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On June 9, Louisiana Governor Jeff Landry signed House Bill 1230, enacting the Louisiana Money Transmission Act. Effective July 1, 2026, the Act replaces Louisiana’s Sale of Checks and Money Transmission Act with a comprehensive framework governing the licensing, supervision, and regulation of money transmitters operating in the state.
The legislation largely adopts the Conference of State Bank Supervisors' Model Money Transmission Modernization Act and aligns Louisiana's regulatory framework with those adopted in numerous other states. The Act expands the Office of Financial Institutions' supervisory authority, establishes uniform licensing standards, and imposes new operational and financial responsibility requirements on licensed money transmitters. Specifically, the Act:
- Modernizes the licensing process. Money transmitters will use NMLS for licensing, renewals, reporting, background checks, fee processing, and examinations, giving the Office of Financial Institutions a more centralized process for overseeing licensed activity.
- Adds ongoing reporting and compliance obligations. Licensees must submit quarterly call reports, annual audited financial statements, and authorized-agent reports, while also maintaining records for at least five years and filing required reports under the Bank Secrecy Act and other anti-money laundering laws.
- Updates financial responsibility standards. Licensees must maintain minimum tangible net worth, surety bonds, and permissible investments tied to outstanding money transmission obligations, with those requirements designed to protect customer funds if a licensee experiences financial distress.
- Expands oversight of authorized agents. Before conducting business through an authorized agent, licensees must adopt written policies and procedures, enter into a written contract, and conduct a risk-based background review to assess whether the agent is likely to comply with applicable law.
- Strengthens enforcement tools. The commissioner may suspend or revoke licenses, issue cease-and-desist orders, assess civil money penalties, seek injunctions, and take action against unlicensed money transmission activity.
The Act also includes transition provisions for existing licensees. Current licensees generally are not subject to conflicting or newly imposed requirements until they renew their current license or twelve months after the Act's effective date, whichever occurs later.
Putting It Into Practice: Louisiana joins a growing number of states that have adopted legislation modeled on the Conference of State Bank Supervisors' Model Money Transmission Modernization Act (previously discussed here, here, and here). Companies engaged in money transmission should evaluate how the Act's revised licensing, reporting, financial responsibility, and authorized-agent requirements affect their operations and update compliance programs before the applicable transition period expires.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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