News & Analysis as of

Money Transmission Act Virtual Currency

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

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

Shipkevich PLLC

Michigan Suspends FTX Lend Money Transmitter License and Orders FTX US License as Expired

Shipkevich PLLC on

On January 10, 2023 by the Michigan Department of Insurance and Financial Services (DIFS), issued an order regarding two companies, West Realm Shires Services, Inc. dba FTX US (“FTX US”) and FTX Lend Inc. Both companies are...more

Sheppard Mullin Richter & Hampton LLP

Blockchain Game Developers and FinCEN: When are State Money Transmission Laws Applicable?

The rising prevalence of crypto and virtual currencies has invited the scrutiny of several regulatory bodies who continue to grapple with the unique challenges posed by blockchain technology, FinCEN being one prime example....more

Ballard Spahr LLP

D.C. Department of Insurance, Securities and Banking issues bulletin on money transmission

Ballard Spahr LLP on

On August 8, 2022, the District of Columbia Department of Insurance, Securities and Banking (the Department”) issued a Bulletin on money transmission (the “Bulletin”). The Department issued the Bulletin to ensure that...more

Sheppard Mullin Richter & Hampton LLP

Connecticut Banking Commission Releases Advisory on Money Transmission

On July 20, 2022, the Connecticut Department of Banking (the “Department”) issued a Consumer and Industry Advisory on Money Transmission (the “Advisory”). The Advisory provides general guidance on what types of activities and...more

Sheppard Mullin Richter & Hampton LLP

DFPI: Virtual Currency Platform is not Money Transmitter

On March 23, the California Department of Financial Protection and Innovation (DFPI) responded to a request for an interpretative legal opinion as to whether the virtual currency services offered by a company require it to...more

Ballard Spahr LLP

DOJ Again Charges Crypto “Mixer” Under the BSA and District of Columbia’s Money Transmitters Act

Ballard Spahr LLP on

In Related Case, Federal Court Holds that Bitcoin-to-Bitcoin “Tumbler” Can Represent “Money Transmission” On April 27, IRS CI and FBI Special Agents arrested Roman Sterlingov, a dual citizen of Russia and Sweden, for his...more

Carlton Fields

State Regulations on Virtual Currency and Blockchain Technologies (Updated March 2021)

Carlton Fields on

Introduction: There exists no uniformity with respect to how businesses that deal in virtual currencies (also known as "cryptocurrencies") such as Bitcoin are treated among the states. For these proprietors, often the first...more

Fox Rothschild LLP

Uniform Money Transmitting Rules May Make It Easier For The Cryptocurrency Business

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Money service businesses received a reprieve last week that will make cryptocurrency firms very happy since they will be able to more easily expand across the United States. The Conference of State Bank Supervisors (“CSBS”) –...more

Morrison & Foerster LLP

Bitcoin Is “Money” For Purposes Of D.C. Money Transmission Law, Says Federal Court

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

Allen Matkins

Will California License Virtual Currency Issuers?

Allen Matkins on

The California Department of Business Oversight regulates the money transmission business pursuant to the Money Transmission Act, Cal. Fin. Code § 2000 et seq. The Act currently defines "money transmission" as any of the...more

Manatt, Phelps & Phillips, LLP

Pennsylvania Joins Other States With Guidance on Virtual Currency

Is virtual currency “money” for purposes of the Pennsylvania Money Transmitter Act? Not according to recently issued guidance from the Pennsylvania Department of Banking and Securities (DoBS), which has joined a growing...more

Ballard Spahr LLP

PA Department of Banking and Securities: Virtual Currency is not “Money”

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Typical Virtual Currency Exchanges Do Not Require PA Money Transmitter Licenses - The Pennsylvania Department of Banking and Securities (“DoBS”) just released Guidance declaring that virtual currency, “including Bitcoin,”...more

Shumaker, Loop & Kendrick, LLP

Internet Startups: Beware of Being a Money Transmitter

So, you’ve got a great idea. Social media platforms are all about finding new solutions for old inefficiencies. And what’s more efficient than serving as a platform for an account holder to obtain a single cash payment in...more

Perkins Coie

Admin Rulings: FinCEN Clarifies Money Transmitter Exemptions for Virtual Currency and Payment-Related Services

Perkins Coie on

On April 29, 2014, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a series of administrative rulings determining whether five different companies constitute money services...more

Allen Matkins

DBO Issues Guidance Regarding Virtual Currencies And Asks For Comments On Proposed Money Transmission Rules

Allen Matkins on

Yesterday, the Department of Business Oversight issued this cautionary guidance for consumers regarding virtual currencies. However, amidst the warnings, the Department disclosed that “California has been working with...more

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