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December opened with a price of $4,117 and continued to decrease until it reached the price of $3,225 in the middle of the month, which is the lowest price of Bitcoin in the entire 2018.  After, the price continued to rise and hit the highest mark in the past month at $4,179. December ended at $3,792 which is a 7,9% decrease in comparison to the beginning of the month.

Bitcoin Price December 2018, source: blockchain.info

Unlike the price downward trajectory, the number of new machines continues to grow at a slightly slower rate than in previous months.

Period Start: 4040, Period End: 4111
Opened: 173, Closed: 102, Net Growth: +71(1.8%)

Change by Manufacturers
Name Start End Diff
General Bytes 1208 1255 +47 (3.9%)
Genesis Coin 1280 1304 +24 (1.9%)
BitAccess 216 237 +21 (9.7%)
Orderbob ATM 88 101 +13 (14.8%)
BBFPro 14 19 +5 (35.7%)
Shitcoins Club 26 29 +3 (11.5%)
Bitnovo 8 10 +2 (25%)
Robocoin Kiosk 2 4 +2 (100%)
Lamassu 440 441 +1 (0.2%)
Cryptomat 0 1 +1
Coinsource 193 192 -1 (-0.5%)
BTC facil 26 25 -1 (-3.8%)
Trovemat 13 12 -1 (-7.7%)
BitTeller 18 15 -3 (-16.7%)
Covault 114 110 -4 (-3.5%)
BitXatm 70 65 -5 (-7.1%)
RusBit 49 16 -33 (-67.3%)

General Bytes continues to top the manufacturers list in this month with 47 new machines (3.9% increase) followed by Genesis Coin with 24 installations (1.9% increase). The change came in the third place where BitAccess took the place with 21 new machines (9.7% increase).

Another manufacturer installed its first ATM this month. Cryptomat, the Ukranian based company, installed a buy only machine in Lviv.

We also have to notice that Russian manufacturer RusBit had a significant decrease with 33 machines removed (67.3% decrease).

Change by Operators

Operators who increased the number of machines by 4 or more over the past month:

Name Start End Diff
CoinCloud 191 204 +13 (6.8%)
BTC Management Gmbh 78 91 +13 (16.7%)
Localcoin 135 145 +10 (7.4%)
Athena Bitcoin 77 84 +7 (9.1%)
RockItCoin 139 145 +6 (4.3%)
National Bitcoin ATM 24 30 +6 (25%)
CoinFlip Bitcoin ATMs 115 120 +5 (4.3%)
SP Bedarev A.A. 14 19 +5 (35.7%)
Kurant 42 46 +4 (9.5%)
Bitcoin Romania 11 15 +4 (36.4%)

In December, CoinCloud (6.8% increase) and BTC Management Gmbh (16.7% increase) shared the first place with 13 new installations. Localcoin followed by with 10 new machines (7.4% increase). These were the only 3 operators that increased their numbers by more than 10 in the past month.

Change by Countries
Name Start End Diff
United States 2239 2288 +49 (2.2%)
Canada 608 623 +15 (2.5%)
Spain 57 66 +9 (15.8%)
Austria 257 265 +8 (3.1%)
Romania 24 28 +4 (16.7%)
Argentina 4 8 +4 (100%)
United Kingdom 199 201 +2 (1%)
Switzerland 42 44 +2 (4.8%)
Vietnam 4 6 +2 (50%)
Australia 50 51 +1 (2%)
Italy 31 32 +1 (3.2%)
Poland 27 28 +1 (3.7%)
Colombia 25 26 +1 (4%)
Greece 19 20 +1 (5.3%)
Slovenia 11 12 +1 (9.1%)
Georgia 10 11 +1 (10%)
Ukraine 8 9 +1 (12.5%)
Dominican Republic 7 8 +1 (14.3%)
Malaysia 7 8 +1 (14.3%)
Bahamas 0 1 +1
Turkey 0 1 +1

In the countries list in December, the top remains unchanged where the United States dominate 49 new installations (2.2% increase). Canada took the second place with 15 new machines (2.5% increase), followed by Spain with 9 new machines (15.8% increase).

In the past month there were two Countries that had their first ATM installed:

  • The Bahamas – Buy only machine manufactured by General Bytes located in Nassau;
  • Turkey – Buy and Sell machine manufactured by General Bytes located in Istanbul.
Other Cryptocurrencies Support

Find latest stats of other cryptocurrency machines here.

Cryptocurrencies support saw the following increases over the past month:

Name Start End Diff
Ether 1882 2011 129 (6.85%)
Altcoins 2519 2644 125 (4.96%)
Bitcoin 4042 4106 64 (1.58%)
Monero 86 124 38 (44.19%)
Litecoin 2403 2433 30 (1.25%)
Bitcoin Cash 1338 1365 27 (2.02%)
Dash 722 738 16 (2.22%)
Zcash 60 69 9 (15.00%)
Dogecoin 77 79 2 (2.60%)

The number of other currencies accepted in Bitcoin ATM’s got to 64% this month. Ether was again the coin that was added at the most machines in December with 129 (6.85% increase). Like in November Bitcoin followed by with 64 (1.58% increase). Monero came in the third place with 38 (44.19% increase).


