Wyoming Division of Banking

Overview

The Wyoming Division of Banking is the primary state regulator responsible for licensing and supervising money transmitters and financial service providers operating in Wyoming. As an official state banking regulator, the Division operates under Layer 1 authority with binding regulatory power. Wyoming has positioned itself as a crypto-friendly jurisdiction through its pioneering Special Purpose Depository Institution (SPDI) charter framework, making it a notable destination for digital asset and fintech innovation.

The Division administers the Wyoming Money Transmitter Act and maintains oversight of multiple categories of financial service providers, including money transmitters, consumer lenders, check cashers, and virtual currency service providers. Since 2019, Wyoming has also issued the nation's first SPDI charters, enabling crypto-focused banking operations.

Regulator Profile:

Entity Type: Official State Regulator
Jurisdiction Level: State (Wyoming)
Legal Authority: Binding regulatory authority
Primary Function: Money transmitter licensing, bank chartering, financial services supervision

Basic Identity

Field	Value
Official Name (English)	Wyoming Division of Banking
Official Name (Local Language)	Wyoming Division of Banking
Acronym	[Not applicable]
Country	United States
Jurisdiction Level	State
Official Website	https://wyomingbankingdivision.wyo.gov"
Official Website Language(s)	English
Headquarters	United States
Year Established	2019
Current Status	Active

Classification

Field	Value
Entity Type	Official Regulator
Control Layer	Layer 1 — Sovereign/Government Regulator
Legal Authority Level	Binding
Jurisdiction Level	State
Scope of Power	Licensing, Supervision, Enforcement, Rulemaking

Inclusion Justification

Field	Value
Why This Entity Is Included	Government-backed financial regulatory authority with statutory licensing, supervisory, and enforcement powers
Type of Influence	Direct
Exclusion Risk	Removes a key financial regulatory authority from the jurisdiction's control map

What This Entity Oversees

Examination Authority and Scope

The Wyoming Division of Banking has statutory authority to:

Conduct periodic examinations of all money transmitter licensees
Inspect books, accounts, and records
Interview employees and principals
Require submission of reports at any time
Verify compliance with all applicable statutes and regulations

Examination Frequency and Standards

Examination Schedule:

Initial examination: Typically within [UNVERIFIED - specific timeframe] of license issuance
Ongoing examinations: Risk-based frequency (annual, biennial, or as-needed) [UNVERIFIED - exact schedule]
Special examinations: Conducted when risk factors warrant additional oversight

Examination Standards:

Safety and soundness of operations
Capital adequacy and financial stability
Compliance with the Wyoming Money Transmitter Act
Anti-money laundering (AML) and Know Your Customer (KYC) procedures
Customer protection and complaint handling
Technology and cybersecurity controls
Authorized delegate supervision

Reporting Requirements

Annual Reporting:

Audited financial statements (balance sheet, income statement, cash flow)
Outstanding payment instrument reports
Changes in ownership, control, or principal officers
Enforcement actions or legal proceedings
Material changes in business operations or service providers

Quarterly Reporting:

[UNVERIFIED - frequency and content of interim reports]

Event-Based Reporting:

Material changes to operations within [UNVERIFIED - specified days]
Customer complaints and dispute resolutions
Cybersecurity incidents or data breaches
Bankruptcy filings or insolvency proceedings
Key personnel changes

Data Security and Cybersecurity Standards

[UNVERIFIED - specific cybersecurity and data protection requirements not fully documented in search results]

Licensees must implement:

Multi-factor authentication for customer accounts
Encryption of customer personal information
Network security and intrusion detection
Incident response and breach notification procedures
[Additional standards to be verified]

Customer Fund Protection and Segregation

[UNVERIFIED - specific segregation and protection requirements for customer funds]

Licensees must:

Maintain clear accounting separation of customer funds
Hold customer funds in trust accounts
Protect against unauthorized access or commingling
Provide regular account statements to customers

Complaint and Dispute Resolution

Customer Complaint Process:

Customers may file complaints with the Wyoming Division of Banking
Division logs complaints and notifies the licensee
Licensee has [UNVERIFIED - specified timeframe] to respond
Division investigates and mediates resolution
Division may order restitution or take enforcement action

Complaint Information:

Phone: (307) 777-7797
Email: [email protected]
Online portal: [UNVERIFIED - complaint filing portal URL]
Mailing address: Wyoming Division of Banking, Hathaway Building, 2nd Floor, 2300 Capitol Avenue, Cheyenne, WY 82002

