News & Analysis as of

State and Local Government Money Transmitter

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)

Ankura on

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

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

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

Paul Hastings LLP

State-Level Developments: The Regulatory Landscape for Digital Assets

Paul Hastings LLP on

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

Orrick, Herrington & Sutcliffe LLP

Maryland finalizes money transmitter regulation; adds agent of the payee exemption

On November 17, the Maryland Commissioner of Financial Regulation recently adopted edits to proposed regulations, Code Md. Code Regs. 09.03.14.01, .03-.18, bringing Maryland generally in alignment with the CSBS Money...more

Orrick, Herrington & Sutcliffe LLP

Hawaii amends money transmitter provisions

On July 3, the Hawaii governor signed HB 1027 (the “Act”) into law, amending several provisions relating to the Money Transmitters Modernization Act. The Act adds and amends several definitions. Changes include defining...more

Sheppard Mullin Richter & Hampton LLP

Money Transmission Licenses Required for Virtual Currency Activities in Arkansas and Florida

Recently Florida and Arkansas made it a requirement for those engaging in virtual currency activities to obtain money transmission licenses in their respective jurisdictions. - In August, the Florida Office of Financial...more

Woods Rogers

How does El Salvador’s Bitcoin Law Impact U.S.-based Virtual Currency Exchanges?

Woods Rogers on

In our recent article on the legal framework governing virtual currencies, we briefly discussed the distinction between money transmitters and virtual currency exchanges.  In short, transmitters are entities that convert fiat...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

Morrison & Foerster LLP

Are You A Money Transmitter In South Dakota? In Delaware?

One of the defining aspects of the payments revolution of the past few years—at least from a regulatory perspective—has been the question of whether a particular payments service is subject to regulation as money...more

Orrick - On the Chain

Wyoming, the “Equality State,” Seeks to Level the Playing Field for Digital Assets Businesses

Orrick - On the Chain on

In its continued effort to establish itself as the go-to jurisdiction for digital asset businesses, Wyoming, through its Department of Audit, Division of Banking, recently published a digital asset custody regime for its...more

Alston & Bird

Rhode Island Requires Licensure for Virtual Currency Business Activity

Alston & Bird on

A&B Abstract: Effective January 1, 2020, Rhode Island will regulate virtual currency under its money transmission laws....more

Carlton Fields

State Regulations on Virtual Currency and Blockchain Technologies - (Updated)

Carlton Fields on

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 question asked...more

Ballard Spahr LLP

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

Ballard Spahr LLP on

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

Perkins Coie

Blockchain Week in Review - January 2019 #3

Perkins Coie on

U.S. Developments - Flood of State Virtual Currency Legislation - Since the start of the new year there have been roughly nine virtual currency bills introduced or passed in four different states. Overall, the bills...more

Carlton Fields

State Regulations on Virtual Currency and Blockchain Technologies (Updated)

Carlton Fields on

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....more

Ballard Spahr LLP

Significant changes to Connecticut consumer finance licensing laws to take effect October 1, 2018

Ballard Spahr LLP on

Significant changes to Connecticut’s licensing laws for consumer financial services providers will take effect on October 1, 2018.  In addition to changes impacting mortgage-related licensees (e.g. mortgage lenders,...more

Robinson+Cole Data Privacy + Security Insider

Wyoming Enacts Comprehensive Blockchain Legislation

As numerous states propose and enact legislation focused on blockchain technology and cryptocurrencies, in 2018, no state has been more aggressive in this space than Wyoming. ...more

Ballard Spahr LLP

State Regulators Agree to Multistate Licensing Process for Money Service Businesses

Ballard Spahr LLP on

The Conference of State Bank Supervisors (CSBS) announced last week that seven states have agreed to a multi-state compact that, according to the CSBS, “standardizes key elements of the licensing process for money services...more

Carlton Fields

State Regulations On Virtual Currency And Blockchain Technologies

Carlton Fields on

As of this inaugural publication, 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...more

Perkins Coie

Blockchain Week in Review – April 2017 #3

Perkins Coie on

Below is a summary of some of the significant legal and regulatory actions that occurred over the past week. This alert is not intended to be a comprehensive list of all such developments, but rather a selection of...more

Davis Wright Tremaine LLP

New Mexico To Regulate Money Transmission

The number of states that do not regulate money transmitters grows ever smaller as New Mexico recently enacted the New Mexico Uniform Money Services Act. Prior to the enactment, New Mexico only regulated issuers and sellers...more

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