On June 9, 2026, Louisiana enacted House Bill 1230 (HB 1230), the Louisiana Money Transmission Act, which replaces the Louisiana Sale of Checks Act with a new licensing regime and regulatory framework for money transmitters operating in the state. HB 1230 largely adopts the Conference of State Bank Supervisors’ Model Money Transmission Modernization Act (MMTMA).

HB 1230 took effect on July 1, 2026. Existing money transmission licensees (licensed under the Sale of Checks Act) will not be subject to new or conflicting requirements of HB 1230 until license renewal or 12 months from the statute’s effective date, whichever is later.

Scope of Louisiana’s HB 1230

HB 1230 requires licensure for — and imposes operational requirements on — companies that engage in or hold themselves out as engaging in “money transmission” in Louisiana. The statute defines “money transmission” to include selling or issuing payment instruments or stored value, or receiving money or monetary value for transmission, from a person located in Louisiana. HB 1230, like the Sale of Checks Act before it, tasks the Louisiana Office of Financial Institutions with issuing money transmission licenses and supervising licensees.

Key Requirements

In addition to licensing, HB 1230 imposes several notable operational requirements on regulated entities:

  • NMLS Licensing Administration. Licensing applications, reporting, examinations, and certain background-check functions will be administered through the Nationwide Multistate Licensing System (NMLS).
  • Reporting and Record Retention. Licensees must provide periodic financial and operational reports, including quarterly filings and annual audited financial statements, to the Louisiana Office of Financial Institutions. Licensees must also comply with record-retention requirements outlined in the federal Bank Secrecy Act, 31 U.S.C. 5311, et. seq., and other anti-money laundering laws.
  • Financial Safeguards. The law establishes minimum financial responsibility requirements, including tangible net worth standards, maintenance of a surety bond, and requirements regarding permissible investments.
  • Authorized Agent Controls. Companies operating through authorized agents must conduct reasonable due diligence into the agent’s history, enter into a written agreement with the agent, and establish policies and procedures to help ensure agent compliance with applicable federal and state laws.

Takeaways for Businesses

By enacting HB 1230, Louisiana joins more than 30 states that have adopted MMTMA, at least in part, in an effort to promote greater consistency in money transmitter regulation at the state level. While companies that already comply with MMTMA-based laws in other states may find some of HB 1230’s concepts familiar, the requirements of the new Louisiana law should be carefully reviewed. ExistingLouisianamoney transmission licensees should use the transition period to prepare for a different licensing process and new operating requirements. Companies considering Louisiana money transmission operations should also carefully consider HB 1230’s scope and requirements, as the law is already in effect. 

Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of Timothy A. Butler Timothy A. Butler

Tim Butler helps companies thrive by developing tailored strategies to address their regulatory compliance challenges and vigorously defending them in government enforcement actions and bet-the-company lawsuits.

A former prosecuting attorney for the Federal Trade Commission (FTC) and former senior official in the Georgia…

Tim Butler helps companies thrive by developing tailored strategies to address their regulatory compliance challenges and vigorously defending them in government enforcement actions and bet-the-company lawsuits.

A former prosecuting attorney for the Federal Trade Commission (FTC) and former senior official in the Georgia Attorney General’s Office, Tim has led the defense of dozens of government investigations and enforcement actions brought by the FTC, the Consumer Financial Protection Bureau (CFPB), and the various state attorneys general. Tim also regularly defends clients in bet-the-company lawsuits, including complex business disputes and consumer class actions alleging privacy, false advertising, and unfair or deceptive business practice claims.

Tim is an experienced guide for companies struggling with regulatory complexity. He offers clear advice that helps his clients meet the demands of the ever-growing set of laws and regulations governing data privacy and cybersecurity, advertising and marketing practices, and consumer financial products and services. Clients rely on Tim’s business-minded and practical strategies to address their most difficult regulatory compliance challenges.

A graduate of the University of Chicago and Stanford Law School, Tim is a prolific author and regularly speaks to industry and trade groups about the evolving privacy landscape, about cutting-edge issues affecting payments and fintech companies, and about developments at the FTC, the CFPB, and within the state attorneys general community.

Photo of Matthew White Matthew White

Matt White guides clients through regulatory compliance challenges and represents clients in regulatory and civil investigations and litigation.

Matt has counseled fintech and payment companies on regulatory compliance matters, including those involving the Electronic Fund Transfer Act, the Fair Credit Reporting Act, the…

Matt White guides clients through regulatory compliance challenges and represents clients in regulatory and civil investigations and litigation.

Matt has counseled fintech and payment companies on regulatory compliance matters, including those involving the Electronic Fund Transfer Act, the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, the Truth in Lending Act, and their respective implementing regulations (Regulations E, V, P, and Z). Adept with the Consumer Financial Protection Bureau’s (CFPB) Prepaid Rule, Matt has provided guidance regarding prepaid cards and related compliance.

Matt has also aided clients in developing regulatory compliant products and functionalities, including an earned wage access program, reimbursement prepaid card programs, new merchant cash advance products, and tokenized payment capabilities. In connection with products on which Matt advises, he has also negotiated high-stakes technology sales agreements involving complex regulatory issues, including compliance with data privacy laws, financial regulations, and card network rules.

Beyond helping clients strategize for regulatory complexity, Matt also helps clients navigate government investigations and enforcement actions brought by the Federal Trade Commission (FTC), CFPB, and state attorneys general.

Photo of Tessa Cierny Tessa Cierny

Tessa Cierny advises companies on financial technology and data privacy issues. She has experience counseling companies on state and federal regulatory compliance, including existing and emerging privacy laws, such as the E.U.’s General Data Protection Regulation (GDPR) and the California Consumer Privacy Act

Tessa Cierny advises companies on financial technology and data privacy issues. She has experience counseling companies on state and federal regulatory compliance, including existing and emerging privacy laws, such as the E.U.’s General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), as well as financial and banking regulations, such as the CFPB’s Section 1071 Small Business Lending Rule (Regulation B). In addition, she assists clients in defending business disputes and data breach litigation.

Prior to joining Greenberg Traurig, she served as global records manager for WestRock, where she developed and implemented email and data retention policies for global data privacy regulation compliance. In this role, she also advised on data privacy concerns related to data retention, data loss prevention, and data governance.

Photo of Cody B. Davis Cody B. Davis

Cody Davis advises clients on regulatory compliance, data privacy, and consumer protection matters within the financial technology sector, with a focus on payments, emerging platforms, and evolving regulatory frameworks. He works with companies navigating complex federal and state requirements, including regulatory compliance, government…

Cody Davis advises clients on regulatory compliance, data privacy, and consumer protection matters within the financial technology sector, with a focus on payments, emerging platforms, and evolving regulatory frameworks. He works with companies navigating complex federal and state requirements, including regulatory compliance, government investigations, and risk management across the fintech ecosystem.

Cody also has prior experience working with clients in the health care space on mergers and acquisitions as well as regulatory compliance with HIPAA, state telehealth rules, and facility licensure requirements.