# ANNEX M - U.S. STATE-BY-STATE ACTIVATION MATRIX

> Balanced Exchange Framework (BEF) - Framework Version 1.0, 2026-08-22.
> Source of record: https://balancedexchangeframe.work/doc/annex-m

Scope limitation: the P08 column addresses only the state money-transmission / virtual-currency licensing layer for the strict proprietary-treasury facts. READY is not blanket legal approval. P07/P02 is a broader direct customer sale/use indicator. Across all states and DC: Mode B is HOLD until CP-46; Lana8Wonder retail and Direct.Lana.Fund public/retail are HOLD until federal securities route + CP-50; custody is HOLD unless separately cleared.

| State / DC | P08 strict treasury | P07 BuyLana.com / P02 direct sale/use | Main issue / primary authority |
| --- | --- | --- | --- |
| Alabama | CONDITIONAL | CONDITIONAL | ASC / Money Transmitter Act; VC/monetary-value transmission regulated; no explicit corporate own-account safe harbor located in source freeze. |
| Alaska | CONDITIONAL | CONDITIONAL | AK DCCED, 3 AAC 13; virtual-currency transmission licensing since 2023; direct principal purchase not expressly resolved. |
| Arizona | CONDITIONAL | CONDITIONAL | AZ DIFI money-transmitter law; no explicit VC corporate own-account safe harbor located. |
| Arkansas | CONDITIONAL | CONDITIONAL / HIGH | Arkansas Money Services Act includes virtual currency/monetary value transmission; written perimeter required. |
| California | HOLD | HOLD | DFAL effective licensing 1 Jul 2026; own-behalf exemption is limited to personal/family/household/academic purposes. Corporate treasury needs DFPI determination/licence/exemption analysis. |
| Colorado | CONDITIONAL | CONDITIONAL | Colorado MTMA (HB25-1201, effective 2025); no explicit proprietary VC safe harbor located. |
| Connecticut | CONDITIONAL | CONDITIONAL / HIGH | CT DOB virtual-currency/money-transmission framework; customer exchange/control risks; written DOB conclusion. |
| Delaware | CONDITIONAL / TRANSITION | CONDITIONAL | 2026 Money Transmission & Virtual Currency Modernization changes include own-behalf concepts; final effective implementation/regulatory treatment must be confirmed. |
| Florida | READY* | CONDITIONAL | Ch. 560 centers intermediary receipt/transmission to another; strict two-party principal purchase has favorable non-intermediary facts. Confirm no other digital-asset activity. |
| Georgia | CONDITIONAL / HIGH | CONDITIONAL / HIGH | GA DBF money-transmitter/MTMA framework; active enforcement in VC market; written state determination before targeting. |
| Hawaii | READY* | CONDITIONAL | Hawaii DFI ended state money-transmitter licensing requirement for digital-currency activity after 30 Jun 2024; fiat transmission remains separate. |
| Idaho | CONDITIONAL-GREEN | CONDITIONAL | Idaho DFI guidance focuses legal tender accepted for later delivery to third party; strict P08 lacks third-party delivery, but written confirmation prudent. |
| Illinois | READY* | CONDITIONAL | Digital Assets and Consumer Protection Act expressly excludes buying/selling/trading digital assets for own account in principal capacity from “Exchange”. |
| Indiana | CONDITIONAL | CONDITIONAL / HIGH | IN DFI MTMA/VC questionnaire scrutinizes acceptance, storage, conversion, transmission and private-key control; no explicit own-account exclusion located. |
| Iowa | CONDITIONAL | CONDITIONAL | Iowa Code Ch. 533C MTMA; no explicit VC corporate own-account safe harbor located. |
| Kansas | READY* | CONDITIONAL | HB 2591, effective 1 Jul 2026, excludes two-party money/virtual-currency exchanges (non-kiosk) from money transmission; “two-party exchange” uses party inventory. |
| Kentucky | READY* | CONDITIONAL | Kentucky 2025 legislation excludes exchange of digital assets from money-transmission licensing; securities/consumer laws remain. |
| Louisiana | CONDITIONAL-GREEN | CONDITIONAL | Louisiana Virtual Currency Business Act has own-use and other exemptions but corporate commercial fit is fact-specific; OFI classification memo. |
| Maine | READY* | CONDITIONAL | 32 M.R.S. §6100-PP expressly exempts person using VC, including investing/buying/selling, solely on the person’s own behalf. |
| Maryland | CONDITIONAL-GREEN | CONDITIONAL | MD Office of Financial Regulation money-transmission framework; use formal licensing-predetermination route for strict P08. |
| Massachusetts | READY* for B2B / CONDITIONAL individuals | CONDITIONAL | Massachusetts money-transmission consumer scope is primarily personal/family/household; B2B strict P08 materially cleaner. Individual flows need separate review. |
| Michigan | CONDITIONAL-GREEN | CONDITIONAL | Michigan MT law focuses receipt for transmission; no explicit VC principal safe harbor located. |
| Minnesota | READY* | CONDITIONAL | Minn. Stat. §53B.70 expressly exempts person using VC, including investing/buying/selling, solely on own behalf. |
| Mississippi | CONDITIONAL | CONDITIONAL | Mississippi MTMA effective 1 Jul 2025; no explicit VC corporate own-account safe harbor located. |
| Missouri | CONDITIONAL-GREEN | CONDITIONAL | Missouri MTMA focuses receipt for transmission/payment instruments/stored value; proprietary VC purchase not expressly addressed. |
| Montana | READY* at MT layer | CONDITIONAL | Montana Division of Banking does not regulate money transmitters; securities/consumer/tax law still applies. |
