisdiction alone. **Sources and findings (4)** 1. T3 [https://www.fintechfutures.com/remittances/how-remitly-marries-remittances-with-financial-inclusion](https://www.fintechfutures.com/remittances/how-remitly-marries-remittances-with-financial-inclusion) retrieved 2026-07-05 2. T1 [https://news.remitly.com/company-and-product-news/everything-we-announced-at-remitly-reimagine/](https://news.remitly.com/company-and-product-news/everything-we-announced-at-remitly-reimagine/) retrieved 2026-07-05 3. T3 [https://greater-seattle.com/startups/](https://greater-seattle.com/startups/) retrieved 2026-07-05 4. T1 [https://www.federalreserve.gov/econres/notes/feds-notes/stablecoins-in-2025-developments-and-financial-stability-implications-20260408.html](https://www.federalreserve.gov/econres/notes/feds-notes/stablecoins-in-2025-developments-and-financial-stability-implications-20260408.html) retrieved 2026-07-05 ### W10 Consumer Protection & APP Fraud Probable confirmed 2026-07-05 Consumer protection for Washington payments customers rests on the general Consumer Protection Act (RCW 19.86), the money-transmitter-specific refund right in RCW 19.230.330, and federal Regulation E remittance-transfer disclosure/error-resolution obligations; there is no Washington-specific mandatory APP-fraud reimbursement regime analogous to the UK's PSR rules. Standing sub-brief · as of 5 July 2026 102 words · last cycle 2026-07-05 #### Consumer Protection & APP Fraud Washington has no state-specific mandatory Authorised-Push-Payment fraud reimbursement scheme analogous to the UK Payment Systems Regulator's rules; consumer recourse instead rests on the broadly-interpreted Consumer Protection Act, the statutory money-transmitter refund right, and federal Regulation E error-resolution procedures. Licensees must maintain Reg E-compliant error-resolution policies and procedures, enforced via DFI examination. #### Outlook Absent a dedicated APP-fraud reimbursement regime, Washington consumers' practical recourse for push-payment fraud losses remains dependent on the general CPA standard and the money-transmitter refund right rather than a scheme-specific liability allocation; this gap is worth monitoring against any future federal or state reimbursement-mandate proposals. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T3 [https://www.stritmatter.com/washington-consumer-protection-act/](https://www.stritmatter.com/washington-consumer-protection-act/) retrieved 2026-07-05 2. T1 [https://www.atg.wa.gov/consumer-refunds](https://www.atg.wa.gov/consumer-refunds) retrieved 2026-07-05 3. T1 [https://dfi.wa.gov/money-services/examinations](https://dfi.wa.gov/money-services/examinations) retrieved 2026-07-05 4. T3 [https://news.bloomberglaw.com/banking-law/fintechs-cash-advances-for-workers-draw-suits-as-states-diverge](https://news.bloomberglaw.com/banking-law/fintechs-cash-advances-for-workers-draw-suits-as-states-diverge) retrieved 2026-07-05 ### W11 AML/CFT & Financial Crime (Sentinel.gi-fed) [Sourced from Sentinel.gi ↗](https://sentinel.gi/jurisdictions/united-states-washington-state/#sec-dom-D7) Probable confirmed 2026-07-05 This module is Sentinel.gi-fed per methodology and carries the Sentinel payments-context position rather than original illicit-finance analysis. Direct Sentinel.gi feed content was not accessible within this collection pass; the module is seeded with the one directly observable, DFI-sourced payments-context financial-crime enforcement item (the multistate Block/Cash App BSA/AML settlement) pending Sentinel feed integration. Standing sub-brief · as of 5 July 2026 126 words · last cycle 2026-07-05 #### AML/CFT & Financial Crime (Sentinel.gi-fed) This module is sourced from Sentinel.gi's financial-crime intelligence feed; per methodology, WPM does not perform original illicit-finance analysis here and instead attributes and links out to the underlying feed, seeded this cycle with the single directly-observable DFI payments-context item available pending full feed integration — the finding that state regulators assessed Block, Inc. as non-compliant with Bank Secrecy Act/anti-money-laundering customer due-diligence, suspicious-activity-reporting and high-risk-account control requirements, creating potential for its services to support money laundering or terrorism financing. #### Outlook Direct Sentinel.gi feed integration for Washington remains pending; this module should be read as a placeholder seeded from a single adjacent payments-context finding