News & Analysis as of May 19, 2025

Money Transmitter

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Virtual Currency (aka Digital Currency or Digital Money) is a type of currency or medium of exchange that is not issued by any government nor guaranteed by a government currency. Despite lacking legal tender status, Virtual Currency is still traded and exchanged in some environments, typically online environments or communities. Bitcoin is the most well-known form of Virtual Currency. less -

United States: The Continuing Shift to Modern Money Transmission Laws

K&L Gates LLP on 5/13/2025

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

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

Alston & Bird on 1/22/2025

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

Louisiana Adopts Virtual Currency License

Shipkevich PLLC on 1/18/2023

Louisiana has become the first state to follow New York's lead in issuing a crypto-specific license, accepting Louisiana Virtual Currency Business Activity (VCBA) license applications as of January 1, 2023. All entities...more

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

Orrick - On the Chain on 12/4/2019

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

FinCEN – We Will Identify Where Compliance Is Not Taking Place And Take Appropriate Action

Sheppard Mullin Richter & Hampton LLP on 5/15/2019

Last week we reported that FinCEN had issued new guidance addressing cryptocurrency and other convertible virtual currency. The need for compliance was reinforced this week. In a speech by Sigal Mandelker, Under Secretary for...more

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

Ballard Spahr LLP on 1/25/2019

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

Blockchain Week in Review - January 2019 #3

Perkins Coie on 1/24/2019

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

State Regulations on Virtual Currency and Blockchain Technologies (Updated)

Carlton Fields on 1/9/2019

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

Retaining North Carolina's Booming Virtual Currency Industry

Ward and Smith, P.A. on 6/27/2018

North Carolina rightfully regards itself as a leader in innovation and as a hub for technology—it hosts Research Triangle Park and world-renowned universities, and according to the NCTech’s 2018 State of Technology Industry...more

FinCEN Is Watching ICOs for BSA Violations

Perkins Coie on 3/14/2018

In a recently published letter to the Senate Finance Committee, FinCEN confirmed that when an ICO token is a “convertible virtual currency,” administrators or exchangers of the token would be “money transmitters” under...more

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