$2,000 Daily Caps, 14-Day Scam Refunds, and Mandatory Blockchain

New Hampshire lawmakers passed Senate Bill 482-FN on April 24, 2026, imposing a $2,000 daily transaction cap on cryptocurrency ATMs, requiring operators to refund scam victims — including all fees — within 14 days of a report, and mandating that every machine use blockchain analytics to block transfers to wallets linked to fraud, theft, or sanctions violations. The bill now sits on the governor's desk. For the roughly 127 Bitcoin ATMs operating across the state, this is the most consequential regulatory event in New Hampshire's crypto ATM history. But the bill's ambitions — particularly its novel refund mandate — raise a question no state has yet answered: can you force an operator to make a scam victim whole when the scammer's wallet was drained days ago?

$22M

NH Crypto ATM Scam Losses in 2024

$2,000

Daily Transaction Cap Per Customer

14 Days

Window to Report Fraud for Full Refund

~127

Crypto ATMs Currently in New Hampshire

Why New Hampshire Acted Now

For the past two years, New Hampshire has been an anomaly. As neighboring states imposed transaction limits and fraud-prevention requirements on Bitcoin ATMs, the Granite State had none. Law enforcement officials told legislators that scammers noticed — deliberately steering victims toward New Hampshire kiosks precisely because there were no caps or cooling-off periods to interrupt the fraud. The numbers bore that out. New Hampshire residents lost approximately $22 million to scams routed through cryptocurrency kiosks in 2024 alone, according to data cited during legislative hearings. The state's Attorney General and local police chiefs pushed for the legislation, framing SB 482-FN as a direct response to that surge. The bill passed both chambers on April 24, 2026. It joins legislation from 24 other states that have already enacted some form of crypto kiosk safeguard. Supporters, including the bill's sponsor Senator Birdsell, have described SB 482-FN as a "moderate, reasonable approach" — strict enough to deter fraud without destroying an industry that does serve legitimate users.

What SB 482-FN Actually Requires

The bill, if signed, takes effect 180 days after passage — roughly October 2026 — giving operators a transition window to build compliance infrastructure. The requirements go well beyond a simple transaction cap.

Key Provisions of SB 482-FN:

Chart summarizing reported crypto atm scam losses in the u.s., 2023–2025. — Reported Crypto ATM Scam Losses in the U.S., 2023–2025. Highlights the sharp increase in nationwide losses from crypto ATM scams, to illustrate why regulators (like NH lawmakers) are intervening. Source: prismedia.ai

$2,000 daily cap: No operator may accept or dispense more than $2,000 per customer per day, aggregated across all of that operator's kiosks in the state
48-hour hold for first-time users: A new customer's initial transaction must be held for at least 48 hours, during which the customer can cancel and receive a full refund
14-day scam refund: If a customer was fraudulently induced into a transaction and reports it to the operator and law enforcement within 14 days, the operator must provide a full refund including all fees
Blockchain analytics: Operators must use blockchain analytics tools to screen and block transfers to wallet addresses associated with scams, theft, sanctions, or other illicit activity
Fraud warnings and screening questions: Kiosks must display prominent scam warnings, ask fraud-screening questions, and block the transaction if the customer's answers indicate potential fraud
Fee transparency: All fees and exchange rate markups must be disclosed on-screen and on receipts
Identity verification: Operators must verify customer identity and only allow transactions under the customer's true name, in compliance with state and federal laws

The identity verification and true-name requirements go beyond what many operators currently implement for sub-$2,000 transactions, where federal BSA/AML rules permit lighter-touch KYC. New Hampshire is effectively saying: every transaction, regardless of size, requires full identity verification.

The 14-Day Refund Mandate: Bold or Unworkable?