rather than a systematic illicit-finance survey, and readers seeking the underlying AML/CFT analysis should consult the Sentinel.gi feed directly. no periodic updates on record for this sub-brief ** Sources and findings (6)** 1. T1 sentinel.washington-dfi-block-bsa-aml-2025 2. T? FIM (sentinel.gi) per-JID baseline profile — United States — Washington State — Washington operates within the federal BSA/FinCEN AML/CFT/CPF architecture (US is a FATF member, not grey-listed). State-level oversight runs through the WA Department of Financial Institutions (DFI) under the Uniform Money Services Act (RCW 19.230), covering money transmitters and virtual-currency businesses. No WA-specific AML enforcement action or MER event was identified in the 18-month window; risk instead flows from federal-level deregulatory shifts (BOI/CTA narrowing, IRS crypto-examiner cuts, OCC preemption of state chartering authority) that dilute DFI's practical supervisory reach over the state's dense crypto-ATM/VASP and global tech-corporate population. 3. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: sourcing-thinness 4. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: regulatory-failure 5. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: capacity-deficit 6. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-004) — Gap: legal-gap ### W12 Correspondent Banking, Settlement & Access Probable confirmed 2026-07-05 Washington's correspondent-banking/settlement access story is dominated by cannabis-sector de-risking: only a small number of state-chartered banks and credit unions are willing to bank cannabis retailers given federal Schedule I status, with DFI maintaining an active list of compliant depository and non-depository providers. Standing sub-brief · as of 5 July 2026 143 words · last cycle 2026-07-05 #### Correspondent Banking, Settlement & Access Only a handful of Washington state banks and credit unions — including O Bee, Numerica, Sound Community Bank, Timberland Bank and Twin City Bank — handle most cannabis-related deposit accounts given marijuana's federal Schedule I status, illustrating a structural bank-versus-non-bank access asymmetry that pushes cannabis retailers toward money-transmitter and non-bank payment-provider workarounds; Remitly's own settlement access, by contrast, runs through bank partner Lead Bank under Visa U.S.A. licensing, the standard non-bank-PI-plus-bank-partner model. State officials have sought to preserve 2014 FinCEN guidance permitting regulated cannabis banking. #### Outlook The bank-versus-non-bank access asymmetry is this module's analytical spine: mainstream depository access remains concentrated in a small number of willing state banks and credit unions for cannabis, while nonbank PSPs like Remitly rely on a bank-partner settlement model for everyday operations — two structurally distinct correspondent-access problems that should not be conflated. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T3 [https://en.wikipedia.org/wiki/Cannabis_banking_in_Washington](https://en.wikipedia.org/wiki/Cannabis_banking_in_Washington) retrieved 2026-07-05 2. T1 [https://dfi.wa.gov/cannabis/financial-services](https://dfi.wa.gov/cannabis/financial-services) retrieved 2026-07-05 3. T1 [https://news.remitly.com/company-and-product-news/everything-we-announced-at-remitly-reimagine/](https://news.remitly.com/company-and-product-news/everything-we-announced-at-remitly-reimagine/) retrieved 2026-07-05 4. T3 [https://www.herringbank.com/business-banking/cannabis-banking/washington-state/](https://www.herringbank.com/business-banking/cannabis-banking/washington-state/) retrieved 2026-07-05 ### W13 Commercial Intelligence (M&A, Investment & Product) Probable confirmed 2026-07-05 Trailing-12-month commercial activity in Washington payments is led by Remitly's product/membership expansion (Remitly One, forthcoming line of credit) and continued early-stage fintech funding activity in the Seattle ecosystem, alongside a major multistate regulatory settlement affecting Block/Cash App. Standing sub-brief · as of 5 July 2026 189 words · last cycle 2026-10-18 #### Commercial Intelligence Remitly One, a $9.99-per-month membership bundling Flex, Wallet and Card offerings, became available to select US customers on 9 September 2025 with broader US availability by the end of 2025, an event classified as a completed product release rather than a structural market trend. Separately, Seattle-based OpenCFO — founded by former CrowdStrike and Bloomberg