title: United States – Wisconsin Payments Regulation Monitor | World Payments Monitor canonical: https://payments.gi/jurisdictions/united-states-wisconsin/ date_modified: 2026-10-21 publisher: Asymmetric Intelligence # United States – Wisconsin US-WI schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-21 · 14 modules · 65 sourced findings · 139 sources in the cumulative register 14 Modules baseline.modules[] 65 Findings modules[].findings[] 41 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 – Wisconsin is covered once, on the [United States](https://payments.gi/jurisdictions/united-states/) page. This page covers United States – Wisconsin’s own layer: its own law, regulators and enforcement. ## Jurisdiction brief ###### Latest update · 11 October 2026 #### Lead Signal Wisconsin enacted a kiosk-specific sub-regime within its existing money-transmission licensing framework this cycle, through 2025 Wisconsin Act 226 and the resulting Wis. Stat. 217.12. The statute requires any person operating a virtual currency kiosk in the state to hold a Chapter 217 money-transmitter licence, and it layers kiosk-specific identity-verification duties on top of that licensing requirement: operators must verify customer identity before an initial transaction and re-verify with a photograph on each subsequent transaction. The Wisconsin Department of Financial Institutions has stated it cannot issue company-specific safe-harbor or no-action letters on whether a given crypto business's activities require licensure, leaving operators to assess their own exposure against the statutory text without individualised pre-clearance. #### Other Developments **A daily transaction cap and a consumer fraud-refund mechanism were introduced alongside the licensing requirement.** Secondary legal commentary places the new daily kiosk transaction limit at $1,000 in fiat per customer; this figure has not been independently confirmed against the statutory text this cycle and should be treated with that caveat. The statute also requires operators to affix a printed fraud warning and display it electronically before any other disclosure, with the customer required to affirmatively acknowledge the warning before a transaction proceeds, and it grants a full refund, including fees, to a customer who reports fraud to both the operator and a law-enforcement or government agency within thirty days of the transaction. #### Cross-Monitor Connections The kiosk-specific identity-verification and transaction-cap provisions function simultaneously as consumer-protection and financial-crime controls, since the same pre-transaction identity check that limits fraud exposure for an individual customer also narrows the window for illicit use of a cash-to-crypto conversion channel. This dual effect places Wisconsin's new statute at the intersection of payments conduct regulation and financial-integrity-adjacent control design, even though this brief addresses only the payments and consumer-protection reading of the same underlying provisions. #### Outlook The principal item to watch is whether the Wisconsin Department of Financial Institutions issues supervisory guidance implementing the Act 226 kiosk provisions in operative detail; none had been identified as of this cycle, and such guidance would move the compliance picture from statutory text to a defined supervisory standard. Confirmation of the $1,000 daily transaction-cap figure against primary statutory text, rather than secondary law-firm commentary, would also strengthen the evidentiary basis of this finding. _4 earlier updates not shown here._ ###### Standing brief · as of 6 August 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Lead Signal Wisconsin Assembly Bill 471, introduced 2025-09-29 by Rep. Neylon and eight cosponsors, would exempt node operation, crypto-to-crypto exchange with no fiat conversion, blockchain software development, and mining or staking from money-transmitter licensing under Chapter 217, and would bar state or local restriction of self-hosted wallets and crypto payment acceptance. Wisconsin currently regulates money transmission under Chapter 217, the Model Money Transmission Modernization Law, administered by the Department of Financial Institutions. The bill has been referred to the Assembly Committee on Financial Institutions, and as of the most recent reporting it remains pending with no confirmed floor vote or enactment. Wisconsin law does not currently define money to include virtual currencies, leaving self-custody of cryptocurrency in a regulatory gray zone as to DFI licensure, which is the gap AB471 is designed to close. If enacted, the bill would materially narrow the state's money-transmission licensing perimeter for digital-asset activity, aligning Wisconsin with a growing majority of states that already exempt node operation, non-fiat crypto exchange, and mining or staking from money-transmitter requirements. #### Other Developments At the federal level, the GENIUS Act, Public Law 119-27, was signed July 18 2025 and classifies payment stablecoins as digital money restricted to Permitted Payment Stablecoin Issuers, applying nationally including to Wisconsin-serving issuers. Final implementing rules are targeted for July 18 2026, with enforcement beginning January 2027. A US Treasury notice of proposed rulemaking dated April 14 2026 addresses how state-chartered stablecoin issuers fit within the federal GENIUS Act framework, a matter that directly implicates the state-federal licensing interface relevant to Wisconsin-chartered or -licensed entities. Wisconsin-serving payment-stablecoin issuers therefore face a layered compliance stack once GENIUS Act enforcement begins in January 2027, combining new federal bank-style reserve and audit obligations with any pre-existing state money-transmitter licensing. Separately, Wisconsin's money-transmitter surety-bond schedule requires $10,000 for a first licensed location plus $5,000 for each additional location, capped at $300,000, administered by DFI, though this figure was not cross-checked against DFI's fee schedule this cycle. #### Cross-Monitor Connections The Financial Integrity Monitor flags that GENIUS Act-related April 2026 rulemakings add FinCEN and OFAC illicit-finance secondary-market monitoring duties for stablecoin issuers, a distinction this monitor notes without adopting: illicit-finance analysis of stablecoin usage belongs to FIM, not to this monitor's regulatory-perimeter tracking. #### Outlook The near-term watch list centers on whether AB471 advances to a committee vote or reaches enactment, whether the GENIUS Act's final implementing rules are issued on schedule by July 18 2026, and whether