United States – Washington Payments & Fintech Regulation

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

Last updated · 14 modules · 125 sourced findings · 140 sources in the cumulative register

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

Jurisdiction brief

Latest update · 26 October 2026

Lead Signal

Washington's Department of Financial Institutions has entered a multistate consent order with crypto-kiosk operator Coinme, Inc., dated 8 October 2026, requiring the company to cease crypto-kiosk operations, pay $2.5 million in penalties and costs, and adopt additional compliance measures. The action is notable for market-access purposes because Washington brings it entirely through its general money-transmitter licensing perimeter rather than through any crypto-specific authorisation regime: virtual-currency kiosks, exchange platforms that settle transactions, hosted-wallet services with transfer control, and virtual-currency payment processors are all treated as falling within the existing money-transmitter framework under the Uniform Money Services Act, RCW 19.230, and WAC 208-690, provided they serve Washington residents. For non-bank payment-institution and e-money-style operators considering the Washington market, this confirms that licensing under the general money-transmitter category is the applicable authorisation route for virtual-currency activity, and that the state is prepared to enforce actively against licensees operating kiosk infrastructure that falls short of its requirements.

Key regulatory facts for United States – Washington
Regulatory DimensionUnited States – Washington Standing Position
JurisdictionUnited States – Washington (US-WA)
Regulatory ScopePayments & Fintech Regulation (14 modules, 125 sourced findings)
Licensing, Authorisation & Market AccessWashington licenses money transmitters (including virtual-currency transmitters) under the Uniform Money Services Act (RCW 19.230 / WAC 208-690), administered by DFI; a new Earned Wage Access Services Act licensing...
Conduct, Safeguarding & PromotionsWashington's conduct regime centres on a named Responsible Individual per licensee, mandatory permissible-investment/safeguarding of customer funds, a statutory refund right, and federal Regulation E...
Stablecoins & Digital MoneyWashington treats virtual currency (including stablecoins) as money transmission under 2017 RCW 19.230 amendments, layering a state licensing/custody regime atop the federal GENIUS Act (enacted 18 Jul 2025 but NOT...
Operational Resilience & Critical InfrastructureOperational resilience obligations for Washington money transmitters are embedded in WAC 208-690 rather than a standalone resilience statute: cybersecurity, business-continuity, recordkeeping and third-party/agent...
Primary Instruments CitedUnited States – Washington Official Instrument (app.leg.wa.gov default-aspx-Cite-19-230-full-tr), United States – Washington Official Instrument (dfi.wa.gov money-transmitter-and-currency-e), United States – Washington Official Instrument (app.leg.wa.gov default-aspx-cite-208-690-060), United States – Washington Official Instrument (app.leg.wa.gov default-aspx-cite-208-690-040), United States – Washington Official Instrument (dwt.com washington-state-updates-money-s)
Last Confirmed / Updated2026-11-04 (140 sources in cumulative register)

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Washington licenses money transmitters (including virtual-currency transmitters) under the Uniform Money Services Act (RCW 19.230 / WAC 208-690), administered by DFI; a new Earned Wage Access Services Act licensing regime under DFI commenced July 1, 2026; DFI's multi-state Coinme consent order (Oct 7-8, 2026) and a parallel Bitcoin Depot Statement of Charges materially restrict crypto-kiosk licensee market access.

Key judgment — Probable · impact ELEVATEDWashington's continued use of the general money-transmitter licensing perimeter (rather than a bespoke crypto statute) to enforce against crypto-kiosk operators signals a consistent sub-national regulatory approach that treats crypto custody/transmission as a variant of existing payment services regulation.claims: wpm-2026-W43-001, wpm-2026-W43-002
Open gap — wpm-int-1Full text of the Coinme multistate consent order (with WA-specific penalty allocation) was not independently retrieved this cycle.no under-indexing note recorded
Horizon · 2027-01-01 (± a quarter)Coinme nationwide crypto-kiosk wind-down deadlineAdopted, not yet in force · Tier 1 source
Standing sub-brief · as of 5 July 2026 208 words · last cycle 2026-10-25

Licensing, Authorisation & Market Access

Washington regulates all non-bank money transmission, currency exchange and virtual-currency business activity under a single Money Transmitter/Currency Exchanger licence issued under RCW 19.230 and WAC 208-690, administered through NMLS — there is no separate EMI/PI licence category as found in EU/UK regimes. Licensees must scale tangible net worth to $10,000 per $1 million of company-wide transmission volume, with a floor of $10,000 and a ceiling of $3 million (rising to a $100,000 minimum where virtual-currency storage is offered), and must post a surety bond of $10,000 per $1 million of volume, capped at $550,000. The Department of Financial Institutions participates in the Multistate MSB Licensing Agreement via NMLS; authorized delegates must be physically located in Washington absent prior director approval, and licences are perpetual subject to annual assessment and attestation.

Periodic update · new data 2026-10-26

Licensing, Authorisation & Market Access

Washington's market-access framework for virtual-currency money transmission runs through the general money-transmitter licensing category established under the Uniform Money Services Act, RCW 19.230, and its implementing rules at WAC 208-690, rather than through any bespoke crypto-licensing authorisation. Guidance describes how virtual-currency kiosks and ATMs, exchange platforms that settle transactions, hosted-wallet services exercising transfer control, and virtual-currency payment processors generally fall within this money-transmitter perimeter when serving Washington residents. That standing architecture is the setting for the material development: the Department of Financial Institutions entered a multistate consent order, dated 8 October 2026, with crypto-kiosk operator Coinme, Inc., requiring the company to cease its crypto-kiosk operations, pay $2.5 million in penalties and costs, and implement additional compliance measures. This is not an isolated action. A separate DFI consent order dated 9 February 2026, against an unnamed digital-assets-focused money transmitter, required licence surrender within ninety days, imposed a three-year industry bar, and levied a $150,000 civil penalty (with $50,000 stayed to February 2029) for net-worth, recordkeeping and reporting failures under the same statutory framework. Read together, these two actions indicate that DFI is treating virtual-currency money transmission as a segment warranting sustained supervisory attention within its existing non-bank payment-institution licensing category, rather than leaving the activity under light-touch or dormant oversight pending separate crypto-specific legislation. For any non-bank payment institution or e-money-style operator assessing market access into Washington for crypto-adjacent products, the correct authorisation pathway is the standard money-transmitter licence application, and the compliance bar being actively enforced includes the standard net-worth, recordkeeping and reporting obligations applicable to that licence category.

Outlook

The full text of the Coinme consent order, including the Washington-specific share of the $2.5 million penalty across the thirty-five participating regulators, had not been independently retrieved at the point this material was compiled. Whether Washington moves toward a dedicated virtual-currency money-transmitter sub-category, distinct from the general licence class currently in use, is the main structural question for this module going forward; no legislative proposal to that effect was identified.

6 earlier distinct update(s)
Periodic update · new data 2026-10-18

Licensing, Authorisation & Market Access

Washington's Earned Wage Access Services Act (SSB 5328/HB 1063) brought EWA providers under a DFI licensing requirement as of 1 July 2026. The Department of Financial Institutions set an initial licensing fee of $1,500 and reports approximately 28 initial licensees, establishing EWA as a formally supervised product category under state money-services law rather than an unregulated fintech niche operating outside any dedicated licensing perimeter. This is a market-access development in the most direct sense: firms wishing to offer earned-wage-access products to Washington consumers must now hold a DFI licence to do so lawfully, where previously no such dedicated requirement existed.

On a separate licensee segment, Washington DFI's multi-state consent order with Coinme, Inc., entered 7-8 October 2026, has a direct market-access consequence for that firm: the order requires Coinme to surrender or cease its crypto-kiosk money-transmission activity in Washington by 1 January 2027. This is a market-access restriction imposed through enforcement rather than a change in licensing policy, but its effect is the same in practice, removing a licensed operator's ability to continue offering a specific product in the state.

The parallel Statement of Charges against Bitcoin Depot Operating LLC, entered 8 June 2026 under the same Uniform Money Services Act, remains open in DFI's enforcement register. Its continuing presence alongside the now-resolved Coinme matter indicates that DFI's market-access scrutiny of the crypto-kiosk licensee class is not limited to a single firm; a second major brand in the same product category faces unresolved charges under the same statutory framework.

