title: United States – Florida Payments Regulation Monitor | World Payments Monitor canonical: https://payments.gi/jurisdictions/united-states-florida/ date_modified: 2026-10-21 publisher: Asymmetric Intelligence # United States – Florida US-FL schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-21 · 14 modules · 65 sourced findings · 132 sources in the cumulative register 14 Modules baseline.modules[] 65 Findings modules[].findings[] 76 Tier-1 sources run_metadata.t1_source_count Confidence mix (sums to 14 rendered modules; click to filter) ** United States federal law** that applies in United States – Florida is covered once, on the [United States](https://payments.gi/jurisdictions/united-states/) page. This page covers United States – Florida’s own layer: its own law, regulators and enforcement. ## Jurisdiction brief ###### Latest update · 6 October 2026 #### Lead Signal Florida's payment-stablecoin regime took effect on 1 October 2026, establishing one of the more prescriptive state-level stablecoin frameworks in the United States. Under Fla. Stat. s.658.997, created by ch. 2026-176, a trust company may not engage in the activity of a qualified payment stablecoin issuer in Florida unless it obtains a certificate of approval from the Florida Office of Financial Regulation or qualifies for an exemption under the section. The statute is explicit on timing: the obligation binds "effective October 1, 2026," with no phase-in period for entities already issuing stablecoins into the state. The approval gate is paired with a capital-backing rule. Florida Statutes Chapter 658 requires a qualified payment stablecoin issuer to maintain identifiable reserves backing its outstanding payment stablecoins on at least a one-to-one basis. Read together, the two provisions mean a trust company cannot simply register and issue; it must hold a state authorisation (or fit a defined exemption) and continuously demonstrate that every unit of stablecoin in circulation is matched by an identifiable reserve asset. This is a state regulator asserting a direct, ongoing supervisory claim over a product category that, in much of the country, still sits in a federal-state grey zone. A second feature of the regime gives it a built-in sunset against its own state-level scope: a qualified payment stablecoin issuer must transition to federal oversight within 360 days of its consolidated issuance reaching $10 billion, unless a waiver applies. Florida has therefore built a framework that assumes its own jurisdiction over any single issuer is temporary past a defined scale threshold, with federal oversight taking over once issuance crosses that line. For a payments business already issuing or planning to issue dollar-pegged stablecoins at scale, this creates a two-stage compliance path: state approval and 1:1 reserve backing now, with a federal transition obligation engineered to trigger automatically later if the product succeeds. For payments institutions operating or routing through Florida-chartered trust companies, the near-term consequence is straightforward: any entity functioning as a qualified payment stablecoin issuer without a certificate of approval or a qualifying exemption is outside the law as of 1 October 2026, and any issuer already holding approval needs continuous, demonstrable 1:1 identifiable reserves to remain compliant. The framework is new enough that no multi-cycle supervisory record yet exists showing how the Office of Financial Regulation will apply the certificate-of-approval and exemption tests in practice, but the statutory text itself leaves little ambiguity about what is required going into the law's first weeks in force. #### Other Developments No other Florida payments modules carried material movement this cycle; the stablecoin licensing and reserve regime is the sole active development in scope. #### Cross-Monitor Connections The Florida stablecoin framework sits adjacent to AML/CFT obligations that apply to any licensed issuer, but that analysis is supplied elsewhere and is not re-derived here. The structural point for payments readers is that Florida has created a new category of state-licensed entity — the qualified payment stablecoin issuer — whose downstream compliance posture spans licensing, prudential reserve rules, and an eventual handoff to federal oversight, rather than any one of those in isolation. #### Outlook The statutory transition trigger at $10 billion in consolidated issuance, due within 360 days of that threshold being reached, is the clearest forward marker for this regime: it points toward a 2027-Q4 horizon for issuers approaching that scale, assuming no waiver is granted. Before then, the practical test is how the Office of Financial Regulation handles certificate-of-approval applications and exemption determinations in the regime's first months in force, since that early pattern will shape whether Florida's model becomes a template other states look to or a cautionary case of state-federal overlap. _5 earlier updates not shown here._ ###### Standing brief · as of 5 July 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Lead Signal Florida has become the first US state to enact a comprehensive payment-stablecoin issuer licensing framework, establishing a state-qualified pathway aligned to the federal GENIUS Act. The framework, created by HB175/SB314, carries a two-tier effective-date structure rather than a single date: definitional provisions, the Office of Financial Regulation's rulemaking authority, and an amendment to the state's Money Laundering Act took effect upon the bill becoming law in March 2026, while the substantive licensing and prudential requirements for qualified issuers take effect on 1 October 2026. Under the reserve regime, Florida payment stablecoins must be backed 1:1 with high-quality liquid assets — US currency, insured deposits, short-term Treasuries and government money-market funds — with issuers required to provide monthly CPA-verified reserve disclosures. The Florida Department of Financial Services operates a Stablecoin Pilot Program under s.17.72, F.S., allowing acceptance of designated stablecoins for state regulatory fee payments such as licensing applications and renewals, positioning Florida as a potential first-mover on government stablecoin acceptance under the GENIUS Act architecture. The Office of Financial Regulation's Division of Consumer Finance administers this alongside its existing non-bank money-transmission regime under Chapter 560, F.S. and Rule 69V-560, F.A.C., a regime kept separate from the Chapter 663 international-banking framework governing foreign bank offices, under which Part II money-transmitter licensees may conduct