Massachusetts
Massachusetts’s regulation of money transmission is only money transmission to foreign countries. See209 CMR 45.02; Mass.gov, “Apply for aMoney Transmitter License“ .
In a 2020 opinion letter, the Massachusetts Department of Banking found that transactions where fiat currency was exchanged for virtual currency between two parties across international borders, without more, was not money transmission requiring licensure. SeeDivision of Banks, Opinion 19-008(Jan. 17, 2020). A digital wallet service was also found, on its facts, not to require a license. SeeDivision of Banks, Opinion 20-003(May 22, 2020).
Selected Department of Banking opinion letters on virtual currency can be foundon the Department’s website.
