United States – Nevada Payments & Fintech Regulation

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

Last updated · 14 modules · 110 sourced findings · 164 sources in the cumulative register

United States federal law that applies in United States – Nevada is covered once, on the United States page. This page covers United States – Nevada’s own layer: its own law, regulators and enforcement.

Jurisdiction brief

Latest update · 18 October 2026

Lead Signal

Upgrade, Inc., the consumer-fintech lender, filed applications with the Nevada Financial Institutions Division and the FDIC on October 12, 2026 to establish "Upgrade Bank" as a Nevada-chartered industrial loan company and wholly owned, FDIC-insured subsidiary. The filing uses the industrial-loan-company route under Nevada's ILC charter framework, a path that has periodically drawn fintech interest because it permits a nonbank consumer-lending platform to obtain a federally insured deposit-taking subsidiary without becoming a full bank holding company under the Bank Holding Company Act. Upgrade has stated that the proposed bank would complement, not replace, its existing bank-partner relationships with Cross River Bank, a New Jersey state-chartered bank, and Celtic Bank, a Utah industrial loan company, which currently fund its buy-now-pay-later, personal loan, credit card and auto-finance products. That framing matters: it signals Upgrade is adding a captive funding vehicle to its existing partner-bank model rather than disintermediating those partners, at least in the near term.

Key regulatory facts for United States – Nevada
Regulatory DimensionUnited States – Nevada Standing Position
JurisdictionUnited States – Nevada (US-NV)
Regulatory ScopePayments & Fintech Regulation (14 modules, 110 sourced findings)
Licensing, Authorisation & Market AccessUS-NV has no dedicated payments/EMI licensing regime; money transmission (including virtual-currency transmission) is licensed under NRS Chapter 671 by the Nevada Financial Institutions Division (NFID), which...
Conduct, Safeguarding & PromotionsSafeguarding of transmitted funds in Nevada rests on the NRS 671 surety-bond/permissible-investment regime rather than a segregation-trust mandate; general conduct and promotional practices are policed under NRS...
Stablecoins & Digital MoneyNevada has no dedicated stablecoin/virtual-currency licensing statute; digital-asset custody is routed through the NRS 669 trust-company regime or NRS 671 money-transmitter regime.
Operational Resilience & Critical InfrastructureNevada has no general cross-sector payments operational-resilience statute; the standing regime is sector-specific to gaming payments via Regulation 14.
Primary Instruments CitedUnited States – Nevada Official Instrument (leg.state.nv.us nrs-671-html), United States – Nevada Official Instrument (fid.nv.gov ISSUERS_OF_INSTRUMENTS_FOR_TRANS), United States – Nevada Official Instrument (cooley.com 2023-09-12-model-money-transmiss), United States – Nevada Official Instrument (fid.nv.gov FID-20Statement-20on-20Crypotcur), United States – Nevada Official Instrument (sec.gov d75989dex991-htm)
Last Confirmed / Updated2026-11-04 (164 sources in cumulative register)

#

US-NV has no dedicated payments/EMI licensing regime; money transmission (including virtual-currency transmission) is licensed under NRS Chapter 671 by the Nevada Financial Institutions Division (NFID), which determines applicability case-by-case; a 2015 SB 195 proposal to create a bespoke virtual-currency licence class did not pass.

Open gap — wpm-int-1No regulator (Nevada FID / NGC / FDIC) confirmation of the Upgrade ILC application's approval status was available this cycle.no under-indexing note recorded
Standing sub-brief · as of 5 July 2026 127 words · last cycle 2026-10-04

Licensing, Authorisation & Market Access

Nevada's Financial Institutions Division administers a dual-track licensing regime: non-bank money transmission is licensed under NRS Chapter 671 via the Nationwide Multistate Licensing System, while digital-asset custody is routed through the NRS Chapter 669 trust-company licence. That framework was modernized by AB21, based on the CSBS Model Money Transmission Modernization Act, which took effect July 1, 2023 and eased officer and director residency requirements while updating bonding and control-acquisition standards; Nevada did not, however, adopt the Act's optional virtual-currency-business licensing article.

Periodic update · new data 2026-10-04

Licensing, Authorisation & Market Access

Nevada's money-transmission licensing regime under NRS Chapter 671 was modernised this cycle rather than restructured. Assembly Bill 21 amended NRS Chapter 671, adding sections that introduce updated definitional terms, including authorized delegate and average daily money transmission liability, along with an explicit cross-reference to Bank Secrecy Act obligations and expanded NMLS-based fingerprint and background-check authority for the Commissioner. This is a modernisation of the existing framework's definitions and the Commissioner's investigative tools, not the creation of a new licence category or a change to who must be licensed.

A separate but connected development concerns the treatment of digital-asset custody businesses. The Nevada Financial Institutions Division has stated that where an entity proposes to serve as a digital custodian for any form of digital currency, that business may instead be regulated as a trust company under NRS Chapter 669, rather than as a money transmitter under NRS 671. This is a functional, business-model-dependent classification rather than a single bespoke licence for digital-asset custody, meaning a firm's precise activities determine which of two distinct regulatory pathways, and which set of prudential and licensing requirements, applies. This creates classification uncertainty for novel payments and custody business models considering Nevada market entry, since the outcome depends on the Division's case-by-case assessment rather than a bright-line statutory test.

A further narrowing development from 2025 remains relevant context: Assembly Bill 430 removed payroll-processing services from the NRS 671 definition of money transmission, effective 1 October 2025. This reduces the range of business activity that triggers money-transmitter licensure in Nevada, distinct from, but part of the same broader modernisation trend as, the AB 21 amendments.

Taken together, these developments show Nevada's money-transmission regime tightening its definitional and enforcement precision (AB 21) while simultaneously narrowing its scope at the margins (AB 430) and leaving an open, functional classification question for digital-asset custody businesses (the NRS 669/671 boundary). None of these changes alter the fundamental requirement that money transmission in Nevada requires state licensure; they refine which activities count and how the Commissioner may investigate licensees.