In December prices fluctuated and experienced a decrease at the end of the month. Manufacturers General Bytes and Genesis Coin installed the most machines. The Bahamas and Turkey installed their first machines. Ether was the most added coin.

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In this interview streamed live on 16 October 2018, we have a chance to hear Martijn Wismeijer from General Bytes answering questions about Bitcoin ATMs.

Deciphered # 10 - Interview with Martijn Wismeijer from General Bytes - YouTube

Martijn states that he got into crypto somewhere in 2010, while he was designing home banking systems. When he discovered Bitcoin, he thought it was like Napster for cash and, as he says, he was hooked from day one. Eventually, he started operating Bitcoin ATMs. Before he joined General Bytes, he did the marketing for them, but as he says, that was easy since you have a great product to sell. He also points that, although he considers himself as a Bitcoin maximalist, their ATMs embrace all crypto, and it would be bad if they were to decide for their customers on what crypto to use. The company grew over 5 years and now they are 29 people working for General Bytes.

Q&A Session
  • In your opinion, what is the state of Bitcoin ATMs across the globe, where do you see the most uptake?

We see the professionalization of the market. In the past, there were just mom and pop companies, but now those early operators are expanding way beyond just a few locations. We see some operators actually have over 100 or 200 locations because it is easy to scale. Basically, you just need to run one server and connect all your ATMs there, so now we see fewer single machine operators and more larger networks.

  • How are you guys coping in the bear market? Do you get more customers or fewer customers? Are the sales going down or are they increasing?

The price is not really an issue for operators since they run a cash-based business. They make money on percentage, so if Bitcoin price is high or low it doesn’t really matter to them.

Many operators are buying machines in the dip, and they keep increasing the numbers so the orders did not slow down. I think that in general business is still very good,  we are not seeing a real slow down because of the dip, and the bear market, so that tells me that Bitcoin and cryptocurrencies, in general, will keep going strong.

  • From what I’ve seen here you guys have the cheapest Bitcoin ATMs on the market for the amount of features you offer. On your machines, you have bright orange colors with a Bitcoin logo, and on your newer ATMs, you guys have this neon outer border. Maybe you can give us some of your thoughts around that design?

Actually, the first ATM was designed to be compact and easy to ship, and we didn’t give it that much thought, it was in Bitcoin yellow because we wanted it to be bright and very visible and it needed to fit all the components.

General Bytes BATM3 and BATM2 models

But when we designed the BATMThree, a 2-way model, it had to be larger and we added the neon vessel so that our operators can customize it to the color of the design of their location, and attract the attention of the customers. we didn’t want to make it look like an ATM because quite frankly ATMs look boring and we wanted to stand out.

  • Could you maybe go ahead and tell us a little bit of the description
    behind the software? For example what kind of software stack are you guys running? I want to hear the backend tech but then I also want to hear what you guys have in store for the front-end?

The thing is that any project you create that has a touchscreen, usually needs a keyboard and they are a bit fiddly to program. So, we selected the Android OS and basically stripped it from everything except the TCP stack and the keyboards. The rest we totally redesigned as an ATM. There is no Play Store or anything, just hardware, keyboards, and TCP stack.

Since Android is primarily based on Java, we use Java technologies for the back end and also on server and terminals. This makes it easier to develop, and find programmers that will be able to manage the entire process instead of mixing and matching different technologies. We are now able to develop new features a lot faster. Every few weeks we bring out a new software version.

For us, it is really important that we are working on decentralized technologies. If we want cryptocurrencies to succeed, we also need to make sure that the network architecture behind ATMs is also decentralized. Some manufacturers like to centralize it because they keep their fingers in the wallets of the clients, however, we do not do so. We recommend to our clients to install their own ATM software, so even if we wouldn’t exist anymore, it would be business as usual for them, and it is important. We always say decentralize everything, it is our mantra. There are some centralized features in the software like reporting the rates displayed on the screen but it switches off by default, otherwise, we would break our “decentralize everything” promise.

The software itself contains no wallets, no exchange software or anything. It’s the ATM server that will communicate to the client and their wallets. So, if you run your version of BItcoin or Ethereum wallet the software will be able to connect to it. It is the same thing with exchanges, most exchanges are supported. We do not dictate our clients on what wallet or exchange to use.

Everybody who runs their own exchange, or creates a cryptocurrency, they can just add it to our Github, the link is in the footer of the General Bytes website, and make a request. Once done, if they have any questions, they can use Github to directly contact our developers. I think this is one of the reasons we’ve been able to add so many different cryptocurrencies, exchanges, and wallets.

There’s also an option to create plugins. So, for example, if you have a connection to your bookkeeping software, you can make it automatically trigger an entry every time a transaction is posted online in your ATM, so your bookkeeper will always be in the loop. Those little things are what makes us one of the fastest-growing networks at this moment.

