Virtual Currency Regulations: Key Insights for the Payments Industry — Payments Pros – The Payments Law Podcast
Navigating New Compliance Challenges: The Impact of the Money Transmitter Modernization Act on Payroll Processing - Payments Pros – The Payments Law Podcast
The Conference of State Bank Supervisors (CSBS) recently issued interpretive guidance addressing the accounting treatment of stablecoins in the tangible net worth (TNW) calculation under its Model Money Transmission...more
On March 10, 2026, FinCEN issued a renewed and expanded Geographic Targeting Order (GTO) imposing enhanced reporting and recordkeeping requirements on certain money services businesses (MSBs) operating along the Southwest...more
Florida is advancing legislation that would formally bring operators of cryptocurrency kiosks within the state’s money transmitter licensing framework. House Bill 505 has passed both chambers of the Florida Legislature and,...more
On March 3, Maine enacted Public Law Chapter 542, authorizing the registration of certain cash-dispensing machines through the NMLS and adding an express prohibition on operating such machines as virtual currency kiosks...more
The U.S. Department of the Treasury recently released the National Money Laundering Risk Assessment, the National Terrorist Financing Risk Assessment, and the National Proliferation Financing Risk Assessment reports. ...more
Through the provisions of the Bank Secrecy Act and various Office of Foreign Assets Control (OFAC) sanctions programs, the US Department of the Treasury (Treasury) has imposed certain compliance obligations on financial...more
On February 9, 2026, the Washington State Department of Financial Institutions (DFI) entered into a consent order with a digital assets-focused money transmitter requiring the company to cease and desist from violating...more
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) recently announced a sweeping enforcement operation targeting money services businesses (MSBs) operating along the Southwest U.S. border....more
The year 2025 marked a turning point in Canada's anti-money laundering (AML) enforcement landscape, with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) adopting a markedly more aggressive approach....more
On January 9, the U.S. Treasury announced a series of measures aimed at addressing alleged widespread government benefits fraud in Minnesota, purporting that billions of taxpayer dollars were lost to what the Treasury deemed...more
In December, the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a $3,500,000 civil penalty against Paxful, Inc. and Paxful USA, Inc. (“Paxful”), pursuant to a consent order. Paxful is an...more
On December 22, FinCEN announced a multi-tiered operation targeting more than 100 money services businesses (MSBs) operating along the southwest border for potential noncompliance with BSA/AML regulations. ...more
On December 9, FinCEN announced a consent order levying a $3.5 million civil money penalty against a peer-to-peer virtual currency trading platform for willful BSA violations. FinCEN alleged the company facilitated more than...more
On November 28, FinCEN issued an alert as part of Treasury’s efforts to combat exploitation of the U.S. financial system by individuals without legal status seeking to remit potentially illicit funds. ...more
On November 25, the Washington Department of Financial Institutions (DFI) issued a Temporary Order to Cease and Desist and a Statement of Charges against a virtual-currency kiosk operator, alleging violations of the Uniform...more
The Senate has introduced the Streamlining Transaction Reporting and Ensuring Anti-Money Laundering Improvements for a New Era Act, or the STREAMLINE Act, an initiative led by Senate Banking Committee Chairman Tim Scott and...more
On September 30, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued a request for information (“AML Survey”) on the costs that nonbank financial institutions (“NBFIs”) incur to comply with anti-money laundering...more
On September 29, 2025, FinCEN issued a Notice and Request for Comment (the “Notice”) on a proposed information gathering exercise – A Survey of the Costs of Anti-Money Laundering and Countering the Financing of Terrorism...more
On September 18, the California DFPI ordered a digital financial asset kiosk operator to cease operations for violating the state’s Consumer Financial Protection Law and Digital Financial Assets Law by allegedly operating...more
In this article, we examine (1) the new regime for safeguarding of customer funds applying to UK payment and electronic money institutions, (2) the impact these reforms will have on those firms and (3) in particular, the...more
The GENIUS Act (Act) allows “permitted payment stablecoin issuers”—which term includes nonbanks that are either Federal qualified payment stablecoin issuers (FQPSI) (regulated by the OCC) or State qualified payment stablecoin...more
On August 6th, 2025, following a four-week trial, a jury found Roman Storm, the founder of a crypto mixing service called Tornado Cash, guilty of conspiracy to operate an unlicensed money transmitting business. The jury was...more
When regulators propose a new rule, financial institutions can often find themselves pushed into a reactionary position, left to deal with consequences that rule makers may not have foreseen. Once a rule hits the books, legal...more
Key Takeaways - - The Financial Crimes Enforcement Network’s recently issued notice, which addresses regulations and increased rates of fraud surrounding convertible virtual currency kiosks, carries significant implications...more
We continue our series on the legal and regulatory challenges facing individual coverage health reimbursement arrangements (ICHRAs); this time, we are focusing on the fintech-related requirements that may apply to ICHRA...more