Part III activities without added fees. #### Other Developments Alongside the stablecoin framework, Florida enacted HB505, the Virtual Currency Kiosk Act, creating a registration-only regime, not full licensing, for VC kiosk operators, with already-licensed money transmitters exempted. Effective dates are staged: consumer-protection provisions, including transaction limits, disclosures and refund rights, take effect 1 January 2027, while the operator registration requirement follows on 1 March 2027. Those protections respond to more than $33 million in FBI/FTC-reported Florida kiosk-fraud losses between January 2020 and December 2025, and will impose daily transaction limits of $2,000 for new customers and $10,000 for existing customers, plus mandatory full refunds within 72 hours for fraud losses. Chapter 560 licensing applicants remain subject to bonding requirements under s.560.209, F.S., a corporate surety bond or collateral of $50,000 to $2,000,000 depending on size and location count, with ongoing net worth of at least $100,000 and annual audited financials, against a two-year licence term and a $750 renewal fee. Conduct-side, licensees and authorised vendors must retain compliance-relevant books and records for five years and produce them to OFR within three business days of a written request under s.560.1105, F.S., while the Florida Attorney General's Consumer Protection Division has secured more than $565 million in total relief since 2019, including over $426 million in direct consumer relief, under FDUTPA — a cumulative figure that carries no as-of date on its source page and is treated here as background context pending a dated refresh. On enforcement, the Office of Financial Regulation issued a final order on 13 March 2026 approving a consent agreement with a Delaware-based software company that had operated as an unlicensed money transmitter in Florida from January 2011 to August 2025, resulting in a $155,000 fine and a forward compliance commitment under Chapter 560. Global E-Trading LLC, doing business as Chargebacks911 and based in Florida, remains subject to a joint FTC/Florida Attorney General enforcement action, pending in federal court in Tampa, alleging use of prepaid-gift-card microtransactions to disguise merchants' true chargeback rates and evade card-network scrutiny. In scheme-compliance terms, Florida card-accepting merchants sit within the nationwide $5.54 billion Visa/Mastercard interchange-fee settlement covering January 2004 to January 2025 and affirmed by the Second Circuit in 2023, while Walmart's petition to decertify the settlement class, to allow large national merchants to pursue independent remedies against Visa and Mastercard, remained pending before Judge Cogan as of late 2025. On market structure, Florida counted 663 licensed money services businesses operating 42,846 authorised locations and branches as of January 2025, underpinning Miami's role as the principal US gateway for Latin America and Caribbean remittance corridors, through which roughly $170 billion was remitted in 2024, 80% of it originating from the United States. Incumbent operators such as Miami-headquartered Intermex Wire Transfer, licensed across multiple US states, continue to anchor that corridor infrastructure. Félix, a Miami-based remittance fintech, runs a WhatsApp-native product requiring no app download that uses stablecoins behind the scenes to cut cost and settlement time on the US-Mexico, Guatemala and Honduras corridors, and reported its user base more than doubling from 175,000 to 400,000 and its team growing from 150 to 300 employees over the trailing twelve months to March 2026. Governor DeSantis signed the stablecoin issuer and virtual-currency-kiosk bills into law on 27 June 2026, a market-enabling regulatory event for future Florida stablecoin-issuance activity; no Florida-specific fintech or payments M&A transaction was identified within the trailing-twelve-month baseline window despite dedicated search, a gap consistent with known under-indexing of private-company deal activity. Operational resilience remains governed by the Florida Information Protection Act, which mandates breach notification to the Department of Legal Affairs within 30 days for breaches affecting 500 or more Florida residents, among the strictest notification windows in the country, enforced by the Attorney General with penalties of up to $500,000 per incident; no DORA-equivalent dedicated resilience regime for payments firms was identified. #### Cross-Monitor Connections Two Florida payments developments carry an illicit-finance dimension that exceeds this monitor's scope and has been routed to the Financial Intelligence Monitor. A Miami-Dade-headquartered bank faces a derivative lawsuit, pending in the Southern District of Florida, over board decisions including the 2017 opening of a correspondent account for Banco de Venezuela despite competitor de-risking amid sanctions pressure, a dynamic that later drew regulatory scrutiny via a consent order. Separately, SB314 extends Bank Secrecy Act-aligned AML obligations to stablecoin issuers by adding stablecoins to the statutory definition of monetary value under the Florida Control of Money Laundering in Money Services Business Act, effective alongside the substantive stablecoin licensing provisions on 1 October 2026. The underlying AML program requirements, risk assessment, employee training, a compliance officer, and SAR filing to FinCEN upon identification of questionable transactions, are carried in this monitor via the Sentinel.gi feed rather than original illicit-finance analysis. Florida's correspondent-banking access architecture, run through Chapter 663 licensing of foreign-bank agency, branch and representative offices with capital-equivalency deposit requirements, sits alongside the Florida International Bankers Association's role as a recognised Center for Excellence for AML compliance training across the Latin America/Caribbean correspondent-banking corridor. #### Outlook Florida's regulatory calendar over the next nine months is dominated by staged stablecoin and virtual-currency-kiosk effective dates: substantive stablecoin issuer licensing and prudential requirements become operative 1 October 2026, alongside the SB314 AML-Act extension; virtual-currency-kiosk consumer-protection provisions take effect 1 January 2027; and the kiosk operator registration requirement itself takes effect 1 March 2027. Watch for OFR rulemaking detail on qualified-issuer supervision as the October deadline approaches, for further movement in the Walmart interchange-settlement decertification dispute, and for whether Florida's Stablecoin Pilot Program for state fee