  • You guys say that you’ve sold over 2000 machines in 54 countries, and support over 123 fiat currencies, and of course you have a support of multiple cryptocurrencies, but let’s talk a little bit about the ROI, maybe you can go and describe some of the ROI that you guys have seen now?
Since our network is decentralized, we can’t have a clear picture of our clients revenue. It is bad for marketing, but in the end, it is not our transaction to look at.
What we can see from the hard data is that after about six to ten months on average, we see second orders from new clients. That means that by that time they, either made enough money to purchase another machine or they can justify the purchase and grow their network.
Some of our clients are purchasing 20 or more machines and that tells me that they do make a nice revenue. As I said, I don’t know the revenue myself since the log files with transactions are on their server.
We also run a few machines in Prague, on the subways and other locations, and if I extrapolate the data on to all the machines of our clients we get that all of them put together make between forty and sixty million dollars in revenue every month.
  • Let’s talk a bit more about the KYC and about some of that stuff that you support.

From the very first day, we started creating those ATMs, we built in KYC AML features. Primarily because, even though cryptocurrencies are not regulated, cash money is regulated everywhere, so there are always limits and identity checks. So, gradually you need to expand those features based on requirements of governments.

It’s the operator’s responsibility to check local laws and regulations. For example, there might be a limit on the number of anonymous cash transactions, or there might be requirements for registration. So, it’s up to the operator to check the AML or to check the identity cards. The cameras on the ATM can do a scan of the identity card and once they pass the identity check the machine gets unlocked for them. It can also be unlocked for the entire network, so if the operator has a hundred machines people only have to pass this AML KYC procedure once.

Many operators have enabled some sort of KYC AML. In most cases, it is just OTP or one-time pin sent to a phone number. In other countries, it’s required that you do an identity check before allowing anyone to use the ATM. I think it’s unfortunate, and we want some financial freedom, and I think we are over-regulated, but if we wouldn’t comply with those AML KYC regulations or requirements around the world we will be shut down and there will be no Bitcoin ATMs at all.

  • I’d like you to go ahead and go into a description of the point-of-sale, and how you decided to put that in your ATM services?
I think it was in late 2014 when I got these cheap implants at the time, and my colleague said:
“Martin wouldn’t it be cool if you could use your crypto chip implant and just load up some cash in your hands at one of our ATMs, or just swipe your hands past the ATM and get some cash?” So I thought that was an amazing idea.
The only problem is nobody had a chip back then. So, we came up with an idea to have a card dispenser in BATMThree so it will dispense wallet cards.
You can stock it with standard NXP NTEG 213  cards which is the cheaper one or you can use the 216. These cards are already available worldwide since they have been used in hospitality industry as door cards for more than a decade. They are cheap and they can be printed with a sponsor name on it.
More details on NFC card in this video:
  • Will you be doing Lightning support any time soon?
Absolutely, we’ll be adding a Lightning, SegWit, and Bech32, but it requires extensive testing. Should there be an error it would cause major financial loss to our operators. So yes, it is in the pipeline, I don’t know exactly when but I expect it to be out soon. It will just be an update, like any other update, and the ATM operators will be able to deploy it with one click, and even machines sold in 2013 will be compatible with everything.
  • I believe that you guys have this product called the Bitcoin ATM sign, so maybe you can go a bit into the history?

So, it is basically a voice-operated neon sign in a shape of Bitcoin logo. It is just really cool additional bonus for businesses and for the point-of-sale, but since it is hand blown glass, we do not produce them ourselves. We order them and sell them to our clients because many clients say they want to get some attention for their location.

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The price of Bitcoin was fairly stable this October. The month started with a price of $6,591. The lowest value was on the 10th where it was at $6,249. October ended with a Bitcoin price at $6,310 which is a 5,1% decrease when we compare it to the price from the beginning of the month.

Bitcoin Price October 2018, source: blockchain.info

Unlike the price fluctuating trajectory, the number of new machines continues to grow at an approximately same rate as in September.

Period Start: 3781, Period End: 3931
Opened: 206, Closed: 56, Net Growth: +150(3.9%)

Change by Manufacturers
Name Start End Diff
General Bytes 1091 1153 +62 (5.7%)
Genesis Coin 1241 1273 +32 (2.6%)
Orderbob ATM 66 84 +18 (27.3%)
Lamassu 423 433 +10 (2.4%)
LightningXchange 20 30 +10 (50%)
BitAccess 208 216 +8 (3.8%)
RusBit 47 51 +4 (8.5%)
wBTCb 31 33 +2 (6.5%)
Shitcoins Club 22 24 +2 (9.1%)
Criptec 3 5 +2 (66.7%)
BitTeller 19 20 +1 (5.3%)
Bcash Greece Inc 12 13 +1 (8.3%)
Trovemat 11 12 +1 (9.1%)
zzBit 9 10 +1 (11.1%)
BBFPro 6 7 +1 (16.7%)
Coinsource 197 192 -5 (-2.5%)

As in September, General Bytes takes the first place with 62 new machines (5.7% increase), followed by Genesis Coin with 32 new machines (2.6% increase). Also, Orderbob ATM remained third with 18 new installations (27.3% increase). LightningXchange is back on the list this October and takes the fifth place with 10 installations (50% increase).