enforcement begins as planned in January 2027. Both threads will determine whether Wisconsin's digital-asset payments perimeter narrows through state legislative action, tightens through federal stablecoin regulation, or moves on both fronts simultaneously. Coverage this cycle did not extend to AB471's committee status after September 30, 2025, Wisconsin merchant-acquiring or high-risk-MCC activity, or Sentinel-fed AML/CFT items for Wisconsin, each of which remains an open item for the next research pass. trust tier: ai_unverified ###### Latest update · 8 September 2026 #### Regulatory Status Wisconsin's payments regulatory framework rests on the confirmed, tier-one Chapter 217 money-transmitter licensing regime, administered by the Department of Financial Institutions via the Nationwide Multistate Licensing System, which governs crypto exchange and custody businesses in the absence of any bespoke digital-asset licence. This cycle adds two material developments on top of that stable baseline: a confirmed 2026 crypto-kiosk consumer-protection statute imposing 1,000 dollar daily transaction limits, mandatory fraud warnings, identity checks, fee caps, and a 30-day victim-reimbursement obligation on the state's more than 700 bitcoin ATMs; and a confirmed, critical-impact federal preemption suit, CFTC v. Wisconsin, filed 28 April 2026, in which the CFTC seeks to block Wisconsin's own gambling-law suits against five prediction-market platforms and assert exclusive federal derivatives jurisdiction over these products. Together these developments show a state regulatory environment tightening its consumer-facing product rules even as its authority over an adjacent product category, prediction markets, is being actively contested by a federal regulator. The overall regulatory direction this cycle is tightening, and Wisconsin's risk level is assessed as elevated given the live, unresolved federal litigation. #### Outlook The CFTC v. Wisconsin ruling and the practical enforcement record under the new kiosk statute are the two items most likely to move Wisconsin's regulatory picture in the next cycle. No direct DFI enforcement-action register for either the general Chapter 217 regime or the kiosk statute specifically was located this cycle, leaving supervisory intensity an open question alongside the jurisdictional litigation. _2 earlier updates not shown here._ ###### Standing brief · as of 6 August 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Regulatory Status Wisconsin's payments regulatory perimeter rests on Chapter 217, the Model Money Transmission Modernization Law, administered by the Department of Financial Institutions. Against that baseline, Assembly Bill 471 is pending in the Assembly Committee on Financial Institutions, proposing to exempt node operation, non-fiat crypto exchange, blockchain development, and mining or staking from money-transmitter licensing. The jurisdiction risk tracker records Wisconsin's regulatory direction across licensing and stablecoin policy as uncertain, with a watch trajectory pending resolution of the state bill and the federal rulemaking timeline. Underlying the licensing debate is a definitional gap in Wisconsin law, which does not currently treat virtual currency as money, leaving self-custody of cryptocurrency outside clear DFI licensure. Layered on top of this state-level picture, the federal GENIUS Act (Public Law 119-27) applies nationally to Wisconsin-serving payment-stablecoin issuers, with final implementing rules due July 18 2026 and enforcement beginning January 2027. #### Outlook For Wisconsin, the two items that will move this jurisdiction's status are whether AB471 advances out of committee toward enactment, and whether the GENIUS Act's implementation proceeds on schedule through the July 2026 rules deadline and January 2027 enforcement start. 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 Wisconsin regulates money transmission under Chapter 217 (Model Money Transmission Modernization Law), administered by DFI; AB471 (pending, referred to Assembly Committee on Financial Institutions) would carve digital-asset activities out of this licensing perimeter. Standing sub-brief · as of 6 August 2026 294 words · last cycle 2026-10-11 #### Licensing, Authorisation & Market Access Wisconsin administers money-transmission licensing through the Department of Financial Institutions under Chapter 217, the Model Money Transmission Modernization Law. Assembly Bill 471, introduced September 29 2025 by Representative Neylon with eight cosponsors, proposes to remove node operation, crypto-to-crypto exchange without fiat conversion, blockchain software development, and mining or staking from the Chapter 217 licensing perimeter, and would prohibit state or local restrictions on self-hosted wallets and crypto payment acceptance. The bill sits with the Assembly Committee on Financial Institutions and has not, per the most recent reporting, reached a floor vote or been enacted. The underlying driver is a definitional gap: Wisconsin statute does not currently treat virtual currency as money, which leaves self-custodied cryptocurrency activity outside clear DFI licensure and is the gap AB471 is written to close. On the existing bonding side of the licensing regime, Wisconsin requires a surety bond of $10,000 for a licensee's first location plus $5,000 for each additional location, capped at $300,000 and administered by DFI, though this bonding figure derives from a secondary compliance-guide source not cross-checked against DFI's own fee schedule this cycle. Assessed against the broader state landscape, enactment of AB471 would materially narrow Wisconsin's money-transmission licensing perimeter for digital-asset activity and align the state with a growing majority of jurisdictions that already exempt node operation, non-fiat exchange, and mining or staking from money-transmitter requirements. #### Outlook The committee-stage trajectory of AB471 is the determinative near-term marker for this module: a vote to advance, table, or amend the bill would reset Wisconsin's licensing perimeter for digital-asset intermediaries, while continued committee dormancy preserves the current gray-zone status quo for self-custody and node-level activity. Committee-vote or enactment developments after September 30 2025 were not sourced this cycle and remain an open item. Periodic update · new data 2026-10-11 #### Licensing, Authorisation & Market Access Wisconsin's licensing framework for virtual-currency kiosk operators tightened this cycle via 2025 Wisconsin Act 226, which created Wis. Stat. 217.12. The provision is a backfill item: the statute was enacted on 8 April 2026, with the licensing