Connecticut Digital Currency Kiosk Consumer Protection Regime

The regime sits inside Connecticut’s Money Transmission Act. The current statutory definitions include money transmission by virtual currency kiosk or digital wallet, define “virtual currency” broadly, and define a virtual currency kiosk as an electronic terminal that facilitates the exchange of virtual currency for fiat currency or other virtual currency. The statute also defines new and existing customers for purposes of the daily kiosk transaction limits.

Public Act 25-66 broadened several duties beyond kiosk operators. The current text applies disclosure and receipt duties to each licensee that receives, transmits, stores, or maintains custody or control of virtual currency, while keeping separate kiosk-specific obligations where a transaction uses a physical terminal.

• Risk disclosures. Licensees must provide clear, conspicuous, legible disclosures before opening an account and before each transaction. Required topics include material risks, transaction amounts, fees, exchange rates, the nature of the transaction, irreversibility warnings, kiosk limits, and the spread between the sale price and market price.
• Receipts. After a virtual currency transaction, licensees must provide a receipt with customer and transaction information, transaction hash or identification number, wallet information, fees, taxes, exchange rates, refund policy, liability statements, and Department of Banking contact information. For kiosk transactions, electronic receipts are permitted only when the customer requests or agrees to receive one.
• Fee cap and daily limits. Kiosk fee and commission charges may not exceed 15% of the transaction amount. The statute sets daily limits of $2,000 for a new customer and $5,000 for an existing customer.
• Fraud-related refund right. A new customer may request cancellation and a full refund for fraudulent kiosk transactions that occurred within 72 hours after registration if the customer contacts the operator and a government or law enforcement agency, and files a report, within the statutory time frame.
• Kiosk controls. Owners and operators must collect government-issued identification, restrict shared wallet use, block designated wallets, use blockchain-analysis screening for high-risk or sanctioned wallets, offer live telephone support during kiosk hours, and maintain compliance staffing.

Connecticut’s statute adds telephone-intervention requirements for certain higher-risk kiosk interactions. A kiosk owner or operator must speak with a new customer over 60 before that customer completes a first transaction. It must also speak with a new customer attempting a transaction above a predesignated large-transaction amount. The calls must be recorded and retained, and the operator’s approval depends on its assessment of the communication.

Public Act 25-66 also added restrictions on how licensees handle customer virtual currency. A licensee may not sell, transfer, lend, pledge, or otherwise use or encumber customer-controlled virtual currency except at the customer’s direction. A licensee also may not use another person, including a virtual currency control services vendor, to store or hold customer virtual currency unless the person is licensed, is a qualifying bank or credit union, or has Banking Commissioner approval.

The Connecticut Department of Banking remains the primary state regulator. In March 2026, the department announced an enforcement matter alleging violations of several § 36a-613 requirements, including fee caps, transaction limits, receipt content, senior-customer calls, refund obligations, disclosures, and policies and procedures. That enforcement item is included here as status context, not as legal advice or a compliance conclusion.