News & Analysis as of

Money Transmission Act

Orrick, Herrington & Sutcliffe LLP

Maine settles with crypto kiosk operator for $1.9M over alleged unlicensed activity and consumer protection failures

On January 5, the Maine Bureau of Consumer Credit Protection (BCCP) announced it has entered into a consent agreement with a virtual currency kiosk operator, resolving its dispute over alleged unlicensed money transmission...more

Katten Muchin Rosenman LLP

State-Level Digital Asset Licensing: What to Watch as We Head Into 2026

California, Louisiana, and Illinois have established comprehensive crypto licensing frameworks that mirror New York’s BitLicense regime. With multiple rulemaking processes now established or soon-to-be adopted and critical...more

Sheppard Mullin Richter & Hampton LLP

Oklahoma Issues Memo Detailing New Digital Asset Kiosk Licensing Requirements

On October 15, the Oklahoma State Banking Department issued a memo detailing new licensing and compliance obligations for digital kiosk operators. The memo details the requirements under Senate Bill 1083, enacted in May under...more

Orrick, Herrington & Sutcliffe LLP

Massachusetts finalizes new money transmission regulation and updates related rules

On October 24, the Massachusetts Division of Banks (DOB) released a comprehensive set of regulatory changes, effective November 7, to align with the commonwealth’s Money Transmission Act (MTA) enacted in January....more

Morrison & Foerster LLP

The Anti-Money Laundering Quarterly

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On July 9, 2025, money-transmission regulators for six states entered a coordinated consent order with Wise US, Inc. following a multistate examination to ascertain Wise’s compliance with applicable state and federal laws and...more

Orrick, Herrington & Sutcliffe LLP

California proposes modifications to digital asset and money transmission regulations

Recently, the California DFPI announced, and requested comment on, proposed modifications to regulations implementing the Digital Financial Assets Law (DFAL) and the California Money Transmission Act (MTA). The revised...more

Stinson LLP

California DFPI Issues Modified Proposed Regulations Implementing the State’s Digital Financial Assets Law

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The California Department of Financial Protection and Innovation (DFPI) has issued modified proposed regulations implementing certain portions of the state’s Digital Financial Assets Law (DFAL) and aimed at clarifying the...more

Troutman Pepper Locke

California’s DFPI Announces Modifications to Digital Financial Asset Regulations

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On September 29, the California Department of Financial Protection and Innovation (DFPI) announced significant modifications to the proposed regulations under the Digital Financial Assets Law (DFAL) and the Money Transmission...more

Sheppard Mullin Richter & Hampton LLP

Georgia and Nebraska Update Money Transmission Statutes

Two states have recently finalized significant updates to their money transmission laws, signaling continued nationwide alignment with the Conference of State Bank Supervisors’ Model Money Transmission Modernization Act...more

Troutman Pepper Locke

CSBS Issues Guidance on Virtual Currency and Tangible Net Worth

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On June 26, the Conference of State Bank Supervisors (CSBS) released new guidance regarding the treatment of virtual currency in the calculation of a licensee’s tangible net worth under the Money Transmission Modernization...more

Venable LLP

California Proposes Licensing Framework for Digital Financial Asset Businesses

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The California Department of Financial Protection and Innovation (DFPI) has released proposed regulations implementing the Digital Financial Assets Law (DFAL), creating a formal licensing regime for businesses engaging in a...more

Orrick, Herrington & Sutcliffe LLP

Arkansas adds crypto kiosk provisions to its money transmission act

On April 14, Arkansas enacted HB 1467 (the “Act”) to amend the Arkansas Uniform Money Services Act to enhance consumer protection and transparency in virtual currency transactions, particularly those through kiosks. The Act...more

Paul Hastings LLP

Daily Financial Regulation Update -- Tuesday, April 8, 2025

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April 4, 2025 - The commissioner of the Department of Financial Protection and Innovation (DFPI) has proposed regulations to implement provisions of the Digital Financial Assets Law and amend the Money Transmission Act....more

Orrick, Herrington & Sutcliffe LLP

Massachusetts enacts a new act on money transmission

Recently, the Governor of Massachusetts signed into law H.4840 creating Chapter 169B: The Money Transmission Act. The Act is designed to regulate money transmission especially through payment apps. The bill repeals...more

Goodwin

Massachusetts Amends State Money Transmission Law to Apply to Domestic Transactions and Stored Value

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On January 1, 2025, Massachusetts Gov. Maura Healey approved House Bill No. 4840, which repeals and replaces Massachusetts’ money transmission law with a revised law (MTL Law), which is based in part on the model Money...more

K&L Gates LLP

Massachusetts Revamps Its Money Transmission Law

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On 2 January 2025, Massachusetts went from being one of the least regulated states for money transmission to becoming one of the more highly regulated states. Formerly, only entities engaging in foreign money transmission...more

Shipkevich PLLC

Massachusetts New Money Transmission Act Set To Broaden Payments Regulation Effective September 2025

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On January 2, 2025, Massachusetts Governor Maura Healey signed the state’s new Money Transmission Act (“MTA” or the “Act”), Bill H4840, into law, introducing more stringent money transmission regulations for transmitters...more

Shipkevich PLLC

Illinois Adopts Model Money Transmission Act in Quest for Money Transmission Regulatory Consistency

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As of August 9, 2024, Illinois joins Maryland, South Dakota, Wisconsin, Kansas, Maine, Vermont, South Carolina, Missouri, and Connecticut as the latest state this year to have enacted legislation or regulations stemming from...more

Cooley LLP

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

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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

Troutman Pepper Locke

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

Morrison & Foerster LLP

All Your Sale Are Belong to Us - Mitigating IP and Payments Risk in In-Game Economies

The digital age has ushered in innovative forms of entertainment and commerce, including through the development of in-game economies. In recent years, the digital landscape of gaming has expanded beyond mere entertainment,...more

Ballard Spahr LLP

Wisconsin and Maine enact Model Money Transmission Modernization Law

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In April 2024, Wisconsin and Maine enacted the Model Money Transmission Modernization Law (“MTML”) to implement the Conference of State Bank Supervisors’ Model Money Transmission Modernization Act.  As of April 22, 2024,...more

McGlinchey Stafford

Pennsylvania Quietly Reinterprets Current Law to Regulate Virtual Currency as “Money” Under the Money Transmitter Act

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In February 2019, the Pennsylvania Department of Banking and Securities (DoBS) issued public guidance on the applicability of the Money Transmitter Act (MTA) to virtual currency exchanges by means of a link entitled “Money...more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - March 2024

Editor's Note The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically...more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - December 2023

Editor's Note - The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency,...more

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