Outlook

The open classification question between money-transmitter status under NRS 671 and trust-company status under NRS 669 for digital-custody businesses is the primary item to watch for market entrants with novel digital-asset business models, since the Division's case-by-case approach means the outcome is not predictable from statute alone. Firms should expect the Commissioner's expanded NMLS-based background-check authority under AB 21 to apply more rigorously to new applicants going forward.

2 earlier distinct update(s)
Periodic update · new data 2026-08-25

Licensing, Authorisation & Market Access

Nevada's Financial Institutions Division clarified this cycle that cryptocurrency operators must obtain a money-transmitter licence and post a surety bond under Nevada Revised Statutes Chapter 671, on the basis that any entity engaged in receiving for transmission or transmitting money or credits falls within the statute's scope (wpm-2026-W34-001). Licensing determinations are made case by case rather than under a dedicated virtual-currency licence category: Nevada has no bespoke crypto-licensing class, and a 2015 legislative proposal, Senate Bill 195, to create one did not pass (wpm-2026-W34-002). This places Nevada among the US states relying on their general money-transmission statute for crypto market access, a bank-versus-nonbank-relevant distinction in practice since the licence obligation attaches to the nonbank payment-institution/money-services-business function of receiving and transmitting value, irrespective of the underlying asset being fiat or digital currency.

Outlook

Watch for whether Nevada revisits a dedicated virtual-currency licensing framework given the passage of time since the 2015 SB 195 proposal, or whether the Financial Institutions Division's case-by-case approach becomes the entrenched long-term model. No legislative signal toward reform was identified this cycle.

Periodic update · new data 2026-08-11

Licensing, Authorisation & Market Access

Nevada's Gaming Commission adopted Regulations 5.045 through 5.048 in April 2026, restructuring licensing and compliance-accountability requirements for nonrestricted gaming licensees. Regulation 5.045 requires licensees operating a compliance review and reporting system to designate named individuals responsible for the AML program and marketing department, subject to administrative approval. Regulation 5.046 goes further, making the individual who oversees a licensee's overall compliance framework a licensable key employee in their own right, a new licensing gate that did not previously exist in this form. Regulation 5.048 classifies individuals with primary AML-program responsibility as gaming employees. Regulation 5.047 prohibits business entities from funding patron wagering activity through front money, wagering accounts, or credit payments, with a six-month delayed effective date.

Outlook

Regulation 5.047 becomes enforceable in the fourth quarter of 2026, six months after adoption, marking the next concrete compliance deadline for nonrestricted licensees. Regulation 5A's interactive-gaming technical-standard detail beyond the existing poker-only carve-out was not substantively covered this cycle and remains a gap.

Sources and findings (13)
  1. T1https://www.leg.state.nv.us/nrs/nrs-671.htmlretrieved
  2. T1https://fid.nv.gov/Licensing/Money_Transmitter/ISSUERS_OF_INSTRUMENTS_FOR_TRANSMISSION_OR_PAYMENT_OF_MONEY/retrieved
  3. T2https://www.cooley.com/news/insight/2023/2023-09-12-model-money-transmission-modernization-act-12-states-take-actionretrieved
  4. T1https://fid.nv.gov/uploadedFiles/fidnvgov/content/Home/features/FID%20Statement%20on%20Crypotcurrency.pdfretrieved
  5. T1https://www.sec.gov/Archives/edgar/data/0002025416/000119312526012903/d75989dex991.htmretrieved
  6. T3https://faisalkhan.com/solutions/licensing/money-transmitter-license-mtl/money-transmitter-license-nevada/retrieved
  7. T1Nevada Financial Institutions Division (FID) — Nevada Financial Institutions Division (FID) — Non-bank money-transmission licensing under NRS Chapter 671 (via NMLS) and trust-company licensing under NRS Chapter 669 (digital-asset-custody route)retrieved
  8. T2Nevada AB21 (2023) — Nevada AB21 (2023) — AB21, based on the CSBS Model Money Transmission Modernization Act, took effect July 1, 2023, easing officer/director residency requirements and updating bonding/control-acquisition standardsretrieved
  9. T3Nevada Financial Institutions Division — Nevada Financial Institutions Division — Crypto exchanges and Bitcoin ATM operators must obtain a Nevada money-transmitter licence and surety bond; the Division determines the exact licence category case-by-caseretrieved
  10. T3Nevada Senate Bill 437 — Nevada Senate Bill 437 — SB 437 (effective Oct 1, 2025) amended the Nevada Installment Loan and Finance Act to streamline licensing/operational requirements for consumer lenders, including new exemptions from the in-state office ruleretrieved
  11. T1Nevada Financial Institutions Division — Nevada Financial Institutions Division — All money transmitters, including virtual-currency exchange/custody businesses, must be licensed under NRS Chapter 671 via NMLS by the Commissioner of Financial Institutionsretrieved
  12. T1Nevada Financial Institutions Division — Nevada Financial Institutions Division — SB 195 (2019), a proposed dedicated statutory virtual-currency licence program, did not pass; FID resumed licensing crypto exchange/custody activity under existing NRS 671 authorityretrieved
  13. T3Bitcoin ATM operators — Bitcoin ATM operators in Nevada are required to hold an NRS 671 money-transmitter licence and bond, per FID's case-by-case interpretationretrieved

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Safeguarding of transmitted funds in Nevada rests on the NRS 671 surety-bond/permissible-investment regime rather than a segregation-trust mandate; general conduct and promotional practices are policed under NRS Chapter 598, enforced by the Attorney General's Consumer Affairs Unit and the Commissioner of Financial Institutions.

