Crypto ATM laws in Missouri: a guide for operators (2026)

Licensing in Missouri

Since 2025-08-28, anyone who owns, operates, solicits, markets, advertises or facilitates virtual currency kiosks in Missouri is deemed to be engaged in money transmission and must be licensed under Missouri's Money Transmission Modernization Act (RSMo 361.900-361.1035, enacted 2024 by SB 1359, effective 2024-08-28), through NMLS.

Regulator: Missouri Division of Finance · License: Money transmitter license

Sources: Missouri Division of Finance: Virtual Currency Kiosk Operators · RSMo Chapter 361 index (MTMA 8/28/2024; VCKCPA 361.1100 8/28/2025)

Missouri's kiosk law

RSMo 361.1100 (2025) · effective 2025-08-28

• Kiosk operators are deemed money transmitters and must be licensed under the MTMA.
• Operators must file quarterly reports with the Division of Finance listing the location of each kiosk in Missouri.
• Before a customer's first transaction, the operator must disclose in writing all material risks (not legal tender, not FDIC/SIPC insured, may be irreversible, fraud losses may not be recoverable, volatility, and others) and the relevant terms and conditions.
• Receipts must show operator name and contact phone number, transaction type, value, date and precise local time, fee, exchange rate, liability for non-delivery or delay, and the refund policy.
• Blockchain analytics software is mandatory to help stop sends to wallets known to be linked to fraud; the Division may ask for proof.
• Live customer service must be available at least Monday-Friday, 8 a.m.-10 p.m., with a toll-free number displayed on the kiosk or screen.
• Operators must keep a written anti-fraud policy covering risk assessment, controls, responsibility for monitoring and periodic review.

Sources: RSMo 361.1100 (Revisor of Missouri) · Missouri Senate, 2025 Truly Agreed To and Finally Passed bill summaries · Missouri Division of Finance: Virtual Currency Kiosk Operators

Bills and changes to watch

• 2026 kiosk bills (limits or refunds) were introduced (e.g., fastdemocracy MOB00028319); bill numbers and status not confirmed.

Enforcement and lawsuits

• 2025-12-17: AG Catherine Hanaway opened an investigation and issued civil investigative demands to CoinFlip (GPD Holdings), Rockitcoin, Bitcoin Depot, Athena Bitcoin and Byte Federal.
• 2026-05-20: AG Hanaway sued CoinFlip (GPD Holdings LLC), alleging it knowingly facilitated fraudulent transactions and charged excessive, poorly disclosed fees at more than 140 Missouri kiosks.

Practical hurdles

• Active AG investigation of the five largest operators and a pending lawsuit against CoinFlip make Missouri a high-scrutiny state.
• Live support must be staffed at least 8 a.m.-10 p.m. on weekdays, longer than many states require.

What we couldn't confirm

• Whether RSMo 361.1100 has any daily transaction limit, fee cap or refund duty; none appeared in the excerpts read, but the full section was not read end to end.
• Compliance officer requirement under 361.1100 (not seen in excerpts).
• Bill numbers and status of 2026 Missouri kiosk bills.
• Missouri money transmitter bond and net worth amounts (not checked).