Money Transmitter Tip

20 May

checkMany state money transmitter licensing laws expressly state that if you provide money transmission services to persons in that state, no matter where you are located, then you must be licensed as a money transmitter under that state’s law.  For example, Hawaii’s Money Transmitter’s Act states that a company is engaged in providing money transmission in Hawaii if the company provides money transmitter services to persons in Hawaii, even if the company engaged in money transmission has no physical presence in Hawaii.  Similarly, California’s Money Transmission Act covers anyone who transmits money with, to, or from persons located in California.  This means that if your services are open to anyone in the US, including offering the services over the internet (i.e., you do not restrict your services geographically) you could be subject to the money transmitter laws in every applicable state.

Heather Maldegen-Long

Attorney

heamal@jaffelaw.com

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