News & Analysis as of July 19, 2025

Money Transmission Act

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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 -

CSBS Issues Guidance on Virtual Currency and Tangible Net Worth

Troutman Pepper Locke on 7/9/2025

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

Michigan Suspends FTX Lend Money Transmitter License and Orders FTX US License as Expired

Shipkevich PLLC on 1/18/2023

On January 10, 2023 by the Michigan Department of Insurance and Financial Services (DIFS), issued an order regarding two companies, West Realm Shires Services, Inc. dba FTX US (“FTX US”) and FTX Lend Inc. Both companies are...more

D.C. Department of Insurance, Securities and Banking issues bulletin on money transmission

Ballard Spahr LLP on 8/26/2022

On August 8, 2022, the District of Columbia Department of Insurance, Securities and Banking (the Department”) issued a Bulletin on money transmission (the “Bulletin”). The Department issued the Bulletin to ensure that...more

DFPI: Virtual Currency Platform is not Money Transmitter

Sheppard Mullin Richter & Hampton LLP on 4/20/2022

On March 23, the California Department of Financial Protection and Innovation (DFPI) responded to a request for an interpretative legal opinion as to whether the virtual currency services offered by a company require it to...more

State Regulations on Virtual Currency and Blockchain Technologies (Updated March 2021)

Carlton Fields on 4/19/2021

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

Bitcoin Is “Money” For Purposes Of D.C. Money Transmission Law, Says Federal Court

Morrison & Foerster LLP on 8/17/2020

A recent federal district court ruling in a criminal anti-money laundering case suggests that the transmission of virtual currency on behalf of another person requires a state money transmission license—even if the state’s...more

Will California License Virtual Currency Issuers?

Allen Matkins on 2/12/2020

The California Department of Business Oversight regulates the money transmission business pursuant to the Money Transmission Act, Cal. Fin. Code § 2000 et seq. The Act currently defines "money transmission" as any of the...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

Internet Startups: Beware of Being a Money Transmitter

Shumaker, Loop & Kendrick, LLP on 11/3/2014

So, you’ve got a great idea. Social media platforms are all about finding new solutions for old inefficiencies. And what’s more efficient than serving as a platform for an account holder to obtain a single cash payment in...more

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