News & Analysis as of

Money Transmitter

Orrick, Herrington & Sutcliffe LLP

Connecticut amends its money transmission licensing laws

On June 30, the governor of Connecticut signed into law HB 7042 to amend various provisions to its money transmission statutes, state payments and investments in virtual currency, and minors’ money sharing application...more

Orrick, Herrington & Sutcliffe LLP

California and other state regulators fine money transmitter $4.2M for BSA/AML violations

On July 9, the California DFPI, alone and joining five other state financial regulatory agencies, announced a multistate enforcement action resulting in a $4.2 million penalty against a licensed money transmitter for alleged...more

Wilson Sonsini Goodrich & Rosati

Association of State Financial Regulators Issues Guidance on Virtual Currency for Licensed Money Transmitters

Recognizing the evolving landscape of digital finance, the Conference of State Bank Supervisors (CSBS), an association of state financial regulators, issued advisory guidance on the treatment of virtual currency held on a...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

Orrick, Herrington & Sutcliffe LLP

State bank supervision group releases money transmission guidance

Recently, an association of state bank supervisors issued new guidance to clarify how money transmitters must calculate tangible net worth under the model legislation known as the Money Transmission Modernization Act (MTMA),...more

Cozen O'Connor

Stablecoins: Navigating the Money Transmitter Minefield & Forthcoming Federal Regulatory Frameworks

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As digital assets gain traction across financial markets, stablecoins—cryptocurrencies pegged to fiat currencies like the U.S. dollar—are emerging as a practical medium for capital contributions, settlements, and liquidity...more

Goodwin

NY Attorney General Announces $250,000 Settlement with Money Transfer Provider

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On June 16, 2025, the New York Attorney General announced it had entered into a stipulated final judgment to settle its suit against ​a non-bank money transfer provider over alleged violations of federal and state consumer...more

Orrick, Herrington & Sutcliffe LLP

Florida revises its code on financial services and money transmitters

On June 13, the governor of Florida signed HB 1549 and approved amendments to the state’s financial institutions codes and money services business chapter. For financial services, the act (i) changes the due dates for...more

Buchalter

New Colorado Money Transmission Act Parallels Key Provisions of CSBS Money Transmission Modernization Act

Buchalter on

Colorado has adopted a new Money Transmission Modernization Act (“Act”), replacing the old Colorado Money Transmitters Act...more

Sheppard Mullin Richter & Hampton LLP

New York AG Secures $250,000 Settlement With Money Transmitter Over Remittance Rule Violations

On June 13, Judge Katherine Polk Failla of the U.S. District Court for the Southern District of New York entered a stipulated final judgement resolving claims brought by the New York Attorney General against a global money...more

Brownstein Hyatt Farber Schreck

Colorado Enacts the Model Money Transmission Act

On April 18, 2025, Colorado enacted the Model Money Transmission Modernization Act (MTMA) (HB 25-1201), which repeals and replaces the state’s previous Money Transmitters Act. The law updates standards for the licensing,...more

Ankura

An Update on the CSBS Money Transmission Modernization Act (MTMA)

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The financial landscape is rapidly evolving, with digital payment solutions becoming increasingly integral to both consumers and businesses. Amidst this shift, the Money Transmission Modernization Act (MTMA) emerged as a...more

K&L Gates LLP

United States: The Continuing Shift to Modern Money Transmission Laws

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Within the past two months, three states have adopted the Money Transmission Modernization Act (MTMA). The governors of Virginia, Mississippi, and most recently Colorado, signed bills that implement the MTMA, and two other...more

Sheppard Mullin Richter & Hampton LLP

Colorado Overhauls Money Transmission Law to Align with Multistate Licensing Standards 

On April 16, the Colorado General Assembly enacted House Bill 25-1201, replacing the state’s prior money transmitter law with the Money Transmission Modernization Act (the “Act”). Modeled on the multistate framework developed...more

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)

Shipkevich PLLC on

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

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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

DLA Piper on

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

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