News & Analysis as of

Money Transmitter

Orrick, Herrington & Sutcliffe LLP

Washington, D.C., attorney general files complaint against crypto ATM operator

On September 8, the District of Columbia through its Office of the Attorney General filed a complaint alleging violations of the district’s Consumer Protection Procedures Act, as well as the Abuse, Neglect, and Financial...more

WilmerHale

DOJ Signals Approach to Digital Assets - What It Means for Developers and Platforms

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On August 21, 2025, Acting Assistant Attorney General Matthew R. Galeotti delivered remarks at the American Innovation Project (AIP) Summit in Jackson, Wyoming. Mr. Galeotti’s remarks focused on the digital asset ecosystem...more

Venable LLP

Cryptocurrency Victory Amid a Shifting Political Environment: Lesser Charge Still Brings Important Ramifications for Decentralized...

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On Wednesday, August 6, a Southern District of New York jury found Roman Storm, the founder of Tornado Cash, guilty of conspiracy to operate an unlicensed money-transmitting business in violation of Section 371 of Title 18 of...more

Latham & Watkins LLP

DOJ Official Addresses DeFi Platform Developer Liability Under Money Transmission Statute

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DOJ will focus on criminal intent over mere code creation, seeking to balance legal accountability with support for innovation....more

Ballard Spahr LLP

Tornado Cash Jury Deadlocked on Most Serious Charges, but Convicted Founder Roman Storm on Conspiracy to Operate an Unlicensed...

Ballard Spahr LLP on

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

Venable LLP

CFPB Reviewing International Money Transfer Larger Participant Rule

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The Consumer Financial Protection Bureau (CFPB) is inviting comment on whether the 2014 larger participant rule for international money transfers should be revised to better reflect market conditions and supervisory...more

Holland & Knight LLP

CFPB Seeks Comments on Increased Larger Market Participant Thresholds in 4 Key Markets

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The CFPB published four advanced notices for proposed rulemaking in the Federal Register on Aug. 8, 2025. Each notice seeks comment from experts within the automobile financing, international money transfer, consumer...more

Orrick, Herrington & Sutcliffe LLP

CFPB publishes four ANPRs seeking comment on the definitions of “larger participants” in specific supervised industries

On August 8, the CFPB published four advance notices of proposed rulemaking in the Federal Register seeking public comment to reconsider the test for defining larger participants in the consumer reporting, debt collection,...more

Lowenstein Sandler LLP

Crypto Brief - Lowenstein Crypto Newsletter - August 7, 2025

On August 5, the Securities and Exchange Commission’s (SEC) Division of Corporation Finance (Division) issued a statement clarifying that liquid staking activities do not involve the offer and sale of securities within the...more

Troutman Pepper Locke

Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – July 2025 # 5

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week....more

Sheppard Mullin Richter & Hampton LLP

Connecticut Updates Money Transmission Law to Cover Digital Wallets and Virtual Currency

On June 30, 2025, Connecticut Governor Ned Lamont signed Public Act No. 25-66, enacting broad revisions to Connecticut’s money transmission statutes. The new law, effective October 1, 2025, updates definitions, expands...more

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

Troutman Pepper Locke on

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

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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

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