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Jurisdiction brief
Lead Signal
Wisconsin Assembly Bill 471, introduced 2025-09-29 by Rep. Neylon and eight cosponsors, would exempt node operation, crypto-to-crypto exchange with no fiat conversion, blockchain software development, and mining or staking from money-transmitter licensing under Chapter 217, and would bar state or local restriction of self-hosted wallets and crypto payment acceptance. Wisconsin currently regulates money transmission under Chapter 217, the Model Money Transmission Modernization Law, administered by the Department of Financial Institutions. The bill has been referred to the Assembly Committee on Financial Institutions, and as of the most recent reporting it remains pending with no confirmed floor vote or enactment. Wisconsin law does not currently define money to include virtual currencies, leaving self-custody of cryptocurrency in a regulatory gray zone as to DFI licensure, which is the gap AB471 is designed to close. If enacted, the bill would materially narrow the state's money-transmission licensing perimeter for digital-asset activity, aligning Wisconsin with a growing majority of states that already exempt node operation, non-fiat crypto exchange, and mining or staking from money-transmitter requirements.
Other Developments
At the federal level, the GENIUS Act, Public Law 119-27, was signed July 18 2025 and classifies payment stablecoins as digital money restricted to Permitted Payment Stablecoin Issuers, applying nationally including to Wisconsin-serving issuers. Final implementing rules are targeted for July 18 2026, with enforcement beginning January 2027. A US Treasury notice of proposed rulemaking dated April 14 2026 addresses how state-chartered stablecoin issuers fit within the federal GENIUS Act framework, a matter that directly implicates the state-federal licensing interface relevant to Wisconsin-chartered or -licensed entities. Wisconsin-serving payment-stablecoin issuers therefore face a layered compliance stack once GENIUS Act enforcement begins in January 2027, combining new federal bank-style reserve and audit obligations with any pre-existing state money-transmitter licensing. Separately, Wisconsin's money-transmitter surety-bond schedule requires $10,000 for a first licensed location plus $5,000 for each additional location, capped at $300,000, administered by DFI, though this figure was not cross-checked against DFI's fee schedule this cycle.
Cross-Monitor Connections
The Financial Integrity Monitor flags that GENIUS Act-related April 2026 rulemakings add FinCEN and OFAC illicit-finance secondary-market monitoring duties for stablecoin issuers, a distinction this monitor notes without adopting: illicit-finance analysis of stablecoin usage belongs to FIM, not to this monitor's regulatory-perimeter tracking.
Outlook
The near-term watch list centers on whether AB471 advances to a committee vote or reaches enactment, whether the GENIUS Act's final implementing rules are issued on schedule by July 18 2026, and whether enforcement begins as planned in January 2027. Both threads will determine whether Wisconsin's digital-asset payments perimeter narrows through state legislative action, tightens through federal stablecoin regulation, or moves on both fronts simultaneously. Coverage this cycle did not extend to AB471's committee status after September 30, 2025, Wisconsin merchant-acquiring or high-risk-MCC activity, or Sentinel-fed AML/CFT items for Wisconsin, each of which remains an open item for the next research pass.
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Regulatory Status
Wisconsin's payments regulatory perimeter rests on Chapter 217, the Model Money Transmission Modernization Law, administered by the Department of Financial Institutions. Against that baseline, Assembly Bill 471 is pending in the Assembly Committee on Financial Institutions, proposing to exempt node operation, non-fiat crypto exchange, blockchain development, and mining or staking from money-transmitter licensing. The jurisdiction risk tracker records Wisconsin's regulatory direction across licensing and stablecoin policy as uncertain, with a watch trajectory pending resolution of the state bill and the federal rulemaking timeline. Underlying the licensing debate is a definitional gap in Wisconsin law, which does not currently treat virtual currency as money, leaving self-custody of cryptocurrency outside clear DFI licensure. Layered on top of this state-level picture, the federal GENIUS Act (Public Law 119-27) applies nationally to Wisconsin-serving payment-stablecoin issuers, with final implementing rules due July 18 2026 and enforcement beginning January 2027.
Outlook
For Wisconsin, the two items that will move this jurisdiction's status are whether AB471 advances out of committee toward enactment, and whether the GENIUS Act's implementation proceeds on schedule through the July 2026 rules deadline and January 2027 enforcement start.
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Wisconsin regulates money transmission under Chapter 217 (Model Money Transmission Modernization Law), administered by DFI; AB471 (pending, referred to Assembly Committee on Financial Institutions) would carve digital-asset activities out of this licensing perimeter.
Movement — NEWAB471 pending crypto-licensing exemption identified.First-cycle capture for US-WI baseline.
