Virtual Currency Kiosks — Department of Financial Institutions, Division of Consumer Services
Summary
A slide presentation titled Virtual Currency Kiosks from the Department of Financial Institutions, presented by Ali Higgs, Director of the Division of Consumer Services, and Drew Bouton, Director of Policy. The slides define virtual currency kiosks as electronic terminals that allow users to purchase and/or send virtual currencies. Listed concerns include anonymous transactions, inability to pursue restitution for victims, and a disproportionate target toward elderly and vulnerable consumers. Other slides cover kiosk transaction volume for 2020-2024, the stages of a scam process, federal highlights from FinCEN, the FTC and the FBI, and a legislation map sourced to AARP as of August 21, 2025.
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“Virtual Currency Kiosks — Department of Financial Institutions, Division of Consumer Services.”
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Virtual Currency Kiosks
Department of Financial Institutions
Ali Higgs, Director of the Division of Consumer Services
Drew Bouton, Directory of Policy
What are Virtual Currency Kiosks?
• Electronic terminals that allow users to
purchase and/or send virtual currencies
Definition • Often referred to as crypto kiosks or Bitcoin
ATMS
• Uniform Money Services Act
Regulation • Guidance from DFI
• Other federal and state laws and regulations
• Allows for anonymous transactions
• Inability to pursue restitution for victims
Concerns • Disproportionate target toward elderly and
vulnerable consumers
Virtual Currency Kiosk Licensee Locations
Virtual Currency Kiosk Volume
Total Dollar Volume from 2020-2024
140,000,000
120,000,000 $121,400,151
100,000,000 $101,956,579
80,000,000
$69,705,699
60,000,000
$53,548,336
40,000,000
$23,520,721
20,000,000
0
2020 2021 2022 2023 2024
Total WA Transaction Volume
Average Virtual Currency Kiosk Transaction Amount
Average Transaction Amount for 2020-2024
$780.00
$760.25
$760.00
$740.00
$720.00
$705.03
$700.00
$680.00
$676.38 $654.78
$660.00 $672.75
$640.00
$620.00
$600.00
2020 2021 2022 2023 2024
Average WA Transaction Amount
Flow of Funds
Virtual Currency Kiosk Customers
Cash users: People who prefer to transact in cash and may be unbanked or underbanked.
Elder adults: Older users who may not be as adept with current technology but are used to
traditional ATMs. These users tend to prefer familiar, personal, and tangible experiences.
Privacy seekers: Users who want greater anonymity than is provided by a crypto exchange.
Convenience-focused consumers: Users who want quick and easy transactions and are willing
to pay a fee for this convenience.
Cross-border payments: Users who send virtual currency as a form of remittance.
Source: Federal Reserve of Kansas City, as of August 30, 2023
Virtual Currency Kiosk Fraud Demographics
Source: Federal Bureau of Investigation Internet Crime Report 2024
The Scam Process
Initial Contact Building Inducing Payment Disappearance
Trust Action and Theft and Loss
• Social Media • Foster a • Lucrative • Victims are • Once victim tries to
• Dating apps relationship: investment directed to fake withdraw funds, they
• Wrong number text romantic or opportunity websites or will be hit with fees,
messages platonic by typically platforms taxes, etc.
engaging in involving crypto • Scammers • Once money runs out,
regular • Evidence of own occasionally or victim catches on,
conversations to success allow victims to the scammer
establish a bond • Insider withdraw small disappears
knowledge profits • Victim suffers
financial harm and
significant emotional
distress
Federal Highlights
FinCEN
Advisory on Illicit Activity Involving
Convertible Virtual Currency
Notice on the Use of Convertible Virtual
Currency Kiosks for Scam Payments and
Other Illicit Activity
FTC
Bitcoin ATMS: A Payment Portal for
Scammers
FBI/Internet Crime Complaint Center (IC3)
Internet Crime Report 2024
Source: Federal Bureau of Investigation Internet Crime Report 2024
Legislation WA
ME
and OR
MT ND
Regulatory
MN VT
ID NH
SD NY
WI
Actions WY MI
MA
CT
RI
IA
NE PA
NJ
NV OH
IL
UT IN DE
CO
WV
CA KS
MO VA
MA
KY
NC RI
TN
AZ OK
NM AR SC
GA
AL
MS
NJ
AK TX
LA
Bill Introduction in 2025 DE
Pending Governor’s Approval in 2025 FL MD
HI
Regulation/Guidance Issued DC
Law Enacted
Source: AARP, as of August 21, 2025
Consumer Protection Elements
Protections Other States have Enacted
LICENSING AND RECEIPTS AND DAILY TRANSACTION FEE
REGISTRATION DISCLOSURE TRANSACTION LIMITS
REQUIREMENTS REQUIREMENTS LIMITS
Questions
Ali Higgs Drew Bouton
Director of the Division of Consumer Director of Policy
Services
Department of Financial Institutions
Department of Financial Institutions
Drew.Bouton@dfi.wa.gov
Ali.Higgs@dfi.wa.gov
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