Ohio Bitcoin ATM Regulations

Licensing Requirements

The Ohio Division of Financial Institutions issued Interpretive Guidance 2022-01 (June 2022) confirming that any person engaged in buying or selling cryptocurrency as a business qualifies as a money transmitter under the Ohio Money Transmitter Act (OMTA), codified in ORC Chapter 1315.

A company operating a Bitcoin ATM or crypto kiosk is considered a money transmitter unless it can conclusively verify in all instances that the individual conducting the transaction is the owner of the receiving wallet. In practice, most operators cannot meet this bar and must obtain a license.

License requirements include:

• Minimum net worth of $500,000 (audited financial statement required)
• Surety bond of $300,000 (up to $2 million based on volume)
• Application fee of $5,000 filed through NMLS
• Third-party security audit of all computer and information systems
• Background checks and fingerprinting for all control persons
• Capital plan demonstrating ability to maintain minimum net worth for 2 years

For licensing questions, contact the Division of Financial Institutions at (614) 728-2636 or DFI-Compliance@com.ohio.gov.

Transaction Limits

Ohio currently has no state-level daily transaction limits for Bitcoin ATMs. This is a significant gap compared to states that have enacted recent consumer protection legislation. Only federal reporting thresholds apply.

Fees & Disclosure

While no state fee cap exists, federal regulations require that fees be disclosed before a transaction is completed. The lack of a state-level cap means Ohio consumers may pay significantly more than customers in regulated states for the same service.

Operators are required under general consumer protection law to avoid deceptive practices. The Ohio Attorney General's Consumer Protection Section can investigate complaints about undisclosed or misleading fee structures.

KYC & Compliance

Ohio defers to federal Bank Secrecy Act (BSA) requirements for customer identification. All Bitcoin ATM operators registered as Money Services Businesses (MSBs) with FinCEN must comply with:

• Customer Identification Program (CIP) — operators must verify identity for transactions, with thresholds set by operator policy
• Currency Transaction Reports (CTRs) — mandatory filing for transactions exceeding $10,000 in a single day
• Suspicious Activity Reports (SARs) — required for transactions suspected to involve fraud, money laundering, or terrorist financing
• NMLS Registration — licensed operators must register with the Nationwide Multistate Licensing System
• Recordkeeping — duplicate BSA reports must be filed with the Ohio Attorney General per ORC §1315.54

Ohio does not define a "new customer" period or impose state-level KYC requirements beyond federal standards. This is one area the pending ELDER Act (HB 648) would change.

Pending: ELDER Act (HB 648)

The ELDER Act (Ending Losses and Deception in Electronic Resources), introduced by Representatives Matthew Kishman (R-Minerva) and Melanie Miller (R-Ashland), is the most significant pending Bitcoin ATM legislation in Ohio. It is currently before the House Financial Institutions Committee.

If enacted, HB 648 would introduce:

• Transaction limits — tiered daily caps for new and existing customers
• Mandatory money transmitter license — closing the wallet-ownership verification loophole
• Compliance officer requirement — each operator must appoint a designated compliance officer
• Phone verification for large transactions and for new customers over age 60
• Blockchain analysis — operators must screen transactions against risky wallet addresses
• Mandatory risk warnings — posted warnings about irreversibility and volatility of crypto
• Fee disclosures — transparent fee display before transaction completion
• Transaction receipts — detailed records for every transaction
• Fraud refund rights — new customers who report fraud promptly to law enforcement may be eligible for refunds

The bill has received support from AARP Ohio, reflecting the disproportionate impact of crypto ATM scams on older adults. Adults 60+ account for over 80% of reported Bitcoin ATM fraud losses nationally.

Consumer Protection Resources

Ohio Attorney General Dave Yost established the Electronic Fraud Investigations Unit within the Bureau of Criminal Investigation (BCI) specifically to combat cryptocurrency fraud. The unit has successfully recovered stolen funds, including $35,000+ for a Hamilton County victim in April 2025.

If you suspect a Bitcoin ATM scam or have been a victim:

• Contact local law enforcement immediately — time is critical for tracing crypto transactions
• BCI Hotline: 855-BCI-OHIO (855-224-6446)
• Email: Intel@OhioAttorneyGeneral.gov
• Ohio AG Consumer Protection: 800-282-0515
• FBI IC3: ic3.gov — file an internet crime complaint

The Ohio Narcotics Intelligence Center (ONIC) has published a cryptocurrency scam bulletin with red flags to watch for, including unsolicited calls directing victims to deposit cash at Bitcoin ATMs.

Legislative Reference

The regulatory framework governing Bitcoin ATM operations in Ohio spans existing law, administrative guidance, and pending legislation:

ORC Chapter 1315 — Ohio Money Transmitter Act

Interpretive Guidance 2022-01 — Licensing of Cryptocurrency Businesses (June 2022)

HB 648 — ELDER Act (Pending, 135th General Assembly)

HB 116 — Ohio Blockchain Basics Act (Passed House, 136th General Assembly)