Standing sub-brief · as of 5 July 2026 116 words · last cycle 2026-07-05

Conduct, Safeguarding & Promotions

Money transmitters safeguard customer funds via a surety bond payable to the State of Nevada, sized at the greater of a statutory minimum or 100% of average daily transmission liability up to a $500,000 cap, alongside restrictions on permissible investments such as excluding delegate receivables older than seven days. Trust companies, the digital-asset-custody route, instead must segregate trust funds and investments from their own assets, separately designated to the beneficial trust or estate, and maintain fidelity bonds or insurance under NRS 669.240.

no periodic updates on record for this sub-brief

Sources and findings (7)
  1. T1https://www.leg.state.nv.us/nrs/nrs-671.htmlretrieved
  2. T1https://www.leg.state.nv.us/nrs/NRS-598.htmlretrieved
  3. T3https://businesslaw.uslegal.com/deceptive-trade-practices-laws/nevada-deceptive-trade-practices-laws/retrieved
  4. T1https://www.leg.state.nv.us/nrs/nrs-669.htmlretrieved
  5. T3https://legalclarity.org/nevada-cryptocurrency-laws-licensing-taxes-and-compliance/retrieved
  6. T1NRS Chapter 671 (Nevada) — NRS Chapter 671 (Nevada) — Surety bond payable to the State of Nevada, greater of statutory minimum or 100% of average daily transmission liability (capped $500,000), plus permissible-investment restrictionsretrieved
  7. T1NRS Chapter 669 (Nevada) — NRS Chapter 669 (Nevada) — Retail trust companies must segregate trust funds/investments from own assets, separately designated to the beneficial trust/estate, plus NRS 669.240 fidelity bonds/insuranceretrieved

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Nevada has no dedicated stablecoin/virtual-currency licensing statute; digital-asset custody is routed through the NRS 669 trust-company regime or NRS 671 money-transmitter regime. The Prime Trust receivership (2023) is the standing-state anchor event for custody-failure risk.

Standing sub-brief · as of 5 July 2026 137 words · last cycle 2026-07-05

Stablecoins & Digital Money

Nevada has no dedicated statute licensing virtual-currency or stablecoin issuers; a 2019 bill, S.B. 195, proposed a bespoke license but did not pass, and Nevada was not among the states that adopted the Model Act's optional virtual-currency-business licensing article. That gap was starkly exposed by Prime Trust, LLC, whose 2023 collapse under the NRS 669 trust-company regime remains Nevada's anchor digital-custody-failure precedent: state regulators issued a cease-and-desist on June 21, 2023 and petitioned for receivership five days later, alleging roughly $85 million in fiat obligations against only about $2.9 million in fiat reserves.

no periodic updates on record for this sub-brief

Sources and findings (8)
  1. T2https://legalclarity.org/nevada-cryptocurrency-laws-licensing-taxes-and-compliance/retrieved
  2. T2https://legalclarity.org/nevada-cryptocurrency-laws-licensing-taxes-and-compliance/retrieved
  3. T1https://www.business.nv.gov/news-media/press-releases/2023/financial-institutions/nevada-financial-institutions-division-statement-regarding-prime-trust-llc/retrieved
  4. T1https://www.business.nv.gov/News_Media/Press_Releases/2023/Financial_Institutions/Nevada_Financial_Institutions_Division_files_court_petition_to__Prime_Trust_LLC_in_receivership/retrieved
  5. T2https://www.fintechanddigitalassets.com/2023/08/money-transmission-modernization-act-adopted-in-several-states/retrieved
  6. T1https://www.business.nv.gov/news-media/press-releases/2019/financial-institutions/nevada-financial-institutions-division-statement-on-regulation-of-cryptocurrency-in-nevada/retrieved
  7. T1Prime Trust, LLC — Prime Trust, LLC — NFID issued a cease-and-desist (June 21, 2023) and petitioned for receivership (June 26, 2023) after alleging insolvency (~$85m fiat obligations vs ~$2.9m fiat reserves) and misuse of customer funds since Dec 2021retrieved
  8. T1State of Nevada (NFID) — State of Nevada (NFID) — Virtual-currency/stablecoin issuer licensing; S.B. 195 (2019) proposed a bespoke license but did not pass, and NV did not adopt the Model Act's optional virtual-currency-business licensing articleretrieved

#

Nevada has no general cross-sector payments operational-resilience statute; the standing regime is sector-specific to gaming payments via Regulation 14.

Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. Open its jurisdiction pages on Dataprotection.gi →

Standing sub-brief · as of 5 July 2026 74 words · last cycle 2026-07-05

Operational Resilience & Critical Infrastructure

Nevada has no general cross-sector payments operational-resilience statute; the standing regime is gaming-sector-specific and administered by the Nevada Gaming Control Board through Regulation 14, which governs cashless wagering, mobile gaming and interactive gaming systems and requires independent testing laboratories to certify systems and modifications before deployment.

Outlook

Absent a general operational-resilience statute, gaming-sector technical certification under Regulation 14 will likely remain Nevada's de facto substitute for a DORA-equivalent framework.

no periodic updates on record for this sub-brief

Sources and findings (6)
  1. T1https://www.gaming.nv.gov/siteassets/content/home/features/Regulation14.pdfretrieved
  2. T1https://www.gaming.nv.gov/divisions/audit-division/faqs/slots/retrieved
  3. T3https://cdcgaming.com/nevada-gaming-regulators-approve-changes-covering-cashless-gaming-and-digital-payments/retrieved
  4. T3https://thenevadaindependent.com/article/nevada-gaming-commission-approves-regulation-allowing-cashless-registrationretrieved
  5. T3https://thenevadaindependent.com/article/as-cashless-gaming-spreads-how-are-nevada-regulators-making-sure-its-saferetrieved
  6. T1Nevada Gaming Control Board — Nevada Gaming Control Board — Regulation 14 governs cashless wagering, mobile gaming and interactive gaming systems; independent testing laboratories must certify systems/modifications before deploymentretrieved

#

Nevada's scheme-compliance layer is federal-rules-driven (Durbin, Visa/Mastercard surcharge caps) overlaid with state surcharge disclosure/cash-discount protections and gaming-specific Regulation 14.