requirement becoming legally effective 10 April 2026, but it had not previously been captured in this jurisdiction's payments-licensing baseline. The core requirement is straightforward: no person may operate a virtual currency kiosk in Wisconsin unless licensed under Chapter 217 as a money transmitter. This brings kiosk operation unambiguously within the existing non-bank payment-institution licensing category that already governs money transmission in the state, rather than creating a wholly new licence type. On top of the licensing base, the statute imposes kiosk-specific customer-identification timing: operators must verify customer identity before an initial transaction and re-verify with a photograph on each subsequent transaction. The Wisconsin Department of Financial Institutions has confirmed it will not issue company-specific safe-harbor or no-action letters addressing whether a particular business's activities require licensure under this framework, meaning kiosk operators and other crypto money-transmission providers must assess their own licensing exposure against the statutory text directly rather than seeking individualised regulatory pre-clearance. This is a materially higher-friction compliance posture than a jurisdiction offering case-by-case classification guidance, since any uncertainty about whether an activity model falls within scope is resolved without agency assistance. #### Outlook Whether the Department of Financial Institutions publishes implementing guidance specific to Act 226's kiosk provisions is the central item to watch; this would convert the current bare-statutory compliance baseline into a defined supervisory standard, which is particularly material for non-bank payment institutions in the kiosk segment that currently have no safe-harbor mechanism available to them. **4 earlier distinct update(s)** Periodic update · new data 2026-09-28 #### Licensing, Authorisation & Market Access Wisconsin tightened its market-access framework for virtual currency kiosk operators this cycle with the enactment of 2025 Act 226, effective April 10, 2026. The statute, confirmed directly from the Wisconsin State Legislature's own text, requires any person operating a virtual currency kiosk in the state to hold a money-transmitter licence under Wis. Stat. 217.12, subject to kiosk-specific conditions including a $1,000 per-customer daily transaction limit, mandatory fraud-warning disclosures, and pre-transaction customer identification. This sits within Wisconsin's existing non-bank payment-institution licensing architecture. The money-transmitter licence under Chapter 217 is a non-bank PI/EMI-style pathway, distinct from bank-charter authorisation, and is administered by the Department of Financial Institutions' Division of Banking. Act 226 does not create a separate licence category for kiosks; it inserts kiosk-specific conditions into the existing money-transmitter licence that already governs virtual currency exchange and other money-transmission activity in the state. The broader context, confirmed via secondary trade-press reporting, is that Wisconsin is not acting alone: it joins Virginia (HB 665) and Kentucky (SB 189) in enacting virtual-currency-kiosk-specific licensing and consumer-protection statutes within the same 2026 legislative window. This is evidence of a broader multi-state regulatory trend targeting the crypto-ATM channel specifically, using licensing conditions and transaction limits rather than blanket prohibitions. The overall trajectory on this domain is tightening: a previously general money-transmission licensing requirement now carries an explicit, binding kiosk sub-track with quantified transaction limits and mandatory disclosures, sourced from primary statutory text. #### Outlook The question for the coming cycle is whether this multi-state 2026 kiosk-licensing pattern, visible now in Wisconsin, Virginia, and Kentucky, continues to spread to additional states, and whether Wisconsin's Division of Banking issues further administrative rules elaborating on Act 226's licensing conditions. No indication of a move toward a bespoke crypto-exchange licence category (as distinct from the existing money-transmitter licence) was identified this cycle. Periodic update · new data 2026-09-08 #### Licensing, Authorisation & Market Access Wisconsin governs payments and crypto-adjacent money-services activity through a single general regime: money transmission, including virtual-currency exchange and custody businesses, requires a licence under Wisconsin Statute Chapter 217, administered by the Department of Financial Institutions via the Nationwide Multistate Licensing System. This is a confirmed, tier-one-sourced finding, and it establishes clearly that no bespoke crypto licence exists in Wisconsin; crypto exchange and custody businesses are folded into the same non-bank payment-institution and e-money-institution licensing track that governs traditional money transmitters. This distinction, between a purpose-built digital-asset licence and a general-purpose money-transmitter licence carrying crypto activity within its existing scope, matters for market entrants: the compliance burden and prudential requirements are those designed for money transmission generally, not calibrated specifically to crypto-asset risk. The prudential backbone of that licence is capital-based: licensees must maintain tangible net worth exceeding the greater of 100,000 dollars or a tiered percentage of total assets, specifically three percent of the first 100 million dollars in assets, two percent of the next tranche up to one billion dollars, and half a percent of assets thereafter. This tiered structure means the practical capital burden scales with the size of the licensee's balance sheet rather than being a flat entry cost, and it is a standard prudential requirement under Chapter 217 rather than a crypto-specific overlay. A secondary, lower-tier finding corroborates the absence of any standalone virtual-currency licensing law in Wisconsin: crypto businesses are confirmed to be folded into the general money-transmitter licensing track rather than governed under any bespoke digital-asset statute. This is consistent with, and reinforces, the primary Chapter 217 finding, though it is sourced only at tier four and should be read as corroborative rather than independently load-bearing. The bank-versus-non-bank distinction is material here: the entities captured by this licensing regime are classified as non-bank payment institutions and e-money institutions rather than as depository banks, meaning Wisconsin's Chapter 217 licence functions analogously to money-services-business licensing regimes found