"Pennsylvania Money Transmitter Act Amendments" — DoBS letter on Act 7 of 2025 and rescission of the Virtual Currency Statement of Policy

Bitcoin Research — Law, Regulation, Markets & Origins (2026)

States

Pa

2025-08-12

Download PDF 📷 View Wayback snapshot (2025-08-12) ↗ Live URL (may be dead)

Document text

Research, not advice. Part of the Bitcoin research archive (October 2026). Claims labelled unverified, contested or fringe are reported, not endorsed; statuses of bills and rules are as of the date checked. Government, court and patent records are public domain; the research notes are CC BY 4.0.

Pennsylvania Money Transmitter Act Amendments

Act 7 was signed into law on June 27, 2025 and amends the Money Transmission Business
Licensing Law, also known as the Money Transmitter Act (“MTA”) or Act 249. Act 7 makes
several amendments to the MTA and should be reviewed thoroughly.

A substantial amendment is found in Section 2(a)(2) which states:

 Section 2. License Required.—
  (a) No person shall:
    (2) Engage in the business of transmitting virtual currency by means of a transmittal
    instrument for a fee or other consideration with or on behalf of an individual without first
    having obtained a license from the department.

The Department of Banking and Securities (“Department”) previously published a Virtual
Currency Statement of Policy (“VCSOP”) on April 20, 2024. The VCSOP became effective on
October 15, 2024. The VCSOP provided that “For purposes of this chapter, the Department
interprets the definition of ''money'' to include virtual currency, such as Bitcoin.”

All persons that were engaged in the business of transmitting virtual currency by means of a
transmittal instrument for a fee or other consideration with or on behalf of an individual were
required to apply for a license or cease unlicensed activity as of October 15, 2024. There will be
no grace period for licensure when the Act 7 amendments become effective on August 26, 2025,
and concurrently the VCSOP will be rescinded.

The Department does not provide licensing determinations, nor does it provide legal advice. The
Department encourages you to engage legal counsel in all aspects of compliance, including but
not limited to, license determination, license application, compliance management systems,
compliance examinations, etc.

It is critical that the entire Money Transmission and Virtual Currency Transmission Business
Licensing Law, Regulation, and all applicable federal statutes are reviewed:
          • Money Transmission and Virtual Currency Transmission Business Licensing Law
          • Money Transmitter Act Regulation
              • NMLS is used to apply, renew, and manage Pennsylvania’s MTA licenses.
                      o Pennsylvania’s resource page on NMLS
                      o Pennsylvania’s Money Transmitter Application Checklist can be found on
                          the NMLS Checklist Compiler under New Application, PA, Company,
                          then Money Transmitter License.

Questions related to the Licensing process not addressed above can be sent by email to the
Licensing office at [email protected].