How to File a Complaint:

Official complaint filing procedures are available at https://wyomingbankingdivision.wyo.gov/how-to-file-a-complaint

Disclosure and Transparency Requirements

Licensees must disclose:

Fee schedules and pricing in advance of service provision
Terms and conditions of money transmission services
Estimated delivery times for funds transfers
Refund and cancellation policies
Exchange rate methodologies (for currency exchange services)

Customer Rights and Remedies

Customers have the right to:

Accurate and timely fund delivery
Clear disclosure of all fees and terms
Refund of fees or payment instruments not used
Dispute resolution and complaint investigation
Restitution if harm occurs due to licensee misconduct

Regulatory Powers

Violation and Non-Compliance Authority

The Wyoming Division of Banking has broad enforcement authority to address violations of the Wyoming Money Transmitter Act, including:

Administrative Actions:

Cease and desist orders
License suspension
License revocation
Civil penalties and fines
Mandatory remediation and corrective action plans
Mandatory customer restitution programs

Grounds for Enforcement:

Failure to maintain required net worth or bonding
Violation of capital requirements or investment restrictions
Failure to file required reports or submit to examinations
Misrepresentation in license applications
Unsafe or unsound business practices
Violations of the Bank Secrecy Act or AML regulations
Customer harm or breach of fiduciary duty
Fraud or intentional misconduct
Unauthorized operation without a license

License Revocation and Denial

Revocation Triggers:

Persistence of serious violations despite notice
Customer protection failures
Inability to meet regulatory standards
Insolvency or capital inadequacy
Criminal convictions of principals or officers (as determined by the Division)

Revocation Process:

Notification of alleged violations
Opportunity for hearing and response [UNVERIFIED - specific procedural requirements]
Division determination
Formal revocation order
[UNVERIFIED - appeal or reconsideration rights]

Civil and Criminal Remedies

Civil Liability:

Customer restitution for damages
Disgorgement of profits
Civil penalties up to [UNVERIFIED - specific dollar amount]

Criminal Referrals:

Division may refer cases to Wyoming state prosecutors
Federal referrals to FinCEN and DOJ for money laundering or fraud

Regulatory Role and Function

Role	Description
Primary Role	Financial regulation and supervision within statutory mandate
Licensing Role	Issues authorizations and licenses within scope of authority
Supervisory Role	Supervision of regulated entities within mandate
Enforcement Role	Enforcement of applicable financial laws and regulations
Payment Systems Oversight Role	Payment system oversight where within mandate
AML / CFT Role	AML/CFT supervision within regulatory scope

Legal Foundation

Statutory Framework

The Wyoming Division of Banking derives its authority to regulate money transmitters from the Wyoming Money Transmitter Act (Wyo. Stat. § 40-22-101 et seq.), codified under Title 40 (Trade and Commerce), Chapter 22 of the Wyoming Statutes.

Key Statutory Provisions:

40-22-101: Definitions and scope of money transmission activities
40-22-103: License requirement mandate—no person may engage in money transmission without a Division license
40-22-104: Application and approval procedures
40-22-105: Net worth and bonding requirements
40-22-106: Authorized delegates and third-party servicer responsibilities
40-22-107: Annual reporting and examination requirements

The Act applies to all entities engaged in the business of money transmission, including those:

Advertising, offering, or providing money transmission services to Wyoming residents
Operating via internet, electronic means, or other media
Engaging in personal, family, or household financial transactions

Organizational Structure

The Wyoming Division of Banking is housed within the Wyoming Department of Audit, Public Funds and General Services. The Division operates under the leadership of a Banking Commissioner appointed by state authority and reports to the Department director.

Current Leadership:

Banking Commissioner: Jeremiah Bishop

Interstate and Federal Coordination

The Division coordinates with:

Federal Deposit Insurance Corporation (FDIC) - for bank charter oversight
National Multistate Licensing System (NMLS) - for license filing and tracking
FinCEN (Financial Crimes Enforcement Network) - for Money Transmitter Regulation compliance
Conference of State Bank Supervisors (CSBS) - for peer coordination
Wyoming Legislature - for statutory updates and regulatory framework adjustments

Licensing and Authorization Relevance

License Requirement and Scope

No person, firm, corporation, association, or other entity may engage in the business of money transmission in Wyoming or advertise/offer such services to Wyoming residents without first obtaining a license from the Wyoming Division of Banking.