Taken together, these two threads describe a licensing environment that is simultaneously opening a new regulated channel (EWA) and tightening an existing one (crypto-kiosk money transmission). Both developments run through the same supervisory authority, DFI, and the same general statutory architecture of money-services licensing in the state, even though the specific instruments differ: EWA licensing is product-specific statute, while the crypto-kiosk actions proceed under the Uniform Money Services Act's existing money-transmitter licensing and enforcement powers.

Outlook

For EWA, the figure to watch is the licensee count: whether the initial approximately 28 licensees grows as more providers register under the new $1,500 fee structure, or whether some exit the market rather than absorb the compliance cost, will indicate how the regime beds in over its first full year. For crypto-kiosk money transmission, the key date remains 1 January 2027, Coinme's wind-down deadline, alongside the unresolved disposition of the Bitcoin Depot Statement of Charges, which will show whether DFI's enforcement approach to this licensee class is converging toward a consistent template or will vary materially case by case.

Periodic update · new data 2026-10-11

Licensing, Authorisation & Market Access

Washington's market-access framework for nonbank payment and money-services firms saw its most consequential enforcement event of the year with the Washington State Department of Financial Institutions leading a 34-regulator multi-state consent order against Coinme, Inc., a crypto-kiosk operator, entered 7-8 October 2026. The order, coordinated with money-transmission regulatory agencies across thirty-one other states, requires Coinme to cease all crypto-kiosk operations nationwide before 1 January 2027, undergo an independent BSA/AML compliance review, replace compliance-responsible managers, and pay a $2.5 million penalty distributed across the settling agencies. Coinme's crypto-kiosk business falls within Washington's licensing perimeter under the Uniform Money Services Act (RCW 19.230), which treats virtual currency as money or its equivalent, bringing exchange, custody and kiosk operation within the general money-transmission licence administered by DFI -- the same statutory perimeter that governs traditional money-transmission businesses, with no separate crypto-specific licensing code.

This enforcement action should be read against the backdrop of DFI's broader, routine supervisory activity: the department's public enforcement list shows numerous 2026 consent orders and statements of charges spanning mortgage, consumer-loan, check-cashing and securities licensing categories, indicating that the Coinme matter sits within an active and ongoing state-level enforcement capacity rather than representing an isolated or exceptional intervention into the crypto sector specifically.

Separately, and unrelated to the Coinme enforcement action, Washington's market-access architecture for nonbank payment products also includes the Earned Wage Access Services Act, a new chapter of RCW Title 31 created by SB 5328, which took effect 1 July 2026. EWA providers must now hold a DFI licence and maintain a minimum $30,000 surety bond, with employer-integrated EWA fees capped at $10 per month. The statute expressly excludes EWA products from classification as a loan, extension of credit, or money-transmission service, meaning EWA providers sit in a distinct DFI-licensed category rather than under the money-transmitter perimeter that captures crypto-kiosk businesses. This regime was already in force before this cycle and did not change during it; it is noted here as part of the state's layered nonbank-payment licensing structure.

Outlook

The nationwide crypto-kiosk shutdown deadline of 1 January 2027 is the key date for assessing market-access continuity for Coinme and for any other crypto-kiosk operator subject to similar multi-state coordinated scrutiny. Completion of the independent BSA/AML compliance review and the replacement of compliance-responsible managers, both required by the consent order, will be the practical indicators of whether DFI treats the existing RCW 19.230 licensing perimeter as adequate for crypto-kiosk business models going forward, or whether further rulemaking specific to crypto money-transmission activity follows.

Periodic update · new data 2026-09-28

Licensing, Authorisation & Market Access

Washington regulates money transmitters, including virtual-currency businesses, under the general Uniform Money Services Act (UMSA, RCW 19.230; implementing rule WAC 208-690), with no separate crypto-specific licensing track. This is a nonbank PI/EMI-style licensing framework administered by the Washington State Department of Financial Institutions, distinct from any bank-chartering pathway, and it now shows clear signs of active, escalating enforcement specifically against digital-asset operators within that nonbank category.

A February 2026 consent order against an unnamed digital-assets-focused money transmitter required cease-and-desist from UMSA violations, licence surrender within 90 days, a civil penalty of $150,000 (of which $50,000 was stayed to 2029), a $4,170 investigation fee, and a three-year industry bar. This action is corroborated by law-firm syndication reporting on what is understood to be a primary DFI order, though the order text itself was not independently retrieved this cycle. A second, larger action followed in September 2026, when DFI filed a Statement of Charges against crypto-kiosk operator CoinFlip (GPD Holdings LLC) seeking licence cancellation, an industry bar, customer refunds, and a civil penalty of $1,029,600. The action cites elder-fraud exposure at cash-to-crypto kiosks as its basis, reported currently through trade-press coverage of a pending regulatory filing rather than a document independently retrieved this cycle.

The licensing pathway for nonbank crypto money transmitters in Washington therefore remains open and functioning as a matter of statute, but the two actions taken within roughly seven months indicate materially elevated market-access risk for any nonbank PI/EMI-class operator judged non-compliant with UMSA's licensing conditions. The absence of a bespoke crypto statute means this risk sits entirely within the general money-transmitter licensing regime rather than a separately calibrated crypto framework.

Outlook

The disposition of the CoinFlip Statement of Charges, whether by settlement, contested hearing, or default, is the clearest near-term signal for how Washington intends to apply its licensing-enforcement authority against nonbank digital-asset money transmitters going forward, with direct implications for market-access conditions in this segment.

Periodic update · new data 2026-09-08

Licensing, Authorisation & Market Access

Washington's Department of Financial Institutions entered a $150,000 consent order against a digital-assets-focused money transmitter this cycle, requiring licence surrender within 90 days for violations of the Uniform Money Services Act spanning net-worth requirements, recordkeeping accuracy, and regulatory filing timeliness. This action confirms that DFI is willing to enforce the full UMSA licensing regime, including its net-worth and reporting provisions, against digital-asset-focused business models with the same rigor applied to traditional money transmitters. Corroborating this, virtual currency is expressly captured as 'equivalent value' for money-transmission licensing purposes under RCW 19.230, meaning that crypto exchange, custody, and money-transmission activity fall within Washington's existing Money Transmitter Licence regime rather than requiring, or benefiting from, a bespoke crypto licence. There is no exemption category currently available to crypto MSBs under this framework.

The structural safeguarding backstop for this licensing regime is the surety-bond mechanism under RCW 19.230 and its implementing rule WAC 208-690: bond levels scale from a $10,000 minimum to a $550,000 maximum according to a licensee's prior-year money-transmission dollar volume, with mandatory annual updates by 1 July. This bond runs to the benefit of the state and of any person who suffers loss by reason of a licensee's violation, functioning as Washington's principal consumer-protection mechanism for nonbank payment institutions and electronic-money issuers operating without bank-grade prudential capital requirements. This is squarely a nonbank_pi_emi regime: bank-affiliated money transmission does not depend on this bond mechanism in the same structural way, and the bank-PSP versus nonbank-PI/EMI distinction is the analytical spine of how this licensing framework actually bites on different entity types.

Taken together, this cycle's single enforcement action, combined with the confirmed regulatory scope-capture of virtual currency, evidences a tightening trajectory in Washington's licensing and market-access posture toward crypto-adjacent money-services businesses, achieved entirely through active enforcement of an existing general statute rather than through any new legislative instrument.

Outlook

Whether DFI's UMSA enforcement extends to further crypto MSBs in coming cycles will determine whether this reflects a durable tightening trajectory in market-access conditions for nonbank crypto payment institutions in Washington, or an isolated action. The identity of the money transmitter named in the February 2026 consent order was not disclosed in sources retrieved this cycle, which limits how precisely the affected segment of the licensed population can be characterised.