payments expands ahead of the licensing regime going live. The absence of a DORA-equivalent operational-resilience regime, an APP-fraud reimbursement mandate, or a bespoke chargeback-dispute statute leaves Florida's payments conduct baseline resting on FIPA breach notification, FDUTPA enforcement and federal Reg E and card-network rules, gaps that will bear continued monitoring as the state's stablecoin and kiosk regimes come into force. trust tier: ai_unverified ###### Latest update · 13 October 2026 #### Regulatory Status Florida's payments-regulatory status this cycle is defined by the commencement of the first comprehensive US state-level payment-stablecoin regulatory framework, effective October 1, 2026. A person may not engage in authorized payment-stablecoin issuer activity in Florida without holding a money services business license or a trust-company certificate of approval from the Office of Financial Regulation, with reserve, redemption, and AML-monetary-value provisions all now in force. A companion virtual-currency-kiosk registration regime under a separate statutory provision commences January 1, 2027, establishing a lighter-touch registration pathway for crypto ATM operators distinct from the stablecoin-issuer licensing track. Florida's broader payments-regulatory environment shows continuity alongside this new stablecoin activity: OFR's March 13, 2026 consent order fining an unlicensed money-transmission software company $155,000 demonstrates the state's Chapter 560 licensing regime remains actively enforced against conventional money-services businesses, the same regulatory framework the new stablecoin and kiosk categories now sit within. Miami's fintech funding environment, meanwhile, continued at a reduced pace in 2026 year-to-date relative to 2025, based on market-data vendor reporting. #### Outlook The virtual-currency-kiosk registration regime's January 1, 2027 commencement and the stablecoin framework's first annual OFR compliance certification, due February 1, 2027, are the two near-term dated milestones for Florida's payments-regulatory landscape. No US-FL state-level EMI or payment-institution-equivalent licensing change outside these stablecoin and kiosk measures was identified this cycle. _6 earlier updates not shown here._ ###### Standing brief · as of 5 July 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Regulatory Status Florida enters this baseline cycle at an elevated risk level with a liberalising regulatory direction: the state has enacted the first comprehensive US state-level payment-stablecoin issuer licensing framework (HB175/SB314), aligned to the federal GENIUS Act, alongside a new registration-only virtual-currency-kiosk regime (HB505). Both carry staged, two-tier effective dates rather than single go-live dates, corrected this cycle from an earlier single-date framing. The non-bank money-transmission regime under Chapter 560, F.S., administered by the Office of Financial Regulation, remains statutorily separate from the Chapter 663 international-banking regime for foreign bank offices, preserving a clear bank/non-bank licensing split across the state's payments architecture. Enforcement activity remains active: a March 2026 OFR consent order fined an unlicensed money transmitter $155,000, the FTC/Florida Attorney General Chargebacks911 chargeback-manipulation case remains pending in Tampa federal court, and an Edge Act correspondent-banking derivative suit continues in the Southern District of Florida. Florida also hosts a substantial licensed non-bank payments base of 663 MSBs and 42,846 locations as of January 2025, anchoring Miami's role as the principal US gateway for Latin America/Caribbean remittance corridors and a recognised correspondent-banking hub via the Florida International Bankers Association. #### Outlook Florida's forward calendar is dominated by staged effective dates: substantive stablecoin issuer licensing and prudential requirements, plus the SB314 AML-Act extension, take effect 1 October 2026; virtual-currency-kiosk consumer-protection provisions take effect 1 January 2027; and the kiosk operator registration requirement takes effect 1 March 2027. The state's regulatory direction remains liberalising and innovation-oriented on stablecoins even as enforcement against unlicensed and non-compliant conduct continues, and as a sanctions-driven correspondent de-risking dynamic (flagged to the Financial Intelligence Monitor) persists in the background of its correspondent-banking hub role. 14 of 14 modules Signal Density Selections OR within a group, AND across groups. Press / to search. ### W1a Licensing, Authorisation & Market Access Confirmed confirmed 2026-07-05 Florida operates the canonical dual federal/state US money-transmitter-licensing model; HB 505 (2026) extends this perimeter via a new OFR registration track for virtual-currency-kiosk operators not otherwise licensed as money transmitters. Horizon · 2027-01-31 (±quarter) VC-kiosk registration-application deadline for pre-existing operators_adopted · TT1_ Horizon · 2027-03-01 (±quarter) Florida VC-kiosk operator registration requirement in force_in_force_pending · TT1_ Horizon · 2027-01-31 (±quarter) VC-kiosk registration-application deadline for pre-existing operators_adopted · TT1_ Standing sub-brief · as of 5 July 2026 268 words · last cycle 2026-10-04 #### Licensing, Authorisation & Market Access Florida's non-bank money-transmission regime sits under Chapter 560, F.S. and Rule 69V-560, F.A.C., administered by the Office of Financial Regulation's Division of Consumer Finance, and is kept separate from the Chapter 663 international-banking regime for foreign bank offices; Part II licensees may conduct Part III activities without added fees. Two pieces of 2026 legislation extend this architecture. HB175/SB314 creates a state-qualified payment-stablecoin issuer licensing pathway aligned to the federal GENIUS Act, with a two-tier effective-date structure: definitional provisions, OFR rulemaking authority, and the Money Laundering Act amendment took effect upon the bill becoming law in March 2026, while the substantive licensing and prudential requirements for qualified issuers take effect 1 October 2026. HB505, the Virtual Currency Kiosk Act, creates a registration-only regime, not full licensing, for VC kiosk operators, exempting already-licensed money transmitters; its effective dates are staged, with consumer-protection provisions effective 1 January 2027 and the operator registration requirement effective 1 March 2027. Across the Chapter 560 licensing base, applicants must obtain a corporate surety bond or collateral of $50,000 to $2,000,000 depending on size and location count