Title
An Ordinance to Add Chapter 83 (Virtual Currency Kiosks) to Title VII of the Code of the City of Ann Arbor
Memorandum
transfer it to a digital wallet. That speed and the difficulty of reversing transactions have made the kiosks an increasingly common tool for fraud, including scams in which criminals impersonate government agencies, law enforcement, financial institutions, businesses, or family members and direct victims to deposit cash into a kiosk.
According to AARP, the FBI received more than 13,460 complaints involving virtual currency kiosks in 2025, with reported losses exceeding $389 million. Adults aged 60 and older accounted for nearly 76% of reported losses for which age was available.
This ordinance regulates virtual currency kiosks operating in Ann Arbor by requiring operators to obtain a city license, and establishing consumer protection and fraud-prevention safeguards. These include:
Clear on-screen disclosures about the risks of virtual currency and the operator’s terms and conditions.
Prominent warnings before each transaction addressing common scams, along with fraud-warning signage at businesses hosting kiosks.
Photo identification, transaction receipts, supervised premises, and live customer service.
Written anti-fraud policies and use of blockchain analytics to help identify wallets associated with fraudulent activity.
Transaction limits of $500.00 per day for new users, $1,000.00 per day for other users, and $10,000.00 in any 30-day period.
A dedicated communications channel for law enforcement responding to reports of fraud.
City inspection and enforcement authority, including the ability to deny, suspend, or revoke a kiosk license for violations.
These requirements are intended to help consumers recognize scams before transferring money, limit potential losses, and give law enforcement better tools to respond when fraud occurs.
Staff
Reviewed by: Michelle Landis, Senior Assistant City Attorney
Body
(See Attached Ordinance)
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