News & Analysis as of

Money Transmitter

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

Troutman Pepper

2024 State Legislative Review: Key Payment Laws and Their Impacts — Payments Pros – The Payments Law Podcast

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In this episode of Payments Pros, host Keith Barnett reviews state legislative actions in 2024 related to payments, focusing on the Money Transmission Modernization Act (MTMA), earned wage access (EWA), and peer-to-peer...more

Orrick, Herrington & Sutcliffe LLP

New Hampshire enacts a new money transmission law

On August 23, New Hampshire Governor Chris Sununu signed HB 1241 (the “Act”) into law, creating new money transmitter licensing requirements, and adjusting renewal procedures for certain consumer credit entities. The Act...more

Orrick, Herrington & Sutcliffe LLP

Illinois enacts the Uniform Money Transmission Modernization Act

On August 9, the Governor of Illinois signed SB 3412 (the “Act”) into law, creating a new regulatory framework for money transmission. This Act, named the Uniform Money Transmission Modernization Act, replaces the previous...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

Wilson Sonsini Goodrich & Rosati

Pending Changes to Anti-Money Laundering Program Requirements for MSBs and Other Financial Institutions

Money services businesses (MSBs), a category which includes money transmitters (e.g., PayPal and other payment facilitators), as well as administrators and exchangers of convertible virtual currencies (e.g., Bitcoin...more

Orrick, Herrington & Sutcliffe LLP

MSB Call Report updates effective for Q3 reporting

Recently, NMLS announced updates to the Money Services Business (MSB) Call Report effective in the third quarter for filings due November 14. These updates aim to align the report with the Model Money Transmission...more

Orrick, Herrington & Sutcliffe LLP

Missouri updates its money transmission statute in new act

On July 11, the Governor of Missouri signed into law SB 1359 (the “Act”) to modify provisions relating to financial institutions. The Act included the Money Transmission Modernization Act of 2024, which was intended to help...more

Troutman Pepper

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

BakerHostetler

Weekly Blockchain Blog - June 2024 #3

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EigenLayer TVL Surpasses $20B; New Self-Custodial Wallet Features Launch - According to recent reports, the total value locked (TVL) on the Ethereum network-based EigenLayer restaking protocol recently surpassed $20...more

Orrick, Herrington & Sutcliffe LLP

Connecticut amends its Money Transmission Act

On June 6, Connecticut enacted HB 5211 (the “Act”), amending laws regulating virtual currency and money transmission. The Act updated "permissible investment" to include additional forms of assets and clarified that “cash”...more

Orrick, Herrington & Sutcliffe LLP

Colorado extends its money transmitter regulations

On June 3, Colorado enacted HB 1328, (the “Act”), which will extend the state’s regulation of money transmitters until September 2030. The law had previously been scheduled to sunset on September 1. The Act will implement the...more

Hudson Cook, LLP

Feeding the Loot Box Monster: The CFPB's Concerns with Payment Transmission in Gaming

Hudson Cook, LLP on

On May 9, 2024, we published our first article in a series of articles on the CFPB's interest in gaming. Back on April 4, 2024, the Consumer Financial Protection Bureau ("CFPB") issued a report identifying various risks to...more

Ballard Spahr LLP

PA Department of Banking and Securities: Virtual Currency is “Money”

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On April 20, 2024, the Pennsylvania Department of Banking and Securities (“DoBS”) issued a policy statement (“Policy Statement”) to “clarify” that the Department’s interpretation of the term “money” in the Pennsylvania Money...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

Hudson Cook, LLP

"OVER THE LINE!"  Where Banking and Gaming Intersect, the CFPB Has Something to Say.

Hudson Cook, LLP on

The line between virtual and reality is getting thinner. Gamers pay gaming companies real currency for virtual in-game currency to buy skins, create the world they want to live in (virtually), or purchase loot that aid in...more

Orrick, Herrington & Sutcliffe LLP

Maine enacts new money transmission law in line with the Money Transmission Modernization Act

On April 22, the Governor of Maine signed into law LD 2112 (the “Act”) which will codify a new law titled the “Maine Money Transmission Modernization Act.” The Act will amend and repeal many parts of the state’s money...more

Goodwin

Significant State Regulatory Development in the Virtual Currency Industry in California and New York

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California enacted its own version of New York’s “BitLicense” law, the Digital Financial Assets Law (DFAL), becoming one of the first US states to implement a virtual currency-specific regulatory regime. ...more

Orrick, Herrington & Sutcliffe LLP

Iowa enacts new money transmission provisions

On April 10, Iowa’s governor signed into law HF 2262 (the “Act”) relating to money transmission services. The Act will exempt a person appointed as an agent of a payor for purposes of providing payroll processing services...more

Orrick, Herrington & Sutcliffe LLP

Arizona enacts new money transmission requirements for licensees

On April 8, the Governor of Arizona signed into law SB 1034 which will amend money transmission requirements for licensees. The new law will require a licensee, before transmitting any money (either in person or...more

Stinson LLP

Wisconsin Adopts Model Money Transmission Modernization Act, Joining 19 Other States

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On April 4, 2024, the State of Wisconsin enacted S.B. 668 (the Act), repealing the state’s existing Seller of Checks Act, which solely regulated money transmitters with a physical presence in Wisconsin, and replacing the...more

Latham & Watkins LLP

WisdomTree Granted New York Limited Purpose Trust Company Charter

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As federal regulation remains patchy, firms may want to consider a New York state charter as a potential avenue to expand digital asset offerings in a compliant manner. On March 22, 2024, WisdomTree, Inc., a global asset...more

Ballard Spahr LLP

KuCoin and Founders Charged with Operating Illegally as Money Transmitter and Futures Commission Merchant

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Last week, the United States Attorney’s Office for the Southern District of New York unsealed an indictment against global cryptocurrency exchange KuCoin and two of its founders, Chun Gan and Ke Tang, for allegedly conspiring...more

Troutman Pepper

Sigue Corporation Ordered to Cease and Desist Operations

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On March 22, a group of 39 states, Puerto Rico, and the District of Columbia (participating states) entered an interim consent order against Sigue Corporation, a licensed money transmitter corporation, ordering it to cease...more

Sheppard Mullin Richter & Hampton LLP

CFPB Issues Guidance on Deceptive Practices by Remittance Transfer Providers

On March 27, the CFPB issued Circular 2024-02, which warns that remittance providers may be liable under the CFPA for certain deceptive marketing practices related to the speed or cost of sending a remittance transfer. Under...more

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