Standing sub-brief294 words · last cycle wpm-2026-08-05
Licensing, Authorisation & Market Access
Wisconsin administers money-transmission licensing through the Department of Financial Institutions under Chapter 217, the Model Money Transmission Modernization Law. Assembly Bill 471, introduced September 29 2025 by Representative Neylon with eight cosponsors, proposes to remove node operation, crypto-to-crypto exchange without fiat conversion, blockchain software development, and mining or staking from the Chapter 217 licensing perimeter, and would prohibit state or local restrictions on self-hosted wallets and crypto payment acceptance. The bill sits with the Assembly Committee on Financial Institutions and has not, per the most recent reporting, reached a floor vote or been enacted. The underlying driver is a definitional gap: Wisconsin statute does not currently treat virtual currency as money, which leaves self-custodied cryptocurrency activity outside clear DFI licensure and is the gap AB471 is written to close. On the existing bonding side of the licensing regime, Wisconsin requires a surety bond of $10,000 for a licensee's first location plus $5,000 for each additional location, capped at $300,000 and administered by DFI, though this bonding figure derives from a secondary compliance-guide source not cross-checked against DFI's own fee schedule this cycle. Assessed against the broader state landscape, enactment of AB471 would materially narrow Wisconsin's money-transmission licensing perimeter for digital-asset activity and align the state with a growing majority of jurisdictions that already exempt node operation, non-fiat exchange, and mining or staking from money-transmitter requirements.
Outlook
The committee-stage trajectory of AB471 is the determinative near-term marker for this module: a vote to advance, table, or amend the bill would reset Wisconsin's licensing perimeter for digital-asset intermediaries, while continued committee dormancy preserves the current gray-zone status quo for self-custody and node-level activity. Committee-vote or enactment developments after September 30 2025 were not sourced this cycle and remain an open item.
Periodic update · new data 2026-08-11 · run wpm-2026-08-05
Licensing, Authorisation & Market Access
Wisconsin regulates money transmission under Chapter 217, the Model Money Transmission Modernization Law, administered by the Department of Financial Institutions. This is the standing regulatory-perimeter baseline against which this cycle's principal development, Assembly Bill 471, must be read. AB 471, introduced September 29, 2025 by Representative Neylon and eight cosponsors, would exempt node operation, crypto-to-crypto exchange without fiat conversion, blockchain software development, and mining and staking activity from money-transmitter licensing, and would bar state or local restriction of self-hosted wallet use and of crypto-payment acceptance. The definitional gap the bill targets is that Wisconsin law does not currently define money to include virtual currencies, leaving self-custody of cryptocurrency in a regulatory grey zone as to DFI licensure. As of the most recent reporting available this cycle, AB 471 has been referred to the Assembly Committee on Financial Institutions, with no confirmed floor vote or enactment; this status update carries assessed rather than high confidence, reflecting reliance on secondary trade-press reporting for the referral status specifically. The existing licensing baseline for non-exempted money-transmission activity in Wisconsin includes a tiered surety-bond requirement of $10,000 for the first licensed location plus $5,000 per additional location, capped at $300,000, administered by DFI; this bonding figure itself rests on a Tier-4 secondary money-transmitter-license guide and was not cross-checked against DFI's own fee schedule this cycle. If enacted, AB 471 would align Wisconsin with a growing number of states that already exempt comparable digital-asset activities from money-transmitter licensing requirements, narrowing the population of crypto-native activity subject to Chapter 217's nonbank payment-institution and e-money-issuer regime.
Outlook
Watch for AB 471's committee disposition beyond its initial referral, which was not sourced further this cycle, and for whether Wisconsin's legislature moves the definitional fix ahead of or independent of federal stablecoin developments under the GENIUS Act. The bill's fate will determine whether Wisconsin's money-transmission perimeter for digital assets narrows through targeted state legislation or continues to rely on the current definitional ambiguity.
Safeguarding rests on a surety bond/permissible-investments model, with new consumer conduct obligations on virtual currency kiosk operators via 2025 Act 226.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
No periodic updates recorded against this sub-brief.
Federal GENIUS Act stablecoin framework (Public Law 119-27) applies as a national overlay to Wisconsin-serving payment stablecoin issuers; final rules due July 2026, enforcement January 2027.
Movement — NEWGENIUS Act federal overlay identified.First-cycle capture for US-WI baseline.
Standing sub-brief217 words · last cycle wpm-2026-08-05
Stablecoins & Digital Money
The GENIUS Act, enacted as Public Law 119-27 and signed July 18 2025, establishes payment stablecoins as a form of digital money that may only be issued by Permitted Payment Stablecoin Issuers, a national framework that applies to Wisconsin-serving issuers regardless of the state's own licensing regime. Final implementing rules are due July 18 2026, and the enforcement phase begins January 2027, at which point full compliance obligations attach. A US Treasury notice of proposed rulemaking issued April 14 2026 works through how state-chartered stablecoin issuers interlock with the federal GENIUS Act regime, a question that bears directly on the state-federal licensing interface for any Wisconsin-chartered or Wisconsin-licensed entity engaged in stablecoin issuance. Taken together, Wisconsin-serving payment-stablecoin issuers face a layered compliance stack once enforcement begins in January 2027: new federal bank-style reserve, attestation, and audit obligations stack on top of any pre-existing state money-transmitter licensing that already applies to their activities.
