Virtual Currency Regulations: Key Insights for the Payments Industry — Payments Pros – The Payments Law Podcast
Navigating New Compliance Challenges: The Impact of the Money Transmitter Modernization Act on Payroll Processing - Payments Pros – The Payments Law Podcast
On August 6th, 2025, following a four-week trial, a jury found Roman Storm, the founder of a crypto mixing service called Tornado Cash, guilty of conspiracy to operate an unlicensed money transmitting business. The jury was...more
When regulators propose a new rule, financial institutions can often find themselves pushed into a reactionary position, left to deal with consequences that rule makers may not have foreseen. Once a rule hits the books, legal...more
We continue our series on the legal and regulatory challenges facing individual coverage health reimbursement arrangements (ICHRAs); this time, we are focusing on the fintech-related requirements that may apply to ICHRA...more
In March, we wrote about the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issuing a Geographic Targeting Order (GTO) aimed to combat Mexican-based drug cartels. The GTO signals Treasury’s efforts to...more
On March 14, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) in the Federal Register that will impose new obligations on many money services...more
In the latest episode of Payments Pros, hosts Keith Barnett and Carlin McCrory discuss the latest FinCEN and OFAC guidance on virtual currency transactions, specifically tailored for companies in the payments industry. They...more
We have written previously about the new administration’s significant shifts in its approach to criminal enforcement and prosecution of money laundering cases. Specifically, we wrote about shifts at the U.S. Department of...more
In the dynamic landscape of financial services, the Nationwide Multistate Licensing System (NMLS) has emerged as a cornerstone for regulation and compliance. Serving as an online platform, NMLS facilitates the state license...more
On November 14, the CFPB issued a consent order and stipulation against a company and its subsidiaries for allegedly engaging in unfair and abusive practices related to its money-transfer services used by the friends and...more
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
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
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
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
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
On February 15, Senators Sherrod Brown (D-OH), Jack Reed (D-RI) and Elizabeth Warren (D-MA) sent a letter to Zelle seeking clarification of its reimbursement policy for victims of imposter scams. Calling its protocol for...more
On February 15, 2024, Senators Sherrod Brown (D-OH), Jack Reed (D-RI) and Elizabeth Warren (D-MA) sent a letter to Zelle seeking clarification of its reimbursement policy for victims of imposter scams and urging Zelle to...more
Decentralized Finance (DeFi) is an umbrella term used to describe financial services provided outside of the traditional markets, that rely on blockchain technologies to create innovative products instead of relying on...more
• Highlights of recent joint agency guidance on Third-Party Risk Management (3PRM) • How 3PRM considerations have increased in importance in BSA/AML compliance programs and enforcement actions • Lessons learned from...more
Among the many state licenses that can impact financial services companies, money transmitter licensing can be among the harder to figure out. In addition to uncertainties about digital currency and developing technologies,...more
The next item in McGlinchey's Deep Dive into Payments Series is a podcast on money transmission by attorneys Jeff Barringer, Amy Greenwood-Field, and Aaron Kouhoupt. Their discussion centers around the impacts of money...more
The next item in McGlinchey’s Deep Dive into Payments Series is on money transmission by attorneys Jeff Barringer, Amy Greenwood-Field, and Aaron Kouhoupt. Their discussion centers around the impacts of money transmission...more
The Act aims to modernize and streamline state regulation of money transmitters while promoting innovation and consumer protection. More than a dozen US states have enacted the Money Transmission Modernization Act (MTMA)...more
While all states except Montana currently require licensure at the state level for entities seeking to act as a money transmitter, generally defined as an intermediary receiving money or monetary value for transmission to...more
The CFPB's latest regulatory agenda signals that it is considering rules to define larger participants in markets for consumer payments, to be published in July 2023. This action, if implemented, would represent a sea change...more
The Iowa governor recently signed HF 675 to revise certain provisions of the Uniform Money Transmission Modernization Act. The Act is designed to eliminate unnecessary regulatory burden and harmonize the licensing and...more