across other US states, with DFI acting as the sole supervisory authority for this non-bank population engaging in virtual-currency exchange and custody. #### Outlook No direct DFI enforcement-action register for Chapter 217 money-transmitter licensees was located this cycle, leaving the practical supervisory posture, beyond the statutory requirements themselves, an open question. Because no bespoke crypto licence exists, any future Wisconsin legislative activity extending or modifying Chapter 217, or introducing a crypto-specific licensing track, would represent a material structural change to this module and should be watched closely in subsequent cycles. Periodic update · new data 2026-08-25 #### Licensing, Authorisation & Market Access 2025 Wisconsin Act 226 creates a new licensable activity class for virtual currency kiosk operation under Wis. Stat. §217.12, effective April 9, 2026. This folds kiosk operators, a non-bank population, into Wisconsin's existing Chapter 217 money-transmission licensing architecture for the first time as a defined category, rather than leaving kiosk operation to be assessed case-by-case under the general money-transmitter definition. Wisconsin's baseline money-transmission framework traces to the Conference of State Bank Supervisors' Model Money Transmission Modernization Act, adopted by Wisconsin among the earliest states in April 2024; thirty-one states have since enacted the model law in full or part, covering an estimated 99 percent of reported money-transmission activity nationally. Act 226's kiosk provision is therefore a narrow amendment layered onto a well-established multistate licensing architecture rather than a standalone or novel regime. The licensing perimeter for other categories of crypto activity did not move this cycle. AB471, which would have exempted node operation, crypto-to-crypto exchange, blockchain software development, and mining or staking from Chapter 217 licensing, failed to pass on March 23, 2026, leaving those questions statutorily unresolved rather than settled in either direction. #### Outlook Watch for how the Wisconsin Department of Financial Institutions implements the new kiosk-licensing requirement in practice, and whether a future legislative session revisits the licensing status of node operation, exchange, or staking activity that AB471 would have addressed. Periodic update · new data 2026-08-11 #### Licensing, Authorisation & Market Access Wisconsin regulates money transmission under Chapter 217, the Model Money Transmission Modernization Law, administered by the Department of Financial Institutions. This is the standing regulatory-perimeter baseline against which this cycle's principal development, Assembly Bill 471, must be read. AB 471, introduced September 29, 2025 by Representative Neylon and eight cosponsors, would exempt node operation, crypto-to-crypto exchange without fiat conversion, blockchain software development, and mining and staking activity from money-transmitter licensing, and would bar state or local restriction of self-hosted wallet use and of crypto-payment acceptance. The definitional gap the bill targets is that Wisconsin law does not currently define money to include virtual currencies, leaving self-custody of cryptocurrency in a regulatory grey zone as to DFI licensure. As of the most recent reporting available this cycle, AB 471 has been referred to the Assembly Committee on Financial Institutions, with no confirmed floor vote or enactment; this status update carries assessed rather than high confidence, reflecting reliance on secondary trade-press reporting for the referral status specifically. The existing licensing baseline for non-exempted money-transmission activity in Wisconsin includes a tiered surety-bond requirement of $10,000 for the first licensed location plus $5,000 per additional location, capped at $300,000, administered by DFI; this bonding figure itself rests on a Tier-4 secondary money-transmitter-license guide and was not cross-checked against DFI's own fee schedule this cycle. If enacted, AB 471 would align Wisconsin with a growing number of states that already exempt comparable digital-asset activities from money-transmitter licensing requirements, narrowing the population of crypto-native activity subject to Chapter 217's nonbank payment-institution and e-money-issuer regime. #### Outlook Watch for AB 471's committee disposition beyond its initial referral, which was not sourced further this cycle, and for whether Wisconsin's legislature moves the definitional fix ahead of or independent of federal stablecoin developments under the GENIUS Act. The bill's fate will determine whether Wisconsin's money-transmission perimeter for digital assets narrows through targeted state legislation or continues to rely on the current definitional ambiguity. **Sources and findings (6)** 1. T1 [https://dfi.wi.gov/Pages/FinancialServices/LicensedFinancial/MoneyTransmitter.aspx](https://dfi.wi.gov/Pages/FinancialServices/LicensedFinancial/MoneyTransmitter.aspx) 2. T1 [https://docs.legis.wisconsin.gov/document/statutes/217.04](https://docs.legis.wisconsin.gov/document/statutes/217.04) retrieved 2026-07-05 3. T1 [https://dfi.wi.gov/Pages/FinancialServices/LicensedFinancial/MoneyTransmitterModernizationAct.aspx](https://dfi.wi.gov/Pages/FinancialServices/LicensedFinancial/MoneyTransmitterModernizationAct.aspx) 4. T1 [https://dfi.wi.gov/Pages/FinancialServices/LicensedFinancial/MoneyTransmitter.aspx](https://dfi.wi.gov/Pages/FinancialServices/LicensedFinancial/MoneyTransmitter.aspx) 5. T1 [https://docs.legis.wisconsin.gov/statutes/statutes/217](https://docs.legis.wisconsin.gov/statutes/statutes/217) retrieved 2026-07-05 6. T1 [https://law.justia.com/codes/wisconsin/chapter-217/section-217-01/](https://law.justia.com/codes/wisconsin/chapter-217/section-217-01/) retrieved 2026-07-05 ### W1b Conduct, Safeguarding & Promotions Confirmed confirmed 2026-07-05 Safeguarding rests on a surety bond/permissible-investments model, with new consumer conduct obligations on virtual currency kiosk operators via 2025 Act 226. Absence reason not determinable No sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T1 [https://dfi.wi.gov/Pages/FinancialServices/LicensedFinancial/MoneyTransmitterModernizationAct.aspx](https://dfi.wi.gov/Pages/FinancialServices/LicensedFinancial/MoneyTransmitterModernizationAct.aspx) 2. T1 [https://law.justia.com/codes/wisconsin/chapter-217/section-217-09/](https://law.justia.com/codes/wisconsin/chapter-217/section-217-09/) retrieved 2026-07-05 3. T1 [https://docs.legis.wisconsin.gov/2025/related/acts/226.pdf](https://docs.legis.wisconsin.gov/2025/related/acts/226.pdf) 4. T3 [https://www.aarp.org/states/wisconsin/new-crypto-kiosk-law-stops-criminals-in-their-tracks/](https://www.aarp.org/states/wisconsin/new-crypto-kiosk-law-stops-criminals-in-their-tracks/) retrieved 2026-07-05 5. T1 [https://docs.legis.wisconsin.gov/statutes/statutes/217/01](https://docs.legis.wisconsin.gov/statutes/statutes/217/01) retrieved 2026-07-05 ### W2 Stablecoins & Digital Money limited signal Confirmed confirmed 2026-07-05 Federal GENIUS Act stablecoin framework (Public Law 119-27) applies as a national overlay to Wisconsin-serving payment stablecoin issuers; final rules due July 2026, enforcement January 2027. Standing sub-brief · as of 6 August 2026 217 words · last cycle 2026-08-05 #### Stablecoins & Digital Money The GENIUS Act, enacted as Public Law 119-27 and signed July 18 2025, establishes payment stablecoins as a form of digital money that may only be issued by Permitted Payment Stablecoin Issuers, a national framework that applies to Wisconsin-serving issuers regardless of the state's own licensing regime. Final implementing rules are due July 18 2026, and the enforcement phase begins January 2027, at which point full compliance obligations attach. A US Treasury notice of proposed rulemaking issued April 14 2026 works through how state-chartered stablecoin issuers interlock with the federal GENIUS Act regime, a question that bears directly on the state-federal licensing interface for any Wisconsin-chartered or Wisconsin-licensed entity engaged in stablecoin issuance. Taken together, Wisconsin-serving payment-stablecoin issuers face a layered compliance stack once enforcement begins in January 2027: new federal bank-style reserve, attestation, and audit obligations stack on top of any pre-existing state money-transmitter licensing that already applies to their activities. #### Outlook The two forward markers to track are the final GENIUS Act implementing rules due July 18 2026 and the start of enforcement in January 2027, either of which would sharpen the compliance timeline for any Wisconsin-serving stablecoin issuer. Illicit-finance monitoring duties tied to these same rulemakings are tracked separately by the Financial Integrity Monitor and are not analysed further here. Periodic update · new data 2026-08-11 #### Stablecoins & Digital Money The GENIUS Act, Public Law 119-27, signed July 18, 2025, is the federal overlay most directly relevant to Wisconsin-serving digital-money activity this cycle. The Act classifies payment stablecoins as digital money restricted to Permitted Payment Stablecoin Issuers, with final implementing rules targeted for July 18, 2026 and enforcement beginning January 2027; it applies nationally, including to any issuer serving Wisconsin customers, independent of Wisconsin's own money-transmitter statute. The framework applies to both bank and non-bank issuers, a notable departure from state licensing regimes that typically draw a sharper line between bank and non-bank payment institutions and e-money issuers. A Treasury notice of proposed rulemaking dated April 14, 2026 addresses how state-chartered stablecoin issuers fit within this federal framework, a question directly relevant to the state-federal licensing interface for any Wisconsin-chartered or -licensed entity; this specific reading is assessed at low confidence, resting on a Tier-4 secondary source with no primary NPRM text retrieved this cycle. Wisconsin-serving payment-stablecoin issuers therefore face a layered compliance stack once GENIUS Act enforcement begins in January 2027, combining new federal bank-style reserve, attestation, and audit obligations with whatever state money-transmitter licensing status applies to their Wisconsin operations, an interaction the state-federal NPRM appears intended to clarify but has not yet done so definitively. #### Outlook Watch for the GENIUS Act's final implementing rules around the July 2026 target date and their treatment of state-chartered issuers, and for any primary Treasury text on the state-federal licensing interplay raised in the April 2026 NPRM, neither of which was available in primary form this cycle. **Sources and findings (4)** 1. T1 [https://docs.legis.wisconsin.gov/2025/related/proposals/sb975/1/_21](https://docs.legis.wisconsin.gov/2025/related/proposals/sb975/1/_21) 2. T1 [https://dfi.wi.gov/Pages/FinancialServices/LicensedFinancial/MoneyTransmitter.aspx](https://dfi.wi.gov/Pages/FinancialServices/LicensedFinancial/MoneyTransmitter.aspx) 3. T1 [https://docs.legis.wisconsin.gov/2025/related/acts/226.pdf](https://docs.legis.wisconsin.gov/2025/related/acts/226.pdf) 4. T2 [https://www.billtrack50.com/billdetail/1903492](https://www.billtrack50.com/billdetail/1903492) retrieved 2026-07-05 ### W3 Operational Resilience & Critical Infrastructure Probable confirmed 2026-07-05 Operational resilience rests on the state Data Breach Notification Law and Insurance Data Security Law for OCI licensees, with no dedicated state operational-resilience regime. 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/) Absence reason not determinable No sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://docs.legis.wisconsin.gov/statutes/statutes/134/98](https://docs.legis.wisconsin.gov/statutes/statutes/134/98) 2. T2 [https://www.constangy.com/data-privacy-us-wi](https://www.constangy.com/data-privacy-us-wi) 3. T1 [https://law.justia.com/codes/wisconsin/chapter-217/section-217-01/](https://law.justia.com/codes/wisconsin/chapter-217/section-217-01/) retrieved 2026-07-05 4. T3 [https://pivitstrategy.com/wisconsin-cybersecurity-laws-you-should-know-2026/](https://pivitstrategy.com/wisconsin-cybersecurity-laws-you-should-know-2026/) retrieved 2026-07-05 ### W4 Scheme & Network Compliance Probable confirmed 2026-07-05 Wisconsin imposes no state-level restriction on credit card surcharging, deferring to the federal 4% cap and card-network rulebooks. Absence reason not determinable No sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T3 [https://www.getnickel.com/surcharge-laws/wisconsin](https://www.getnickel.com/surcharge-laws/wisconsin) 2. T1 [https://docs.legis.wisconsin.gov/2013/related/proposals/sb213](https://docs.legis.wisconsin.gov/2013/related/proposals/sb213) retrieved 2026-07-05 3. T1 [https://docs.legis.wisconsin.gov/document/proposaltext/2021/REG/AB587](https://docs.legis.wisconsin.gov/document/proposaltext/2021/REG/AB587) retrieved 2026-07-05 4. T1 [https://dhub.deloitte.com/Newsletters/Tax/2025/STM/250509_13.html](https://dhub.deloitte.com/Newsletters/Tax/2025/STM/250509_13.html) retrieved 2026-07-05 5. T3 [https://merchantcostconsulting.com/lower-credit-card-processing-fees/wisconsin-credit-card-surcharge-laws/](https://merchantcostconsulting.com/lower-credit-card-processing-fees/wisconsin-credit-card-surcharge-laws/) ### W5 