Also, Coinsource experienced a 2.5% decrease by removing 5 machines.

Change by Operators

Operators who increased the number of machines by 4 or more over the past month:

Name Start End Diff
BTC Management Gmbh 58 74 +16 (27.6%)
Bitcoin of America 54 68 +14 (25.9%)
Digital Mint 63 74 +11 (17.5%)
Crypto Dispensers Bitcoin ATMs 10 20 +10 (100%)
RockItCoin 126 133 +7 (5.6%)
Kurant 33 39 +6 (18.2%)
iQCashNow 84 89 +5 (6%)
Hodl Digital Services 14 19 +5 (35.7%)
Shomul Bitcoin ATM 10 15 +5 (50%)
CoinFlip Bitcoin ATMs 100 104 +4 (4%)
Athena Bitcoin 66 70 +4 (6.1%)
RusBit 47 51 +4 (8.5%)
Unbank.world 2 6 +4 (200%)

Again, BTC Management Gmbh remains the first on the Operators list with 16 new installations (27.6% increase). Following by is Bitcoin of America with 14 new machines (25.9% increase). Only other Operators that increased their numbers by more than 10 machines were Digital Mint with 11 new machines (17.5% increase), and Crypto Dispensers Bitcoin ATMs who doubled their numbers with 10 installations (100% increase).

Change by Countries
Name Start End Diff
United States 2117 2183 +66 (3.1%)
Austria 215 243 +28 (13%)
Canada 592 599 +7 (1.2%)
Russian Federation 64 70 +6 (9.4%)
Czech Republic 61 66 +5 (8.2%)
Switzerland 36 41 +5 (13.9%)
United Kingdom 196 200 +4 (2%)
Hong Kong 25 29 +4 (16%)
Romania 15 19 +4 (26.7%)
Colombia 19 22 +3 (15.8%)
Spain 55 57 +2 (3.6%)
Slovakia 33 35 +2 (6.1%)
Netherlands 23 25 +2 (8.7%)
Greece 15 17 +2 (13.3%)
Argentina 1 3 +2 (200%)
Australia 50 51 +1 (2%)
Croatia 5 6 +1 (20%)
Malaysia 5 6 +1 (20%)
Belgium 4 5 +1 (25%)
South Africa 4 5 +1 (25%)
Liechtenstein 3 4 +1 (33.3%)
Costa Rica 2 3 +1 (50%)
Estonia 1 2 +1 (100%)
Germany 0 1 +1

As always, United States were the Country with the most installations this month with 66 (3.1% increase). As in September Austria is in second place with 28 new machines (13% increase), and Canada stays right after with 7 new installations (1.2% increase).

We are glad to say that Germany got again bitcoin ATM. It is a buy and sell, Bitcoin only machine installed by Orderbob, and it is located in Munich. All previous installations in Germany ended with removal of ATM due to legal requirements applied by BaFin. However, this time situation might change as on 25th September 2018 Superior Court of Justice in Berlin issued a verdict that Bitcoin is not financial instrument, which is against to position BaFin took in the past.

Other Cryptocurrencies Support

Find latest stats of other cryptocurrency machines here.

Cryptocurrencies support saw the following increases over the past month:

Name Start End Diff
Ether 1435 1743 308 (21.46%)
Litecoin 2102 2298 196 (9.32%)
Altcoins 2217 2406 189 (8.53%)
Bitcoin Cash 1105 1270 165 (14.93%)
Bitcoin 3796 3927 131 (3.45%)
Dash 648 674 26 (4.01%)
Dogecoin 50 63 13 (26.00%)
Monero 71 73 2 (2.82%)
Zcash 48 49 1 (2.08%)

This month the number of Altcoins accepted at Bitcoin ATM’s remained at 58%. Ether was the coin that was accepted the most with 308 additions (21.46% increase). Litecoin followed by with 196 additions (9.32% increase), while Bitcoin Cash ended up on the third place with 165 additions (14.93% increase). Bitcoin remained the only other coin that was added in more than 100 ATM’s with 131 additions (3.45% increase).


In October the prices were fairly stable and ended with a slight decrease.  Manufacturers General Bytes and Genesis Coin installed the most machines. The average Operators machine increase was between 5 and 6 per day. Germany installed new ATM, which might be a start for larger number of machines in the country with high demand. Ether was the most added coin.

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Coin ATM Radar Blog by Bitcoin Atm Statistics - 5M ago

In the first half of July the price of bitcoin maintained a steady flow, keeping the value between $6,250 – $6,750. While in the other half of the month, the price started to grow. The month ended with a price tag of $7,917 which is an 24% increase in comparison to $6,375 at the beginning of the month.