Standing sub-brief · as of 5 July 2026 68 words · last cycle 2026-07-05

Scheme & Network Compliance

Nevada permits merchant card surcharging capped at the merchant's actual cost of acceptance, layered on top of the federal Durbin debit-interchange cap and the Visa 3% and Mastercard 4% network surcharge ceilings, with mandatory signage, itemization and disclosure at the point of sale.

Outlook

Nevada's scheme-compliance layer will continue to track federal Durbin and card-network surcharge-cap changes rather than diverge with bespoke state rulemaking.

no periodic updates on record for this sub-brief

Sources and findings (6)
  1. T1https://www.nevadatreasurer.gov/uploadedFiles/nevadatreasurergov/content/Merch/Forms/General_Electronic_Payment_Acceptance_Fees.pdfretrieved
  2. T3https://www.getflexpoint.com/credit-card-surcharging-us-states/nevadaretrieved
  3. T3https://www.nfib.com/wp-content/uploads/2025/07/Credit-Card-Surcharge-Guide-Final-PDF.pdf
  4. T1https://www.gaming.nv.gov/regulations/gaming-statutes-regulations/retrieved
  5. T1https://law.justia.com/codes/nevada/chapter-622/statute-622-233/retrieved
  6. T1State of Nevada (surcharge regime) — State of Nevada (surcharge regime) — Surcharge capped at merchant cost-of-acceptance, layered on federal Durbin debit-interchange cap and Visa (3%)/Mastercard (4%) network caps; signage, itemization and disclosure mandatoryretrieved

#

Nevada's transmitter base is embedded in the US-Mexico corridor, with growing crypto-exchange rail share and forthcoming GENIUS Act federal stablecoin oversight.

Standing sub-brief · as of 5 July 2026 120 words · last cycle 2026-07-05

Payment Corridor Dynamics

Nevada-licensed transmitters operate within the US-Mexico remittance corridor, where the average fee stood near 5% on a $200 transfer in the first quarter of 2025, Mexico received $64.7 billion in remittances in 2024, and crypto-exchange rails, led by Bitso, now account for more than 10% of corridor volume, over $6.5 billion. That crypto-rail growth is occurring against a newly settled federal backdrop: the GENIUS Act, signed into law July 18, 2025, brings US dollar-backed stablecoin issuers under federal oversight, requiring 100% reserve backing and monthly reserve attestations.

no periodic updates on record for this sub-brief

Sources and findings (6)
  1. T1https://www.dallasfed.org/banking/pubs/dfb/2025/2504-dunbar-remitretrieved
  2. T1https://www.dallasfed.org/banking/pubs/dfb/2025/2504-dunbar-remitretrieved
  3. T1https://www.dallasfed.org/banking/pubs/dfb/2025/2504-dunbar-remitretrieved
  4. T3https://moneytransmitterlaw.com/state-laws/nevada/retrieved
  5. T1US-Mexico remittance corridor — US-Mexico remittance corridor — Average fee ~5% (Q1 2025, $200 transfer); Mexico received $64.7bn in 2024; Bitso alone processed >$6.5bn (>10% of corridor volume) via crypto conversionretrieved
  6. T1GENIUS Act (US federal stablecoin law) — GENIUS Act (US federal stablecoin law) — Signed by President Trump on July 18, 2025 (a date prior to this July 5, 2026 research cycle), bringing US dollar-backed stablecoin issuers under federal oversight with 100% reserve backing and monthly reserve attestationsretrieved

#

Nevada's payments industry structure is dominated by gaming-payments specialists (Everi, Pavilion Payments), with 2025 PE consolidation (Apollo/Everi-IGT) and a secondary Reno fintech cluster.

Standing sub-brief · as of 5 July 2026 68 words · last cycle 2026-07-05

Industry Structure & Commercial Dynamics

Apollo Global Management completed its acquisition of Everi Holdings and IGT's gaming and digital assets on July 1, 2025, forming a combined enterprise valued near $6.4 billion and consolidating gaming-payments infrastructure under private-equity ownership, reinforcing Las Vegas as the dominant US gaming-payments cluster.

Outlook

Further private-equity consolidation of Nevada's gaming-payments specialists is likely as owners seek scale in cashless and interactive gaming infrastructure.

no periodic updates on record for this sub-brief

Sources and findings (6)
  1. T3https://fintechmagazine.com/company-reports/everi-leading-gaming-into-a-digital-futureretrieved
  2. T3https://en.wikipedia.org/wiki/Everi_Holdingsretrieved
  3. T3https://www.privsource.com/acquisitions/payments-fintech/state/nevadaretrieved
  4. T3https://gamingamerica.com/directory/36/everi-holdingsretrieved
  5. T3https://www.edawn.org/media-pr/two-biotech-and-fintech-company-headquarters-make-the-move-to-northern-nevada/retrieved
  6. T3Apollo Global Management / Everi Holdings / IGT — Apollo Global Management / Everi Holdings / IGT — Apollo completed acquisition of Everi and IGT gaming/digital assets July 1, 2025, forming a combined enterprise valued near $6.4bn, reinforcing Las Vegas as the dominant US gaming-payments clusterretrieved

The landmark NV payments litigation event is the Prime Trust receivership/Chapter 11 (2023); historical precedent includes a 2010 Global Cash Access securities settlement.

