News & Analysis as of

Money Services Business Money Transmitter

Wilson Sonsini Goodrich & Rosati

Pending Changes to Anti-Money Laundering Program Requirements for MSBs and Other Financial Institutions

Money services businesses (MSBs), a category which includes money transmitters (e.g., PayPal and other payment facilitators), as well as administrators and exchangers of convertible virtual currencies (e.g., Bitcoin...more

Orrick, Herrington & Sutcliffe LLP

MSB Call Report updates effective for Q3 reporting

Recently, NMLS announced updates to the Money Services Business (MSB) Call Report effective in the third quarter for filings due November 14. These updates aim to align the report with the Model Money Transmission...more

Troutman Pepper

Navigating New Compliance Challenges: The Impact of the Money Transmitter Modernization Act on Payroll Processing - Payments Pros...

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In this episode of Payments Pros, Keith Barnett is joined by Eli Polanco, founder and CEO of Nivelo, to discuss critical issues in payroll processing. They highlight the significant impact that the Money Transmitter...more

Orrick, Herrington & Sutcliffe LLP

Colorado extends its money transmitter regulations

On June 3, Colorado enacted HB 1328, (the “Act”), which will extend the state’s regulation of money transmitters until September 2030. The law had previously been scheduled to sunset on September 1. The Act will implement the...more

Ballard Spahr LLP

PA Department of Banking and Securities: Virtual Currency is “Money”

Ballard Spahr LLP on

On April 20, 2024, the Pennsylvania Department of Banking and Securities (“DoBS”) issued a policy statement (“Policy Statement”) to “clarify” that the Department’s interpretation of the term “money” in the Pennsylvania Money...more

Orrick, Herrington & Sutcliffe LLP

Iowa enacts new money transmission provisions

On April 10, Iowa’s governor signed into law HF 2262 (the “Act”) relating to money transmission services. The Act will exempt a person appointed as an agent of a payor for purposes of providing payroll processing services...more

Hudson Cook, LLP

Florida Regulator Clarifies Money Transmitter Licensing Exemptions (or lack thereof)

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Among the many state licenses that can impact financial services companies, money transmitter licensing can be among the harder to figure out. In addition to uncertainties about digital currency and developing technologies,...more

McGlinchey Stafford

Podcast: Deep Dive Into Payments: Impacts of Money Transmission Laws [More with McGlinchey, Ep. 59]

McGlinchey Stafford on

The next item in McGlinchey's Deep Dive into Payments Series is a podcast on money transmission by attorneys Jeff Barringer, Amy Greenwood-Field, and Aaron Kouhoupt. Their discussion centers around the impacts of money...more

McGlinchey Stafford

Deep Dive Into Payments: Impacts of Money Transmission Laws

McGlinchey Stafford on

The next item in McGlinchey’s Deep Dive into Payments Series is on money transmission by attorneys Jeff Barringer, Amy Greenwood-Field, and Aaron Kouhoupt. Their discussion centers around the impacts of money transmission...more

Latham & Watkins LLP

Money Transmission Modernization Act Adopted in Several States

Latham & Watkins LLP on

The Act aims to modernize and streamline state regulation of money transmitters while promoting innovation and consumer protection. More than a dozen US states have enacted the Money Transmission Modernization Act (MTMA)...more

Stinson LLP

Modernization of Money Transmission Laws

Stinson LLP on

While all states except Montana currently require licensure at the state level for entities seeking to act as a money transmitter, generally defined as an intermediary receiving money or monetary value for transmission to...more

Orrick, Herrington & Sutcliffe LLP

Texas enacts Money Services Modernization Act

On May 29, the Texas governor signed SB 895 (the “Act”) to enact the Money Services Modernization Act, the money transmitter model law created by industry and state experts. The goal of the Act is to create a set of...more

