News & Analysis as of

Money Transmitter

Orrick, Herrington & Sutcliffe LLP

Colorado enacts its Money Transmission Modernization Act

On April 16, the Colorado General Assembly enacted HB 25-1201, which repeals the state’s current Money Transmitters Act and replaces it with the Money Transmission Modernization Act (the “Act”), which is based on the model...more

Shipkevich PLLC

California Regulatory Update: DFPI Proposes Rules Regarding Licensing Under Digital Financial Assets Law (DFAL)

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On April 4, 2025, the California Department of Financial Protection and Innovation (“DFPI”) issued a notice of proposed rulemaking to implement portions of the State’s Digital Financial Assets Law (“DFAL”) related to...more

Sheppard Mullin Richter & Hampton LLP

CFPB Drops Remittance Lawsuit against Money Transfer Provider

On April 8, a federal court granted the CFPB’s motion to withdraw from its joint enforcement action against a global money transmitter. The lawsuit, originally filed in April 2022 in partnership with the New York Attorney...more

Sheppard Mullin Richter & Hampton LLP

NYDFS Joins Multistate Action Against Money Transmitter for Financial and Licensing Violations

On March 20, the New York Department of Financial Services (NYDFS) entered into a consent order with a money transmitter, joining a group of state financial regulators acting through a multi-state task force coordinated by...more

Morrison & Foerster LLP

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

As in-game economies evolve, the complexity surrounding virtual goods and services, content creation, and payment structures deepens. As part of this ongoing series on in-game economies, this installment explores issues...more

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: A Debate About The Need, If Any, For a Federal Charter for Non-Banks Engaged in the...

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Our podcast show today features Professor Dan Awrey of Cornell Law School, and Matt Lambert, Deputy General Counsel of the Conference of State Bank Supervisors (“CSBS”) who discuss the pros and cons of Congress enacting a...more

Orrick, Herrington & Sutcliffe LLP

FinCEN requires several southwest counties to report cash transactions over $200

On March 11, FinCEN issued a Geographic Targeting Order (GTO) to combat “illicit activities and money laundering of Mexico-based cartels” along the U.S. southwest border. The order requires money service businesses in select...more

Alston & Bird

FinCEN Issues Geographic Targeting Order for U.S. Southwestern Border

Alston & Bird on

Our Financial Services and White Collar, Government & Internal Investigations Groups unpack the Financial Crimes Enforcement Network’s new geographic targeting order aimed at combatting money laundering and other illegal...more

Buchalter

FinCEN Lowers Reporting Threshold for MSBs Near U.S.-Mexico Border to Combat Money Laundering

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On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) requiring all money services businesses (MSBs) operating within 30 specified ZIP codes near the U.S.-Mexico border...more

Orrick, Herrington & Sutcliffe LLP

Cryptoasset exchange pleads guilty for unlicensed money transmitting

On January 27, DOJ announced a cryptocurrency exchange platform (the platform) pled guilty to operating as an unlicensed money transmitting business and failing to implement adequate AML and know-your-customer (KYC) programs....more

DLA Piper

Recent Settlement Demonstrates DOJ’s Focus on Foreign Entities Misrepresenting Anti-Money Laundering Compliance

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The US Department of Justice (DOJ) has announced that Wall Street Exchange (WSE), a Dubai-based money exchange service provider, entered into a non-prosecution agreement (NPA) and agreed to pay more than $9.2 million to...more

Alston & Bird

The (Bay) State of the Model Money Transmission Modernization Act

Alston & Bird on

Massachusetts has joined the growing list of states that have at least partially adopted the Model Money Transmission Modernization Act. Our Financial Services Group examines the model act, how the Bay State has adopted it,...more

Orrick, Herrington & Sutcliffe LLP

Massachusetts Adopts Law to Regulate Domestic Money Transmission

Massachusetts H4840 requires a license for anyone who transmits money or holds itself out as providing money transmission services, expanding an existing licensing requirement covering only foreign remittance transactions....more