Periodic update · new data 2026-08-26

Licensing, Authorisation & Market Access

Washington's W1a domain recorded two developments this cycle moving in opposite directions. The Washington State Earned Wage Access Services Act establishes a new Department of Financial Institutions licence requirement for Earned Wage Access providers, effective July 1, 2026, with background-check and a minimum thirty-thousand-dollar surety-bond requirements attached. This licence sits under the nonbank_pi_emi classification, extending the state's existing bank-PSP versus non-bank-PI/EMI distinction to a product category not previously subject to a dedicated licensing regime. Separately, on February 9, 2026, the Department of Financial Institutions issued a $150,000 consent order and licence-surrender directive against a digital-assets-focused money transmitter for Uniform Money Services Act violations spanning net-worth, recordkeeping, and adverse-action reporting failures; that licensee is also classified under the nonbank_pi_emi distinction. The consent order rests on a single Tier-3 secondary source this cycle, with no independent Tier-1-or-higher corroboration located, a gap carried forward rather than resolved. This cycle's key judgment, assigned an elevated impact rating, reads the two developments together as evidence that Washington's non-bank payments licensing perimeter is simultaneously expanding, through the new Earned Wage Access category, and tightening, through active supervisory enforcement against an existing digital-asset money-transmission licensee.

Outlook

The Earned Wage Access licensing regime's July 1, 2026 effective date, tracked on the regulatory horizon within a quarter-band uncertainty window, is the principal near-term item to watch, alongside whether in-scope providers complete their background-check and surety-bond obligations ahead of that date. The digital-asset money transmitter's licence-surrender process should also be watched for completion, and a primary Washington DFI document corroborating this cycle's secondary reporting would strengthen the evidentiary basis of that finding in a future cycle.

Periodic update · new data 2026-08-11

Licensing, Authorisation & Market Access

Washington's Department of Financial Institutions treats crypto and virtual-currency businesses as fully within money-transmission licensing scope under the state's Uniform Money Services Act (RCW 19.230, WAC 208-690), not as a regulatory gray area, and this cycle produced two enforcement actions that operationalise that standing position. DFI's consent order against CoinZoom, Inc., effective February 9, 2026, requires the firm to cease its UMSA violations and surrender its Washington money-transmitter licence within ninety days, following an alleged tangible-net-worth deficiency. Separately, a Temporary Cease and Desist Order against Coinme, dated December 1, 2025, halts the firm's money-transmission activity and orders refund of more than eight million dollars in unredeemed Bitcoin-ATM voucher balances, alleging a tangible-net-worth failure spanning 2020 through 2025; this finding currently rests on a single Tier-4 source and has not yet attracted Tier-1 or Tier-2 corroboration this cycle.

Both firms fall into the non-bank payment-institution and e-money-institution licensee category rather than the bank-affiliated payment-services channel, and neither could avail itself of an identified exemption pathway from full UMSA licensing once DFI determined a violation. The safeguarding basis in both matters rests on tangible-net-worth and bonding requirements under UMSA, an other-categorised safeguarding mechanism distinct from a codified customer-fund-segregation regime; the Coinme matter in particular alleges that unredeemed Bitcoin-ATM voucher balances were treated as company revenue rather than as customer funds requiring segregation, a safeguarding-architecture gap specific to the crypto cash-in and cash-out layer. Separately, Washington's money transmitters and currency exchangers, including crypto-focused licensees, faced a standing Online Annual Assessment Report filing deadline of July 1, 2026, with late filing risking licence suspension and late fees; this is a durable, standing-brief-tier compliance-calendar obligation rather than a crypto-specific development in itself.

Outlook

The items to watch next cycle are whether CoinZoom completes its ninety-day licence-surrender process on schedule, and whether the Coinme cease-and-desist matter attracts Tier-1 or Tier-2 corroboration beyond its current single Tier-4 source. Washington DFI's willingness to apply full UMSA net-worth, bonding, and safeguarding standards to crypto-focused non-bank money transmitters, evidenced by two enforcement actions within an eight-month window, signals continued tightening of state-level market-access conditions for this licensee category, independent of any federal-level digital-asset regulatory development.

Sources and findings (33)
  1. T1https://app.leg.wa.gov/rcw/default.aspx?Cite=19.230&full=trueretrieved
  2. T1https://dfi.wa.gov/money-services/money-transmitter-and-currency-exchange-licensingretrieved
  3. T1https://app.leg.wa.gov/Wac/default.aspx?cite=208-690-060retrieved
  4. T1https://app.leg.wa.gov/wac/default.aspx?cite=208-690-040retrieved
  5. T2https://www.dwt.com/blogs/financial-services-law-advisor/2018/07/washington-state-updates-money-services-rulesretrieved
  6. T1https://dfi.wa.gov/money-services/licensing-frequently-asked-questionsretrieved
  7. T1Coinme, Inc. — Coinme, Inc. — WA DFI entered a multistate consent order (8 Oct 2026) requiring cessation of crypto-kiosk operations, $2.5m penalty/costs, and additional compliance measures.retrieved
  8. T1Coinme, Inc. — WA DFI led a 34-regulator multi-state consent order against Coinme, Inc. over deficient BSA/AML program at crypto kiosks
  9. T1Washington State Department of Financial Institutions — Washington State Department of Financial Institutions — $150,000 consent order against digital-assets-focused money transmitter requiring licence surrender within 90 days for UMSA violations (net worth, recordkeeping, filings).retrieved
  10. T3Washington State Earned Wage Access Services Act — Washington State Earned Wage Access Services Act — New DFI EWA licence requirement effective 2026-07-01, $30,000 surety bond.retrieved
  11. T3Washington State Department of Financial Institutions — Washington State Department of Financial Institutions — $150,000 consent order vs digital-asset money transmitter, 2026-02-09.retrieved
  12. T?GENIUS Act (federal payment stablecoin framework) — GENIUS Act (federal payment stablecoin framework)
  13. T?CLARITY Act Section 404 (federal, pending) — CLARITY Act Section 404 (federal, pending)
  14. T?Coinme — Coinme
  15. T?CoinZoom, Inc. — CoinZoom, Inc.
  16. T1RCW 19.230 (Uniform Money Services Act) / WAC 208-690 — RCW 19.230 (Uniform Money Services Act) / WAC 208-690 — Surety-bond tiers ($10,000 minimum, $550,000 maximum) scaled to prior-year money-transmission dollar volume; licensees update bonds annually by July 1.retrieved
  17. T1Washington State Department of Financial Institutions — Washington State Department of Financial Institutions — Virtual currency is expressly captured as 'equivalent value' for money-transmission licensing purposes under RCW 19.230.retrieved
  18. T1Washington State Department of Financial Institutions — Washington State Department of Financial Institutions — Money transmitters, including virtual-currency businesses, must be licensed under the Uniform Money Services Act (UMSA, RCW 19.230; WAC 208-690).retrieved
  19. T3Unnamed digital-assets-focused money transmitter — Unnamed digital-assets-focused money transmitter — WA DFI Feb 2026 consent order requiring UMSA cease-and-desist, licence surrender within 90 days, $150,000 penalty ($50,000 stayed to 2029), $4,170 investigation fee, 3-year industry bar.retrieved
  20. T3CoinFlip (GPD Holdings LLC) — CoinFlip (GPD Holdings LLC) — WA DFI Sept 2026 Statement of Charges seeking licence cancellation, industry bar, customer refunds and $1,029,600 penalty against crypto-kiosk operator, citing elder-fraud exposure via cash-to-crypto kiosks.retrieved
  21. T1Washington State Department of Financial Institutions — Washington State Department of Financial Institutions — Money transmitter licensee surety bond amounts are based on prior-year money-transmission and payment-instrument dollar volume, recalculated quarterly in the first licensing year and annually thereafter, due by July 1.retrieved
  22. T1Washington State Department of Financial Institutions — Washington State Department of Financial Institutions — Washington money transmitter licences are perpetual, contingent on completing annual assessment and other maintenance requirements; NMLS system fees are due annually between November 1 and December 31.retrieved
  23. T1Washington State Department of Financial Institutions — Washington State Department of Financial Institutions — Consent order (Feb 9, 2026) against a digital-assets money transmitter: licence surrender within 90 days, 3-year industry bar, $150,000 civil penalty ($50,000 stayed to Feb 9, 2029), $4,170 investigation fee, for UMSA net-worth, recordkeeping and filing violations.retrieved
  24. T1Washington State Department of Financial Institutions — Washington State Department of Financial Institutions — Temporary Order to Cease and Desist against a different licensed crypto-kiosk/money-transmission business, citing RCW 19.230.170 recordkeeping violations and unsafe/unsound practices, ordering an immediate halt to new Washington customer transmissions.retrieved
  25. T1Washington State Department of Financial Institutions — Washington State Department of Financial Institutions — DFI's winter 2026 industry update reports 242 main money-transmitter licensees as of February 2026 (down from 245 in February 2025) and 9,323 authorized delegates (down from 9,768).retrieved
  26. T3Uniform Money Services Act (RCW 19.230) — Uniform Money Services Act (RCW 19.230) — Virtual currency treated as money/equivalent value, bringing crypto exchange/custody/kiosk businesses within the licensing perimeter administered by DFI
  27. T1Washington State Earned Wage Access Services Act — Washington State Earned Wage Access Services Act — EWA providers must be DFI-licensed from 2026-07-01; $30,000 minimum surety bond; employer-integrated fees capped at $10/month; excluded from classification as loan, credit or money-transmission serviceretrieved
  28. T1Washington State Department of Financial Institutions — Washington State Department of Financial Institutions — DFI's public enforcement lists show numerous 2026 consent orders/statements of charges across licensing categories (mortgage, consumer-loan, check-cashing, securities), indicating active routine state-level enforcement capacityretrieved
  29. T1Washington Earned Wage Access Services Act (SSB 5328/HB 1063) — Washington Earned Wage Access Services Act (SSB 5328/HB 1063) — EWA providers required to be DFI-licensed beginning July 1, 2026; DFI set an initial licensing fee of $1,500 with an estimated ~28 initial licensees.retrieved
  30. T1Coinme, Inc. — Coinme, Inc. — DFI's multi-state consent order with Coinme (entered 10/07/2026) required the firm to surrender/cease crypto-kiosk money-transmission activity in Washington by Jan 1 2027.retrieved
  31. T1Bitcoin Depot Operating LLC — DFI's enforcement register shows a parallel Statement of Charges against Bitcoin Depot Operating LLC entered 06/08/2026, indicating sustained supervisory activity on the crypto-kiosk licensee segment.retrieved
  32. T3Washington Uniform Money Services Act (RCW 19.230) / WAC 208-690 — Washington Uniform Money Services Act (RCW 19.230) / WAC 208-690 — Virtual-currency kiosks, exchange platforms, hosted-wallet services and payment processors generally fall within the money-transmitter licensing perimeter; crypto-specific add-ons (SB 5031, 2017) require $100,000 minimum net worth, third-party security audit, and like-kind holding requirement.retrieved
  33. T3DFI consent order, Feb 2026 (unnamed digital-assets money transmitter) — DFI consent order, Feb 2026 (unnamed digital-assets money transmitter) — A separate WA DFI consent order (9 Feb 2026) against an unnamed digital-assets-focused money transmitter required licence surrender within 90 days, a 3-year industry bar, and a $150,000 civil penalty ($50,000 stayed to Feb 2029) for net-worth, recordkeeping and reporting failures under UMSA.retrieved