Orrick, Herrington & Sutcliffe LLP

Iowa modernizes money transmission provisions

The Iowa governor recently signed HF 675 to revise certain provisions of the Uniform Money Transmission Modernization Act. The Act is designed to eliminate unnecessary regulatory burden and harmonize the licensing and...more

Orrick, Herrington & Sutcliffe LLP

Tennessee enacts Money Transmission Modernization Act

On April 4, the Tennessee governor signed HB 316 / SB 268 to enact the Money Transmission Modernization Act, the money transmitter model law created by industry and state experts. Provisions under the Act amend Tennessee Code...more

Orrick, Herrington & Sutcliffe LLP

North Dakota passes law on money transmitter licensure

On March 15, the North Dakota governor signed SB 2119, which revises provisions related to money transmitters. The act, among other things, provides that a “person may not engage in the business of money transmission or...more

Orrick, Herrington & Sutcliffe LLP

Illinois announces new consumer protections for digital assets, proposes new money transmitter licensing provisions

On February 21, the Illinois Department of Financial and Professional Regulation (IDFPR) announced several legislative initiatives to establish consumer protections for cryptocurrencies and other digital assets and provide...more

McGlinchey Stafford

FTX collapse suggests money transmitters focus on permissible investments

McGlinchey Stafford on

The collapse of cryptocurrency exchange FTX has been widely reported across the world. One interesting exception to the fallout appears to involve U.S. customers, according to a tweet from FTX’s former CEO. We’ve received...more

BakerHostetler

Applying the Bank Secrecy Act, FinCEN Regulations, and Sanctions to the Nascent NFT Market

BakerHostetler on

Non-fungible tokens (NFTs) often involve two areas with known money laundering and terrorist financing risks: cryptocurrencies and high-value assets, like art. As detailed below, the U.S. Treasury Department’s Financial...more

Wilson Sonsini Goodrich & Rosati

Money Transmitter Model Law Poised to Change Regulatory Landscape

The Conference of State Bank Supervisors (CSBS) released its Money Transmission Modernization Act (Money Transmitter Model Law) (Model Law) to create a single money transmitter regulatory regime across the country and...more

The Volkov Law Group

Payoneer Pays $1.4 Million to Resolve OFAC Sanctions Violations

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Payoneer, Inc., an online money transmitter and prepaid access company, agreed to pay $1.4 million to OFAC to settle violations of multiple sanctions programs.  ...more

McGlinchey Stafford

Scared Of Your Clients’ Involvement With Cryptocurrency?

McGlinchey Stafford on

Cryptocurrency, and its most-noted asset Bitcoin, has been breaking into the mainstream press. While most lawyers have heard terms like “blockchain” and probably even know a few people who have been deeply interested in the...more

Skadden, Arps, Slate, Meagher & Flom LLP

FinCEN and Federal Reserve Propose To Significantly Lower Threshold for International Funds Transfers Under Recordkeeping and...

On October 27, 2020, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) and the Board of Governors of the Federal Reserve System (Federal Reserve, together with FinCEN, “the Agencies”)...more

Troutman Pepper

CSBS Continues Streamlining for Payments Firms, Announces One Company, One Exam Program

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On September 15, the Conference of State Bank Supervisors (CSBS) announced that money transmitters operating in 40 or more states will be able to take advantage of a new, comprehensive exam designed to satisfy all state money...more

Troutman Pepper

CSBS Continues Streamlining of Licensing for Payments Firms Through 'One Company, One Exam' Program

Troutman Pepper on

On September 15, the Conference of State Bank Supervisors (CSBS) announced that money transmitters operating in 40 or more states will be able to take advantage of a new, comprehensive exam designed to satisfy all state money...more

Ballard Spahr LLP

State Bank Regulators Launch Single-Exam Plan for Multistate Money Transmitters in wake of OCC’s Payments Charter Proposal

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The Conference of State Bank Supervisors (CSBS) recently announced plans to establish a program under which money transmitters licensed in multiple states will undergo a single comprehensive exam that seeks to satisfy all...more

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