Louisiana's Virtual Currency Licensing Law Taking Effect (Finally)

In August 2020, Louisiana adopted the Virtual Currency Businesses Act (VCBA) to regulate virtual currency activity in the state. In doing so, it joined New York as only the second US state to establish a stand-alone payments regulatory regime for virtual currency activities, although other states that have expressly addressed the regulation of virtual currency have generally done so through their existing money transmission laws.

The implementation of the Louisiana law was pending the promulgation of final regulations by the state's financial regulator, the Office of Financial Institutions (OFI). Those regulations were formally adopted through an emergency rule last month. As a result, Louisiana's virtual currency regulatory scheme finally takes effect on January 1, 2023, and applications for licensure are supposed to be available through the Nationwide Multistate Licensing System (NMLS) as of that date. A license or other equivalent permission is required for a