Bitcoin Price July 2018, source: blockchain.info

Accompanying the upward price trajectory was the growth in the number of new machines, but the growth is significantly slower than in previous months.

Period Start: 3415, Period End: 3470
Opened: 187, Closed: 132, Net Growth: +55 (+1.6%)

The end of period of quick growing prices also result in some slow down on bitcoin ATM market. We steadily have several second-hand bitcoin ATMs for sale, which was empty section during several months of high prices. Also as manufacturers deliver machines to operators with delay of several months (usually about 3 months) approximately middle of spring was the time when machines ordered on the peak of hype were delivered, since then the installations speed reduced.

Change by Manufacturers
Name Start End Diff
Lamassu 378 403 +25 (6.6%)
Genesis Coin 1158 1182 +24 (2.1%)
RusBit 36 43 +7 (19.4%)
LightningXchange 11 17 +6 (54.5%)
wBTCb 24 29 +5 (20.8%)
Coinme 65 67 +2 (3.1%)
BBFPro 17 19 +2 (11.8%)
Bitcoin D.A.V.E. 7 9 +2 (28.6%)
Bcash Greece Inc 5 7 +2 (40%)
Trovemat 3 5 +2 (66.7%)
Covault 118 119 +1 (0.8%)
BitXatm 72 73 +1 (1.4%)
BTC facil 23 24 +1 (4.3%)
Shitcoins Club 17 18 +1 (5.9%)
CoinOutlet 13 14 +1 (7.7%)
Skyhook 8 9 +1 (12.5%)
zzBit 8 9 +1 (12.5%)
CryptoATM 1 2 +1 (100%)
BitTeller 19 18 -1 (-5.3%)
BitAccess 209 207 -2 (-1%)
Orderbob ATM 47 45 -2 (-4.3%)
General Bytes 949 925 -24 (-2.5%)

This month there was a change at the top of the list. Lamassu had 25 new installations (6.6% increase), just behind was Genesis Coin with 24 new machines (2.1% increase), while RusBit stayed on the third spot with 7 new machines (19.4% increase).

General Bytes, an operator that was constantly in the top of the list, had a net decrease of  24 machines (2.5% decrease) this July. This is mainly due to closure and remove of all ATMs that were previously run by Cointed (they had roughly 70 machines under management). Without this event General Bytes would have been growing by +45 machines and being at the top of the list. Other manufacturers that reduced the number of machines are: BitTeller with 1 (-5.3% decrease), BitAccess with 2 (-1% decrease) and Orderbob ATM with 2 (-4.3% decrease).

Change by Operators

Operators who increased the number of machines by 4 or more over the past month:

Name Start End Diff
Instacoin 88 95 +7 (8%)
RusBit 36 43 +7 (19.4%)
RockItCoin 107 112 +5 (4.7%)
CoinFlip Bitcoin ATMs 76 81 +5 (6.6%)
Digital Mint 59 64 +5 (8.5%)
BITMAT 44 49 +5 (11.4%)
WBTCB 24 29 +5 (20.8%)
Bitcoin Depot 144 148 +4 (2.8%)
SatoshiPoint 25 29 +4 (16%)
Pelicoin LLC 12 16 +4 (33.3%)
AlphaVend 10 14 +4 (40%)
BITCOINMAT.sk 6 10 +4 (66.7%)
Bitiago 6 10 +4 (66.7%)

At the top of the Operators list there is a completely different situation than last month. Instacoin sits at the top with 7 new installations (8% increase), while RusBit remained on second place with the same number of new machines 7 (19.4% increase). On the third place there is RockItCoin that had 5 new installations (4.7% increase). Basically, in July all operators from the list made a similar increase varying from 3 to 7 new machines.

Change by Countries
Name Start End Diff
United States 1982 2005 +23 (1.2%)
Canada 513 532 +19 (3.7%)
Russian Federation 56 68 +12 (21.4%)
United Kingdom 158 169 +11 (7%)
Colombia 10 17 +7 (70%)
Czech Republic 52 58 +6 (11.5%)
Slovakia 26 32 +6 (23.1%)
Switzerland 25 29 +4 (16%)
Hong Kong 18 21 +3 (16.7%)
Georgia 3 6 +3 (100%)
Malaysia 1 4 +3 (300%)
Australia 48 50 +2 (4.2%)
Poland 20 22 +2 (10%)
Greece 7 9 +2 (28.6%)
Netherlands 22 23 +1 (4.5%)
Slovenia 10 11 +1 (10%)
Singapore 9 10 +1 (11.1%)
Taiwan 7 8 +1 (14.3%)
Ukraine 4 5 +1 (25%)
Portugal 2 3 +1 (50%)
Liechtenstein 1 2 +1 (100%)
Ireland 1 2 +1 (100%)
Armenia 0 1 +1

As usual, United States with 23 (1.2% increase) and Canada with 19 new machines (3.7% increase) are the two countries that have greatest increase in new installations from month to month. Following them are European countries Russian Federation with 12 new machines (21.4% increase) and United Kingdom with 11 new installations (7% increase). A new country on the list this year is Colombia, there were 7 new machines (70% increase) installed in this country in July.