Standing sub-brief · as of 5 July 2026 79 words · last cycle 2026-07-05

Legal & Litigation

The Nevada Financial Institutions Division petitioned the Eighth Judicial District Court of Nevada on June 26, 2023, under NRS 669.2846, alleging that Prime Trust, LLC breached its fiduciary duties under Nevada trust law and was insolvent; Prime Trust subsequently filed for Chapter 11 in Delaware in August 2023, with a former Bank of Nevada president appointed receiver.

no periodic updates on record for this sub-brief

Sources and findings (10)
  1. T1https://www.business.nv.gov/News_Media/Press_Releases/2023/Financial_Institutions/Nevada_Financial_Institutions_Division_files_court_petition_to__Prime_Trust_LLC_in_receivership/retrieved
  2. T3https://cryptodaily.co.uk/2023/08/prime-trust-files-for-chapter-11-bankruptcyretrieved
  3. T3https://www.law360.com/articles/1711252/crypto-firm-prime-trust-hits-ch-11-after-nevada-receivershipretrieved
  4. T1https://www.sec.gov/Archives/edgar/data/0001318568/000095012310024985/c97914exv99w1.htmretrieved
  5. T1https://www.sec.gov/Archives/edgar/data/0000781891/000093066101500072/dex207.txtretrieved
  6. T1Nevada Financial Institutions Division (NFID) v. Prime Trust LLC — Nevada Financial Institutions Division (NFID) v. Prime Trust LLC — NFID petitioned the Eighth Judicial District Court of Nevada (June 26, 2023) under NRS 669.2846 alleging Prime Trust breached fiduciary duties under Nevada trust law and was insolventretrieved
  7. T29th Circuit Court of Appeals — 9th Circuit Court of Appeals — 9th Circuit unanimously ruled Nevada gaming regulators may enforce state gambling law against Kalshi's sports-event contracts, rejecting Kalshi's Commodity Exchange Act preemption argument
  8. T1KalshiEX LLC v. Assad (9th Cir. No. 25-7516) — KalshiEX LLC v. Assad (9th Cir. No. 25-7516) — Ninth Circuit affirmed dissolution of Kalshi's preliminary injunction against NGCB, holding CEA preemption unlikely to succeed on the merits.retrieved
  9. T1CFTC — CFTC asserted exclusive federal jurisdiction over event-contract markets in the underlying Ninth Circuit litigation. Applies beyond this jurisdiction (United States)retrieved
  10. T3Kalshi — Kalshi filed a petition for en banc rehearing of the Aug 28 panel decision on Sept 9, 2026, pausing further escalation to SCOTUS from Nevada's case specifically.retrieved

#

Nevada permits regulated card surcharging while cannabis merchants remain the acute high-risk-merchant segment excluded from mainstream acquiring.

Standing sub-brief · as of 5 July 2026 52 words · last cycle 2026-08-05

Merchant Acquiring & Risk

Nevada's cannabis-related businesses remain excluded from mainstream card-network acquiring despite state legalization, forcing reliance on specialized high-risk payment processors and cannabis-friendly banks to access basic merchant services.

Outlook

Cannabis-sector exclusion from mainstream acquiring is likely to persist until federal rescheduling or bank-access legislation changes the underlying risk calculus.

Periodic update · new data 2026-08-11

Merchant Acquiring & Risk

The Nevada Gaming Commission approved a narrow regulation change permitting remote, pre-arrival registration for cashless wagering accounts, a departure from the state's in-person registration norm for gaming account onboarding. Regulators flagged an identity-verification integrity trade-off against the added convenience when approving the change, under an NGC gaming licence covering cashless wagering systems, with no stated exemption from the change.

Outlook

The scope of this carve-out is narrow and specific to cashless wagering accounts; the extent to which comparable registration relaxations might extend to other account-opening contexts was not evidenced this cycle.

Sources and findings (6)
  1. T3https://merchantcostconsulting.com/lower-credit-card-processing-fees/nevada-credit-card-surcharge-laws/retrieved
  2. T3https://greenleafbizsolutions.com/banking/cannabis-hemp-business/retrieved
  3. T3https://nevadastatecannabis.org/business/bankingretrieved
  4. T3https://www.herringbank.com/business-banking/cannabis-banking/nevada/retrieved
  5. T1https://law.justia.com/codes/nevada/2010/title1/chapter1/nrs1-113.htmlretrieved
  6. T3Nevada cannabis-related businesses — Nevada cannabis-related businesses — Excluded from mainstream card-network acquiring despite state legalization; reliant on specialized high-risk processors and cannabis-friendly banksretrieved

#

Nevada operates the REPPI statutory fintech sandbox and has progressively liberalized cashless/mobile gaming-payment technology since 2020.

Standing sub-brief · as of 5 July 2026 82 words · last cycle 2026-10-04

Product Innovation & Market Development

Nevada's REPPI fintech sandbox permits bounded product testing capped at 5,000 consumers, waivable to 7,500, with money-transmittal limits of $2,500 per transaction and $25,000 per consumer series, waivable to $15,000 and $50,000 respectively, a 90-day regulatory decision window, and test periods running up to two years.

Outlook

As one of the few US states running a statutory fintech sandbox, Nevada is likely to keep REPPI as its primary controlled-testing channel for new payment and money-transmittal product models.

Periodic update · new data 2026-10-04

Product Innovation & Market Development

The most significant product-access development this cycle for a payments-adjacent product in Nevada is the exclusion of sports-referencing prediction-market event contracts from the state, achieved through gaming-regulatory rather than payments-regulatory or securities-regulatory enforcement. The Nevada Gaming Control Board filed a civil enforcement action against Coinbase Financial Markets, Inc., a CFTC-registered Futures Commission Merchant, on 2 February 2026, seeking a declaration and injunction to stop the firm offering unlicensed sports event-contract wagering in the state. The Ninth Circuit's ruling of 28 August 2026, affirming Nevada's authority over the same product line as offered by Kalshi, reinforces that the operative market-access lever for this product category is the state's gaming statute, not its money-transmission or securities framework.

