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

Licensing in New Jersey

The New Jersey Money Transmitters Act (N.J.S.A. 17:15C-1 et seq.; rules at N.J.A.C. 3:27) requires a license from the Department of Banking and Insurance (DOBI) to receive or transmit 'money'. The Act defines money as government-issued currency. Neither the statute nor DOBI's money transmitter pages we opened mention virtual currency, and we found no published DOBI guidance on virtual currency or kiosks. Pending 2026 bills A3386/S2957 would expressly require kiosk operators to hold a DOBI money transmitter license, which suggests current law does not clearly say so. Rule-based net worth: $100,000 plus $25,000 per location or agent, up to $1,000,000 (N.J.A.C. 3:27-5.1, per the DOBI rule proposal). A surety bond is required; the amount was not confirmed.

Regulator: NJ Department of Banking and Insurance (DOBI), Division of Banking · License: Money transmitter license (crypto coverage unclear)

Sources: NJDOBI Money Transmitter licensing page · N.J.S.A. 17:15C-2 definitions (Justia copy) (secondary) · N.J.S.A. 17:15C-4 License required (NJ Legislature statutes) · DOBI rule proposal, N.J.A.C. 3:27 (net worth) · DOBI readoption of N.J.A.C. 3:27 (effective 2023-04-06, expires 2030-04-06)

Kiosk-specific rules

New Jersey 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.

Bills and changes to watch

• S2141, statewide ban on crypto ATMs (Moriarty, Ruiz). Introduced 2026-01-13. Senate Commerce Committee reported it 5-0 on 2026-06-08. Passed the Senate 37-3 on 2026-06-30, then received in the Assembly and referred to the Assembly Science, Innovation and Technology Committee the same day. No later action was found as of 2026-10-28.
• S2141 terms: no business entity may own, control, install, manage, sell or offer a cryptocurrency ATM in NJ. A violation is a Consumer Fraud Act unlawful practice, with fines up to $10,000 for a first offense and $20,000 for later ones. It takes effect on the first day of the sixth month after enactment.
• A3244, the Assembly 'same as' bill to S2141 (Hutchison, Sampson, Bagolie, plus many co-sponsors). Introduced 2026-01-13 and referred to the Assembly Science, Innovation and Technology Committee. No committee vote was found, and no Assembly floor action on A3244 or S2141 was found.
• A3386 / S2957, the 'Virtual Currency Kiosk Consumer Protection Act' (identical bills). Introduced 2026-01-13. They would require a DOBI money transmitter license, disclosures, compliance and consumer-protection officers, blockchain analytics, an anti-fraud policy and location reporting. Only the introduction is listed.
• A3454, the 'Digital Asset and Blockchain Technology Act' (Lopez, Tully, Danielsen). Introduced 2026. It would license digital asset businesses through the Bureau of Securities and require disclosures at electronic kiosks. Status beyond introduction was not confirmed.
• Carried over from the 2024-2025 session without passing: S3694 (introduced 2024-09-30) and A4880 (introduced 2024-10-17), both ban bills. A5384 and S4288 were the earlier kiosk-regulation bills.

Practical hurdles

• Ban risk: S2141 has passed the Senate 37-3. If the Assembly passes it and the governor signs, all crypto ATMs would be prohibited six months after enactment. Operators should treat NJ as high-risk for new placements.
• It is unclear whether DOBI requires a money transmitter license for crypto-only kiosk activity. No published DOBI guidance was found; operators should get a written position from DOBI.
• Secondary reporting: CoinFlip runs 124 NJ machines in more than 100 municipalities. Federal data cited by the press shows 369 NJ kiosk-fraud cases and $18M in losses in 2025, which fuels the push for a ban.

What we couldn't confirm

• Current S2141/A3244 status straight from njleg.state.nj.us. The official bill-status page and API could not be loaded from this environment: the network blocked them and the page needs JavaScript. Status comes from LegiScan plus the official bill text and committee statement on pub.njleg.gov. No Assembly committee action was found, but the official site was not checked directly.
• Whether DOBI treats virtual currency as 'money' under N.J.S.A. 17:15C. No DOBI bulletin or guidance on virtual currency was found.
• Whether NJ money transmitter licensing runs through NMLS. Not stated on the DOBI pages opened.
• The NJ surety bond amount: the DOBI bond form leaves it blank.
• No NJ AG lawsuits against kiosk operators and no NJ municipal kiosk ordinances were found.