Activities Requiring a License:

Transmitting money or monetary value on behalf of customers
Issuing or selling payment instruments (prepaid cards, checks, etc.)
Providing currency exchange services
Operating remittance networks or settlement services
Providing digital asset custody or transmission services [UNVERIFIED - SPDI-specific scope]

Exceptions to Licensing:

Entities regulated as state or federally chartered banks
Entities regulated under the Securities Act
Certain limited activities by postal services or transportation companies [UNVERIFIED - exact scope]

Application Process

Applicants must file through the Nationwide Multistate Licensing System (NMLS) for all money transmitter applications and license activities. The NMLS serves as the centralized hub for application submission, fee payment, and renewal processing.

Required Submission Documents:

Organizational Information:

Legal business name and DBA names
Federal Employer Identification Number (EIN)
Complete ownership and control structure
Identification and contact information for all principals, managers, and officers

Financial Documentation:

Audited financial statements for the current year and preceding two years, including:
Balance sheet
Statement of income/loss
Statement of changes in financial position
Proof of minimum tangible net worth of $25,000
Detailed list of permissible investments and asset composition

Operational Documentation:

Business plan and operational procedures
Contingency and business continuity plans
List of all states where applicant currently holds licenses or has applied
Outstanding payment instrument details (dollar amount and quantity)
Third-party service provider agreements and authorizations

Personnel Background:

Five-year employment history for all executive officers and key shareholders
Criminal background disclosures for all principals
Fingerprints and identification (if required)
Personal financial statements for controlling owners

License Term and Renewal

Initial License Duration: [UNVERIFIED - typically annual or multi-year]
Renewal Process: License renewal applications must be submitted through NMLS
Renewal Interval: [UNVERIFIED - annual, biennial, or other]
Continuing Fees: [UNVERIFIED - renewal fee structure and amounts]

Authorized Delegates

Licensees may use authorized delegates to conduct money transmission on their behalf, subject to:

Written authorization agreements on file with the Division
The delegate must meet equivalent licensing standards or be approved by the Division
The primary licensee remains liable for all delegate activities
All delegates must comply with the Bank Secrecy Act and AML/KYC requirements

Net Worth Requirement

Minimum Tangible Net Worth: $25,000

This requirement must be maintained at all times throughout the license tenure. Tangible net worth is calculated as:

Total assets minus total liabilities
Excluding intangible assets (goodwill, patents, trademarks, etc.)
Including only liquid or readily convertible assets

Compliance:

Audited financial statements must demonstrate compliance at application
Annual audited statements required to maintain compliance Requires verification from official sources
Any breach triggers notification requirements and remediation obligations

Surety Bond / Capital Guarantee Requirement

Bond Requirement Structure:

Standard Bond Amount: $500,000 surety bond
Alternative: Premium-based guarantee of $12,500
Calculation Basis: The greater of:
$10,000, OR
2.5% of the amount of outstanding payment instruments held by licensee or its delegates
Cap: Bond amount may not exceed $500,000 in any case

Bond Requirements:

Bond must be issued by a Wyoming-approved surety company
Bond must remain in force continuously during the license term
Claims against the bond may be filed by the Division or customers
Bond renewal must occur prior to expiration
Any lapse in bond coverage may result in license suspension or revocation

Permissible Investment and Liquid Asset Requirements

[UNVERIFIED - specific investment restrictions and liquid asset percentage requirements not fully determined from search results]

Licensees must maintain approved investment portfolios consisting of:

Cash and cash equivalents
U.S. Treasury securities
FDIC-insured deposits
State and municipal bonds
Other approved liquid instruments [UNVERIFIED - exact list]

Special Purpose Depository Institution (SPDI) Charter

Wyoming offers the Special Purpose Depository Institution (SPDI) charter—the first of its kind in the United States, created through the Special Purpose Depository Institution Act (Wyo. Stat. § 13-1-101 et seq.), as amended by House Bill 74 (2019).