This is an atypical mechanism for excluding a payments-adjacent product from a state market: the entity in question holds federal commodities-market registration, yet that registration provides no defence against a state gaming regulator's determination that the underlying product constitutes unlicensed wagering. For product teams evaluating event-contract or prediction-market-adjacent product lines, the Nevada experience demonstrates that federal financial-market registration does not substitute for compliance with state gaming law where a product's underlying mechanics resemble wagering on an event outcome, regardless of how the product is structured or registered at the federal level.

Outlook

The circuit split between the Ninth Circuit (affirming Nevada's authority) and the Third Circuit (ruling favourably to Kalshi in a New Jersey matter) raises the prospect of further appellate or Supreme Court activity that could alter the durability of this gaming-law-based product exclusion mechanism. Any product team building event-contract or prediction-market-adjacent offerings with US market ambitions should treat Nevada's current posture as a live and contested legal question rather than a settled one.

Sources and findings (9)
  1. T1https://business.nv.gov/Programs/Nevada_Sandbox_FAQs/retrieved
  2. T3https://nevadabusiness.com/2020/01/nevada-establishes-leadership-in-tests-of-new-financial-blockchain-products/retrieved
  3. T2https://csgsouth.org/wp-content/uploads/EDTCA-Fintech-Sandbox.pdfretrieved
  4. T3https://www.casino.org/news/nevada-gaming-commission-approves-first-step-to-expand-cashless-wagering-at-casinos/retrieved
  5. T2https://legalclarity.org/nevada-cryptocurrency-laws-licensing-taxes-and-compliance/retrieved
  6. T1Nevada REPPI (fintech sandbox) — Nevada REPPI (fintech sandbox) — Tests limited to 5,000 consumers (waivable 7,500); money-transmittal caps $2,500/txn, $25,000/consumer series (waivable $15k/$50k); 90-day decision window; up to 2-year test periodretrieved
  7. T1Kalshi — Kalshi entered a settlement agreement admitting continued violation of a Nevada court order, agreeing to a $120,000/day penalty pending full complianceretrieved
  8. T3Sports-related prediction-market contracts (Nevada) — Sports-related prediction-market contracts (Nevada) — As of Oct 2, 2026, Nevada residents still lack access to sports-related prediction-market contracts, confirming continued enforcement effect of the Aug 28 ruling.retrieved
  9. T3Nevada Gaming Control Board — Nevada Gaming Control Board — NGCB chair stated at G2E (early Oct 2026) that prediction markets must meet the same licensing, AML, taxation and integrity bar as licensed sportsbooks.retrieved

#

Consumer protection for payments-adjacent conduct runs through NRS 598 rather than a bespoke payments-conduct statute; no dedicated APP-fraud reimbursement mandate identified.

Standing sub-brief · as of 5 July 2026 76 words · last cycle 2026-07-05

Consumer Protection & APP Fraud

Nevada has no dedicated payments-conduct or mandatory app-fraud reimbursement statute of the UK Payment Systems Regulator type; consumer protection instead runs through the general deceptive-trade-practices regime under NRS Chapter 598, enforced by the Attorney General's Consumer Affairs Unit and the Commissioner of Financial Institutions.

Outlook

Absent a UK-style mandatory reimbursement mandate, Nevada consumers facing authorised-push-payment fraud will likely continue to rely on general deceptive-trade-practices remedies rather than a scheme-specific redress mechanism.

no periodic updates on record for this sub-brief

Sources and findings (5)
  1. T1https://www.leg.state.nv.us/nrs/NRS-598.htmlretrieved
  2. T3https://www.jmargolin.com/zandian/zweb/appeal2/nrs598.htmretrieved
  3. T3https://businesslaw.uslegal.com/deceptive-trade-practices-laws/nevada-deceptive-trade-practices-laws/retrieved
  4. T2https://www.figuremarkets.com/disclosures/money-transmission-disclosures/retrieved
  5. T1NRS Chapter 598 (Nevada) — NRS Chapter 598 (Nevada) — General deceptive-trade-practices regime enforced by AG Consumer Affairs Unit and Commissioner of Financial Institutions; no UK-PSR-type mandatory APP-fraud reimbursement scheme identifiedretrieved

#

W11 carries the Sentinel.gi payments-context position only; public BSA/FinCEN material confirms Nevada's Title 31 casino-specific regime (Regulation 6A) with Sparks Nugget as the notable enforcement precedent.

Open gap — wpm-int-2No AML/CFT sentinel-fed delta for US-NV was available this cycle.Reflects known under-indexing of US state-level divergence in corridor data per bias-correction guidance.
Horizon · 2026-09-02 (± a quarter)Southwest Border Geographic Targeting Order (SWB GTO) expirationIn force · Tier 1 source
Horizon · 2026-09-02 (± a quarter)Southwest Border Geographic Targeting Order (SWB GTO) expirationIn force · Tier 1 source
Standing sub-brief · as of 5 July 2026 148 words · last cycle 2026-07-05

AML/CFT & Financial Crime

Per Sentinel.gi-fed material, Nevada casinos with gross annual gaming revenue above $10 million are subject to state-specific Regulation 6A in place of the standard federal Currency Transaction Report regime under a special Treasury arrangement; the standing enforcement precedent is FinCEN's $1 million civil money penalty against Sparks Nugget, Inc. for willful, systemic anti-money-laundering, CTR and SAR-filing violations. Separately, the reissued FinCEN Southwest Border Geographic Targeting Order, effective March 7, 2025 through September 2, 2026, imposes enhanced Currency Transaction Report obligations on covered money-services businesses for transactions between $1,000 and $10,000, relevant to Nevada-licensed MSBs with border-adjacent exposure; original illicit-finance analysis of these materials sits with the Sentinel.gi feed rather than WPM.