The refund provision is the bill's most aggressive feature — and its biggest open question. Under SB 482-FN, if a customer reports to both the operator and law enforcement within 14 days that they were "fraudulently induced" into a transaction, the operator must refund the full amount plus any fees charged. This is not how Bitcoin ATM transactions work in practice. When a scam victim feeds cash into a kiosk, the operator converts it to cryptocurrency and sends it to the wallet address the victim provides — which is controlled by the scammer. Within minutes, those funds are typically moved through multiple wallets, mixers, or cross-chain bridges. They're gone. The refund mandate means operators absorb the loss. That's a fundamental shift: it transforms Bitcoin ATM operators from transaction processors into something more like insurers against customer fraud. The bill doesn't specify a cap on refund liability, nor does it detail what evidence constitutes being "fraudulently induced" beyond the customer's report and a law enforcement filing. This is by design. The bill's sponsors and the New Hampshire Attorney General's office pushed for the refund mandate specifically because the alternative — expecting law enforcement to recover crypto from overseas scammers — has proven essentially impossible. If operators must eat the cost of every scam they fail to stop, the economics of lax compliance change dramatically. But it also raises questions about gaming. What stops a non-scam customer from claiming fraud to get a refund? The law enforcement filing requirement creates a filing-a-false-report deterrent, but operators will need clear procedures for investigating refund claims — and the bill's text leaves those details largely to implementation. For operators running thin margins, this creates a direct financial incentive to either invest heavily in front-end fraud prevention — the screening questions, the blockchain analytics, the 48-hour holds — or exit the state. The bill's architects are betting that operators will choose prevention.

Blockchain Analytics: What It Means Operationally

The requirement that operators use "blockchain analytics tools" to block transfers involving flagged wallet addresses sounds technical, but the concept is straightforward. Companies like Chainalysis, Elliptic, and TRM Labs maintain databases of cryptocurrency wallet addresses linked to known scams, sanctioned entities, ransomware groups, and other illicit activity. Major exchanges already screen outgoing transfers against these databases as part of anti-money-laundering compliance. SB 482-FN requires Bitcoin ATM operators to do the same. Before completing a transaction, the machine would check the destination wallet against these screening databases. If the wallet is flagged, the transaction gets blocked. This is operationally comparable to the OFAC sanctions screening that banks perform daily. The major operators — Bitcoin Depot, CoinFlip, and Byte Federal — already claim to use some form of blockchain analytics. The question is whether smaller operators, which account for a meaningful share of the New Hampshire market, have the infrastructure and vendor relationships to comply within 180 days. The limitation is obvious: blockchain analytics can only flag wallets that are already known to be illicit. A scammer using a fresh wallet that hasn't been flagged won't be caught by this screen. The requirement is a meaningful layer of defense, but not a complete one.

How New Hampshire Compares to Other States

The regulatory landscape for Bitcoin ATMs is now splitting into three distinct approaches:

State Regulatory Approaches (2026):

Outright bans: Tennessee (signed by Governor Bill Lee on April 23, 2026, effective July 1, 2026) and Indiana have banned crypto ATMs entirely, with criminal penalties for non-compliance
Strict regulation: New Hampshire (SB 482-FN) and roughly 24 other states have enacted varying levels of consumer protection — transaction caps, warnings, licensing, refund mandates, or some combination
Minimal oversight: A shrinking number of states still rely primarily on existing money-transmission licensing and general fraud statutes, without crypto-ATM-specific rules

New Hampshire's 14-day refund mandate and blockchain analytics requirement put it on the stricter end of the regulation spectrum. Utah, by comparison, enacted graduated transaction limits and fraud warnings but did not include a scam-victim refund provision or blockchain analytics mandate. A 2026 Utah bill that would have regulated kiosks more aggressively under money transmitter laws failed to pass. The refund mandate is the real differentiator. No other state has imposed a comparable obligation on operators to make scam victims whole out of their own revenue.

Who's Affected: The Operator Landscape

Approximately 10 companies operate the roughly 127 crypto ATMs in New Hampshire. Bitcoin Depot (NASDAQ: BTM) dominates the market with around 70 machines, followed by CoinFlip with approximately 18 and Byte Federal with roughly 10. None of these operators have publicly announced plans to exit the state — a meaningful contrast with Tennessee, where the outright ban is forcing operators to physically remove machines by July 1. But compliance will cost money. The blockchain analytics requirement means ongoing subscription costs with third-party providers. The 48-hour hold on first-time transactions means delayed revenue and potentially lost customers who decide the wait isn't worth it. The fee transparency requirements may pressure operators who currently bury margin in opaque exchange-rate markups. And the 14-day refund mandate creates an entirely new category of financial exposure — one that's impossible to model precisely until operators see how many refund claims materialize.