SPDI Framework:

Full-reserve banking model (100% asset backing of customer deposits)
Enables custody and transmission of digital assets
Uninsured institutions (no FDIC backing)
No lending authority
Focused on crypto, digital securities, and digital consumer assets

SPDI Authorized Activities:

Deposit-taking (fiat and digital assets)
Custody of digital assets (cryptocurrencies, tokenized securities, etc.)
Asset servicing and administration
Transaction facilitation on behalf of customers
Fiduciary asset management
Payment settlement services
Stablecoin issuance (under certain conditions) [UNVERIFIED - specific parameters]

SPDI Licensing Process:

Applications are submitted to the Wyoming Division of Banking and subject to approval based on:

Financial stability and capitalization
Business plan and operational soundness
Compliance with digital asset safeguarding standards
Management experience and competency
Customer protection measures
AML/KYC program adequacy

Notable SPDI Licensees:

Kraken Financial (Kraken Corp.) - Issued 2020, cryptocurrency exchange custody
Custodia Bank (formerly Avanti Bank & Trust) - Issued 2020, digital asset infrastructure

Virtual Currency Service Provider Regulation

[UNVERIFIED - specific registration or licensing requirements for virtual currency exchanges, wallet providers, and DeFi platforms]

The Division regulates entities engaged in:

Virtual currency exchange services
Stablecoin issuance and redemption
Cryptocurrency custody and wallet services
Digital asset trading platforms
[Additional services to be verified]

Fintech Sandbox and Innovation Program

Financial Technology Sandbox:

Wyoming offers a FinTech Sandbox program enabling companies to test innovative financial products and services under the Division's regulated environment with certain exemptions or modified requirements.

Sandbox Features:

Limited operational scope (time-limited, customer-limited, transaction-limited)
Streamlined approval and reduced compliance burden
Real-world testing under regulatory supervision
Clear graduation pathway to full licensure

Sandbox Application Process:

Submit application to Wyoming Division of Banking
Demonstrate innovative product/service
Present risk mitigation and customer protection plan
Receive approval and exemption terms
Operate under sandbox parameters

Resources: https://wyomingbankingdivision.wyo.gov/banks-and-trust-companies/financial-technology-sandbox

Payments and Money Movement Relevance

The Wyoming Division of Banking has the following relevance to payments and money movement in United States:

Function	Relevance
Payment System Oversight	Oversees payment systems and payment service providers within mandate
Licensing	Licenses entities involved in payment services where applicable
Consumer Protection	Enforces consumer protection rules for payment services
AML/CFT	Ensures payment service providers comply with AML/CFT requirements

Payment Systems Governed or Overseen

The Wyoming Division of Banking does not directly operate payment systems. Its payment-related role includes:

Function	Relationship to Payments
Money Transmitter Licensing	Issues and supervises state money transmitter licenses
Consumer Lending Oversight	Regulates consumer lending and credit products with payment components
Bank Supervision	Supervises state-chartered banks that participate in payment systems
Consumer Protection	Enforces state consumer financial protection laws
Fintech Regulation	Oversees fintech companies and payment innovators operating in the state

Money transmitters, payment processors, and fintech companies operating in this jurisdiction require licensing or registration with this entity.

Relationship to Other Regulators

NMLS Integration

The Wyoming Division of Banking fully integrates with the Nationwide Multistate Licensing System (NMLS), operated by the Conference of State Bank Supervisors (CSBS). All money transmitter license applications, renewals, and compliance filings must be processed through NMLS.

NMLS Functions:

Centralized application submission and processing
Uniform licensing database accessible to all state regulators
Fee payment and license term management
Annual report submission and tracking
Real-time regulator coordination and information sharing

Reciprocity and Multi-State Licensing

Entities licensed in Wyoming may apply for reciprocal licenses in other states through the NMLS framework. Similarly, out-of-state licensees may apply for Wyoming licenses through the standardized process.

Multi-State Considerations:

Wyoming maintains separate licensing authority; no automatic reciprocity applies
Each state conducts independent application review
Net worth and bonding requirements may differ by state
Some states recognize Wyoming's stronger regulatory framework [UNVERIFIED - specific state relationships]

FinCEN Reporting and Federal Coordination

As a state regulator, the Wyoming Division of Banking:

Coordinates with FinCEN (Financial Crimes Enforcement Network) on AML/KYC enforcement
Receives Currency Transaction Report (CTR) and Suspicious Activity Report (SAR) data
Shares information on unlicensed money transmitter activity
Participates in multi-state enforcement actions

Geography and Jurisdiction Notes

Field	Value
Applies Nationwide	No
Applies at State or Sub-National Level Only	Yes
Cross-Border or Regional Reach	No
Special Territorial Notes	State jurisdiction within United States

Important Departments and Divisions

Division / Department	Primary Function
Supervision Division	Oversight of regulated entities
Licensing Division	Processing of applications and authorizations
Enforcement Division	Investigation and prosecution of violations
Policy and Research Division	Regulatory policy development
Compliance Division	AML/CFT and regulatory compliance monitoring