Georgia operates under the federal BSA/AML framework administered by FinCEN and OFAC, with state-level MSB/money-transmitter licensing through the Georgia Department of Banking and Finance.
United States federal law that applies in United States – Georgia is covered once, on the United States page. This page covers United States – Georgia’s own layer: its own law, regulators and enforcement.
Georgia (US) real estate sector confirmed as an enabler node for blocked Russian-asset circumvention; OFAC penalty assessed November 2025 against an Atlanta-based real estate investment company for mortgaging, renovating, and selling blocked property in violation of a cease-and-desist order; risk trajectory stable pending further enforcement post-2026 Residential Real Estate Rule rollout.
Georgia carries zero beneficial-ownership reporting obligation at state or federal level for domestically formed LLCs following the FinCEN March 2025 interim final rule; no state beneficial-ownership registry exists; currency of the exemption in-force status as of mid-2026 is unconfirmed and flagged for verification.
Georgia Atlanta-metro payment-processing corridor (Transaction Alley) flagged as an elevated structural merchant-layering and correspondent-exposure risk node, with exposure extending into stablecoin settlement rails as GENIUS Act implementing rules build out through 2026.
Conflict Finance is not yet covered for this jurisdiction in this report.
Georgia's 2026 cycle produced the clearest state-level digital-asset development in the Southeast this year: House Bill 945 established a virtual-currency-kiosk consumer-protection regime, effective July 1, 2026, layering mandatory fraud-irreversibility warnings, an 18 percent fee cap, daily transaction limits of $2,500 for new customers and $10,000 for existing customers, refund obligations for defrauded new customers within a defined reporting window, and blockchain-analytics and receipt-keeping compliance measures onto kiosk operators. This is a disclosure-and-limits architecture rather than a prohibition, and it arrived in the same week that Tennessee adopted an outright statewide ban on crypto-ATM installation and use, giving analysts a direct regional comparison of two divergent regulatory philosophies applied to the same typology risk: elder and vulnerable-victim fraud conducted through virtual-currency kiosks.
The consumer-protection statute did not arrive in isolation. The Georgia Department of Banking and Finance continued active supervisory pressure on unlicensed virtual-asset service providers operating in the state. Its cease-and-desist order against Virtual Assets LLC, doing business as Crypto Dispensers, for unlicensed money transmission under O.C.G.A. Section 7-1-681(b), became final on January 16, 2026. Separately, Bitcoin Depot Operating, LLC, one of the larger licensed kiosk operators nationally, voluntarily surrendered its Georgia money-transmitter licence on July 6, 2026 pursuant to a Consent Order, following a Chapter 11 bankruptcy filing and the shutdown of its kiosk network earlier in the year. Read together, these three developments show a regulator applying licensing enforcement against unlicensed actors while simultaneously building out a more detailed compliance architecture for licensed ones, rather than retreating from the kiosk channel altogether.
The DBF's 2026 omnibus rulemaking package, effective July 6, 2026, formalized the operational mechanics behind HB 945 and related statutes: Rule 80-3-1-.07 and related chapters now require quarterly virtual-currency-kiosk location reporting through the Nationwide Multistate Licensing System, giving the regulator a live inventory of kiosk locations rather than relying on point-in-time licensing filings. This reporting mechanism is a structural enabler for future enforcement and typology monitoring, since it gives DBF visibility into where kiosks are physically located on an ongoing basis, a capability that a kiosk-specific typology relying on unattended cash-to-crypto conversion points would otherwise evade.
The standing AML/CTF backdrop against which this cycle's kiosk-specific development should be read is the same federal Bank Secrecy Act and FinCEN framework, layered with Georgia's own money-transmitter licensing statute (O.C.G.A. Sections 7-1-680 to 7-1-698), that governs all Georgia obliged entities; no independent state financial-intelligence unit exists, and this baseline architecture did not change this cycle. HB 945's requirements are additive to that baseline rather than a replacement for it.
The near-term question is durability: whether Georgia's disclosure-and-limits model for virtual-currency kiosks proves an effective typology countermeasure relative to Tennessee's outright ban, and whether other states in the region converge toward one model or the other. The precise codified O.C.G.A. section number for HB 945's kiosk provisions remains unconfirmed beyond session-law form, an open item for the next verification pass. Continued DBF enforcement against unlicensed operators, combined with the new quarterly location-reporting requirement, suggests the state's kiosk-market visibility will improve materially through 2026 and into 2027, which should be watched for its effect on enforcement volume and on whether further licensed operators exit the market as Bitcoin Depot did.
