Sean Ruff, Adam J. Fleisher, and Jennifer S. Talbert
Banking + Financial Services, Financial Institutions + Financial Services, Financial Services Enforcement, Financial Services Litigation, Financial Services, Financial Technology, and Mobile Payments
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 transmission. A number of states have determined that under certain conditions, state money transmission licensing laws do not apply to services provided as an agent of the payee. The most recent states to affirm this are Hawaii and Connecticut.
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