On October 13, California Governor Gavin Newsom signed into law
Assembly Bill 39 (AB 39), establishing a
Digital Financial Assets Law (DFAL) set to go into effect July 1,
2025.
Whereas previously the California Department of Financial
Protection and Innovation (DFPI) declined to extend its money
transmission statute to apply to digital asset activities, the new
DFAL establishes a comprehensive licensing and examination regime
that some are likening to the Bitlicense framework New York
pioneered in 2015.
Key Provisions
The DFAL licensure requirement extends to businesses conducting
a "digital financial asset business activity" with or on
behalf of a California resident. "Digital financial asset
business activity" is defined as:
