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Selected Opinions of the Division of Banks related to foreign transmittal agencies

Through these opinions, the Division of Banks offers perspective on current issues and questions specific to foreign transmittal agencies.

Table of Contents


  • Opinion 19-005
    • Does providing the specified products and services, as described, require a foreign transmittal agency license – September 26, 2019
  • Opinion 19-004
    • Do payment processing services using the ACH network, as described, require a foreign transmittal agency license - August 13, 2019


  • Opinion 18-003
    • DOB licensure requirement for activities, as described, for purchase, sale and exchange of virtual currency –June 14, 2018
  • Opinion 18-002
    • DOB licensure requirement for business activities involving the sale of cryptocurrency, as described – March 9, 2018


  • Selected Opinion 05-021
    • Is a license required to transmit commercial funds solicited by telephone or personal contact from outside the commonwealth - July 18, 2005


  • Selected Opinion 01-103
    • Do credit unions need a license to have foreign transmittals done by licensed entity - August 16, 2001




Past opinions of the DOB

You can get copies of past opinions by submitting a Public Records Request to the DOB's Record Access Officer.

The DOB's Regulations, found in the Code of Massachusetts Regulations (CMR - agency code number 209), are available through the State House Bookstore.