under s.560.209, F.S., and licensees must thereafter maintain at least $100,000 net worth plus annual audited financials, with licences valid for two years against a $750 renewal fee. #### Outlook The compliance calendar through 2027 is staged rather than singular: stablecoin issuer licensing substantive requirements activate 1 October 2026, kiosk consumer protections activate 1 January 2027, and the kiosk operator registration requirement activates 1 March 2027. Firms operating across licensing categories should track each date separately rather than treat the regime as a single go-live. Periodic update · new data 2026-09-28 #### Licensing, Authorisation & Market Access Florida's Office of Financial Regulation has gained a new licensing perimeter this cycle covering virtual-currency-kiosk businesses. HB 505 creates a new Part V of Chapter 560 F.S., proposed sections 560.501 through 560.507, requiring OFR registration for kiosk operators that do not already hold a money-transmitter license under existing Chapter 560 provisions. This is a non-bank payment-institution and e-money-institution style licensing extension: kiosk operators sit outside the bank-chartered payments system entirely, and the new registration regime is specifically targeted at closing the gap left by kiosk operators who previously fell outside comprehensive state money-services oversight unless they had separately sought a money-transmitter license. The registration regime attaches a daily transaction limit for new customers, reported at $2,000 per day, together with mandatory fraud warnings and a first-transaction fraud-refund duty, market-access conditions that did not previously attach to this business model in Florida. The general effect date for these registration and transaction-limit requirements is reported as January 1, 2027, giving affected kiosk operators a defined runway to register and adjust operations. A Tier-1 gubernatorial chapter-law citation confirming the exact signature date has not yet been retrieved this cycle, which keeps the underlying enactment fact at probable confidence. #### Outlook Watch for kiosk-operator registration volumes with OFR ahead of the January 1, 2027 effective date, and for confirmation via a Tier-1 source of the exact chapter-law citation and signature date. **3 earlier distinct update(s)** Periodic update · new data 2026-09-22 #### Licensing, Authorisation & Market Access Florida's money-transmitter licensing regime, administered by the Florida Office of Financial Regulation, demonstrated active enforcement capacity this cycle through a consent order fining a Delaware-based software company $155,000 for operating as an unlicensed money transmitter from January 2011 through August 2025. This is a Confirmed finding, notable for the length of the unlicensed operating period it captures and for the fact that it was surfaced during a subsidiary's pending money-transmitter-licence application review, indicating that Florida's licensing-application diligence process itself functions as an enforcement discovery channel, not merely a gatekeeping formality. This is a non-bank payment-institution and e-money-institution relevant finding, distinct from bank-channel payment licensing, which was not addressed in this cycle's evidence. Separately, Florida House Bill 505 remains pending and would exempt kiosk-only owners and operators of virtual-currency machines from money-transmitter-licence application and renewal fees. This is a Probable-tier, Tier 1-sourced finding reflecting the bill's not-yet-enacted status. The fee-exemption provision, if enacted, would represent a narrowing of the licensing cost burden for a specific non-bank payment-institution operator category, virtual-currency kiosk operators, while leaving the underlying licensing requirement itself unchanged. #### Outlook Watch for whether HB 505 advances to enactment, which would establish Florida's first kiosk-specific fee carve-out within its general money-transmitter licensing framework. Watch also for whether the OFR's enforcement capacity, demonstrated here against a decade-long unlicensed operator, extends to further non-bank payment-institution enforcement actions in the coming cycle. Periodic update · new data 2026-09-14 #### Licensing, Authorisation & Market Access Florida's Chapter 2026-178 (HB 505) creates a new, distinct licensing sub-category for virtual-currency kiosk businesses under Fla. Stat. §§560.502-503, deliberately structured apart from full money-services-business licensure under the broader Chapter 560 framework. Registration with the Office of Financial Regulation becomes required beginning March 1, 2027, while the substantive disclosure, transaction-limit and refund provisions of the Act take effect January 1, 2027. Notably, the statute carves out an exemption for non-bank payment-instrument and e-money issuers already licensed as money transmitters under Chapter 560 who offer kiosk services: those incumbents avoid dual-registration under the new kiosk-specific category but remain bound to the Act's consumer-facing terms regardless. This is a deliberate two-track design, imposing a lighter-touch registration path on kiosk-only operators while ensuring existing full MSB licensees are not exempted from the substantive consumer-protection obligations simply because they hold a broader licence. The legislative context for this change includes documented supervisory gaps: an OFR 2024 statute review found only 9 of the 26 known Florida virtual-currency-kiosk operators held any money-transmitter licence at all, meaning the substantial majority of the state's kiosk population previously operated with no licensing touchpoint whatsoever. Separately, OFR's enforcement record shows the licensing perimeter was not merely under-populated but also under-enforced: a March 13, 2026 final order fined a Delaware-based software company $155,000 for operating as an unlicensed money transmitter in Florida for over a decade, from January 2011 through August 2025, a violation discovered only incidentally via a related licence application rather than through proactive supervision. Taken together, these developments mark a material tightening of Florida's licensing and market-access framework specifically for the virtual-currency-kiosk segment of the non-bank payment-instrument and e-money space, while leaving the general Chapter 560 MSB licensing regime for other payment-services categories otherwise unchanged this cycle. #### Outlook The registration deadline of March 1, 2027 will be the first concrete test of how many of the previously under-licensed kiosk operators come into compliance, and whether OFR's supervisory posture shifts from