engineers — announced on 16 March 2026 that it had raised $2 million in seed funding to automate finance functions such as accounts-payable, accounts-receivable and treasury for mid-sized companies, connecting directly to banking and payment infrastructure. A broader market tracker separately reports 499 tracked Seattle fintech startups, of which 178 are funded (68 Series A or later, one unicorn), though this aggregate figure is not a discrete event and individual deal amounts within it are not disclosed. #### Outlook Both discrete events this cycle — the Remitly One product release and the OpenCFO seed round — are genuine commercial-intelligence items distinct from W6's structural market-cluster analysis and W9's product-access regulatory theme; expect continued small-scale seed activity in the Seattle fintech cluster alongside further product iteration from Remitly as its bank-partner credit line approaches launch. Periodic update · new data 2026-10-18 #### Commercial Intelligence & Fintech Coinme, Inc., a Seattle-headquartered money transmitter and crypto-kiosk operator, agreed to a $2.5 million multi-state regulatory settlement, entered 7-8 October 2026, that requires the firm to wind down its crypto-kiosk product line nationwide by 1 January 2027. This is a discrete, dated commercial event rather than a structural market trend: a specific firm, facing a specific enforcement action coordinated across 35 state regulators including Washington's DFI, has agreed to exit a specific product line entirely within a fixed window. The $2.5 million figure is disclosed as the combined penalty-and-cost package attached to the settlement; the commercial value of the crypto-kiosk business being wound down itself has not been separately disclosed and is not publicly available from the evidence reviewed this cycle. The settlement followed allegations, reported alongside the regulator's own account, that Coinme claimed more than $8 million owed to customers as its own income in violation of the Uniform Money Services Act. The commercial-intelligence dimension of this event is the forced exit itself: Coinme's agreement to shut down a nationwide product line, rather than merely pay a fine and continue operating, represents a substantial contraction of the firm's business rather than an incremental compliance cost. This is a regulatory-driven restructuring event, distinct from a voluntary M&A transaction, investment round, or product launch; it is nonetheless a discrete commercial development warranting its own entry rather than treatment as part of a broader structural market-dynamics narrative, since it concerns one named firm's specific, dated commercial outcome rather than an industry-wide trend. #### Outlook The commercial development to track is whether Coinme completes the nationwide wind-down by the 1 January 2027 deadline, and whether the firm retains any residual Washington money-transmitter licensing footprint for lines of business outside the crypto-kiosk product. A comparable commercial event involving Bitcoin Depot Operating LLC, whose Statement of Charges under the same statute remains unresolved, would be a second discrete item to watch should it produce a settlement with similar terms. **Sources and findings (4)** 1. T1 [https://news.remitly.com/company-and-product-news/everything-we-announced-at-remitly-reimagine/](https://news.remitly.com/company-and-product-news/everything-we-announced-at-remitly-reimagine/) retrieved 2026-07-05 2. T3 [https://www.geekwire.com/2026/former-crowdstrike-and-bloomberg-engineers-raise-2m-for-seattle-fintech-startup-opencfo/](https://www.geekwire.com/2026/former-crowdstrike-and-bloomberg-engineers-raise-2m-for-seattle-fintech-startup-opencfo/) retrieved 2026-07-05 3. T1 [https://www.einpresswire.com/article/777029125/washington-dfi-jointly-leads-80-million-multistate-enforcement-action-against-block-inc-cash-app](https://www.einpresswire.com/article/777029125/washington-dfi-jointly-leads-80-million-multistate-enforcement-action-against-block-inc-cash-app) retrieved 2026-07-05 4. T3 [https://tracxn.com/d/explore/fintech-startups-in-seattle-united-states/hIA6ahe_JjGiPf2h9u82FtFyhb-EOobZ96Go0J4W2CQ/companies](https://tracxn.com/d/explore/fintech-startups-in-seattle-united-states/hIA6ahe_JjGiPf2h9u82FtFyhb-EOobZ96Go0J4W2CQ/companies) 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 – Washington| 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. 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