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Washington's conduct regime centres on a named Responsible Individual per licensee, mandatory permissible-investment/safeguarding of customer funds, a statutory refund right, and federal Regulation E remittance-transfer disclosure obligations layered on top of the state licence. DFI enforces these conduct standards actively via examinations and administrative actions.

Standing sub-brief · as of 5 July 2026 169 words · last cycle 2026-09-05

Conduct, Safeguarding & Financial Promotions

Each Washington money transmitter licensee must designate a Responsible Individual — a US citizen or lawfully authorised worker employed as a W-2 employee — who is accountable for state and federal compliance under WAC 208-690-014(2). Licensees are further bound by a statutory duty to transmit customer funds within ten business days of receipt and to refund all monies within ten days of a written refund request under RCW 19.230.330; this operates alongside permissible-investment and segregation duties rather than through a discrete named safeguarding-fund mechanism. Layered atop the state regime, licensees must also satisfy federal Regulation E pre-payment disclosure, error-resolution and cancellation/refund obligations for remittance transfers.

Periodic update · new data 2026-09-08

Conduct, Safeguarding & Financial Promotions

A Temporary Cease and Desist Order issued by Washington's DFI against Coinme, a Bitcoin-ATM and kiosk operator, directs repayment of more than $8 million in customer voucher balances that were allegedly treated as company revenue rather than as safeguarded consumer funds. This is a conduct and safeguarding finding, distinct from the separate licensing-scope enforcement action tracked under W1a: the substantive issue here is how a nonbank payment institution characterised and held customer-facing balances within a kiosk-based cash-to-crypto model, not whether it held a valid licence. The safeguarding mechanism implicated is described in general terms as 'other' rather than a formal ring-fencing or trust-account arrangement, and the alleged misclassification of unredeemed voucher balances as revenue points to a gap in how customer funds were segregated from operational funds in this business model.

Confidence on this specific finding is held at Probable, reflecting reliance on a single tier-4 aggregator source without independent primary-source corroboration this cycle; this should be read as a real, if not yet fully corroborated, conduct-supervision signal rather than a settled finding. The elevated-impact rating attached to this development reflects the scale of customer funds involved (over $8 million) relative to the safeguarding-conduct gap alleged, even though the confidence tier remains at Probable pending stronger sourcing.

The broader safeguarding backstop available to Washington nonbank payment institutions generally, the RCW 19.230 surety-bond mechanism scaling from $10,000 to $550,000 by transaction volume, exists as a structural remedy of last resort for exactly this kind of consumer-funds shortfall, running to the benefit of any person who suffers loss from a licensee's violation. Whether that bond mechanism is sufficient to make whole the more than $8 million at issue in the Coinme matter is not established by evidence retrieved this cycle.

Outlook

Independent corroboration of the Coinme cease-and-desist order from a higher-tier source would materially strengthen confidence in this conduct-supervision finding. The broader question worth tracking is whether DFI's conduct-supervision attention to kiosk-based cash-to-crypto safeguarding practices extends beyond this single operator to the wider Washington-licensed Bitcoin-ATM sector.

Sources and findings (9)
  1. T1https://dfi.wa.gov/sites/default/files/documents/money-transmitters/summary-mt-regulation.pdfretrieved
  2. T1https://law.justia.com/codes/washington/title-19/chapter-19-230/section-19-230-330/retrieved
  3. T1https://dfi.wa.gov/money-services/examinationsretrieved
  4. T1https://dfi.wa.gov/money-services/examinationsretrieved
  5. T2https://www.dwt.com/blogs/financial-services-law-advisor/2018/07/washington-state-updates-money-services-rulesretrieved
  6. T4Coinme — Coinme — Temporary Cease and Desist Order directing repayment of over $8 million in customer voucher balances allegedly misclassified as company revenue.retrieved
  7. T1Washington money transmitter licensees — Washington money transmitter licensees — Each licensee must designate a Responsible Individual: a US citizen/lawfully-authorised worker, W-2 employee, accountable for state/federal compliance (WAC 208-690-014(2)).retrieved
  8. T3Washington money transmitter licensees — Washington money transmitter licensees — Licensees must transmit customer funds within 10 business days of receipt and refund all monies within 10 days of a written refund request (RCW 19.230.330).retrieved
  9. T1Washington money transmitter licensees — Washington money transmitter licensees — Licensees must satisfy Reg E pre-payment disclosure (12 CFR 1005.31(b)), error-resolution (1005.33) and cancellation/refund (1005.34) obligations for remittance transfers, layered atop the state licence.retrieved

#

Washington treats virtual currency (including stablecoins) as money transmission under 2017 RCW 19.230 amendments, layering a state licensing/custody regime atop the federal GENIUS Act (enacted 18 Jul 2025 but NOT YET OPERATIVE pending final implementing regulations, expected no later than 18 Jan 2027). A vendor claim attributing a 'Section 404' stablecoin-interest ban to Washington DFI is a misattribution; Section 404 is a provision of the pending, unenacted federal CLARITY Act. DFI has taken high-profile enforcement action (Coinme, CoinZoom) against non-compliant virtual-currency MSBs.