the reactive enforcement pattern evidenced by the software-company fine toward proactive oversight of the newly registered population. Periodic update · new data 2026-09-08 #### Licensing, Authorisation & Market Access Florida's money-transmitter licensing regime under Chapter 560 of the Florida Statutes was extended this cycle to two distinct digital-asset business models. HB 505 creates a registration requirement for virtual-currency-kiosk (crypto ATM) operators with the Office of Financial Regulation, effective January 1, 2027. CS/CS/HB 175 creates a qualified payment stablecoin issuer sub-category, requiring OFR licensing as a money services business or a trust-company certificate of approval, effective October 1, 2026. Both instruments follow the same regulatory strategy: rather than drafting a bespoke crypto licence, Florida is layering new sub-categories onto its existing MTL/MSB framework, extending an established licensing code's reach to instrument types it previously did not name. This licensing extension applies to non-bank payment institutions and e-money-type entities specifically; the bank-versus-non-bank distinction matters here because both the stablecoin-issuer category and the kiosk-registration category are structured as non-bank MSB/trust-company pathways rather than bank-chartered activity, placing the compliance burden on the non-bank payment-institution population that already operates under Chapter 560. OFR's active enforcement of the existing MTL regime reinforces that this is not a symbolic licensing extension. The regulator imposed a $155,000 administrative fine on March 13, 2026 against a company that had operated as a money transmitter without a licence for fourteen years, a gap discovered only during a subsidiary licensing-application review. A supporting operational signal is OFR's revision of Form OFR-560-04, the Money Services Business Quarterly Report, effective July 1, 2026, to expand its scope to capture virtual-currency-transmission activity and gold/silver-coin exchange transactions, giving the regulator a reporting mechanism through which to monitor the newly-covered instrument types once the licensing categories take effect. #### Outlook Watch for OFR implementing guidance ahead of the October 1, 2026 stablecoin-issuer effective date and the January 1, 2027 kiosk-registration effective date. The revised MSB Quarterly Report data, once populated with virtual-currency-transmission figures, will be the first indicator of how much reporting volume these new licensing categories actually generate. **Sources and findings (6)** 1. T1 [https://flofr.gov/divisions-offices/division-of-consumer-finance/money-transmitters](https://flofr.gov/divisions-offices/division-of-consumer-finance/money-transmitters) retrieved 2026-07-05 2. T1 [https://www.flsenate.gov/Session/Bill/2026/505/Analyses/h0505z.IBS.PDF](https://www.flsenate.gov/Session/Bill/2026/505/Analyses/h0505z.IBS.PDF) retrieved 2026-07-05 3. T1 [https://www.hudsoncook.com/article/florida-regulator-clarifies-money-transmitter-licensing-exemptions-or-lack-thereof/](https://www.hudsoncook.com/article/florida-regulator-clarifies-money-transmitter-licensing-exemptions-or-lack-thereof/) retrieved 2026-07-05 4. T1 [https://flofr.gov/divisions-offices/division-of-financial-institutions/international-bank-and-trust-company-offices](https://flofr.gov/divisions-offices/division-of-financial-institutions/international-bank-and-trust-company-offices) retrieved 2026-07-05 5. T1 [https://practiceguides.chambers.com/practice-guides/blockchain-crypto-assets-2026/usa-florida/trends-and-developments](https://practiceguides.chambers.com/practice-guides/blockchain-crypto-assets-2026/usa-florida/trends-and-developments) retrieved 2026-07-05 6. T1 [https://www.aarp.org/states/florida/florida-house-bill-505-virtual-currency-kiosks/](https://www.aarp.org/states/florida/florida-house-bill-505-virtual-currency-kiosks/) retrieved 2026-07-05 ### W1b Conduct, Safeguarding & Promotions Confirmed confirmed 2026-07-05 Florida enacted the first comprehensive US state-level licensing framework for payment stablecoin issuers (HB 175 / companion SB 314, now Ch. 2026-176), integrated into the existing Chapter 560 money-services-business regime and aligned with the federal GENIUS Act; core provisions take effect October 1, 2026. Standing sub-brief · as of 5 July 2026 191 words · last cycle 2026-08-05 #### Conduct, Safeguarding & Financial Promotions Under s.560.1105, F.S., licensees and authorised vendors must retain compliance-relevant books, accounts, documents and files for five years and produce records to the Office of Financial Regulation within three business days of a written request; this recordkeeping baseline is sourced to a 2021 statute snapshot and has not been independently confirmed current for the 2026 session, though no amendment has been identified. Separately, the Florida Attorney General's Consumer Protection Division, which enforces the Florida Deceptive and Unfair Trade Practices Act against deceptive payments and commercial conduct, has secured more than $565 million in total relief since 2019, including over $426 million in direct consumer relief; this cumulative figure carries no as-of date on its source page, so its currency for the current cycle cannot be confirmed and it is treated as background context pending a dated refresh. #### Outlook No material change to Florida's conduct or recordkeeping duties was identified this cycle. The safeguarding architecture for the incoming stablecoin-issuer regime (reserve backing and CPA-verified disclosures) sits in W2 rather than here; watch for whether OFR issues conduct-specific guidance to accompany the 1 October 2026 stablecoin licensing go-live. Periodic update · new data 2026-09-03 #### Conduct, Safeguarding & Financial Promotions Florida enacted Chapter 2026-176 (House Bill 175 / Senate Bill 314) this cycle, establishing an Office of Financial Regulation-supervised licensing framework for payment stablecoin issuers under the state's existing Chapter 560 money-services-business statute, effective October 1, 2026 (wpm-2026-W1b-001). This is the first comprehensive US state-level licensing regime built specifically for payment stablecoin issuers, and it is structured as a nonbank instrument, issued and supervised within the money-services-business track rather than through a bank charter, preserving the bank-PSP versus nonbank-PI/EMI distinction that runs through Florida's broader payments regulatory architecture. The regime requires 1:1 reserve backing for outstanding stablecoin liabilities and provides a substantial-similarity certification pathway tied to the federal GENIUS