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Digital asset business insurance in the District of Columbia

In D.C., the Department of Insurance, Securities and Banking treats a crypto kiosk operator that facilitates customer transfers to a third party as a money transmitter, even if it does not retain the cryptocurrency after the transaction. The regulator distinguishes a business selling its own Bitcoin for cash. Show the broker the exact customer journey and transfer destination; licensing status and a statutory bond do not determine policy coverage. 3,1

What Is Digital Assets?

Digital-asset coverage may address custody, theft and business-liability risks, but a custodian’s policy may protect the custodian rather than you. If you hold or safeguard assets, verify the insured entity, wallets, key-loss protection and valuation. Read the national Digital assets guide.

District of Columbia Requirements

RequirementDetails
Map the full customer transactionD.C.’s regulator says fact-specific activity such as receiving, storing, custody, or facilitating a virtual-currency transfer can constitute money transmission; a kiosk operator facilitating a transfer to a third party can be in scope even without retaining coins afterward. 3
Check license and delegate statusD.C. prohibits engaging in money transmission without a license, subject to statutory exemptions. A licensee’s authorized delegate acting within a written contract’s authority does not need its own chapter license. 1
Separate bond/security from insuranceThe statute requires a bond or other accepted security device for specified money-transmission obligations and claimants; its capped amount and purpose are distinct from any commercial insurance policy. 1

What to Watch for in District of Columbia

  • No post-sale custody does not automatically remove the operator

    The 2024 DISB kiosk bulletin says a kiosk operator facilitating a customer transaction immediately to a third party may still be transmitting money, even if it does not retain the virtual currency. Provide a flowchart of who accepts cash, chooses the destination, initiates transfer, controls keys, and handles a failed delivery. 3

  • Distinguish facilitation from own-inventory sales

    DISB’s earlier bulletin describes buying or selling Bitcoin directly with a customer for cash as potentially outside money transmission, while the later kiosk bulletin identifies facilitation of a third-party transaction as potentially covered. The business model and transaction flow matter; avoid applying either bulletin as a universal rule. 2,3

  • Ask about the loss actually at issue

    For kiosks, separate cash theft, a fraudulent instruction, a compromised wallet, a failed or delayed transfer, and customer allegations about disclosures. Match each risk to the insured entity, crime/cyber/E&O form, customer property definition and exclusions; statutory bond requirements do not establish coverage. 1,3

Who Regulates Insurance in District of Columbia

District of Columbia Department of Insurance, Securities and Banking

DISB licenses and supervises insurance companies and producers, enforces District insurance laws, and provides consumer complaint assistance. Its licensing search covers insurance entities and representatives; consumers can contact the agency’s complaints unit for help. 5,6,8

Surplus-lines tax and stamping office

Reported tax rate: Generally 2% of gross premium, including qualifying placement fees When the District is the insured’s home state, surplus-lines agents and brokers generally owe a 2% tax on gross premium, including necessary fees incidental to placement when separately itemized. An agent or broker procuring insurance on behalf of the District government is exempt for that government business; claiming the exemption requires identifying its allocation in the required affidavit and does not waive other statutory duties. Ask the broker which taxes and fees your agreement passes through to you. DISB generally requires a diligent effort to place risks with authorized insurers. For a purchaser meeting the federal exempt-commercial-purchaser definition, the broker may skip that search only after disclosing that insurance may or may not be available from the admitted market, which may provide greater protection with more regulatory oversight, followed by the purchaser’s written request for nonadmitted placement. This record does not state a District-specific guaranty-fund conclusion. 7,9,10,11,4

Providers With Documented State Licenses

No provider in Spot’s research documents both a state license record and this coverage line. This does not establish that providers are unlicensed. Check the regulator’s license lookup and confirm availability with a provider when requesting a quote.

Questions to Ask Before You Buy in District of Columbia

  1. Does the D.C. operator sell inventory directly, or facilitate a customer transfer to a third party?
  2. Who receives cash, initiates the on-chain transfer, and controls keys at each stage, including any kiosk host or authorized delegate?
  3. Do the schedules include the D.C. legal operator, kiosk locations, online channels, and service providers involved in a transfer?
  4. Which policy would address cash theft, credential compromise, transfer error and a claim that the kiosk facilitated a fraudulent payment?

Digital Assets in District of Columbia: FAQ

Can a D.C. kiosk be in scope if it does not keep cryptocurrency after a sale? 3

Yes. DISB’s 2024 bulletin says facilitating a customer transaction to a third party may be money transmission even without post-transaction custody. It also says the analysis is fact-specific. 3

Does the D.C. transmitter bond replace cyber or crime insurance? 1

No. The D.C. Code bond or security device secures specified transmitter obligations and claimants up to its terms. It does not itself establish protection for stolen customer tokens, a cyber incident, or market losses. 1

