Sponsors: Casimiro, Donovan, Spears, Potter, Alzate, Shallcross Smith
Session: 2026
Amends: R.I. Gen. Laws § 19-14.3-1.1 (Chapter 19-14.3 / P.L. 2025, ch. 113)
Expands the definitions of virtual currency kiosk "operator" and "transaction" to capture app-to-counter and voucher-at-register business models that circumvent the Chapter 19-14.3 regulatory framework enacted last session (S 0016 Sub A / H 5121 Sub A). Targets entities that use digital applications to direct customers to pay in person through a clerk or intermediary rather than at a physical kiosk machine.
Why We Have Concerns
We support the goal of closing regulatory arbitrage — but the bill as drafted is dangerously overbroad. The phrase "facilitates or enables" could sweep in software developers, retail chains, payment processors, and non-custodial service providers who bear no resemblance to the bad actors this bill targets. Critical terms like "digital product or application," "clerk or other intermediary," and "facilitates or enables" are left undefined. Every newly captured entity inherits the full Chapter 19-14.3 compliance stack — six mandated compliance programs (§ 19-14.3-3.7), a full-time compliance officer and blockchain analytics (§ 19-14.3-3.11), extensive disclosures (§ 19-14.3-3.10), extended-hours live customer service (§ 19-14.3-3.13), and money-transmitter licensing (§ 19-14.3-3.9) — with zero implementation runway. The bill also collapses the custodial / non-custodial distinction, a departure from every major federal framework including the GENIUS Act.
Core Issue
Overbroad Language
"Facilitates or enables" sweeps too wide
Compliance Cost
Low–Mid Six Figures / yr
Full Chapter 19-14.3 stack inherited
Implementation
Zero Days
Effective upon passage — no transition
Our Primary Ask
Pass the Blockchain Study Commission (H.7956 / S.2198) before expanding the kiosk framework. Rhode Island is legislating before it has studied — the drafting problems in S.2648 are the predictable result. Convene industry, consumer advocates, law enforcement, and DBR to resolve the technical definitions this bill tries to answer in two paragraphs. Get the expert record built, then legislate from it.