We are happy to announce that Armenia installed their first machine this month. It is a buy only General Bytes ATM operated by CoinBox located in capital city Yerevan.

Other Cryptocurrencies Support

Find latest stats of other cryptocurrency machines here.

Cryptocurrencies support saw the following increases over the past month:

Name Start End Diff
Bitcoin Cash 612 722 110 (17.97%)
Dash 329 427 98 (29.79%)
Altcoins 1759 1836 77 (4.38%)
Bitcoin 3396 3467 71 (2.09%)
Litecoin 1661 1730 69 (4.15%)
Ether 1070 1120 50 (4.67%)
Monero 59 68 9 (15.25%)
Dogecoin 38 44 6 (15.79%)
Zcash 50 50 0

This July, the percentage of cryptocurrencies other than Bitcoin that are accepted in ATMs increased to 53%. Bitcoin Cash was the most added coin in July by being accepted in 110 new machines (17.97% increase). Dash made it to the second spot. This coin was accepted in 98 ATMs which is a 29.79% increase. And the last month’s top spot Bitcoin rolled back to third place in July. It was added at 71 ATMs (2.09% increase) compared to previous month figures.


This July Bitcoin prices experienced an increase in accordance with the overall fluctuation. Manufacturers Lamassu and Genesis Coin added the most installations. The average Operators machine increase was around 5 in this month.  Armenia installed its first ATM. Bitcoin Cash was the most added cryptocurrency to ATMs in July.

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Article is provided by Jennifer L. Moffitt, a privately practicing attorney. Contacts can be found at the end of the post.

In the United States, virtual currency, such as Bitcoin and other similar coins, and virtual currency exchanges have been subject to federal regulations, with taxation and financial crimes the most prominent regulatory issues.[1]  However, it is at the state level that regulation of virtual currency has been most contradictory.  The U.S. states have mixed responses to the emergence of cryptocurrency.  Some of the states have ignored cryptocurrency by not implementing or amending any laws that address virtual currency.  However, other states have taken action with some states somewhat hostile towards virtual currency while other states are more welcoming.  In a number of states, the response towards cryptocurrency is currently ambiguous with no actual position taken.  This discussion will attempt to categorize regulations by restrictions placed on virtual currency and identify states by category of regulation.  In addition, the implications and effects of widely divergent state level legislation and regulations will be examined.

State Level Cryptocurrency Regulatory Tools

There are several regulatory tools used by states to regulate and control virtual currency.  These include money transmission laws, licensing requirements and regulatory guidance.  A brief summary of these tools is provided below.

Money Transmission Laws

Forty-nine of the fifty American states enact their own version of a Money Transmitters Act.  A money transmitter is a business entity that provides money transfer services or payment instruments, such as Western Union.[2]  The original purpose of state level money transmissions laws was to prevent money laundering and other illegal acts.  However, several states have used money transmissions laws to regulate the exchange of virtual currency.  In these situations, transactions which are defined as an exchange of virtual currency for fiat money or other virtual currencies, rather than for goods and services, are considered to fall under the definition of money transmission and thus are subject to that state’s money transmission law.  If Bitcoin transactions, for example, fall under the state law, then the transmitter must fulfill certain criteria such as applications, fees, and a security that is often a surety bond.  A transmitter would find that it would take time and money to comply, thus discouraging smaller such businesses from operating in the state.

Several states have enacted slightly different variations of this tactic.  New Mexico has interpreted its 2016 legislation to require a money transmitters license with bonding for virtual currency activity.  Washington state also specifically includes virtual currency in the definition of money transmission, thus requiring bonding and other compliance measures.  In these and other states with similar laws, virtual currency is specifically treated as money and regulated through fairly stringent money transmission legislation.

Other, more virtual currency friendly states, have passed legislation so that the state money transmission law doesn’t apply to virtual currency.  The state of Montana currently is one of the most friendly states because it does not have a money transmission law so virtual currency in general is not subject to any restrictions imposed by money transmission regulations.  New Hampshire enacted legislation in 2017 that specifically protected virtual currency businesses from being registered as money transmitters.  Wyoming very recently enacted 2018 legislation that exempts virtual currency like Bitcoin from money transmission laws and regulation within the state. Wyoming also enacted in 2018 other legislation favorable to blockchain and virtual currency including legislation exempting virtual currency from state property tax.[3]


In addition to money transmission laws, the states have the option to enact separate laws that require virtual currency purveyors to license in the state.  Connecticut, for example, has enacted 2017 legislation forbidding third parties to sell virtual currency or store virtual currency for others without a license.  Connecticut also decreed that virtual currency licensees must pay a surety bond, determined by the state banking commissioner on a situational basis.  The commissioner calculates the amount of the bond based on the expected amount of profit.

