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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

2023

  • Opinion 23-003
    • Licensing requirements for cryptocurrency exchange services through mobile application, as described– November 29, 2023.

  • Opinion 23-001
    • Licensing requirements to offer cryptocurrency over the counter trading services, as described – June 28, 2023.

2022

  • Opinion 22-004
    • Licensing requirements for the purchase and trading of fractional interests in real estate through an online platform, as described – February 21, 2023.

  • Opinion 22-002
    • Licensing requirements for a platform to purchase virtual currency for fiat or sell virtual currency for fiat, as described – November 1, 2022.

2021

  • Opinion 21-008
    • Licensing requirements to provide cash management services to cryptocurrency kiosk operators, as described – April 25, 2022

  • Opinion 21-009
    • Licensing requirements for digital currency trading and custody services and certain liquidity services – March 2, 2022
  • Opinion 21-004
    • Licensing requirements for online platform enabling the creation and sale of digital assets representing interest in physical metals, as described – August 6, 2021
  • Opinion 21-001
    • Licensing requirement for business providing data processing and payment processing services, as described - March 26, 2021

2020

  • Opinion 020-006
    • Licensing requirements for a foreign transmittal agency to issue funds to consumers by paper check, as described  – February 16, 2021
  • Opinion 020-004
    • Licensing requirements for interactive games using distributed ledger technology – November 3, 2020
  • Opinion 020-002
    • Licensing requirements for virtual currency exchange services through a kiosk or website – August 13, 2020
  • Opinion 020-003
    • Does providing the specified services involving virtual currency through a mobile application and website, require a foreign transmittal agency license – May 22, 2020

2019

  • 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

2018

  • 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

2005

  • 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

2001

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

1999

1998

1997

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.

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