On April 17, 2017, Washington Governor Jay Inslee signed into
law an amendment to section 19.230.020 of Washington's Uniform
Money Services Act (the "Act"). The amendment exempts
most third party payment processors from the state's money
transmitter licensing requirements. This amendment is the
legislators' response to an interpretation from the Washington
Department of Financial Institutions ("DFI") determining
that payment processors must be licensed as money transmitters or
receive a waiver from the license requirement.
The Washington House and Senate overwhelmingly approved the
amendment earlier this year after the DFI issued an interpretive
statement in December 2015 concluding that "[p]ayment
processing is money transmission as defined in the Act" and
payment processors must be licensed as money transmitters under the
Act or apply for a license waiver if the payment processor met
certain conditions. In the December 2015 interpretive statement,
the DFI