Payment Corridor Dynamics Probable confirmed 2026-07-05 Corridor exposure runs through FedNow participation by WI banks/credit unions and ch.217's cross-border money-transmission coverage. Absence reason not determinable No sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason. no periodic updates on record for this sub-brief ** Sources and findings (3)** 1. T2 [https://www.nerdwallet.com/banking/learn/banks-that-use-fednow](https://www.nerdwallet.com/banking/learn/banks-that-use-fednow) 2. T2 [https://bankingjournal.aba.com/2025/10/5-fednow-service-developments-you-may-have-missed/](https://bankingjournal.aba.com/2025/10/5-fednow-service-developments-you-may-have-missed/) 3. T1 [https://docs.legis.wisconsin.gov/document/statutes/217/01](https://docs.legis.wisconsin.gov/document/statutes/217/01) ### W6 Industry Structure & Commercial Confirmed confirmed 2026-07-05 Fiserv, headquartered in Milwaukee since 2024, dominates Wisconsin's payments industry structure alongside a dense community-bank/credit-union sector. Absence reason not determinable No sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T2 [https://www.businesswire.com/news/home/20240304550078/en](https://www.businesswire.com/news/home/20240304550078/en) 2. T1 [https://www.sec.gov/Archives/edgar/data/0000798354/000119312526270336/d153349dex991.htm](https://www.sec.gov/Archives/edgar/data/0000798354/000119312526270336/d153349dex991.htm) 3. T3 [https://en.wikipedia.org/wiki/Fiserv](https://en.wikipedia.org/wiki/Fiserv) retrieved 2026-07-05 4. T2 [https://www.nerdwallet.com/banking/learn/banks-that-use-fednow](https://www.nerdwallet.com/banking/learn/banks-that-use-fednow) 5. T2 [https://www.paymentsdive.com/news/judge-combines-fiserv-lawsuits/819924/](https://www.paymentsdive.com/news/judge-combines-fiserv-lawsuits/819924/) ### W7 Legal & Litigation Probable confirmed 2026-07-05 Milwaukee-based Fiserv is the epicentre of Wisconsin payments litigation: consolidated securities class actions and a Clover merchant-fee class action. Standing sub-brief · as of 8 September 2026 332 words · last cycle 2026-09-05 #### Legal & Litigation The defining legal development in Wisconsin this cycle is CFTC v. Wisconsin, filed 28 April 2026, in which the Commodity Futures Trading Commission sued the state to block Wisconsin's own gambling-law suits against five prediction-market platforms, Kalshi, Polymarket, Coinbase, Robinhood, and Crypto.com, asserting exclusive federal derivatives jurisdiction over these products. This is a confirmed, tier-one-sourced, critical-impact finding, and its significance is structural rather than incidental: it is a direct test of whether a state can use its gambling statutes to regulate products that the federal government classifies as derivatives under exclusive CFTC jurisdiction. The dispute did not originate with the CFTC; it arose because Wisconsin itself initiated litigation against the five named platforms under state gambling law, and the CFTC's suit is a response asserting federal preemption. The outcome will resolve, at least for Wisconsin and potentially with persuasive effect elsewhere, whether prediction-market event contracts are properly classified and regulated as derivatives products under federal law or as a form of wagering subject to state gambling jurisdiction. This is squarely a jurisdictional and classificatory question, not a substantive finding about the legality of the underlying products themselves. The trajectory here is confirmed as escalating: this is a live, unresolved dispute between a federal regulator and a state government, with the litigation still in its early stages as of this cycle. No ruling or resolution has been reported, and the practical consequence for payment-service providers and platforms operating prediction-market or event-contract products in Wisconsin remains genuinely unsettled pending judicial determination. #### Outlook The central item to watch is any ruling, procedural or substantive, in CFTC v. Wisconsin. A ruling favoring federal preemption would clarify that prediction-market event contracts sit outside state gambling jurisdiction nationally, with implications well beyond Wisconsin; a ruling favoring Wisconsin's authority to apply its gambling statute would preserve significant state-level regulatory latitude over these products. Either outcome would be a material development for the classification of digital-asset-adjacent derivative products generally, and neither is resolved as of this cycle. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T2 [https://www.paymentsdive.com/news/judge-combines-fiserv-lawsuits/819924/](https://www.paymentsdive.com/news/judge-combines-fiserv-lawsuits/819924/) 2. T2 [https://www.paymentsdive.com/news/fiserv-shareholders-sue-again/805388/](https://www.paymentsdive.com/news/fiserv-shareholders-sue-again/805388/) retrieved 2026-07-05 3. T2 [https://www.paymentsdive.com/news/fiserv-sued-over-alleged-lax-security/810831/](https://www.paymentsdive.com/news/fiserv-sued-over-alleged-lax-security/810831/) 4. T3 [https://lawfold.com/fiserv-class-action-lawsuit/](https://lawfold.com/fiserv-class-action-lawsuit/) 5. T3 [https://paymentexpert.com/2025/11/14/fiserv-sued-financial-guidance/](https://paymentexpert.com/2025/11/14/fiserv-sued-financial-guidance/) retrieved 2026-07-05 ### W8 Merchant Acquiring & Risk Probable confirmed 2026-07-05 Merchant acquiring is anchored by Fiserv/Clover under a permissive surcharge regime, facing litigation over fee transparency. Absence reason not determinable No sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T2 [https://www.paymentsdive.com/news/fiserv-sued-over-alleged-lax-security/810831/](https://www.paymentsdive.com/news/fiserv-sued-over-alleged-lax-security/810831/) 2. T3 [https://lawfold.com/fiserv-class-action-lawsuit/](https://lawfold.com/fiserv-class-action-lawsuit/) 3. T3 [https://merchantcostconsulting.com/lower-credit-card-processing-fees/wisconsin-credit-card-surcharge-laws/](https://merchantcostconsulting.com/lower-credit-card-processing-fees/wisconsin-credit-card-surcharge-laws/) 4. T3 [https://pivitstrategy.com/wisconsin-cybersecurity-laws-you-should-know-2026/](https://pivitstrategy.com/wisconsin-cybersecurity-laws-you-should-know-2026/) retrieved 2026-07-05 ### W9 Product Innovation & Market Development Probable confirmed 2026-07-05 Product innovation centres on FedNow-enabled instant payments adoption and Fiserv's embedded-finance/agentic-commerce roadmap. Standing sub-brief · as of 8 September 2026 344 words · last cycle 2026-09-05 #### Product Innovation & Market Development Wisconsin's 2026 crypto-kiosk consumer-protection