Colorado: No Licenses Needed For Crypto-Only Transactions

The Colorado Division of Banking recently released an Interim Regulatory Guidance document that provides some much needed direction for transactions that involve only cryptocurrency, and no fiat currency. This would appear to relax restrictions, or at least clarify the legal requirements, for transactions between individuals and crypto-only exchanges. 

The direct transmission of cryptocurrency between two consumers is not subject to
licensure under the Act.

With respect to transactions that involve a third party, the complete absence of fiat
currency from a transmission from one consumer to another is not money transmission.

Conversely, the presence of fiat currency during a transmission may be subject to
licensure under the Act.

Interim Regulatory Guidance Cryptocurrency
and the Colorado Money Transmitters Act

Crypto Exchanges Don’t Need Licenses in Colorado For Fiat, Positive Development