United States – Vermont

Act 110, enacted in 2024, was the most significant recent legislative event in this module. Its Sections 29 through 49 conformed Vermont's money-transmission statute to the Conference of State Bank Supervisors' Model Money Transmission Modernization Act, while Section 48 created a new Chapter 79 subchapter setting bespoke virtual-currency business activity requirements distinct from the model law itself. This dual move — harmonizing with the multistate model law on one hand while retaining Vermont-specific virtual-currency provisions on the other — reflects a state that has been regulating virtual-currency business activity for several years and was not starting from a blank slate.

On the compliance-cost side of licensing, a licensing-guide source indicates that Vermont MTL applicants must maintain a minimum tangible net worth of $100,000, post a surety bond of the same minimum amount, register with FinCEN under the Bank Secrecy Act, and expect a licensing process of approximately three months. This figure comes from a single secondary licensing-guide source rather than a primary statutory citation checked this cycle, and should be treated as indicative rather than confirmed pending direct statutory cross-check.

Outlook

With Act 110's CSBS-model conformance now in force, Vermont's licensing architecture is unlikely to see further structural change in the near term; the module's live edges are downstream in the virtual-currency subchapter it created rather than in the core MTL framework itself.

The conduct layer was extended in 2025 with a new consumer-protection obligation specific to virtual-currency kiosks: operators must now refund fraud victims who report the crime within 90 days, layered onto the existing kiosk licensing and conduct regime. Taken together, the statutory trust, the scaling bond requirement, and the new kiosk fraud-refund duty represent a conduct/safeguarding layer that has strengthened materially since 2024 rather than remaining static.

Outlook

Having added a kiosk-specific consumer remedy in 2025 on top of the 2024 trust reform, Vermont's safeguarding regime appears likely to continue evolving incrementally around the virtual-currency kiosk channel specifically, rather than through broad revision of the core trust/bond framework.

That open item is itself the subject of pending legislation: a Senate proposal of amendment to H.648, dated May 11, 2026, would extend the moratorium under §2577(f) by a further year, to July 1, 2027. As of this cycle the proposal remains pending and has not been enacted.

Outlook

Confirmation of the kiosk moratorium's post-July-2026 status — lapsed, or extended to 2027 via H.648 — is the single highest-priority item for next cycle's Vermont research, given the direct operational consequence for any prospective new kiosk operator.

This framework was substantially amended by Act 89 in 2020, which expanded the definition of personally identifiable information to capture government ID numbers and biometric, genetic, and health data, created a distinct notification process specific to login-credential breaches, and revised the cost threshold for substitute notice to $10,000.

Outlook

No Vermont-specific DORA-equivalent operational-resilience regime was identified this cycle; the Security Breach Notice Act framework, as amended by Act 89, remains the operative standard and no further legislative activity in this module was found.

A pending bill, S.316, would go further by prohibiting card networks from charging interchange fees on the portion of a transaction representing state or local sales, use, or excise tax, or gratuity, and would bar networks from raising fees elsewhere to compensate. The bill was read a first time and referred to committee on January 27, 2026 and has not been enacted. It follows a predecessor bill, H.0317, introduced in February 2025, which died in committee without advancing — a pattern suggesting continued but so-far unsuccessful legislative interest in regulating interchange economics directly.

Outlook

S.316's committee status through mid-2026, set against H.0317's 2025 failure, suggests Vermont's interchange-restriction push remains a live but uncertain legislative front; its progress (or renewed failure) is a forward marker for the scheme-compliance module.

No Vermont-specific corridor volume or flow data was located this cycle; this is consistent with a broader pattern in which corridor-specific data is comparatively under-indexed for small-state MTL populations.

Outlook

Absent a dedicated Vermont corridor regime, this module's near-term trajectory tracks the national money-transmission and correspondent-banking architecture rather than any state-specific development; closing the corridor-data gap is a candidate focus for future cycles.

Institutional oversight follows the standard dual-charter US pattern: the DFR Banking Division charters and regulates state-chartered banks, credit unions, and trust companies, while federally chartered institutions instead fall under the OCC for national banks or the NCUA for federal credit unions.

Outlook

Vermont's credit-union-dense structure, combined with the dual state/federal charter split, is a stable feature of the market unlikely to shift materially in the near term absent a broader sector consolidation wave.

Beyond DFR's administrative track, the Vermont Consumer Protection Act (9 V.S.A. §2451 et seq.) gives private parties a right of action, including treble damages for willful or knowing violations plus attorney's fees, with a three-year statute of limitations running from discovery of the unfair or deceptive act.

Outlook

The consistency of DFR's stipulation-and-consent approach across at least two distinct enforcement actions suggests contested litigation is not the state's preferred enforcement posture for unlicensed transmission; the VCPA private right of action remains the more consequential avenue for aggrieved consumers.

Outlook

Absent a state-specific acquiring framework, this module tracks national scheme-rule and federal-law developments rather than any distinct Vermont dynamic.

Outlook

With no sandbox or open-banking mandate in place, and the Financial Technology Report's recommendations not yet translated into enacted law, product-innovation policy in Vermont remains at the recommendation stage; private-company and product-innovation signal for a state of Vermont's size is structurally thinner than for larger jurisdictions.

This sits alongside a 2025 legislative addition requiring kiosk operators to refund new-customer fraud victims who report the crime within 90 days. That requirement responds to a documented pattern: nationally, crypto-ATM fraud losses rose nearly tenfold between 2020 and 2023 and exceeded $65 million in the first half of 2024 alone, with adults aged 60 and over more than three times as likely to report a loss.

Outlook

The combination of the age/threshold-triggered screening call and the 90-day refund right makes Vermont's kiosk-specific consumer-protection regime one of the more prescriptive state-level APP-fraud interventions built directly into a payments product; further tightening around kiosks appears the most likely direction of travel.

Outlook

For further analysis of illicit-finance implications arising from these Vermont AML/CFT touchpoints, see the Sentinel-fed FIM monitor; this brief does not develop that analysis independently.

A potential structural shift is under consideration at the federal level: in December 2025 the Federal Reserve Board issued a request for information on a special-purpose "Payment Account" prototype tailored to payments-focused institutions. As proposed, this account type would not permit its holder to act as a correspondent for other respondents, distinguishing it from a full Master Account; the proposal remains at the RFI stage and is not yet in force.

Outlook

The Fed's Payment Account prototype, if it proceeds beyond the RFI stage, would be the most consequential near-term development for how Vermont-based payments-focused institutions — as distinct from full-service banks — might access settlement directly; its progress is a priority watch item for next cycle.

Outlook

Absent a Vermont-headquartered deal this cycle, this module's Vermont-specific content remains a research gap to prioritize closing in future cycles; national consolidation context, as with Capital One-Brex, will continue to be noted where directly relevant to Vermont market structure.