statute is the defining product-innovation development this cycle: a confirmed, tier-three-sourced instrument that imposes 1,000 dollar daily transaction limits on cryptocurrency ATMs, requires kiosk operators to reimburse scam victims who report the fraud to law enforcement within 30 days of the transaction, and mandates fraud warnings, identity checks, and fee caps. This statute targets Wisconsin's more than 700 bitcoin ATMs directly, and its trajectory is confirmed as tightening: it represents a new, substantive regulatory layer specifically calibrated to a single product category, the physical crypto kiosk, rather than a general revision of the state's broader payments framework. This kiosk-specific overlay does not replace or substitute for the general money-transmitter licensing regime under Chapter 217; it sits on top of it as an additional, product-specific compliance layer. A kiosk operator in Wisconsin must therefore satisfy both the general Chapter 217 money-transmission licensing requirements and the new kiosk-specific transaction limits, refund obligations, and disclosure mandates. This layering pattern, a general licensing baseline plus a narrower product-specific overlay triggered by a particular delivery channel or risk profile, is itself a notable feature of how Wisconsin is choosing to regulate crypto-adjacent products as they proliferate. The statute's introduction also connects to the state's parallel and separately confirmed CFTC v. Wisconsin dispute over prediction-market classification: both developments illustrate an emerging pattern of state-federal and state-level regulatory activity clustering around digital-asset-adjacent payment products in the United States, even though the kiosk statute and the prediction-market litigation address entirely distinct product categories and were not driven by the same underlying trigger. #### Outlook The key open question is enforcement: no direct DFI enforcement-action register for the kiosk statute was located this cycle, so whether the 1,000 dollar transaction limits, mandatory refund window, and disclosure requirements are being actively supervised and enforced against Wisconsin's kiosk operator population remains unconfirmed. A subsequent cycle surfacing an enforcement action, or the absence of one despite continued elder-fraud reporting, would materially inform whether this statute is functioning as a binding compliance obligation or as a largely aspirational framework. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T2 [https://www.nerdwallet.com/banking/learn/banks-that-use-fednow](https://www.nerdwallet.com/banking/learn/banks-that-use-fednow) 2. T2 [https://www.prnewswire.com/news-releases/fiserv-completes-acquisition-of-payfare-302389984.html](https://www.prnewswire.com/news-releases/fiserv-completes-acquisition-of-payfare-302389984.html) retrieved 2026-07-05 3. T2 [https://thepaypers.com/fintech/news/fiserv-completes-acquisition-of-payfare](https://thepaypers.com/fintech/news/fiserv-completes-acquisition-of-payfare) 4. T2 [https://www.paymentsdive.com/news/fiserv-sued-over-alleged-lax-security/810831/](https://www.paymentsdive.com/news/fiserv-sued-over-alleged-lax-security/810831/) ### W10 Consumer Protection & APP Fraud limited signal Confirmed confirmed 2026-07-05 Consumer protection is led by DATCP, complemented by the Wisconsin Consumer Act and new APP/virtual-currency-kiosk fraud protections enacted in 2026. Standing sub-brief · as of 23 August 2026 147 words · last cycle 2026-10-11 #### Consumer Protection & APP Fraud Under 2025 Wisconsin Act 226, virtual currency kiosk operators must refund the full transaction amount to a customer who reports a transaction as fraudulent to law enforcement within 30 days, effective April 9, 2026. This is a targeted anti-fraud response: the bill followed a multi-year investigative and advocacy process led by AARP Wisconsin and the Wood County Sheriff's Department, which had spent more than three years documenting kiosk-related scams, and was carried on a bipartisan basis by Representative Snyder, Representative Doyle, and Senator James. The refund obligation sits alongside, rather than replacing, the kiosk-licensing requirement created by the same statute, giving Wisconsin a combined licensing-plus-victim-restitution model for this narrow category of payment activity. #### Outlook Watch for early data on how the 30-day refund mechanism performs in practice, and whether other states adopt a comparable mandatory-refund model for kiosk-based fraud following Wisconsin's example. Periodic update · new data 2026-10-11 #### Consumer Protection & APP Fraud 2025 Wisconsin Act 226 introduced kiosk-specific consumer-protection and fraud-mitigation provisions under Wis. Stat. 217.12(6)(a), effective 10 April 2026. Secondary legal commentary describes a daily transaction cap of $1,000 in fiat currency per customer for kiosk transactions, alongside a thirty-day fraud-reporting window that preserves a customer's eligibility for a full refund, including fees, where fraud is reported to both the kiosk operator and a law-enforcement or government agency within that window. This transaction-cap figure is sourced from law-firm commentary summarising the Act rather than confirmed independently against the statutory text this cycle, and should be treated as provisional pending that confirmation. Press coverage situates this legislative response within a broader national pattern: coverage has connected Wisconsin's new transaction-limit and licensing regime to the wider wave of state-level tightening that has been cited, among other factors, in Bitcoin Depot's May 2026 Chapter 11 filing. Bitcoin Depot operated kiosks in Wisconsin among other states; the filing is a national commercial event with an incidental effect on the Wisconsin kiosk-operator landscape rather than a Wisconsin-specific regulatory action, and it illustrates the commercial-pressure dimension of consumer-protection-driven transaction limits on kiosk-based payment channels. #### Outlook Confirmation of the $1,000 daily transaction-cap figure against primary statutory text, and tracking of whether other Wisconsin-facing kiosk operators face comparable commercial pressure under the new fraud-prevention and transaction-limit obligations, are the principal developments to watch for this module going forward. **1 earlier distinct update(s)** Periodic update · new data 2026-09-28 #### Consumer Protection & APP Fraud Wisconsin's 2025 Act 226, effective April 10, 2026, introduces binding consumer-protection and fraud-mitigation controls specific to virtual currency kiosk transactions, confirmed directly from statutory text. Kiosk operators must