Act, administered by the Office of Financial Regulation as a second, OFR-issued instrument layered on top of the base licence (wpm-2026-W1b-002). Neither the state-qualified issuer licence nor the substantial-similarity certification carries a stated exemption, meaning the licensing gate applies without a general carve-out for either instrument. Because the framework is grafted onto Chapter 560 rather than built as a freestanding regime, issuers face conduct and safeguarding obligations, including the 1:1 reserve-segregation requirement, from within an already-functioning supervisory apparatus rather than a newly constituted one. #### Outlook The core date to track is October 1, 2026, when the licensing requirement and the 1:1 reserve standard become operative. Whether other US states reference Florida's Chapter-560-integrated approach as a template for their own stablecoin-issuer frameworks is the structural question for this module going into the next cycle. **Sources and findings (5)** 1. T1 [https://www.flsenate.gov/Laws/Statutes/2021/Chapter560/All](https://www.flsenate.gov/Laws/Statutes/2021/Chapter560/All) retrieved 2026-07-05 2. T1 [https://law.justia.com/codes/florida/2005/TitleXXXIII/ch0560.html](https://law.justia.com/codes/florida/2005/TitleXXXIII/ch0560.html) retrieved 2026-07-05 3. T1 [https://www.myfloridalegal.com/consumer-protection](https://www.myfloridalegal.com/consumer-protection) retrieved 2026-07-05 4. T1 [https://pinellas.gov/recognize-and-avoid-telemarketing-fraud/](https://pinellas.gov/recognize-and-avoid-telemarketing-fraud/) retrieved 2026-07-05 5. T2 [https://www.mofo.com/resources/insights/241111-uptick-in-florida-telephone-solicitation-act-litigation](https://www.mofo.com/resources/insights/241111-uptick-in-florida-telephone-solicitation-act-litigation) retrieved 2026-07-05 ### W2 Stablecoins & Digital Money moved Confirmed confirmed 2026-07-05 Florida requires a trust company to hold a certificate of approval (or qualify for an exemption) before engaging in qualified payment stablecoin issuer activity, effective 1 October 2026 (Fla. Stat. s.658.997). Issuers must maintain identifiable reserves backing outstanding stablecoins on at least a one-to-one basis (Fla. Stat. Ch. 658), with monthly reserve-composition disclosure, monthly CPA examination, and mandatory transition to federal oversight within 360 days of consolidated issuance reaching $10 billion, absent a waiver. Movement — CHANGED Florida stablecoin licensing framework commenced Oct 1, 2026_New in-force state stablecoin law_ Horizon · 2026-10-01 (±quarter) Florida stablecoin issuer substantive licensing/prudential provisions in force_in_force_pending · TT1_ Standing sub-brief · as of 5 July 2026 143 words · last cycle 2026-10-13 #### Stablecoins & Digital Money Payment stablecoins issued under Florida's HB175/SB314 regime must be backed 1:1 with high-quality liquid assets, including US currency, insured deposits, short-term Treasuries, and government money-market funds, with issuers required to provide monthly CPA-verified reserve disclosures. The Florida Department of Financial Services separately operates a Stablecoin Pilot Program under s.17.72, F.S., allowing designated stablecoins to be accepted for state regulatory fee payments such as licensing applications and renewals, positioning Florida as a potential first-mover on stablecoin acceptance for government fees under the GENIUS Act framework. #### Outlook The substantive licensing and prudential requirements for qualified stablecoin issuers take effect 1 October 2026; the definitional, administrative and AML-Act provisions are already in force following enactment. Watch for OFR rulemaking to operationalise the reserve-disclosure and issuer-supervision requirements ahead of that date, and for whether the Stablecoin Pilot Program expands beyond state fee payments. Periodic update · new data 2026-10-13 #### Stablecoins & Digital Money Florida's payment-stablecoin regulatory framework, enacted via CS/CS/HB 175 and SB 314, is now in force as of October 1, 2026, making Florida the first US state with a comprehensive state-level stablecoin regime. A person may not engage in authorized payment-stablecoin issuer activity in Florida without holding a money services business license or, for a trust company, obtaining an OFR certificate of approval. Issuers must maintain reserves backing outstanding stablecoins on at least a one-to-one basis, comprising specified reserve types including US coin and currency, establishing a clear prudential standard for the backing of any Florida-authorized stablecoin. A scale-based transition mechanism connects the state regime to the federal landscape: an issuer whose consolidated total issuance reaches $10 billion must transition to federal oversight unless a waiver is obtained, acknowledging that Florida's framework operates within, rather than independently of, the broader federal GENIUS Act structure for payment stablecoins. This threshold effectively caps the scale at which a purely state-regulated issuer can operate before federal supervision becomes mandatory absent a waiver. A companion measure addresses a different part of the digital-money infrastructure: effective January 1, 2027, virtual-currency-kiosk (crypto ATM) operators not already licensed as money transmitters must register with OFR, display fraud warnings, and cap daily transactions at $2,000 for new customers and $10,000 for existing customers. This registration-only regime is materially lighter-touch than the stablecoin-issuer licensing pathway, reflecting a calibrated regulatory approach that distinguishes between stablecoin issuance and kiosk-based cash-to-crypto conversion as separate risk profiles within the same statutory chapter. #### Outlook The virtual-currency-kiosk registration regime's January 1, 2027 commencement and the stablecoin framework's first annual OFR compliance certification, due February 1, 2027, are the two near-term dated milestones to track. Florida's template, if replicated by other states ahead of full federal GENIUS Act maturity, would shape how a broader US sub-national patchwork of stablecoin regimes develops alongside the federal framework. **3 earlier distinct update(s)** Periodic update · new data 2026-10-06 #### Stablecoins & Digital Money Florida's payment-stablecoin regime entered into force on 1 October 2026 under Fla. Stat. s.658.997, created by ch. 2026-176. The statute states that, "effective October 1, 2026, a trust company may not engage in the activity of a qualified payment stablecoin issuer in this state unless the trust company obtains a certificate of approval or is exempted from such certificate under this section." This