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US States Adopt Model Money Transmission Act, but Harmonization Remains Elusive

So far in 2024, nine states1 – Maryland, South Dakota, Wisconsin, Kansas, Maine, Vermont, South Carolina, Missouri and Connecticut – have passed legislation or enacted regulations based, to varying degrees, on the Model Money...more

Arizona Embraces CSBS Model Money Transmission Law; West Virginia Incorporates Some Key Provisions

On May 20, 2022, Arizona Gov. Doug Ducey signed Senate Bill 1580, which effectively replaces Arizona’s current money transmission law with the Model Money Transmission Modernization Act (the Model Act) announced by the...more

Alert: Virtual Currency Activity Subject to Money Transmission Licensing in Florida and Arkansas

Innovative companies and platforms that seek to bring new virtual currency products and services to market in the US generally need to consider the potential applicability of US state money transmission licensing laws. How...more

Alert: California Finalizes Rulemaking for Agent-of-a-Payee Exemption in Money Transmission Licensing

The California Department of Financial Protection and Innovation (DFPI) has finally adopted final rules relating to the scope of the agent-of-a-payee exemption under the California Money Transmission Act (MTA), Cal. Fin. Code...more

Alert: Who is an Agent of a Payee in California? With Rulemaking Pending, Possible Scope Suggested by Opinion Letters

Any company that intermediates payments for other parties ─ such as a marketplace platform, a billing service, a payment facilitator or a B2B platform provider ─ must take into consideration the applicability of money...more

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