Open gap — wpm-int-2No stablecoin-regime (W2) delta identified for WA this cycle.no under-indexing note recorded
Horizon · 2027-01-18 (± a year)GENIUS Act stablecoin framework becomes operativeAdopted, not yet in force · Tier 1 source
Horizon · 2027-01-18 (± a year)GENIUS Act stablecoin framework becomes operativeAdopted, not yet in force · Tier 1 source
Standing sub-brief · as of 5 July 2026 241 words · last cycle 2026-07-05

Stablecoins & Digital Money

Washington has treated virtual currency, including stablecoins, as money transmission since 2017 amendments to RCW 19.230 brought virtual-currency receipt-for-transmission within the statutory definition, with 2018 rule amendments exempting 'virtual currency storage' from licensing where the storer lacks unilateral transmission ability. The federal GENIUS Act was enacted on 18 July 2025 but remains not yet operative — its effective date is the earlier of eighteen months post-enactment (18 January 2027) or 120 days after final implementing regulations, and only proposed rules from the OCC, FDIC and FinCEN/OFAC have issued as of mid-2026. A vendor claim attributing a Washington-specific 'Section 404' stablecoin-interest ban to DFI is a misattribution: Section 404 is a provision of the pending, unenacted federal CLARITY Act, not codified Washington policy, and no primary DFI source corroborates related vendor claims of mandated staking opt-in or universal proof-of-reserves requirements. DFI's November 2025 enforcement action against Coinme, resolved via a 23 December 2025 Consent Order, required cessation of violations and segregation of Washington customer assets in secure accounts.

no periodic updates on record for this sub-brief

Sources and findings (8)
  1. T2https://cryptoslate.com/crypto-laws/washington-uniform-money-services-act-virtual-currency-regime/retrieved
  2. T2https://www.dwt.com/blogs/financial-services-law-advisor/2018/07/washington-state-updates-money-services-rulesretrieved
  3. T1https://www.federalregister.gov/documents/2026/03/02/2026-04089/implementing-the-guiding-and-establishing-national-innovation-for-us-stablecoins-act-for-theretrieved
  4. T3https://www.bitget.com/academy/coinbase-restrictions-washington-state-2026-comprehensive-america-guideretrieved
  5. T1https://dfi.wa.gov/news/press/washington-state-dfi-takes-action-against-coinme-halt-all-money-transfers-washington-dueretrieved
  6. T3Washington virtual-currency money transmitters — Washington virtual-currency money transmitters — 2017 amendments (SSB 5031, effective 23 Jul 2017) to RCW 19.230 bring virtual-currency receipt-for-transmission within the money transmission definition; 2018 WAC amendments define 'virtual currency storage' as exempt from licensing where the storer lacks unilateral transmission ability.retrieved
  7. T3Washington DFI (alleged, vendor-sourced) — Washington DFI (alleged, vendor-sourced) — A single vendor blog claims DFI mandates active opt-in/repeated risk acknowledgement for staking, prohibits pooled Staking-as-a-Service without individual voting rights, and requires universal proof-of-reserves for exchanges. No primary DFI statute, rule, guidance or enforcement action corroborates these specific requirements.retrieved
  8. T1Coinme — DFI's Nov 2025 action alleged Coinme improperly claimed >$8m owed to consumers as income via a virtual-currency-kiosk voucher system; a 23 Dec 2025 Consent Order required cessation of violations and segregation of Washington customer assets.retrieved

#

Operational resilience obligations for Washington money transmitters are embedded in WAC 208-690 rather than a standalone resilience statute: cybersecurity, business-continuity, recordkeeping and third-party/agent oversight duties are examination-enforced by DFI on a risk-based cycle.

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

Standing sub-brief · as of 5 July 2026 98 words · last cycle 2026-07-05

Operational Resilience & Critical Infrastructure

WAC 208-690 imposes cybersecurity, business-continuity and five-year recordkeeping expectations — transaction logs, customer communications and audit trails — enforced through periodic DFI examination on a risk-based cycle of roughly six to twenty-four months, alongside a requirement that BSA-qualifying licensees maintain an effective anti-money-laundering program and records under 31 CFR Part 103.

no periodic updates on record for this sub-brief

Sources and findings (6)
  1. T3https://www.innreg.com/blog/washington-money-transmitter-license-guideretrieved
  2. T1https://dfi.wa.gov/money-services/examinationsretrieved
  3. T1https://dfi.wa.gov/money-servicesretrieved
  4. T1https://dfi.wa.gov/sites/default/files/documents/money-transmitters/summary-mt-regulation.pdfretrieved
  5. T3Washington money transmitter licensees — Washington money transmitter licensees — WAC 208-690 imposes cybersecurity, business-continuity and 5-year recordkeeping expectations (transaction logs, customer communications, audit trails), enforced via periodic DFI examination.retrieved
  6. T1Washington DFI — Washington DFI — DFI examines money transmitter licensees approximately every 6-24 months (risk-based); BSA-qualifying licensees must maintain an effective AML program and records per 31 CFR Part 103.retrieved

#

Washington imposes no state-specific cap on credit-card surcharging beyond the federal/card-network ceiling, but a state-level interchange-fee ban bill (SB 5070) has been actively debated in the legislature, and the state Department of Revenue has created a distinct B&O tax classification for payment-card processing/acquiring activity.

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

Scheme & Network Compliance

Washington imposes no state-specific surcharge cap beyond federal and card-network rules: credit-card surcharging is legal subject to Visa, Mastercard, Amex and Discover ceilings, while debit-card surcharging remains illegal nationwide under the Durbin Amendment. SB 5070, which would ban interchange/swipe fees outright, has taken no action since a February 2025 executive-session slot and remains dormant in committee with no confirmed forward date. Separately, the Department of Revenue has created a dedicated Payment Card Processing B&O tax classification covering acquiring, processing, routing, issuing and network services, with interchange and network-fee deductions permitted.

no periodic updates on record for this sub-brief

Sources and findings (7)
  1. T3https://merchantcostconsulting.com/lower-credit-card-processing-fees/washington-surcharge-laws/retrieved
  2. T3https://www.nbcrightnow.com/legislature/servers-in-washington-state-hoping-for-reprieve-from-credit-card-fees/article_fa5b9b46-d867-11ef-a91c-bfcf55753fb1.htmlretrieved
  3. T1https://dor.wa.gov/forms-publications/publications-subject/special-notices/new-tax-rate-and-classification-payment-card-processing-activitiesretrieved
  4. T2https://mrsc.org/explore-topics/finance/accounting/credit-card-acceptanceretrieved
  5. T3Washington merchants — Washington merchants — No Washington-specific surcharge cap beyond federal/card-network rules; credit-card surcharging is legal subject to Visa/Mastercard/Amex/Discover ceilings, while debit surcharging remains illegal nationwide under the Durbin Amendment.retrieved
  6. T1Washington SB 5070 (interchange fee ban bill) — Washington SB 5070 (interchange fee ban bill) — SB 5070 (introduced Dec 2024) would ban interchange/swipe fees; had a Jan 2025 hearing and Feb 2025 executive-session slot, but has taken no further action since 21 Feb 2025 and remains retained in committee as of mid-2026 with no confirmed forward action date.retrieved
  7. T1Washington Department of Revenue — Washington Department of Revenue — DOR created a specific Payment Card Processing B&O tax classification covering acquiring/processing/routing services for issuers, acquirers, networks and merchants, with interchange/network-fee deductions permitted.retrieved

#

Washington (via Seattle-headquartered Remitly) is a globally significant node for US outbound remittance corridors, with the state's digital remittance leader benefiting from a federal carve-out on the new 2026 remittance excise tax for electronically funded transfers.

