Crypto ATM laws in District of Columbia: a guide for operators (2026)
DC has no kiosk-specific law, but DISB says crypto ATM operators need a money transmitter license, and the Attorney General is suing Athena Bitcoin.
No kiosk-specific law · Last checked
Esta guía todavía está solo en inglés.
Licensing in District of Columbia
Money transmitter license from DISB under D.C. Code 26-1001 et seq., applied through NMLS. DISB Guidance 24-BB-001-08/09/24 says operators of Bitcoin Teller Machines and virtual currency kiosks need a money transmission license. There is no kiosk-specific license.
Regulator: DC Department of Insurance, Securities and Banking (DISB) · License: Money transmitter license
Sources: DISB: Banking licensing requirements for fintech companies (MTL via NMLS) · DISB FY24-25 pre-hearing answers (Guidance 24-BB-001-08/09/24 on BTMs; MTMA discussed as a recommendation) · DISB FY24 performance report (BTM inspections and investigations)
Kiosk-specific rules
District of Columbia has no law written specifically for crypto ATMs as of 2026-10-28. The general money transmission rules above and the federal rules still apply.
Enforcement and lawsuits
- In September 2025 the DC Attorney General sued Athena Bitcoin, Inc. in DC Superior Court under the CPPA and the Financial Exploitation Act. The suit alleges undisclosed fees, weak anti-fraud measures and a no-refund policy, and says 93% of deposits in the first five months were fraud-induced across Athena's 7 DC machines.
- In FY24 DISB opened seven BTM investigations, mostly into unlicensed money transmission. It reports that known unregistered BTM companies stopped operating in DC and that one company was referred for enforcement.
Practical hurdles
- DISB says it monitors kiosks and carries out quarterly onsite inspections of BTMs (FY24 strategic initiative).
- There is active AG litigation against an operator, and fee-disclosure and refund practices are under scrutiny.
Sources: OAG DC press release: AG Schwalb sues Athena Bitcoin · OAG DC complaint v. Athena Bitcoin · DISB FY24 performance report
What we couldn't confirm
- Whether any DC Council kiosk bill was introduced in 2025-2026. we found none.
- Exact filing date of the Athena suit (September 2025, per the complaint's URL folder and an Orrick alert dated 2025-09-11) and its current status.
- Whether DC has adopted the MTMA since February 2025. The DISB document at that time treated it as a recommendation.
Run machines in District of Columbia? Put them on Bitcoin Scouts
Bitcoin Scouts is the crypto ATM map that shows which machines are working right now. It's built by the team behind QuickieCoin, a bitcoin ATM operator in New Jersey, so we wrote this guide the way we wish someone had written it for us.
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