Digital Assets in Other States

Other Coverage in District of Columbia

Sources

  1. D.C. Code, Chapter 10, Money Transmissions. D.C. Law Library; §§ 26-1001–1003 (definition, license, exemptions); § 26-1007 (bond/security device). Accessed 2026-09-28.
  2. Cryptocurrency and the District of Columbia Money Transmitters Act. D.C. Department of Insurance, Securities and Banking; Bulletin 22-BB-001, August 4, 2022, pp. 1–2; direct sale versus receipt, storage, custody, or transfer activity. Accessed 2026-09-28.
  3. Virtual Currency Kiosk Bulletin Update. D.C. Department of Insurance, Securities and Banking; August 9, 2024, pp. 1–2; facilitation to third party and no-retention fact pattern. Accessed 2026-09-28.
  4. D.C. Code §31–2502.40: License to procure policies from unauthorized companies. Council of the District of Columbia; Subsection (a): broker/agent tax and diligent effort; (c)(1)–(3): District-government procurement tax exemption, allocation statement and continuing duties. Accessed 2026-09-28.
  5. Department of Insurance, Securities and Banking. District of Columbia DISB; Official insurance regulator homepage. Accessed 2026-09-28.
  6. Verify a Financial Institution or Representative Licensed with DISB. District of Columbia DISB; Official license verification for companies and representatives. Accessed 2026-09-28.
  7. Surplus Line Information. District of Columbia DISB; Current 2% tax base including incidental placement fees; fees must be necessary and separately itemized; diligent-effort rule. Accessed 2026-09-28.
  8. File a Complaint or Report Fraud. District of Columbia DISB; Official insurance complaint information and filing form. Accessed 2026-09-28.
  9. 15 U.S.C. §8201: Reporting, payment, and allocation of premium taxes. U.S. House of Representatives, Office of the Law Revision Counsel; §8201(a): exclusive insured home-State authority to require nonadmitted premium tax; (c): separate allocation reporting. Accessed 2026-09-28.
  10. 15 U.S.C. § 8205: Streamlined application for commercial purchasers. U.S. House of Representatives, Office of the Law Revision Counsel; §8205(1)-(2): admitted-market disclosure about possible availability, greater protection and oversight followed by the qualified purchaser’s written request; eligibility separately defined in §8206(5). Accessed 2026-09-28.
  11. 15 U.S.C. §8206: Definitions. U.S. House of Representatives, Office of the Law Revision Counsel; §8206(5) exempt-commercial-purchaser criteria; (6) home State and affiliated-insured rules; (13) qualified risk manager. Accessed 2026-09-28.
  12. Licenses. At-Bay; Current producer introduction and state table; At-Bay Insurance Services LLC; P&C and surplus-lines identifiers. Accessed 2026-09-21.
  13. Licenses and Carriers. Coalition; Licenses and Carriers, re-read 22 September 2026: Insurance Licenses table for Coalition Insurance Solutions, Inc., national producer number 18419475, with producer and surplus-lines numbers for all 50 states and DC including California 0L76155, Georgia 196479, Texas 2199630 and 2205589, Pennsylvania 815731 and 817452, Colorado 539028 and Wisconsin 3000108852. Insurance Carriers table naming, with NAIC numbers, Allianz Underwriters Insurance Company 36420, Arch Specialty Insurance Company 21199, Ascot Specialty Insurance Company 45055, Ascot Insurance Company 23752, Aspen Specialty Insurance Company 10717, Chaucer Insurance Company DAC, Coalition Insurance Company 29530, Fireman's Fund Indemnity Corporation 11380, Fortegra Specialty Insurance Company 16823, Lloyd's of London, MSIG Specialty Insurance USA Inc. 34886, MS Transverse Specialty Insurance Company 41807, Steadfast Insurance Company 26387, Vantage Risk Specialty Insurance Company 16275 and Zurich American Insurance Company 16535. Accessed 2026-09-22.
  14. Insurance Producer Licenses. Corgi Insurance; Current complete Insurance Producer Licenses table for Corgi Insurance Services, Inc.; 50 rows covering 49 states and DC (DC 3003091619); no New Mexico row; no NPN or as-of date shown. Accessed 2026-09-28.
  15. About Hiscox US Insurance. Hiscox; Hiscox Insurance Company Inc. NAIC 10200 as Chicago, IL domiciled insurer admitted or licensed in all 50 states and D.C.; Hiscox Inc. as general agent and Lloyd’s coverholder for Syndicates 33 and 3624; surplus-lines placements through licensed surplus-lines brokers; A.M. Best rating statement. Accessed 2026-09-16.
  16. Licenses. ERGO NEXT Insurance; Current entity-by-state license table reopened 28 September 2026: 50 rows under Next First Insurance Agency, Inc., including Washington, DC; New York rows instead list Next Insurance Services PC-1423070 and AP Intego BR-1198885. Accessed 2026-09-28.
  17. Insurance Licenses by State. TechInsurance; Current state table; identifies TechInsurance as a division of Specialty Program Group LLC d/b/a SPG Insurance Solutions; lists DC 3000041536 and labels Rhode Island “Individual licenses,” without an agency license number. Accessed 2026-09-28.
  18. Licenses. Vouch; Effective 16 January 2025: Vouch Specialty Insurance Services, LLC, NPN 19926463; P&C table (50 states and DC); surplus-lines table includes Idaho 870820; footnote says Georgia and Idaho do not issue agency-level surplus-lines licenses; Idaho retained as producer-only due to conflict. Accessed 2026-09-15.

Updated .

This guide is informational and does not determine whether a policy is available or meets your needs. Editorial policy. To suggest a correction, contact Spot with a supporting source.

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