display mandated fraud warnings and verify customer identity before an initial transaction, and are subject to a $1,000 per-customer daily transaction limit. Read through an authorised-push-payment-fraud lens, these controls target the specific risk profile of the kiosk channel: an in-person, cash-intensive transaction model in which a customer can be induced, often under fraud or scam pressure, to convert cash into cryptocurrency at a kiosk with limited opportunity for a financial institution to intervene before the transfer is irreversible. The mandatory fraud-warning disclosure and acknowledgement requirement is a direct point-of-transaction friction control aimed at interrupting exactly this fraud pattern, while the pre-transaction identity-verification requirement and the $1,000 daily cap jointly limit the maximum single-day exposure any one victim could face at a given kiosk. This development is confirmed as part of a broader multi-state legislative pattern this same window, with Virginia and Kentucky enacting comparable kiosk-specific consumer-protection statutes, indicating that state payments regulators are converging on a similar control set, disclosure plus identity verification plus a transaction cap, as the preferred response to kiosk-fraud exposure, rather than pursuing a single harmonised federal standard. The trajectory on this domain is tightening, reflecting new, specific, binding protections rather than aspirational guidance. #### Outlook What remains to be seen is whether the $1,000 daily cap proves an effective friction point against fraud-induced kiosk transactions in practice, and whether Wisconsin or peer states adjust the cap level or disclosure mechanism based on observed fraud outcomes in a future cycle. No Wisconsin-specific APP-fraud loss data was identified this cycle. 1 further periodic run re-emitted the standing brief unchanged and is not shown. **Sources and findings (5)** 1. T1 [https://www.wbay.com/2026/02/06/in-depth-wisconsins-top-consumer-complaints-how-state-recovered-42m-customers/](https://www.wbay.com/2026/02/06/in-depth-wisconsins-top-consumer-complaints-how-state-recovered-42m-customers/) 2. T1 [https://docs.legis.wisconsin.gov/2025/related/acts/226.pdf](https://docs.legis.wisconsin.gov/2025/related/acts/226.pdf) 3. T1 [https://www.radioplusinfo.com/2025/02/06/2-7-25-wisconsin-department-of-ag-trade-and-consumer-protection-top-ten-consumer-complaints/](https://www.radioplusinfo.com/2025/02/06/2-7-25-wisconsin-department-of-ag-trade-and-consumer-protection-top-ten-consumer-complaints/) retrieved 2026-07-05 4. T1 [https://wilawlibrary.gov/topics/consumer/index.php](https://wilawlibrary.gov/topics/consumer/index.php) retrieved 2026-07-05 5. T1 [https://datcp.wi.gov/Pages/Programs_Services/ConsumerProtection.aspx](https://datcp.wi.gov/Pages/Programs_Services/ConsumerProtection.aspx) retrieved 2026-07-05 ### W11 AML/CFT & Financial Crime [Sourced from Sentinel.gi ↗](https://sentinel.gi/jurisdictions/united-states-wisconsin/#sec-dom-D7) Probable confirmed 2026-07-05 This module carries the Sentinel.gi payments-context AML/CFT position only; the proprietary feed was unreachable this pass, so only the federal BSA/SAR backdrop is captured. Absence reason not determinable No sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason. no periodic updates on record for this sub-brief ** Sources and findings (7)** 1. T1 sentinel.https://docs.legis.wisconsin.gov/2023/related/acts/267/26 2. T? FIM (sentinel.gi) per-JID baseline profile — United States — Wisconsin — Wisconsin operates under the federal BSA/AML framework administered by FinCEN and OFAC; the Wisconsin Department of Financial Institutions (Division of Banking) licenses money transmitters under state statute. There is no state-level beneficial ownership registry — Wisconsin entities rely entirely on the federal Corporate Transparency Act regime, which was substantially rolled back in March 2025. 3. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: sourcing-thinness 4. T1 FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-002) — Sanctions: OFAC delisting 5. T2 FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-001) — Sanctions: OFAC listing 6. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: enforcement-absence 7. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: regulatory-failure ### W12 Correspondent Banking, Settlement & Access Probable confirmed 2026-07-05 Correspondent banking pressures centre on cannabis/hemp-adjacent de-risking, with niche providers filling the service gap pending potential federal rescheduling. Absence reason not determinable No sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T2 [https://www.aba.com/advocacy/our-issues/cannabis](https://www.aba.com/advocacy/our-issues/cannabis) 2. T3 [https://www.herringbank.com/business-banking/cannabis-banking/hemp-banking-wisconsin/](https://www.herringbank.com/business-banking/cannabis-banking/hemp-banking-wisconsin/) retrieved 2026-07-05 3. T3 [https://www.abrigo.com/blog/cannabis-banking-in-wisconsin-mitigating-reputation-risk-to-financial-institutions/](https://www.abrigo.com/blog/cannabis-banking-in-wisconsin-mitigating-reputation-risk-to-financial-institutions/) retrieved 2026-07-05 4. T2 [https://www.icba.org/banking-cannabis-related-businesses](https://www.icba.org/banking-cannabis-related-businesses) ### W13 Commercial Intelligence (M&A, Investment & Product) Probable confirmed 2026-07-05 Trailing-12-month commercial activity in Wisconsin payments is dominated by Fiserv's CEO transition, workforce restructuring, and continued product/partnership activity. Absence reason not determinable No sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://www.sec.gov/Archives/edgar/data/0000798354/000119312526270336/d153349dex991.htm](https://www.sec.gov/Archives/edgar/data/0000798354/000119312526270336/d153349dex991.htm) 2. T2 [https://www.paymentsdive.com/news/judge-combines-fiserv-lawsuits/819924/](https://www.paymentsdive.com/news/judge-combines-fiserv-lawsuits/819924/) 3. T3 [https://www.paymentsdive.com/news/fiserv-sued-over-alleged-lax-security/810831/](https://www.paymentsdive.com/news/fiserv-sued-over-alleged-lax-security/810831/) 4. T2 [https://thepaypers.com/fintech/news/fiserv-completes-acquisition-of-payfare](https://thepaypers.com/fintech/news/fiserv-completes-acquisition-of-payfare) ** 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 – Wisconsin| 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"}}}`. **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), 65 finding(s), 139 source(s) in the cumulative register. Think something on this page is wrong? [Report an error](https://payments.gi/legal/#contact).