establishes a binding licensing gate: a trust company seeking to issue payment stablecoins in Florida must either hold a certificate of approval from the state regulator or fall within a defined statutory exemption before commencing that activity, with no grace period built into the provision's own text. Alongside the approval gate, Florida Statutes Chapter 658 imposes a prudential backing requirement on any issuer that does hold, or is exempted from holding, that approval: it must "maintain identifiable reserves backing the outstanding payment stablecoins of the qualified payment stablecoin issuer on at least a one-to-one basis." The obligation is continuous rather than a one-time condition of entry — it applies for as long as stablecoins remain outstanding, not only at the point of initial authorisation. Together, the certificate-of-approval requirement and the 1:1 identifiable-reserve rule form the core of the regime: entry control plus ongoing prudential backing, both in force from the same 1 October 2026 date. The regime also contains a scale-based exit mechanism from state-level oversight. A qualified payment stablecoin issuer must transition to federal oversight within 360 days after its consolidated issuance reaches $10 billion, unless a waiver applies. This is a structural feature of the Florida framework rather than a separate future law: the state has defined its own supervisory role as provisional once an issuer crosses that issuance threshold, with a fixed 360-day clock running from the moment the threshold is reached. No issuer is reported in this cycle's register as having approached that threshold, so the provision currently functions as a known future trigger rather than an active transition. Because the regime has been in force only since 1 October 2026, there is not yet a multi-cycle supervisory record of how the Office of Financial Regulation evaluates certificate-of-approval applications, what the available exemptions require in practice, or how reserve composition will be examined on an ongoing basis. The statute's own obligations, however, are unambiguous on their face: a trust company issuing payment stablecoins into Florida without approval or an applicable exemption is operating outside the law as of the effective date, and an approved or exempted issuer that cannot demonstrate identifiable 1:1 reserve backing is in breach of a continuing obligation, not a one-off filing requirement. #### Outlook The most concrete forward marker in this regime is the $10 billion consolidated-issuance trigger for mandatory transition to federal oversight, which carries an expected horizon in the 2027-Q4 range on a multi-year uncertainty band, assuming no waiver is sought or granted. Before any issuer reaches that scale, the operative question is how the Office of Financial Regulation handles its first wave of certificate-of-approval and exemption determinations, since the statute leaves considerable room for supervisory practice to define what "identifiable reserves" and a qualifying exemption look like on the ground. Readers with Florida-licensed or Florida-adjacent stablecoin activity should expect this area to generate further developments as the regulator's early application of the regime becomes visible. Periodic update · new data 2026-09-28 #### Stablecoins & Digital Money Florida enacted a state-qualified payment-stablecoin-issuer licensing track this cycle under HB 175 and companion SB 314, reported to have passed both chambers of the Florida Legislature in March 2026. The track is structured to align with the federal GENIUS Act's 'substantially similar' pathway, under which a state regulatory framework can be certified by federal authorities as equivalent to direct federal stablecoin-issuer supervision, giving issuers below the federal threshold a state-level licensing option through the Office of Financial Regulation. This is a first-mover move for a US state and positions Florida-domiciled stablecoin issuance as subject to a defined, state-administered licensing process rather than relying solely on federal GENIUS Act supervision or an absence of state-level framework altogether. Most substantive provisions of the framework are reported to take effect October 1, 2026. As with the kiosk-registration measure, the exact date and confirmation of gubernatorial signature rests this cycle on lower-tier corroborating sources rather than a Tier-1 chapter-law citation, which caps confidence at probable. #### Outlook The October 1, 2026 effective date for substantive provisions is the near-term marker to track, alongside whether the US Treasury certifies Florida's track as 'substantially similar' under the GENIUS Act, a determination that will materially affect how much practical reliance issuers can place on the state-qualified pathway relative to direct federal supervision. Periodic update · new data 2026-09-08 #### Stablecoins & Digital Money CS/CS/HB 175 establishes Florida's payment stablecoin issuer licensing regime, requiring issuers to be licensed as a money services business or hold a trust-company certificate of approval from the Office of Financial Regulation, effective October 1, 2026. The instrument creates the qualified payment stablecoin issuer sub-category directly within Florida's existing Chapter 560 Control of Money Laundering in Money Services Business Act, meaning the stablecoin licensing pathway is structurally an extension of the state's money-transmission code rather than a freestanding digital-money statute. Governor Ron DeSantis signed CS/CS/HB 175 into law alongside other financial-services-related bills, a signing event reported publicly as covering multiple bills with direct impact on Florida's financial services sector. This licensing regime applies to both bank and non-bank issuance pathways, since the trust-company certificate of approval option sits alongside the MSB-licence option, giving stablecoin issuers a choice of regulatory vehicle depending on their corporate structure. #### Outlook The principal item to watch is whether OFR publishes implementing rules or licensing-application guidance for the qualified payment stablecoin issuer category ahead of the October 2026 effective date, and how many issuers pursue the trust-company pathway versus the standard MSB-licence pathway once applications open. **Sources and findings (5)** 1. T1 [https://floridapolitics.com/archives/804440-stablecoin-virtual-currency-kiosk-bills-signed-into-law/](https://floridapolitics.com/archives/804440-stablecoin-virtual-currency-kiosk-bills-signed-into-law/) retrieved 2026-07-05 2. T2 [https://www.bitget.com/amp/news/detail/12560605251439](https://www.bitget.com/amp/news/detail/12560605251439) retrieved 