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

Payment Corridor Dynamics

Seattle-headquartered Remitly Global, Inc. operates a global remittance network completing transfers across more than 5,100 corridors without local operations in each destination, per its own SEC 10-K disclosure. A 1% federal remittance excise tax took effect 1 January 2026 on cash-funded international transfers, but Remitly's fully digital, electronically-funded transfers are exempt under the law's carve-out. Illustrative corridor detail remains thin in this pass, limited chiefly to the founding US-Philippines corridor and an expanding US-Kenya mobile-money interoperability link via M-Pesa.

no periodic updates on record for this sub-brief

Sources and findings (6)
  1. T1https://ir.remitly.com/static-files/d82354f4-cfc3-453c-b3cd-a68f0e31a47cretrieved
  2. T3https://www.fintechfutures.com/remittances/how-remitly-marries-remittances-with-financial-inclusionretrieved
  3. T3https://www.remitly.com/blog/money-transfer/federal-remittance-tax-guide/retrieved
  4. T3https://moneytransfers.com/companies/remitlyretrieved
  5. T3Remitly Global, Inc. — Remitly Global, Inc. — Seattle-headquartered Remitly operates a global network completing transfers across over 5,100 corridors without local operations in each destination, per its 10-K disclosure.retrieved
  6. T3Remitly Global, Inc. — Remitly Global, Inc. — A 1% federal remittance excise tax took effect 1 Jan 2026 on cash/cash-like-funded international transfers; Remitly's 100% digital, electronically-funded transfers are exempt under the law's carve-out.retrieved

#

Washington's payments industry structure is bifurcated between DFI-supervised depository institutions (state-chartered banks and credit unions under a dual state/federal charter system) and a dense non-bank fintech/payments cluster headquartered in Seattle, anchored by Remitly, Coinbase-licensed activity, Block/Square, and a wider venture-backed B2B payments and banking-as-a-service scene.

Standing sub-brief · as of 5 July 2026 117 words · last cycle 2026-10-04

Industry Structure & Commercial Dynamics

Washington operates a genuine dual state/federal bank-charter system: DFI's Division of Banks supervises state-chartered commercial and savings banks and trust companies, while its Division of Credit Unions supervises state-chartered credit unions alongside NCUA federal oversight. Separately, Seattle's fintech cluster is described by one tracker as comprising 475 companies with $3.43 billion raised, and by another vendor source as having raised $4.1 billion across 180-plus rounds in 2025; neither figure is independently corroborated by a primary data provider.

Periodic update · new data 2026-09-28

Industry Structure & Commercial Dynamics

Washington's crypto-kiosk operator CoinFlip (GPD Holdings LLC) faces acute regulatory-capital and licence-continuity risk following the Washington State Department of Financial Institutions' September 2026 Statement of Charges, which seeks licence cancellation, an industry bar, customer refunds, and a civil penalty of $1,029,600. For a kiosk-model operator, licence cancellation in a single state represents a direct threat to that state's revenue base and, depending on the multi-state licensing footprint typical of such operators, could carry reputational spillover into other jurisdictions' licensing reviews.

This sits alongside a separate February 2026 action against an unnamed digital-assets-focused money transmitter, which resulted in licence surrender within 90 days and a $150,000 penalty, illustrating that Washington's enforcement posture toward the nonbank digital-asset money-transmission segment has now produced two commercially consequential outcomes within roughly seven months. For the broader nonbank crypto-kiosk and money-transmission industry structure in Washington, this signals a tightening operating environment in which regulatory-capital exposure (potential penalties, licence-continuity costs, and remediation obligations such as customer refunds) is becoming a live commercial consideration, not merely a compliance-department concern.

Outlook

Whether CoinFlip's Statement of Charges results in settlement, a negotiated licence continuation, or full licence cancellation will be a significant marker for the commercial viability of the cash-to-crypto kiosk business model in Washington specifically, and may influence how other multi-state kiosk operators assess their regulatory-capital exposure in this state going forward.

Sources and findings (7)
  1. T1https://dfi.wa.gov/banksretrieved
  2. T1https://dfi.wa.gov/credit-unions/dual-charterretrieved
  3. T3https://tracxn.com/d/explore/fintech-startups-in-seattle-united-states/__hIA6ahe_JjGiPf2h9u82FtFyhb-EOobZ96Go0J4W2CQretrieved
  4. T3https://www.ellty.com/blog/seattle-fintech-investorsretrieved
  5. T4https://www.dnb.com/business-directory/company-profiles.amazon_payments_inc.d4807d8e003930eaa963fb06eedfbe76.htmlretrieved
  6. T1Washington State DFI — Washington State DFI — DFI's Division of Banks supervises state-chartered commercial/savings banks and trust companies, while its Division of Credit Unions supervises state-chartered credit unions alongside NCUA federal oversight, giving Washington a genuine dual state/federal charter system.retrieved
  7. T3Seattle fintech ecosystem — Seattle fintech ecosystem — One tracker cites 475 Seattle fintech companies with $3.43bn raised (163 funded, 65 Series A+, 1 unicorn, 32 acquisitions, 3 IPOs); a separate vendor blog claims $4.1bn raised across 180+ rounds in 2025. Neither figure is independently corroborated by a primary data provider.retrieved

DFI has been an active enforcer against non-compliant money transmitters, with two major virtual-currency-kiosk/MSB enforcement actions resolved late 2025/early 2026 (Coinme, CoinZoom) and a January 2025 multistate $80m BSA/AML settlement with Block, Inc./Cash App co-led by Washington, alongside routine mortgage-sector consent orders.

Horizon · 2029-02-09 (± a quarter)CoinZoom 3-year WA industry ban / stayed penalty contingency expiresIn force · Tier 1 source
Horizon · 2029-02-09 (± a quarter)CoinZoom 3-year WA industry ban / stayed penalty contingency expiresIn force · Tier 1 source
Standing sub-brief · as of 5 July 2026 201 words · last cycle 2026-07-05

Legal & Litigation

Washington's Department of Financial Institutions closed two virtual-currency money-transmitter enforcement actions within a four-month window: a Temporary Order to Cease and Desist and 23 December 2025 Consent Order against Coinme over more than $8 million allegedly improperly claimed as income from consumers via a kiosk voucher system, and a 9 February 2026 consent order against CoinZoom, Inc. requiring surrender of its licence and a three-year industry bar with a $150,000 civil penalty, of which $50,000 is stayed to February 2029 contingent on compliance. DFI also co-led, alongside regulators in Arkansas, California, Florida, Maine, Massachusetts, Texas and 47 states in total, an $80 million multistate BSA/AML settlement against Block, Inc. over Cash App, with a nine-month compliance-reporting deadline and twelve months to remediate underlying findings. A separate 5 November 2025 consent order addressed Mortgage Broker Practices Act and Consumer Loan Act violations at a Washington mortgage broker, with a $60,000 civil penalty.

no periodic updates on record for this sub-brief

Sources and findings (6)
  1. T1https://dfi.wa.gov/news/press/washington-state-dfi-takes-action-against-coinme-halt-all-money-transfers-washington-dueretrieved
  2. T2https://natlawreview.com/article/washington-dfi-enters-consent-order-digital-assets-focused-money-transmitterretrieved
  3. T1https://www.einpresswire.com/article/777029125/washington-dfi-jointly-leads-80-million-multistate-enforcement-action-against-block-inc-cash-appretrieved
  4. T2https://www.consumerfinanceandfintechblog.com/2025/11/washington-dfi-finalizes-60000-consent-order-addressing-alleged-advertising-disclosure-and-reporting-failures/retrieved
  5. T1Block, Inc. (Cash App) — Block, Inc. (Cash App) — Washington DFI co-led (with regulators in AR, CA, FL, ME, MA, TX and 47 states total) an $80m multistate BSA/AML enforcement settlement against Block, Inc., requiring a compliance report within 9 months and 12 months to remediate findings.retrieved
  6. T2Unnamed Washington mortgage broker — Unnamed Washington mortgage broker — 5 Nov 2025 DFI consent order against a mortgage company/broker for Mortgage Broker Practices Act and Consumer Loan Act violations: $60,000 civil penalty, $1,700 investigation fee, $950 restitution to two borrowers.retrieved

#

Merchant acquiring in Washington follows the standard US card-network model with DOR B&O tax carve-outs for acquirers/processors; the highest-risk merchant segment DFI actively tracks is cannabis retail, for which the state has codified specific settlement-timing rules for money-transmitter, card and check payment methods given federal banking access constraints.

