Massachusetts has passed a bill expanding its money transmitter law to include domestic money transmission. While Massachusetts historically has only regulated entities facilitating money transmission to foreign countries, effective September 2025, the law will now require any person facilitating domestic money transmission for a Massachusetts consumer to maintain a license and comply with certain substantive requirements.
The law, which is based in large part on the Conference of State Bank Supervisors’ Model Money Transmission Modernization Act, applies to any person engaged in “money transmission,” including selling or issuing payment instruments or stored value and receiving money for transmission. Similar to other state money transmitter laws, the law, among other things, will require licensees to maintain liquid assets on deposit to cover outstanding money transmission obligations and to furnish information regarding the licensee’s owners and other control persons to the Massachusetts Division of Banks. The law exempts various persons, including federally insured depository institutions, persons appointed to transmit money as an “agent of the payee,” and persons acting as an agent or service provider to an exempt entity, from these requirements.
With the passage of the Massachusetts law, Montana is now the only remaining state that does not regulate domestic money transmission.
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