Operator Compliance Checklist:

Chart summarizing state responses to crypto atm fraud (2026). — State Responses to Crypto ATM Fraud (2026). Illustrates the divergence in regulatory approaches, contrasting New Hampshire's 'middle path' guardrails with the outright prohibition enacted in Tennessee and local municipalities in Utah. Source: therecord.media, legiscan.com

Blockchain analytics integration: Contract with a screening provider (Chainalysis, Elliptic, TRM Labs, or equivalent) for real-time wallet screening before executing transactions
Refund reserves: Build financial reserves or insurance to cover 14-day refund obligations; model expected fraud-refund volume based on current transaction patterns
KYC upgrades: Implement full identity verification for all transactions, not just those exceeding federal thresholds
48-hour hold infrastructure: Build systems to identify first-time customers and delay crypto delivery for 48 hours while enabling cancellation
Fraud screening UX: Redesign kiosk interfaces to include mandatory warnings, screening questions, and transaction-blocking logic
Fee disclosure: Ensure on-screen and receipt disclosures show both fees and exchange rate markups in plain language
Cross-kiosk tracking: Implement systems to enforce the $2,000 daily cap across all of the operator's machines in the state, not just per kiosk

The cross-kiosk tracking requirement deserves special attention. The bill caps transactions at $2,000 per customer per day "across all its kiosks" — meaning an operator must link its machines in real time to prevent a customer from visiting multiple locations to circumvent the limit. Operators without centralized transaction monitoring will need to build or buy that capability. Smaller operators who lack the technical infrastructure or compliance budgets to meet these requirements may find it easier to exit the state than to comply — which could consolidate the New Hampshire market among larger, better-resourced companies like Bitcoin Depot and CoinFlip.

What This Means for New Hampshire Consumers

What Changes for Bitcoin ATM Users in New Hampshire:

If you're a first-time user: Your initial transaction will be held for 48 hours before processing — giving you time to reconsider or cancel for a full refund
Daily limits: You cannot transact more than $2,000 per day across all machines operated by the same company
If you've been scammed: Report it to the operator and law enforcement within 14 days of the transaction to receive a full refund including fees. Document everything — the transaction receipt, any communications with the scammer, and your police report
Fee transparency: You will see the exact fees and exchange-rate markup before completing any transaction, both on-screen and on your receipt
Fraud screening: Expect on-screen warnings and questions about whether someone is directing you to make the transaction
The law isn't in effect yet: SB 482-FN is awaiting the governor's signature. If signed, these protections take effect 180 days later — likely late October 2026

The 48-hour hold for first-time users is particularly significant. Many Bitcoin ATM scam victims are first-time users being coached through the process in real time by a scammer on the phone. A mandatory 48-hour delay breaks that dynamic — it gives the victim time to realize what happened, talk to a family member, or contact police before the crypto is irreversibly sent. The $2,000 daily cap also limits the damage a single scam can inflict in one session. Law enforcement in New Hampshire noted that some victims have lost tens of thousands of dollars in a single day through multiple transactions. Under SB 482-FN, a scammer can extract at most $2,000 per day from a single victim at one operator's machines. If you've already been a victim of a crypto ATM scam in New Hampshire, these protections do not apply retroactively. For existing victims, consumer protection resources and the New Hampshire Attorney General's consumer protection bureau remain the primary avenues for reporting and potential recovery.

The Real Test Ahead

SB 482-FN is on the governor's desk. Governor Kelly Ayotte has not publicly indicated whether she'll sign or veto the bill, but it passed with bipartisan support and backing from both the Attorney General's office and law enforcement. A veto would be surprising. If signed, the real story begins in October 2026 when the 180-day transition period expires. The bill's effectiveness depends entirely on whether the state has the resources and will to monitor compliance — and on whether operators actually implement these requirements rather than treating them as paper obligations. Twenty-four other states have enacted some form of crypto ATM regulation, but enforcement varies wildly. Watch for three things: whether any operators exit New Hampshire rather than comply, how the first refund disputes between operators and scam victims play out, and — most critically — whether the $22 million in annual fraud losses actually drops. If this framework produces measurable reductions in scam losses without killing the industry, it could become the template for the states that haven't acted yet. If operators game the refund process or scam losses continue unabated, it will be ammunition for the Tennessee approach: just ban the machines. New Hampshire has written an ambitious prescription. The question is whether the industry will take the medicine — or whether, like the scammers themselves, it will simply move to the next state without rules.

New Hampshire Passes Bitcoin ATM Bill: $2,000 Daily Caps, 14-Day Scam Refunds, and Mandatory Blockchain Screening