Standing sub-brief · as of 5 July 2026 112 words · last cycle 2026-07-05

Merchant Acquiring & Risk

Cannabis-sector money-transmitter transactions are subject to codified settlement-timing rules under WAC 314-55-115, requiring initiation no later than the first business day following delivery and payment within five business days, with the transmitter licensed and in good standing with DFI. DFI's own cannabis-financial-services directory lists high-risk payment providers such as Aeropay, CanPay, Dutchie and Vector Payments that meet minimum DFI standards, while explicitly stating that these providers are not themselves DFI-regulated entities.

no periodic updates on record for this sub-brief

Sources and findings (6)
  1. T1https://app.leg.wa.gov/wac/default.aspx?cite=314-55-115retrieved
  2. T1https://dfi.wa.gov/cannabis/financial-servicesretrieved
  3. T1https://dor.wa.gov/forms-publications/publications-subject/special-notices/new-tax-rate-and-classification-payment-card-processing-activitiesretrieved
  4. T3https://merchantcostconsulting.com/lower-credit-card-processing-fees/washington-surcharge-laws/retrieved
  5. T1Cannabis retail merchants (Washington) — Cannabis retail merchants (Washington) — WAC 314-55-115 requires cannabis-sector money-transmitter-based transactions to be initiated no later than the first business day following delivery and paid within 5 business days, with the transmitter licensed and in good standing with DFI.retrieved
  6. T1Washington DFI cannabis payment-provider directory — Washington DFI cannabis payment-provider directory — DFI lists high-risk cannabis payment providers (Aeropay, CanPay, Dutchie, Vector Payments) meeting minimum DFI standards, while explicitly stating these providers are NOT DFI-regulated entities.retrieved

#

Seattle-based Remitly is the state's flagship payments product innovator, having launched a subscription membership (Remitly One), a bank-partnered debit/wallet product, and a forthcoming consumer line of credit in 2025-2026; the University of Washington's CoMotion innovation arm has also stood up a dedicated fintech incubator.

Horizon · 2026-Q2 (± a quarter)Remitly consumer line-of-credit launchProposed · Tier 1 source
Standing sub-brief · as of 5 July 2026 134 words · last cycle 2026-10-18

Product Innovation & Market Development

Remitly launched a $9.99-per-month 'Remitly One' membership on 9 September 2025, bundling its Flex, Wallet and Card offerings for US customers, and plans to add a consumer line of credit reported to a US credit bureau beginning spring 2026, with banking services and its debit card provided by partner Lead Bank under Visa U.S.A. licensing. The University of Washington's CoMotion innovation arm has also announced a fintech-incubator partnership with data-intelligence company Curinos, though this remains a single-source, uncorroborated report.

Periodic update · new data 2026-10-18

Product Innovation & Market Development

The commencement of Washington's Earned Wage Access Services Act licensing requirement on 1 July 2026 is the principal product-innovation development in this cycle. Earned wage access, a product category that allows employees to access a portion of already-earned but not yet paid wages ahead of a standard payroll cycle, has operated in a regulatory grey zone in many US states for several years, with providers often structuring offerings to avoid classification as consumer lending. Washington's dedicated licensing statute resolves that ambiguity for the state by creating a specific regulatory home for the product under DFI supervision, with an initial licensing fee of $1,500 and approximately 28 providers registered under the new regime as of this cycle.

The establishment of a dedicated licensing pathway, rather than folding EWA into an existing consumer-lending or money-transmitter framework, is itself a product-development signal: it indicates the state legislature and DFI judged EWA to be sufficiently distinct from both traditional short-term credit and traditional money transmission to warrant its own statutory category. For product teams building or scaling EWA offerings, Washington's approach now functions as one of a growing number of state-specific licensing regimes that must be navigated separately as EWA providers expand their market footprint across US states with increasingly divergent approaches to the product.

The roughly 28 initial licensees gives an early indication of the size of the regulated EWA market in Washington specifically; whether that number represents close to full market coverage of EWA providers already operating in the state, or whether it reflects only the subset that moved quickly to register ahead of or at the 1 July 2026 effective date, is not resolved by the evidence available this cycle. A fuller picture of market compliance, including whether any unlicensed EWA activity continues to operate in the state despite the new requirement, would require further monitoring in subsequent cycles.

Outlook

The product-development question worth tracking is whether Washington's licensee count stabilises near its current level, grows as the product category expands, or produces consolidation among EWA providers unable to absorb the compliance cost of state-by-state licensing. More broadly, Washington's approach joins a wider pattern of state-level EWA regulation forming piecemeal across the US, and whether other states adopt a comparable dedicated-licensing model, rather than folding EWA into existing lending or money-transmission frameworks, remains an open product-development question beyond this jurisdiction alone.

Sources and findings (7)
  1. T3https://www.fintechfutures.com/remittances/how-remitly-marries-remittances-with-financial-inclusionretrieved
  2. T1https://news.remitly.com/company-and-product-news/everything-we-announced-at-remitly-reimagine/retrieved
  3. T3https://greater-seattle.com/startups/retrieved
  4. T1https://www.federalreserve.gov/econres/notes/feds-notes/stablecoins-in-2025-developments-and-financial-stability-implications-20260408.htmlretrieved
  5. T3Remitly Global, Inc. — Remitly Global, Inc. — On 9 Sep 2025 Remitly launched 'Remitly One', a $9.99/month membership bundling Flex, Wallet and Card offerings for US customers.retrieved
  6. T1Remitly Global, Inc. — Remitly Global, Inc. — Beginning Spring 2026, Remitly plans to offer US customers a line of credit reported to a US credit bureau; banking services and the Remitly debit card are provided by Lead Bank under Visa U.S.A. licensing.retrieved
  7. T3University of Washington CoMotion — University of Washington CoMotion — UW's CoMotion innovation arm announced a partnership with data-intelligence company Curinos to launch a dedicated fintech incubator.retrieved

#

Consumer protection for Washington payments customers rests on the general Consumer Protection Act (RCW 19.86), the money-transmitter-specific refund right in RCW 19.230.330, and federal Regulation E remittance-transfer disclosure/error-resolution obligations; there is no Washington-specific mandatory APP-fraud reimbursement regime analogous to the UK's PSR rules.

Standing sub-brief · as of 5 July 2026 102 words · last cycle 2026-07-05

Consumer Protection & APP Fraud

Washington has no state-specific mandatory Authorised-Push-Payment fraud reimbursement scheme analogous to the UK Payment Systems Regulator's rules; consumer recourse instead rests on the broadly-interpreted Consumer Protection Act, the statutory money-transmitter refund right, and federal Regulation E error-resolution procedures. Licensees must maintain Reg E-compliant error-resolution policies and procedures, enforced via DFI examination.

no periodic updates on record for this sub-brief

Sources and findings (7)
  1. T3https://www.stritmatter.com/washington-consumer-protection-act/retrieved
  2. T1https://www.atg.wa.gov/consumer-refundsretrieved
  3. T1https://dfi.wa.gov/money-services/examinationsretrieved
  4. T3https://news.bloomberglaw.com/banking-law/fintechs-cash-advances-for-workers-draw-suits-as-states-divergeretrieved
  5. T3Washington Consumer Protection Act (RCW 19.86) — Washington Consumer Protection Act (RCW 19.86) — The CPA protects consumers from unfair/deceptive acts or practices affecting the public interest and is interpreted broadly, providing the general consumer-protection backstop for payments/fintech conduct in Washington.retrieved
  6. T1Washington State — Washington State — Washington has no state-specific mandatory Authorised-Push-Payment fraud reimbursement scheme analogous to the UK PSR reimbursement rules; consumer recourse rests on general CPA remedies, the statutory money-transmitter refund right and federal Reg E error resolution.retrieved
  7. T1Washington money transmitter licensees — Washington money transmitter licensees — Licensees must have Reg E-compliant error-resolution policies and procedures per 12 CFR 1005.33, enforced via DFI examination.retrieved

#

This module is Sentinel.gi-fed per methodology and carries the Sentinel payments-context position rather than original illicit-finance analysis. Direct Sentinel.gi feed content was not accessible within this collection pass; the module is seeded with the one directly observable, DFI-sourced payments-context financial-crime enforcement item (the multistate Block/Cash App BSA/AML settlement) pending Sentinel feed integration.

