Section IX governs the terms applicable to Bitcoin and other virtual currency transactions within Cash App, establishing conditions for buying, selling, and transferring virtual currency.
This analysis describes what Cash App's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
Virtual currency services within a consumer financial platform engage a distinct regulatory framework including FinCEN's BSA/AML requirements, state money transmitter licensing, and potentially SEC jurisdiction depending on the classification of specific virtual currency products. The terms applicable to virtual currency transactions may differ materially from those applicable to fiat currency services.
Interpretive note: The full text of Section IX was not reproduced in the provided document excerpt; the characterization is based on the section title and standard virtual currency service terms in comparable consumer fintech agreements.
The updated terms introduce a new stablecoin withdrawal feature that allows Cash App users to convert USD to stablecoins and send them to external blockchain addresses. Under the revised language, users do not acquire ownership or title to stablecoins; Cash App or its partners retain full control until delivery to the specified address. Critically, the terms state that withdrawals cannot be reversed or refunded once initiated on the blockchain, and sending assets to unsupported networks or incorrect addresses will result in permanent and irreversible loss of funds. Users are solely responsible for verifying accurate withdrawal instructions and compatible network addresses before initiating transfers.
View change record →The updated terms increase the Foreign Transaction Fee from 3% to 3.25% and narrow the circumstances under which this fee is waived. Previously, users who spent $500+ monthly or received $300+ in deposits waived the entire Foreign Transaction Fee. Under the revised terms, the fee waiver now applies only to card-present (in-person) transactions, meaning online and card-not-present international purchases remain subject to the fee without a waiver path. Users making qualifying purchases or deposits still receive fee waivers, but only for in-person international card transactions through the end of the following calendar month.
View change record →The updated terms state that Cash App will discontinue its Remittance Service effective May 1, 2026. Any remittance payment still pending on or after May 1, 2026 will continue to be processed unless the sender cancels the transfer. However, any remittance payment sent via cash pickup that is not picked up within 21 days will be automatically canceled, and all remittance payments remaining in pending state on May 21, 2026 will be automatically canceled and refunded to the sender. Additionally, for California residents with Cash App Cards, the gift card cash redemption threshold was increased from $10 to $15. You can cancel pending remittance transfers before May 1, 2026 to manage the transition.
View change record →Under Section IX, users who access Bitcoin or other virtual currency features within Cash App are subject to specific terms governing those transactions, including conditions on purchases, transfers, and applicable fees. Virtual currency transactions are not covered by FDIC insurance or Regulation E protections applicable to fiat prepaid account transactions.
How other platforms handle this
to trade in foreign currencies for speculative purposes (that is, to take advantage of any expected rise or fall in the value of a currency) or to take advantage of discrepancies in the foreign exchange market.
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"IX. Virtual Currency Services— Excerpt from Cash App's Cash App Terms of Service
1. REGULATORY LANDSCAPE: Virtual currency services engage FinCEN's Bank Secrecy Act requirements including KYC/AML obligations for money service businesses. State money transmitter licenses govern Bitcoin transmission in most U.S. jurisdictions. The SEC has ongoing jurisdiction questions regarding certain virtual currency products, and the CFTC has asserted jurisdiction over Bitcoin as a commodity. The FTC has issued consumer guidance on virtual currency fraud and deceptive practices. 2. GOVERNANCE EXPOSURE: Medium. Bitcoin and virtual currency services in consumer fintech products are subject to an evolving and multi-agency regulatory framework. The absence of FDIC insurance and Regulation E protections for virtual currency holdings is a material disclosure consideration for users who may conflate virtual currency accounts with traditional financial accounts. 3. JURISDICTION FLAGS: Several states impose specific virtual currency licensing requirements (New York's BitLicense, for example). The regulatory treatment of virtual currency transactions varies by state and users in certain jurisdictions may face additional restrictions. 4. CONTRACT AND VENDOR IMPLICATIONS: Businesses or developers integrating Cash App's virtual currency features should assess compliance with applicable FinCEN, state money transmitter, and securities law requirements. 5. COMPLIANCE CONSIDERATIONS: Legal and compliance teams should review Section IX against applicable FinCEN guidance, state virtual currency regulations, and the evolving SEC and CFTC jurisdictional framework for virtual currency products.
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Virtual currency services within a consumer financial platform engage a distinct regulatory framework including FinCEN's BSA/AML requirements, state money transmitter licensing, and potentially SEC jurisdiction depending on the classification of specific virtual currency products. The terms applicable to virtual currency transactions may differ materially from those applicable to fiat currency services.
Under Section IX, users who access Bitcoin or other virtual currency features within Cash App are subject to specific terms governing those transactions, including conditions on purchases, transfers, and applicable fees. Virtual currency transactions are not covered by FDIC insurance or Regulation E protections applicable to fiat prepaid account transactions.
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