Montana Pump Fakes A Requirement For Money Transmitters

Against a backdrop of near-daily enforcement actions and constant regulatory changes, Montana inched into the fray by publishing a letter calling on money transmitters to make a submission to the Montana Department of Banking of Administration, Banking & Financial Institutions (the Department). The Department posted the letter requiring a submission, but that letter was withdrawn shortly thereafter.

IN DEPTH

Cryptocurrency exchanges and other crypto companies are most frequently registered and regulated as federal money service businesses (MSBs) and state money transmitters (MTLs), which requires seeking licensure for most state banking departments across the country. This requires an analysis of each state's money transmitter laws, which usually turns on the definition of "money" to determine whether crypto exchanges and related business models need to obtain licensure. These licensing obligations can be found in state statutes, administrative