Georgia took a similar stance as Connecticut by restricting the transmission of virtual currency within the state without a license.  In addition, Georgia permitted its Department of Banking and Finance to authorize future rules and regulations involving the transmission of virtual currency.

New York has followed the licensing model rather than modifying existing money transmission legislation.  New York, like Connecticut and Georgia, requires licensing for virtual currency through its BitLicense, created by the New York State Department of Financial Services. The requirements to obtain such a license are stringent.  New York also requires virtual currency businesses to post a surety bond whose amount was decided on a case by case basis.  A bill introduced in the New York State Senate would create a legislative alternative to such regulatory licensing.

Regulatory Guidance

States can choose to issue regulatory guidance through state agencies such as banking authorities on the treatment of cryptocurrency.  Regulatory guidance does not have the same strength as regulations based on enacted laws, but they are often easier to enact than legislation. Hawaii, for example, does not currently officially recognize virtual currency as monetary transfers through legislation, but the state has required licensing of certain types of virtual currency businesses, including the requirement that fiat currency reserves must be held in addition to virtual currency.  Current bills pending in the 2018 Hawaii legislature may clarify the state’s position on virtual currency as money transmission if enacted.[4]  Kansas has a money transmission law, but the office of the state Bank Commissioner issued a memorandum to the effect that a money transmitter’s license is not necessary for the sale of virtual currency as it is not money.  Texas does not consider most cryptocurrency transactions money transmission unless a third party is involved.  Tennessee guidance is similar to that of Texas.

State Level Virtual Currency Regulatory Rankings

The rapidly changing state regulatory environment with respect to virtual currency, coupled with a lack of uniformity among the states with respect to regulations and guidance, makes it difficult to fit state actions into distinct categories.  However, based on current information from enacted legislation and state regulatory guidance, both formal and informal, all fifty states have been analyzed and where possible have been divided into separate categories based on their friendliness towards virtual currency.  Category One is the most welcoming towards virtual currency while Category Four has explicitly included virtual currency in legislation regulating money transmission.  Most states cannot be currently classified under such a scale due to ambiguities in current state regulations. The table below summarizes the state rankings.

Categories of State Virtual Currency Regulations*
Category 1 Category 2 Category 3 Category 4
Legislatively Exempt Favorable Guidance Restrictive Guidance Regulated Through Regulations
New Hampshire Illinois Idaho Alabama
Montana Kansas Hawaii** Connecticut
Wyoming Massachusetts New Mexico Georgia
Tennessee New York North Carolina
Texas Vermont

*As of date of publication

**Proposed legislation may change categorization

Category One States

Category One states are those that have created laws with the effect that virtual currency is excluded from money transmission statutes.  The state of New Hampshire has amended its money transmitter statute to specifically exclude “persons who engage in the business of selling or issuing payment instruments or stored value solely in the form of convertible virtual currency or receive convertible virtual currency for transactions to another location” from the state’s money transmission regulation.

Wyoming is also a Category One state because of five bills enacted in March 2018 legislation.  As a result, there is now an exemption for virtual currency used within the state from Wyoming money transmission laws and regulation and virtual currency is now exempt from property taxation.  Also, blockchain tokens or “utility tokens,” which are tokens that can be traded for goods and services, are specifically exempted from securities and money transmitters laws.  Other legislation allows corporate records to be maintained in blockchain.[5]

Montana might also fall under Category One, even though it did not amend its money transmitter statute to exclude cryptocurrency, for the simple fact that Montana is now the only state in the Union that does not have a money transmission law.  Therefore, there is no possibility of including cryptocurrency in money transmission regulations in Montana at the current time.

Category Two States

Category Two states are still relatively friendly towards virtual currency, but are a step-down from Category One.  Category Two states have not enacted laws stating that money transmission does not apply to virtual currency, but rather various state agencies have issued rulings or regulations to the same effect.  The regulations should be followed just like laws, but a regulation is weaker than a law.  Illinois is a Category Two state because its Department of Financial and Professional Regulation issued guidance to the effect that virtual currency does not fall under the definition of money and thus does not fall under the money transmission law as well.[6]  Other Category Two states with specific guidance include: Kansas, Tennessee, and Texas.  Massachusetts has issued guidance that Bitcoin ATMs are not financial institutions nor do they fall under rules governing foreign currency. However, even within these states, there is still variation.  Kansas has stated that cryptocurrency cannot be used for campaign contributions in either state or local elections.  Massachusetts has urged citizens to avoid Bitcoin and seeks aggressive policing for ICOs.

Category Three States

Category Three states take a large step away from a Category Two State by being distinctly less friendly to virtual currency.  These states have developed regulations and guidance that state that Bitcoin and other virtual currencies are money and fall under the state’s money transmission legislation or licensing requirements.  For example, Idaho’s Department of Finance issued a statement that a customer that exchanges a third party’s virtual currency is subjected to the Idaho Money Transmitters Act.[7]  Other states that currently conclude that virtual currency should fall under money transmission regulations include Hawaii and New Mexico.  New York state through its BitLicense would also fall into this category.

