Bob Cornish opened his talk at Mining Disrupt Miami 2022, recorded July 26–28, 2022, by asking the room to leave with one number in mind: 102. They would know why, he said, in a few minutes. Cornish, managing shareholder of the Law Offices of Robert V. Cornish, Jr., PC, is an attorney licensed in Wyoming and part of the Wyoming Blockchain Coalition, and he said he helped write some of the state's banking, securities and lending legislation for the blockchain industry.
His audience had been hearing about the SEC, Coinbase and the country's securities and commodities regulators. Cornish spoke to the people in the room who were afraid of dealing with the United States or having second thoughts about keeping their business there. His answer was that one state could not only accommodate their business but wanted it, and that the state had put real time and effort into rolling out the red carpet for the digital asset industry, mining in particular.
You can still rock in America, you just have to do it in Wyoming.
Bob Cornish · 1:27
Bitcoin traded at $22,964 on the first day of the event. As of October 12, 2026, it was $84,128.
A state that trades with itself
Cornish said Wyoming was the first state to enact legislation for digital assets and that work on those laws was continuing. The idea he asked the room to keep was that Wyoming is an ecosystem in itself. He tells clients the state works as a digital asset exchange of its own, because anyone inside its four corners can trade with anyone else in the state: 500,000 people and hundreds of thousands of corporations, including 40,000 with blockchain or crypto in their names.
Residence is open to outsiders. Someone in New York, Florida, Uzbekistan or Canada, he said, can form a Wyoming LLC as easily as someone who lives there, become a Wyoming resident for these purposes and use the state's laws.
What the statutes cover
He then ran through the highlights. Digital assets are personal property under Wyoming law, and he said there is no state tax on their disposition; changing that would take a change to the state constitution, which he did not expect. Tokens deemed utility tokens generally fall outside securities regulation. Provisions he helped write let a lender perfect a security interest in crypto, repossess it if the borrower does not pay, and go to a court that can act on it.
That year Wyoming had also created chancery courts like the ones in Delaware, which he said was done in anticipation of people using the state as a jurisdiction for digital transactions. On banking, he said banks generally cannot discriminate against clients because they are in crypto or blockchain. The state has special purpose depository institutions and trust companies; at the time of the talk the trust companies were operating and the SPDIs were not.
Custody was the first practical use he offered miners. Many he had spoken to that day had a wallet and wanted to distribute from it to somewhere else. His suggestion was to have a Wyoming trust company, a trust it creates, or a Wyoming LLC own that wallet.
Structures for mining ventures
Wyoming has series LLCs, which Cornish compared to structures in the Cayman Islands or the British Virgin Islands: a master LLC with cells beneath it for each venture. His example was one cell per mining rig, all under the same LLC document. Legislation the year before had created DAOs, a form of Wyoming LLC that allows governance tokens without giving holders shareholder rights.
Under the state's regulatory sandbox, he said, a business can get relief from a statute that is preventing it from creating jobs for two years, then renew for about another year. For miners, the point he flagged as a big deal was power.
You can negotiate with local utilities on power, which is a big deal. You don't have to go to a public utility commission.
Bob Cornish · 5:36
The rest of his list: a state crowdfunding statute, similar to the federal one but limited to intrastate assets and transactions; captive insurance legislation that lets a company create its own insurer and fund it with cryptocurrency; and games of chance that can be played with cryptocurrency, so a gaming company can put its servers and its business in the state.
Raising money inside one state
The question he said always comes up is raising money: whether the offering is a security, whether it has to be registered in 50 states, whether the company is shut out of the U.S. altogether. Cornish said he could not apologize for the regulatory environment. The SEC and the CFTC would do what they would do, and his hope was that the CFTC would take over much of the field. Until then, for money from outside the country, he pointed to Regulation S, an offering made entirely outside the United States.
For U.S. investors, his answer was to keep the offering strictly within Wyoming's borders. Investors would form a Wyoming LLC, partnership or trust and be treated as Wyoming residents. They could then custody assets at a Wyoming trust company and borrow, swap and lend under the state's lending provisions. That, he said, was how he thought a company could stay out of the SEC's crosshairs, while adding that Wyoming is not for everyone.
The $102 test
That is where the number came in. It costs $102, he said, to form a one-person LLC in Wyoming. For a company raising money or doing business with partners, his question was whether those people would spend that amount to do business with it in a way that keeps everyone out of trouble.
My view is they can't spend 102 on you, why should you be dealing with them.
Bob Cornish · 9:30
He closed with the limits. A Wyoming raise still calls for care with marketing, and the main requirement is a website or checkbox where the investor states they are a Wyoming resident or a Wyoming corporation. Nobody is ever exempt from tax, he said, and companies have to be comfortable with marketing restrictions, because some things simply cannot be done. His firm was at booth 110 for the rest of the conference.
The session reflects Wyoming law as Cornish described it in July 2022.