As we enter 2020, the payments and money transmission regulatory landscape continues to evolve on a state-by-state basis. Newly adopted regulations in Massachusetts affirm that “agent of a payee” transactions meeting certain criteria, as well as funds transfer services provided to business customers, are not subject to regulation under the state’s money transmission law. Additionally, Rhode Island’s updated money transmission licensing law took effect on January 1st. While it does not provide for an express agent of a payee exemption, it excludes funds transfer services provided to business customers.
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