Standing sub-brief · as of 5 July 2026 126 words · last cycle 2026-07-05

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

This module is sourced from Sentinel.gi's financial-crime intelligence feed; per methodology, WPM does not perform original illicit-finance analysis here and instead attributes and links out to the underlying feed, seeded this cycle with the single directly-observable DFI payments-context item available pending full feed integration — the finding that state regulators assessed Block, Inc. as non-compliant with Bank Secrecy Act/anti-money-laundering customer due-diligence, suspicious-activity-reporting and high-risk-account control requirements, creating potential for its services to support money laundering or terrorism financing.

no periodic updates on record for this sub-brief

Sources and findings (8)
  1. T1sentinel.washington-dfi-block-bsa-aml-2025
  2. T?FIM (sentinel.gi) per-JID baseline profile — United States — Washington State — Washington operates within the federal BSA/FinCEN AML/CFT/CPF architecture (US is a FATF member, not grey-listed). State-level oversight runs through the WA Department of Financial Institutions (DFI) under the Uniform Money Services Act (RCW 19.230), covering money transmitters and virtual-currency businesses. No WA-specific AML enforcement action or MER event was identified in the 18-month window; risk instead flows from federal-level deregulatory shifts (BOI/CTA narrowing, IRS crypto-examiner cuts, OCC preemption of state chartering authority) that dilute DFI's practical supervisory reach over the state's dense crypto-ATM/VASP and global tech-corporate population.
  3. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: sourcing-thinness
  4. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: regulatory-failure
  5. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: capacity-deficit
  6. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-004) — Gap: legal-gap
  7. T1FIM (sentinel.gi) enforcement_action_register — Enforcement action
  8. T1sentinel.financial_integrity.D7 — sentinel.financial_integrity.D7 — Washington has no state AML/CTF statute; obliged-entity AML obligations run through federal BSA/FinCEN. UMSA licensing is a prudential/consumer-protection instrument, not an AML programme.retrieved

#

Washington's correspondent-banking/settlement access story is dominated by cannabis-sector de-risking: only a small number of state-chartered banks and credit unions are willing to bank cannabis retailers given federal Schedule I status, with DFI maintaining an active list of compliant depository and non-depository providers.

Standing sub-brief · as of 5 July 2026 143 words · last cycle 2026-07-05

Correspondent Banking, Settlement & Access

Only a handful of Washington state banks and credit unions — including O Bee, Numerica, Sound Community Bank, Timberland Bank and Twin City Bank — handle most cannabis-related deposit accounts given marijuana's federal Schedule I status, illustrating a structural bank-versus-non-bank access asymmetry that pushes cannabis retailers toward money-transmitter and non-bank payment-provider workarounds; Remitly's own settlement access, by contrast, runs through bank partner Lead Bank under Visa U.S.A. licensing, the standard non-bank-PI-plus-bank-partner model. State officials have sought to preserve 2014 FinCEN guidance permitting regulated cannabis banking.

no periodic updates on record for this sub-brief

Sources and findings (7)
  1. T3https://en.wikipedia.org/wiki/Cannabis_banking_in_Washingtonretrieved
  2. T1https://dfi.wa.gov/cannabis/financial-servicesretrieved
  3. T1https://news.remitly.com/company-and-product-news/everything-we-announced-at-remitly-reimagine/retrieved
  4. T3https://www.herringbank.com/business-banking/cannabis-banking/washington-state/retrieved
  5. T3Washington cannabis-sector correspondent banking — Washington cannabis-sector correspondent banking — Only a handful of state banks/credit unions (incl. O Bee, Numerica, Salal) handle most cannabis-related accounts, given marijuana's federal Schedule I status; state officials have sought to preserve 2014 FinCEN guidance permitting regulated cannabis banking.retrieved
  6. T1Washington DFI cannabis financial services directory — Washington DFI cannabis financial services directory — DFI's cannabis-financial-services page lists depository options including Sound Community Bank (full banking suite tailored to cannabis), Timberland Bank, Twin City Bank and several credit unions.retrieved
  7. T1Lead Bank — Remitly's banking services and debit card are provided by Lead Bank under Visa U.S.A. licensing; Remitly itself is a licensed money transmitter, not a bank, illustrating the standard nonbank-PI-plus-bank-partner settlement access model.retrieved

#

Trailing-12-month commercial activity in Washington payments is led by Remitly's product/membership expansion (Remitly One, forthcoming line of credit) and continued early-stage fintech funding activity in the Seattle ecosystem, alongside a major multistate regulatory settlement affecting Block/Cash App.

Standing sub-brief · as of 5 July 2026 189 words · last cycle 2026-10-18

Commercial Intelligence

Remitly One, a $9.99-per-month membership bundling Flex, Wallet and Card offerings, became available to select US customers on 9 September 2025 with broader US availability by the end of 2025, an event classified as a completed product release rather than a structural market trend. Separately, Seattle-based OpenCFO — founded by former CrowdStrike and Bloomberg engineers — announced on 16 March 2026 that it had raised $2 million in seed funding to automate finance functions such as accounts-payable, accounts-receivable and treasury for mid-sized companies, connecting directly to banking and payment infrastructure. A broader market tracker separately reports 499 tracked Seattle fintech startups, of which 178 are funded (68 Series A or later, one unicorn), though this aggregate figure is not a discrete event and individual deal amounts within it are not disclosed.

Periodic update · new data 2026-10-18

Commercial Intelligence & Fintech

Coinme, Inc., a Seattle-headquartered money transmitter and crypto-kiosk operator, agreed to a $2.5 million multi-state regulatory settlement, entered 7-8 October 2026, that requires the firm to wind down its crypto-kiosk product line nationwide by 1 January 2027. This is a discrete, dated commercial event rather than a structural market trend: a specific firm, facing a specific enforcement action coordinated across 35 state regulators including Washington's DFI, has agreed to exit a specific product line entirely within a fixed window. The $2.5 million figure is disclosed as the combined penalty-and-cost package attached to the settlement; the commercial value of the crypto-kiosk business being wound down itself has not been separately disclosed and is not publicly available from the evidence reviewed this cycle.

The settlement followed allegations, reported alongside the regulator's own account, that Coinme claimed more than $8 million owed to customers as its own income in violation of the Uniform Money Services Act. The commercial-intelligence dimension of this event is the forced exit itself: Coinme's agreement to shut down a nationwide product line, rather than merely pay a fine and continue operating, represents a substantial contraction of the firm's business rather than an incremental compliance cost.

This is a regulatory-driven restructuring event, distinct from a voluntary M&A transaction, investment round, or product launch; it is nonetheless a discrete commercial development warranting its own entry rather than treatment as part of a broader structural market-dynamics narrative, since it concerns one named firm's specific, dated commercial outcome rather than an industry-wide trend.

Outlook

The commercial development to track is whether Coinme completes the nationwide wind-down by the 1 January 2027 deadline, and whether the firm retains any residual Washington money-transmitter licensing footprint for lines of business outside the crypto-kiosk product. A comparable commercial event involving Bitcoin Depot Operating LLC, whose Statement of Charges under the same statute remains unresolved, would be a second discrete item to watch should it produce a settlement with similar terms.

Sources and findings (8)
  1. T1https://news.remitly.com/company-and-product-news/everything-we-announced-at-remitly-reimagine/retrieved
  2. T3https://www.geekwire.com/2026/former-crowdstrike-and-bloomberg-engineers-raise-2m-for-seattle-fintech-startup-opencfo/retrieved
  3. T1https://www.einpresswire.com/article/777029125/washington-dfi-jointly-leads-80-million-multistate-enforcement-action-against-block-inc-cash-appretrieved
  4. T3https://tracxn.com/d/explore/fintech-startups-in-seattle-united-states/__hIA6ahe_JjGiPf2h9u82FtFyhb-EOobZ96Go0J4W2CQ/companiesretrieved
  5. T3OpenCFO — Seattle-based OpenCFO (ex-CrowdStrike/Bloomberg engineers) raised $2m to automate finance functions (AP/AR, treasury) for mid-sized companies, connecting directly to banking/payment infrastructure; announced 16 Mar 2026.retrieved
  6. T3Seattle fintech ecosystem (aggregate) — Seattle fintech ecosystem (aggregate) — Of 499 tracked Seattle fintech startups, 178 are funded (68 Series A+, 1 unicorn), with ~27 new companies launched annually over the past decade; constituent deal amounts are aggregate/undisclosed at the individual-deal level.retrieved
  7. T2Coinme, Inc. — Coinme, Inc. agreed to a $2.5m multi-state settlement requiring it to wind down its crypto-kiosk product line nationwide by Jan 1, 2027 — a commercially material restructuring forced by regulatory settlement.retrieved
  8. T3Sound Credit Union — Sound Credit Union — Adopted Temenos Collections SaaS to modernize debt-collection operations.retrieved
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