Compliance Journal May 2026
Special Focus 2025-2026 State Legislative Update (Part 2) The March Compliance Journal included a special focus article which provided an update on the 2025-2026 Wisconsin legislative session (Part 1). As was discussed in that article, the most active portion of the session has come to a close. However, the biennial legislative term does not formally end until January 4, 2027. During the time since the release of Part 1, additional bills have been signed into law. This article presents a summary of new laws which vary from directly to indirectly relevant to the banking industry. Most of the laws summarized below have been provided for information purposes and should not require action from banks. However, two are of note. First, WBA-supported legislation related to virtual currency kiosks was signed into law. Second, a new law expands the rights of patient representatives to authorize certain expenditures of incapacitated individuals. These two laws are presented at the beginning of this article. The remaining laws are presented in order of perceived relevance and include some notable items such as reorganization of law governing recordings with register of deeds and high school personal financial literacy requirements. New Laws Passed This Session Since Part 1 Virtual Currency Kiosks As discussed in Part 1, a bill was introduced this session designed to regulate virtual currency kiosks. These kiosks appear at many locations across the state and have been increasingly utilized for fraudulent transactions. WBA supported legislation designed to reduce fraud through the use of these kiosks. Specifically, provisions were incorporated into the bill to establish daily transaction limits and require refunds of fraudulent transactions. Since writing of Part 1, the bill regulating virtual currency kiosks was signed into law as 2025 Wisconsin Act 226 and includes those provisions supported by WBA. Among other things, Act 226 requires all virtual currency kiosk operators (operators) to be licensed under state financial laws and creates consumer protection and antifraud measures aimed at reducing the extent of ongoing cryptocurrency‑related scams. It also requires fraud warnings on the front of the kiosk, among other protections. One protection in particular creates a daily transaction limit whereby an operator may not accept from or dispense to a customer, by any means of any virtual currency kiosk, more than $1,000 in fiat currency in the same day. Another protection requires operators to refund the customer, upon request of the customer, the full amount of any transaction, including any fees charged in connection with the transaction, if, not later than 30 days after the transaction, the customer contacted the operator, the Department of Justice, Department of Financial Institutions, or a law enforcement agency to inform them of the fraudulent nature of the transaction. Operators must also provide live, toll‑free customer service during all hours in which the virtual currency kiosk is operable, provide physical and electronic detailed transaction receipts, and maintain a written antifraud policy. WBA is pleased to report this success in the industry’s ongoing efforts to combat fraud. Act 226 is generally effective April 10, 2026; however, the customer identification requirements are delayed by sixty days to allow for creation and implementation of those provisions. Patient’s Representative Another notable banking-relevant law passed since Part 1 is Act 115. Act 115 allows certain individuals to consent