no periodic updates on record for this sub-brief

Sources and findings (10)
  1. T3https://www.solvent.io/cannabis-banking/nevadaretrieved
  2. T?FIM (sentinel.gi) per-JID baseline profile — United States — Nevada — Nevada casinos operate under a 1985 Treasury-Nevada agreement layering state Gaming Control Board/Gaming Commission suitability and reporting rules atop federal BSA obligations administered by FinCEN. Nevada is also a major U.S. shell-company formation state; the 2025 federal CTA rule change now exempts all domestic entities from beneficial-ownership reporting, widening corporate-opacity exposure for Nevada-registered entities.
  3. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-004) — Gap: absent-field-provenance
  4. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: capacity-deficit
  5. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: legal-gap
  6. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: enforcement-absence
  7. T1FIM (sentinel.gi) enforcement_action_register — Enforcement action
  8. T1Nevada casinos (GAGR > $10,000,000) — Nevada casinos (GAGR > $10,000,000) — sentinel.context: subject to Nevada State Regulation 6A instead of the standard federal CTR regime, per special Treasury agreement, given their status as BSA-defined financial institutionsretrieved
  9. T1Sparks Nugget, Inc. — Sparks Nugget, Inc. — sentinel.enforcement: FinCEN imposed a $1 million civil money penalty for willful, systemic AML program, CTR and SAR-filing violationsretrieved
  10. T1FinCEN Southwest Border Geographic Targeting Order — FinCEN Southwest Border Geographic Targeting Order — sentinel.context: Reissued SWB GTO (effective March 7, 2025 through September 2, 2026) requires enhanced CTR obligations for covered MSBs on transactions $1,000-$10,000, relevant to NV-licensed MSBs with border-adjacent exposureretrieved

#

The dominant correspondent-banking/settlement-access issue for Nevada is cannabis-sector de-risking, driving AG advocacy for the SAFER Banking Act and a prior closed-loop settlement pilot.

Standing sub-brief · as of 5 July 2026 81 words · last cycle 2026-07-05

Correspondent Banking, Settlement & Access

Per the module's analytical spine, bank-affiliated payment-service providers retain correspondent-banking access that cannabis-adjacent non-bank money-service businesses in Nevada are largely denied; Attorney General Aaron Ford joined a bipartisan coalition of state attorneys general in 2025 urging Congress to pass the SAFER Banking Act, citing cannabis-sector correspondent-banking and settlement de-risking risk.

no periodic updates on record for this sub-brief

Sources and findings (6)
  1. T2https://www.2news.com/news/nevada-ag-joins-bipartisan-push-to-expand-cannabis-banking-protections-in-renewed-effort/article_d4f5e2ae-5d9c-11ee-b355-736b881dae8a.htmlretrieved
  2. T3https://www.nevadaemployers.org/nevadas-cannabis-industry-to-gain-access-to-banking/retrieved
  3. T3https://greenleafbizsolutions.com/banking/cannabis-hemp-business/retrieved
  4. T1https://www.nevadatreasurer.gov/uploadedFiles/treasurernvgov/content/PublicInfo/Closed-loop%20system%20one-pager.pdfretrieved
  5. T3https://cryptodaily.co.uk/2023/08/prime-trust-files-for-chapter-11-bankruptcyretrieved
  6. T3Nevada Attorney General Aaron Ford — Nevada Attorney General Aaron Ford — Joined bipartisan AG coalition (2025) urging Congress to pass the SAFER Banking Act, citing cannabis-sector correspondent-banking/settlement de-risking risksretrieved

#

The trailing-12-month window is dominated by Apollo's ~$6.4bn Everi/IGT completion (July 2025) and OBOOK's Nevada MTL grant (January 2026), alongside smaller payments-technology bolt-ons.

Key judgment — Probable · impact ELEVATEDUpgrade's Nevada ILC application signals continued fintech interest in the industrial-loan-company charter route as a captive, FDIC-insured funding vehicle that supplements rather than replaces existing bank-partner arrangements.claims: wpm-2026-W42-001, wpm-2026-W42-002
Standing sub-brief · as of 5 July 2026 157 words · last cycle 2026-10-18

Commercial Intelligence (M&A, Investment & Product)

Apollo Global Management completed its acquisition of Everi Holdings and IGT's gaming and digital assets on July 1, 2025, forming a combined enterprise valued near $6.4 billion. Pavilion Payments acquired CasinoSoft, an AML and Title 31 compliance and regulatory-reporting software provider, to build an end-to-end payments-and-compliance platform; the deal value was not publicly disclosed. CPI Card Group Inc. acquired Arroweye Solutions, Inc., an on-demand digitally-driven payment card manufacturer, extending card-production capacity in the Nevada payments cluster; the deal value was not publicly disclosed. OBOOK Holdings Inc., part of the OwlTing Group, announced on January 14, 2026 that it had obtained a Nevada Money Transmitter License, expanding its cross-border payment network's US regulatory footprint to 41 states.

Periodic update · new data 2026-10-18

Commercial Intelligence & Fintech

Upgrade, Inc. filed applications with the Nevada Financial Institutions Division and the FDIC on October 12, 2026 to establish "Upgrade Bank" as a Nevada-chartered industrial loan company, operating as a wholly owned, FDIC-insured subsidiary. The event has not had its financial terms disclosed, which is not unusual for a regulatory-charter filing of this type rather than a transaction with a stated deal value; the filing is a licensing and market-access move, not a disclosed-value commercial transaction.

Upgrade has stated the proposed bank would complement, not replace, its existing bank-partner relationships with Cross River Bank, a New Jersey state-chartered bank, and Celtic Bank, a Utah industrial loan company, both of which currently fund Upgrade's buy-now-pay-later, personal loan, credit card and auto-finance products. This positions the ILC application as an additive, captive funding vehicle rather than a replacement of Upgrade's existing sponsor-bank-dependent model. Both the Nevada FID and FDIC applications remain under regulatory review, and Upgrade has itself disclosed that approval of either application, and its timing, is not guaranteed; no regulator confirmation of the application's status is available at this time.

