News & Analysis as of

Money Transmitter State and Local Government

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

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

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

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

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