Earlier this year, the California Department of Business Oversight (DBO) issued a draft rulemaking relating to the scope of the agent of a payee exemption (the “Exemption”) under the Money Transmission Act, Cal. Fin. Code §...more
A recent federal district court ruling in a criminal anti-money laundering case suggests that the transmission of virtual currency on behalf of another person requires a state money transmission license—even if the state’s...more
A year after issuing an invitation for comments, the California Department of Business Oversight (“DBO”) has finally released a much-anticipated draft rulemaking relating to the scope of the “agent of a payee” exemption (the...more
Perhaps the biggest recent news in the ever-changing money transmission regulatory landscape is the draft model language for standardized regulation of multistate money services businesses that was proposed by the Conference...more
It seems like a natural progression for a company that provides any sort of payments-related information processing to migrate from handling data about payments to seeking to handle the payments themselves. But it can be a...more
The California Department of Business Oversight (DBO) has issued an Invitation for Comments (“Invitation”) relating to the scope of the “agent of a payee” exemption under the Money Transmission Act, Cal. Fin. Code §2000 et...more
On May 14, 2018, the Office of the South Carolina Attorney General (“AG”) issued a press release announcing that it has created a Money Services Division (“Division”) within the AG’s office and that, effective May 14, the...more
One of the defining aspects of the payments revolution of the past few years—at least from a regulatory perspective—has been the question of whether any particular payments service is subject to regulation as money...more