Category Four States

Category Four states have implemented laws that explicitly state that virtual currencies fall under the guidance of money transmission legislation.  Alabama recently amended its Monetary Transmission Act to define “monetary value” as “[a] medium of exchange, including virtual or fiat currencies, whether or not redeemable in money.” As a result, virtual currency is subject to the Act and must obtain a license from the state.  Other states that have amended their monetary transmission legislation or enacted separate licensing laws to specifically regulate virtual currency include Connecticut, Georgia, North Carolina, and Washington.  Vermont has also amended its money transmission law to make virtual currency a permissible investment, a potentially friendly development.

Other States

The majority of U.S. states do not fall in the above categories.  This includes states that issue no guidance and do not currently regulate such as California and Colorado.  It also includes states that issue informal guidance when contacted and decide on a case by case basis whether state regulations and money transmission regulations apply.  For example, a state such as South Dakota, may state that cryptocurrency is money, but ask to see a business plan for a final decision.  Even states with virtual currency legislation may provide for exemptions from the law either within the law or on a case by case basis.  Other states may have enacted legislation related to virtual currency, such as anti money laundering statutes, or taxation issues, or in the case of California, raffle ticket restrictions, but do not yet weigh in on money transmission requirements. State regulatory bodies may have issued consumer warnings on virtual currency but no specific guidelines as to money transmission. Finally, some states have enacted favorable blockchain legislation, such as Nevada or Delaware, but have not directly addressed virtual currency money transmission.


In conclusion, given the widely divergent state positions on virtual currency, economic theory suggests that over time businesses involving cryptocurrency will move away from the heavily regulated states to more welcoming and friendly ones.  It will be interesting to monitor trends over time to see if this is true. However, cryptocurrency legislation and regulations in the states are constantly evolving so firm conclusions about the status of a particular state are difficult.  Wyoming, for example, was until very recently not a welcoming virtual currency state. Given the ambiguity and contradictions in the state regulations, there could be a movement to see virtual currency laws standardized for all fifty states.  A draft of a uniform regulation of virtual currency businesses act has been developed, but only time will tell if standardization is in the future for state level virtual currency laws.[8]  In the meantime, cryptocurrency businesses will need to closely monitor developments at the state level to ensure compliance.

Jennifer L. Moffitt (jennifermoffittlaw.com) is a privately practicing attorney located in Cheyenne, Wyoming specializing in regulation and compliance with respect to virtual currency.  She can be contacted at jennifer@jennifermoffittlaw.com. She has a Bachelor’s Degree in Economics from the University of California, Berkeley, a Master in International Studies from the University of Otago in New Zealand, and a J. D. from the University of San Diego. She is licensed in Colorado, Montana, and Wyoming.

This report should not be construed as legal advice for a specific situation or circumstance. The contents are intended for general information and educational purposes only, and should not be relied on as if it were advice about a particular fact situation.

[1] Although the terms digital currency, cryptocurrency and virtual currency are often used interchangeably, the term “virtual currency” is increasingly used in legislation and legal language.  The term is usually defined as a digital representation of value that is neither issued by a central bank or legal authority nor pegged to a fiat currency, but can be used as a means of legal payment and transferred, stored, and traded electronically.  This paper will use the term virtual currency or cryptocurrency.

[2] Wilson, Wistar, “A Call to Clarify the Regulatory Scope of Money Transmitter Laws,” The Regulatory Review, https://www.theregreview.org/2013/06/19/a-call-to-clarify-the-regulatory-scope-of-money-transmitter-laws/.

[3] Wilmoth, Josiah, “Wyoming House Unanimously Passes Bill Exempting Utility Tokens from Securities Laws,” CCN, https://www.ccn.com/wyoming-house-unanimously-passes-bill-exempting-utility-tokens-securities-laws/.

[4]Testimony on Hawaii House Bill No. 2257, Relating to Virtual Currency, January 31, 2018, https://www.capitol.hawaii.gov/Session2018/Testimony/HB2257_TESTIMONY_IAC_01-31-18_.PDF

[5] Schmidt, Gustav L., “Wyoming leads the way on facilitating blockchain technology,” The Securities Edge, https://www.thesecuritiesedge.com/2018/03/wyoming-leads-the-way-on-facilitating-blockchain-technology/.

[6] “IDFPR Requests Comment on “Digital Currency Regulatory Guidance,” IDFPR, Ihttps://illinoisblockchain.tech/idfpr-requests-comment-on-digital-currency-regulatory-guidance-ded5defdb52d.

[7] “Idaho Money Transmitters Section,” Idaho Department of Finance, http://www.finance.idaho.gov/MoneyTransmitter/MoneyTransmitter.aspx.

[8] “Regulation of Virtual Currency Businesses Act,” Uniform Law Commission, http://www.uniformlaws.org/Committee.aspx?title=Regulation%20of%20Virtual%20Currency%20Businesses%20Act.

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