Outlook
The two forward markers to track are the final GENIUS Act implementing rules due July 18 2026 and the start of enforcement in January 2027, either of which would sharpen the compliance timeline for any Wisconsin-serving stablecoin issuer. Illicit-finance monitoring duties tied to these same rulemakings are tracked separately by the Financial Integrity Monitor and are not analysed further here.
Periodic update · new data 2026-08-11 · run wpm-2026-08-05
Stablecoins & Digital Money
The GENIUS Act, Public Law 119-27, signed July 18, 2025, is the federal overlay most directly relevant to Wisconsin-serving digital-money activity this cycle. The Act classifies payment stablecoins as digital money restricted to Permitted Payment Stablecoin Issuers, with final implementing rules targeted for July 18, 2026 and enforcement beginning January 2027; it applies nationally, including to any issuer serving Wisconsin customers, independent of Wisconsin's own money-transmitter statute. The framework applies to both bank and non-bank issuers, a notable departure from state licensing regimes that typically draw a sharper line between bank and non-bank payment institutions and e-money issuers. A Treasury notice of proposed rulemaking dated April 14, 2026 addresses how state-chartered stablecoin issuers fit within this federal framework, a question directly relevant to the state-federal licensing interface for any Wisconsin-chartered or -licensed entity; this specific reading is assessed at low confidence, resting on a Tier-4 secondary source with no primary NPRM text retrieved this cycle. Wisconsin-serving payment-stablecoin issuers therefore face a layered compliance stack once GENIUS Act enforcement begins in January 2027, combining new federal bank-style reserve, attestation, and audit obligations with whatever state money-transmitter licensing status applies to their Wisconsin operations, an interaction the state-federal NPRM appears intended to clarify but has not yet done so definitively.
Outlook
Watch for the GENIUS Act's final implementing rules around the July 2026 target date and their treatment of state-chartered issuers, and for any primary Treasury text on the state-federal licensing interplay raised in the April 2026 NPRM, neither of which was available in primary form this cycle.
Operational resilience rests on the state Data Breach Notification Law and Insurance Data Security Law for OCI licensees, with no dedicated state operational-resilience regime.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
No periodic updates recorded against this sub-brief.
Corridor exposure runs through FedNow participation by WI banks/credit unions and ch.217's cross-border money-transmission coverage.
Open gap — wpm-int-2No Wisconsin-specific bilateral trade/remittance corridor volume data was located; corridor exposure is inferred from FedNow participation and statutory cross-border coverage only.US state-level corridor/remittance-flow granularity is a known bias-correction target and remains thin here.
No sub-brief written this cycleThe module carries open gaps but no narrative analysis was authored this cycle. Flagged for the next research pass.
No periodic updates recorded against this sub-brief.
Milwaukee-based Fiserv is the epicentre of Wisconsin payments litigation: consolidated securities class actions and a Clover merchant-fee class action.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
No periodic updates recorded against this sub-brief.
This module carries the Sentinel.gi payments-context AML/CFT position only; the proprietary feed was unreachable this pass, so only the federal BSA/SAR backdrop is captured.
Open gap — wpm-int-1Sentinel.gi proprietary payments-context AML/CFT feed was not reachable this collection pass; W11 carries only public federal BSA/SAR backdrop.Illicit-finance/private-intelligence signal for a US sub-national jurisdiction remains under-covered pending Sentinel-fed update.
No sub-brief written this cycleThe module carries open gaps but no narrative analysis was authored this cycle. Flagged for the next research pass.
No periodic updates recorded against this sub-brief.
Correspondent banking pressures centre on cannabis/hemp-adjacent de-risking, with niche providers filling the service gap pending potential federal rescheduling.
Open gap — wpm-int-4The federal Executive Order directing marijuana rescheduling (Dec 18, 2025) has no disclosed implementation date, preventing regulatory_horizon extraction; correspondent-banking access implications for Wisconsin remain unresolved.no under-indexing note recorded
No sub-brief written this cycleThe module carries open gaps but no narrative analysis was authored this cycle. Flagged for the next research pass.
No periodic updates recorded against this sub-brief.
Trailing-12-month commercial activity in Wisconsin payments is dominated by Fiserv's CEO transition, workforce restructuring, and continued product/partnership activity.
Open gap — wpm-int-3Fiserv's Payfare acquisition (closed March 3, 2025) falls outside the trailing-12-month W13 commercial-event window for this baseline and was excluded from commercial_event scoring despite continued product relevance (captured instead under W9).no under-indexing note recorded
No sub-brief written this cycleThe module carries open gaps but no narrative analysis was authored this cycle. Flagged for the next research pass.
No periodic updates recorded against this sub-brief.
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