Compliance Technology & Active Defence is not yet covered for this jurisdiction in this report.
AML/CTF Regime is not yet covered for this jurisdiction in this report.
Commercial Activity is not yet covered for this jurisdiction in this report.
For institutions with exposure to Georgia-based virtual-currency-kiosk operators or their banking relationships, the new daily transaction limits and mandatory fraud warnings are relevant to SAR-trigger calibration and to due diligence on kiosk-operator customers, given continued DBF enforcement against unlicensed VASPs in the same period.
The Crypto Dispensers cease-and-desist and the Bitcoin Depot licence surrender together indicate active DBF supervisory attention to virtual-currency-kiosk licensing status; compliance functions supporting Georgia-facing kiosk relationships should confirm current licensing status given this heightened supervisory activity.
The refund obligation for defrauded new customers and the 18 percent fee cap are binding statutory requirements, not guidance, creating direct compliance and potential private-enforcement exposure for kiosk operators doing business in Georgia.
This regional divergence is a governance-relevant signal for any institution with multi-state virtual-currency-kiosk exposure: regulatory treatment of the same product is diverging materially state-by-state, which raises the compliance-complexity and reputational-exposure profile of operating across state lines in this segment.
This is a modest RegTech mandate rather than a broader technology-architecture requirement: kiosk operators must integrate blockchain-analytics capability and report physical kiosk locations quarterly through the Nationwide Multistate Licensing System, which is a new data-reporting integration point for affected firms' technology stacks.
The new transaction limits and refund duties are direct risk-mitigation measures targeted at this specific typology; risk functions should note that DBF's continued enforcement against unlicensed operators alongside HB 945's licensed-operator obligations indicates the kiosk channel remains an active exposure-concentration point in the state.
No material change for this persona this cycle
Internal audit functions covering Georgia-facing kiosk relationships should note that quarterly location reporting under Rule 80-3-1-.07 creates a new recurring compliance-evidence artifact whose completeness and timeliness can now be tested as part of standard control-testing scope.
Georgia enacted a virtual-currency-kiosk consumer-protection regime (HB 945) with transaction-limit and refund obligations, effective July 1, 2026.
DBF finalized enforcement against an unlicensed VASP and processed a licensed operator's voluntary surrender within the same reporting period.
Georgia's HB 945 kiosk regime imposes statutory refund obligations and fee caps as a matter of enacted state law effective July 1, 2026.
Georgia chose a disclosure-and-limits regulatory model for virtual-currency kiosks rather than the outright ban a neighboring state adopted the same week.
HB 945 requires kiosk operators to deploy blockchain-analytics tooling and quarterly NMLS location reporting as compliance measures.
Georgia's kiosk-specific typology exposure remains centered on elder and vulnerable-victim fraud conducted through unattended virtual-currency kiosks.
No material change this cycle.
HB 945's new quarterly NMLS location-reporting requirement creates a fresh documentation trail for Georgia virtual-currency-kiosk operators.
Illustrative scenario for analytical orientation only: as the Anti-Money Laundering Authority (Reg (EU) 2024/1620) moves toward direct and indirect supervision of designated cross-border obliged entities, alongside the directly-applicable AML Regulation (Reg (EU) 2024/1624) and per-Member-State transposition of the sixth AML Directive, a plausible structural mechanism is that entities previously supervised only at a purely national level could face a harder-to-navigate multi-layer supervisory perimeter, potentially shifting evasion attempts toward jurisdictions and entity types outside AMLA's initial direct-supervision scope. This is an illustration of a possible structural mechanism, not an observed fact about any specific entity or jurisdiction.
Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact.
| Tracker | Status | Note |
|---|---|---|
| T1 · Russian Sanctions-Evasion Architecture | no_change | No material change found attributable to US-GA specifically this cycle; subnational US jurisdiction with no independent sanctions-implementation authority. |
| T2 · EU AML Package / AMLA | no_change | Not applicable to a US subnational jurisdiction. |
| T3 · FATF Grey List | no_change | US-GA is a US subnational jurisdiction; FATF grey-list status attaches to the United States as a country, which is not currently grey-listed. |
| T4 · Beneficial-Ownership Register Status | no_change | No Georgia-specific beneficial-ownership register development found this cycle. |
| T5 · Crypto & Digital-Asset Integrity | material_change | Georgia enacted HB 945's virtual-currency-kiosk regime effective July 1, 2026, and DBF continued enforcement against unlicensed VASPs. |
| T6 · Sanctions Regime Divergence | no_change | Not applicable at the US-state level; sanctions-regime design is a federal (OFAC) competence. |