Paul Hastings LLP

State-Level Developments: The Regulatory Landscape for Digital Assets

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As we begin the 119th Congress, the nation is also preparing for the new administration to take office in just a few weeks. While federal action on digital assets remains a key focus, this week’s Crypto Policy Tracker shifts...more

DLA Piper

CFPB Issues New Rule Addressing Supervision of Nonbank Payment Providers

DLA Piper on

The Consumer Financial Protection Bureau (CFPB) has issued a new rule addressing its supervision of large nonbank companies offering US consumers certain digital funds transfer services and payment wallets and apps....more

Troutman Pepper Locke

Understanding the DFPI's Proposed Rules: A Deep Dive Into California's Digital Financial Assets Law — The Crypto Exchange Podcast

Troutman Pepper Locke on

In this special crossover episode of the Payments Pros and Crypto Exchange podcasts, our hosts are joined by colleague Alexandra Steinberg Barrage to discuss California's Department of Financial Protection and Innovation’s...more

Ballard Spahr LLP

Fifth Circuit Rejects OFAC Designation of Tornado Cash Immutable Smart Contracts

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In a closely watched and complicated case, Van Loon et al. v. Dep’t of the Treasury et al., the U.S. Court of Appeals for the Fifth Circuit ruled that the Office of Foreign Assets Control (“OFAC”) cannot sanction Tornado...more

Ankura

Navigating the New Digital Currency Guidelines in Hawaii: Opportunities for Fintech Innovation

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The recent issuance of guidance regarding digital currency activities in Hawaii marks a significant milestone for Fintech companies and startups operating in or considering expansion into the Aloha State. Effective July 1,...more

BakerHostetler

Weekly Blockchain Blog - November 2024 #3

BakerHostetler on

Crypto Exchanges and Stablecoin Issuers Announce Multiple New Products - Multiple crypto sector companies have recently announced new products. In a press release, LayerZero, “an omnichain interoperability protocol that...more

Orrick, Herrington & Sutcliffe LLP

Connecticut Banking Commissioner suspends bitcoin-ATM operator’s money transmitter license

On October 25, the Connecticut Banking Commissioner has suspended a money transmitter’s license, citing several issues: inadequate KYC policies, multiple consumer complaints about fraudulent activity, and insufficient capital...more

Fenwick & West LLP

Crypto Litigation and Enforcement: Q3 2024 - Key Takeaways and Updates

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Civil and criminal litigation heated up this summer in high-profile crypto matters that will affect crypto projects moving forward. For their quarterly crypto lit update, partner David Feder and associates Rebecca...more

McGlinchey Stafford

Podcast: Deep Dive into Understanding Bank Partnerships in Payment Programs [More with McGlinchey, Ep. 73]

McGlinchey Stafford on

In this latest installment of McGlinchey’s Deep Dive into Bank Partnerships Series, attorneys Amy Greenwood-Field, Aaron Kouhoupt, and David Tallman explore the complexities of payment programs involving partnerships between...more

Sheppard Mullin Richter & Hampton LLP

CFPB Revises Disclosure Requirements for Remittance Providers

On September 20, the CFPB announced a proposed rule which would make a minor yet noteworthy amendment to the guidelines for the disclosures that remittance providers are required to provide to consumers in connection with...more

Pillsbury Winthrop Shaw Pittman LLP

Department of Justice Settles with Las Vegas Casino for $130 Million

The settlement is the latest example of the agency’s enhanced criminal enforcement of money transmitting business and international money-laundering laws. The recent settlement is significant both in terms of its amount...more

Orrick, Herrington & Sutcliffe LLP

Wisconsin to add money transmitter license to NMLS

On August 27, the Wisconsin Department of Financial Institutions (DFI) announced it will start accepting applications for a new money transmitter license through NMLS on October 1. The new license will replace the current...more

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