| Nebraska | CONDITIONAL | CONDITIONAL | Nebraska Money Transmitters Act updated 2026; no explicit proprietary VC safe harbor located in source freeze. |
| Nevada | HOLD / HIGH | HOLD | Nevada FID requires careful licensure determination for crypto businesses facilitating transmission/holding value; strict P08 must receive written state conclusion. |
| New Hampshire | READY* at VC-MT layer | CONDITIONAL | RSA 399-G exemptions/guidance are favorable to specified VC activity; confirm strict no-client-payment/no-custody facts and current text. |
| New Jersey | CONDITIONAL-GREEN | CONDITIONAL | NJDOBI money-transmitter law focuses receipt of money for transmission for fee/benefit; strict P08 pays own consideration, but no explicit VC own-account ruling located. |
| New Mexico | HOLD | HOLD | New Mexico FID guidance has treated business exchange of VC for money/other value with NM persons as licensed money transmission; no reliance on federal own-account ruling alone. |
| New York | HOLD | HOLD | 23 NYCRR Part 200 regulates buying/selling VC “as a customer business”; consumer investment exemption does not clearly protect professional corporate treasury dealing with NY residents. NYDFS written/licensed route required. |
| North Carolina | CONDITIONAL / HIGH | CONDITIONAL / HIGH | NCCOB regulates transmission of virtual currency and offers exemption/determination process; obtain written determination for P08. |
| North Dakota | READY* | CONDITIONAL | ND DFI guidance distinguishes operator-reserve/direct exchange without custody/third-party transmission from money transmission; preserve strict reserve-funded facts. |
| Ohio | READY* | CONDITIONAL | Ohio Rev. Code §1315.01(G) excludes transaction where recipient is principal/authorized representative of principal in underlying transaction from “transmit money”. |
| Oklahoma | CONDITIONAL | CONDITIONAL | Oklahoma clearly licenses digital-asset kiosks; current public guidance does not definitively resolve non-kiosk proprietary direct purchase. |
| Oregon | CONDITIONAL / HIGH | HOLD / CONDITIONAL | Oregon DFR licenses money transmitters and crypto businesses in relevant flows; no official own-account safe harbor located in source freeze. Obtain DFR interpretation. |
| Pennsylvania | READY* B2B | CONDITIONAL individuals | Act 7 of 2025 §2(b)(1) excludes money/VC transmission between business entities under commercial contracts unless personal/household individual activity is involved. |
| Rhode Island | READY* | CONDITIONAL | R.I. Gen. Laws §19-14.3-1(v) expressly exempts person using VC, including investing/buying/selling, solely on its own behalf. |
| South Carolina | CONDITIONAL | CONDITIONAL | SC Uniform Money Services Act 2024; money transmission centers receipt of money/monetary value for transmission; no explicit VC proprietary safe harbor located. |
| South Dakota | CONDITIONAL | CONDITIONAL | SD banking money-transmission framework and VC guidance; no explicit corporate proprietary exemption located in source freeze. |
| Tennessee | CONDITIONAL-GREEN | CONDITIONAL | TDFI guidance historically distinguishes virtual currency itself from sovereign-currency money transmission, but exchange/admin fiat legs can be regulated; written confirmation. |
| Texas | CONDITIONAL-GREEN | CONDITIONAL | Texas virtual-currency supervisory guidance distinguishes direct two-party own-account facts from third-party transmission, but current Ch. 152/2026 changes should be confirmed per launch. |
| Utah | CONDITIONAL-GREEN | CONDITIONAL | Utah has blockchain-token exclusions; READY requires documented conclusion that LANA satisfies statutory token definition and transaction facts. |
| Vermont | HOLD | HOLD | Vermont own-use exemption is limited to personal/family/household/academic purposes; corporate proprietary treasury not expressly protected. DFR exemption/order/licence route. |
| Virginia | CONDITIONAL-GREEN | CONDITIONAL | Virginia Bureau guidance does not regulate virtual currencies as such; fiat transmission can trigger law. Strict principal purchase favorable but written state memo recommended. |
| Washington | CONDITIONAL / HIGH | HOLD / CONDITIONAL | RCW 19.230 includes virtual currency in “equivalent value” received for transmission; exchanges/storage can be licensable. Strict two-party principal flow needs DFI exclusion analysis; licensing structure can require U.S. entity. |
| West Virginia | READY* at MT layer | CONDITIONAL | WV currency-transmission definition centers receipt for purpose of transmitting; strict P08 own consideration/no transmission is favorable. Confirm current commissioner position. |
| Wisconsin | CONDITIONAL-GREEN | CONDITIONAL | WI DFI treats fiat-to-VC delivery to third-party wallet as money transmission; strict P08 direct principal treasury differs, but DFI safe-harbor letters are limited—counsel classification. |
| Wyoming | CONDITIONAL-GREEN | CONDITIONAL | Wyoming money-transmitter/digital-asset framework; no explicit corporate own-account VC safe harbor located in retrieved primary materials. Written Division/counsel position. |
| District of Columbia | HOLD / HIGH | HOLD | DC DISB regulates money transmission and has treated VC transmission as licensable; direct proprietary purchase not expressly resolved. Written DISB conclusion before targeting. |