The filing is notable within the broader pattern of nonbank fintech platforms pursuing the industrial-loan-company charter as a route to a federally insured deposit-taking subsidiary without the consolidated supervision that would attach to a bank holding company structure under the Bank Holding Company Act.

Outlook

The next dated marker to watch is any public notice, comment period opening, or decision from the Nevada Financial Institutions Division or the FDIC on the Upgrade Bank applications. No timeline for either regulator's decision has been disclosed.

1 earlier distinct update(s)
Periodic update · new data 2026-10-11

Commercial Intelligence & Fintech

Navra, a Las Vegas, Nevada-based startup, closed a $19 million Series A funding round on October 6, 2026. The round was led by Ribbit Capital, with Baseline, DCM, Jump Crypto and Figure Technology Solutions also participating. Navra is building a white-label, AI-native blockchain-access platform designed to integrate Figure's YLDS stablecoin and the Democratized Prime yield protocol, positioning the company as an infrastructure provider for other platforms to embed stablecoin and yield functionality rather than as a direct-to-consumer payments brand. The post-money valuation of the round was not disclosed.

This is a discrete commercial event rather than a structural market-trend finding: a single, well-corroborated funding round for one company, not a broader shift in Nevada's or the broader fintech sector's investment patterns. It is distinct from a thematic product-access regulatory development; no new regulatory framework for blockchain-access platforms or stablecoin-integrated products was identified in connection with this raise, and the finding is confined to the transaction itself. A limited rollout of Navra's platform is reported for late October 2026, though the precise scope of that initial rollout was not confirmed in the sourcing available this cycle.

The regulatory footprint of Navra's business model in Nevada is presently unresolved. No confirmation was found, within the scope of commercial-intelligence sourcing, that Navra holds or is required to hold a licence under any Nevada payments-adjacent statute, including the state's money-transmission framework administered by the Nevada Financial Institutions Division. This is an open question rather than a settled finding, and it is flagged rather than resolved here, since confirming licensure status would require research outside this cycle's commercial-intelligence scope.

The transaction connects to two other monitors tracking Nevada this cycle without duplicating their analysis. The crypto-regulatory monitor's coverage of the same Navra round sits under its commercial-activity module, against the backdrop of Nevada's existing case-by-case virtual-currency money-transmission enforcement framework. The financial-integrity monitor's coverage of Nevada this cycle, concerning new named-accountability AML rules for gaming licensees and a pending federal AML/CFT Program Rule proposal, is not directly linked to Navra's business model, but the general direction of AML governance tightening in Nevada is relevant backdrop for any stablecoin-integrated payment intermediary that might, in the future, intersect with BSA-covered activity in the state.

Outlook

The reported late-October 2026 limited rollout is the near-term event most likely to clarify Navra's actual operating model and, by extension, its payments-regulatory exposure in Nevada. Whether the platform's white-label, infrastructure-layer positioning is sufficient to place it outside Nevada money-transmission licensure requirements, or whether its handling of stablecoin-denominated value transfer brings it within that framework, remains the central open question for this jurisdiction's payments-regulatory posture going forward. No further commercial-intelligence development for Nevada was identified this cycle.

Sources and findings (12)
  1. T1https://www.sec.gov/Archives/edgar/data/0002025416/000119312526012903/d75989dex991.htmretrieved
  2. T3https://igamingexpress.com/brands/everi/retrieved
  3. T3https://www.privsource.com/acquisitions/payments-fintech/state/nevadaretrieved
  4. T3https://www.privsource.com/acquisitions/payments-fintech/state/nevadaretrieved
  5. T3Upgrade, Inc. — Upgrade, Inc. filed applications with the Nevada Financial Institutions Division and the FDIC on October 12, 2026 to establish 'Upgrade Bank', a Nevada-chartered industrial loan bank, as a wholly owned FDIC-insured subsidiaryretrieved
  6. T3Navra — Navra (Las Vegas, NV) closed a $19m Series A on Oct 6, 2026, led by Ribbit Capital with Baseline, DCM, Jump Crypto and Figure Technology Solutions participating, to build a white-label AI-native blockchain-access platform integrating Figure's YLDS stablecoin and Democratized Prime yield protocol.retrieved
  7. T3Apollo Global Management / Everi Holdings / IGT — Apollo Global Management / Everi Holdings / IGT — Apollo completed acquisition of Everi Holdings and IGT gaming/digital assets on July 1, 2025, forming a combined enterprise valued near $6.4bnretrieved
  8. T3Pavilion Payments / CasinoSoft — Pavilion Payments / CasinoSoft — Pavilion Payments (Las Vegas) acquired CasinoSoft, an AML/Title 31 compliance and regulatory-reporting software provider, to build an end-to-end payments-and-compliance platformretrieved
  9. T3CPI Card Group / Arroweye Solutions — CPI Card Group / Arroweye Solutions — CPI Card Group Inc. (Nasdaq: PMTS) acquired Arroweye Solutions, Inc., an on-demand digitally-driven payment card manufacturer, extending card-production capacity in the Nevada payments clusterretrieved
  10. T1OBOOK Holdings Inc. (OwlTing Group) — OBOOK Holdings Inc. (OwlTing Group) — Announced January 14, 2026 that it obtained a Nevada Money Transmitter License, expanding its US regulatory footprint to 41 states for its cross-border payment networkretrieved
  11. T3Upgrade, Inc. — Upgrade, Inc. — Upgrade said the proposed bank would complement, not replace, existing bank-partner relationships with Cross River Bank (NJ state-chartered) and Celtic Bank (Utah ILC), funding its BNPL, personal loan, credit card and auto-finance productsretrieved
  12. T3Upgrade, Inc. — Upgrade, Inc. — Both the Nevada FID and FDIC applications remain under regulatory review; Upgrade stated approval of either, and its timing, is not guaranteedretrieved
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