2026-07-05 3. T2 [https://coinmarketcap.com/academy/article/florida-becomes-first-us-state-to-pass-a-stablecoin-regulatory-bill](https://coinmarketcap.com/academy/article/florida-becomes-first-us-state-to-pass-a-stablecoin-regulatory-bill) retrieved 2026-07-05 4. T1 [https://flvoicenews.com/florida-lawmakers-approve-stablecoin-pilot-program-allowing-digital-payments-for-state-fees/](https://flvoicenews.com/florida-lawmakers-approve-stablecoin-pilot-program-allowing-digital-payments-for-state-fees/) retrieved 2026-07-05 5. T2 [https://coinmarketcap.com/academy/article/florida-becomes-first-us-state-to-pass-a-stablecoin-regulatory-bill](https://coinmarketcap.com/academy/article/florida-becomes-first-us-state-to-pass-a-stablecoin-regulatory-bill) retrieved 2026-07-05 ### W3 Operational Resilience & Critical Infra Probable confirmed 2026-07-05 Florida has no DORA-style prudential operational-resilience regime specific to payments; the operative baseline protection is the Florida Information Protection Act (FIPA), a strict 30-day breach-notification law enforced by the Attorney General, supplemented by periodic OFR cybersecurity industry alerts to licensees. Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. [Open its jurisdiction pages on Dataprotection.gi →](https://dataprotection.gi/jurisdictions/) Standing sub-brief · as of 5 July 2026 135 words · last cycle 2026-07-05 #### Operational Resilience & Critical Infrastructure Florida's operative baseline for payments-sector operational resilience is the Florida Information Protection Act (FIPA), s.501.171, F.S., which mandates breach notification to the Department of Legal Affairs within 30 days for breaches affecting 500 or more Florida residents, among the strictest notification windows in the United States, enforced by the Attorney General with penalties of up to $500,000 per incident. No dedicated DORA-equivalent prudential operational-resilience or critical-third-party-outsourcing regime for payments firms or MSBs was identified in Florida beyond FIPA and periodic OFR cybersecurity industry alerts. #### Outlook No material change to Florida's operational-resilience baseline was identified this cycle; FIPA's 30-day breach-notification standard remains the reference point absent a dedicated payments-resilience regime. Continued absence of a DORA-equivalent framework should be monitored as stablecoin issuance brings new technology-dependent infrastructure into scope from October 2026. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://www.flsenate.gov/laws/statutes/2014/501.171](https://www.flsenate.gov/laws/statutes/2014/501.171) retrieved 2026-07-05 2. T2 [https://floridasecurityauthority.com/florida-data-breach-notification-law](https://floridasecurityauthority.com/florida-data-breach-notification-law) retrieved 2026-07-05 3. T2 [https://floridasecurityauthority.com/florida-data-breach-notification-law](https://floridasecurityauthority.com/florida-data-breach-notification-law) retrieved 2026-07-05 4. T1 [https://flofr.gov/news/industry-alerts/2](https://flofr.gov/news/industry-alerts/2) retrieved 2026-07-05 ### W4 Scheme & Network Compliance Probable confirmed 2026-07-05 Florida merchants are subject to the nationwide Visa/Mastercard interchange-fee antitrust settlement framework and to PCI DSS as the scheme-mandated technical standard; a Florida-based payments company (Chargebacks911) has been the subject of a joint FTC/Florida Attorney General enforcement action over scheme-facing chargeback-manipulation conduct. Standing sub-brief · as of 5 July 2026 118 words · last cycle 2026-07-05 #### Scheme & Network Compliance Florida card-accepting merchants sit within the nationwide Payment Card Interchange Fee Settlement, under which $5.54 billion was approved for merchants accepting Visa and Mastercard between January 2004 and January 2025, with the Second Circuit affirming the settlement in 2023. That settlement structure faces a live challenge: Walmart petitioned to decertify the plaintiff class so that large national merchants could pursue independent remedies against Visa and Mastercard, a petition pending before Judge Cogan as of late 2025. #### Outlook The Walmart decertification petition is the primary scheme-compliance dynamic to watch; a ruling permitting large merchants to exit the settlement class would reshape interchange-litigation exposure for card networks nationally, with direct relevance to Florida's card-accepting merchant base. no periodic updates on record for this sub-brief ** Sources and findings (3)** 1. T2 [https://en.wikipedia.org/wiki/Payment_card_interchange_fee_and_merchant_discount_antitrust_litigation](https://en.wikipedia.org/wiki/Payment_card_interchange_fee_and_merchant_discount_antitrust_litigation) retrieved 2026-07-05 2. T3 [https://www.paymentsdive.com/news/walmart-wants-out-of-card-class/807972/](https://www.paymentsdive.com/news/walmart-wants-out-of-card-class/807972/) retrieved 2026-07-05 3. T1 [https://www.ftc.gov/business-guidance/blog/2023/04/411-about-ftc-florida-ag-action-against-chargebacks911](https://www.ftc.gov/business-guidance/blog/2023/04/411-about-ftc-florida-ag-action-against-chargebacks911) retrieved 2026-07-05 ### W5 Payment Corridor Dynamics Probable confirmed 2026-07-05 Florida, and Miami specifically, functions as the principal US gateway for remittance corridors to Latin America and the Caribbean, hosting major money-transfer operators and a growing cluster of digital-first remittance fintechs serving these corridors. Standing sub-brief · as of 5 July 2026 112 words · last cycle 2026-07-05 #### Payment Corridor Dynamics Miami functions as the principal US gateway for Latin America and Caribbean remittance corridors: approximately $170 billion was remitted to the region in 2024 via money-transfer operators, with 80% of that volume originating from the United States. Incumbent corridor infrastructure is anchored by operators such as Intermex Wire Transfer, headquartered in Miami and holding money-transmitter licences across multiple US states. #### Outlook The US-LAC corridor remains a sustained high-volume commercial artery for Florida-based payments firms. Watch for continued share migration toward stablecoin-enabled digital challengers (tracked in W9) alongside the incumbent MTO base, and for any corridor-level effect from the Florida stablecoin-issuer regime once substantive licensing takes effect in October 2026. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T2 [https://thedialogue.org/blogs/2025/04/the-state-of-the-remittance-industry-and-an-outlook-for-2025](https://thedialogue.org/blogs/2025/04/the-state-of-the-remittance-industry-and-an-outlook-for-2025) retrieved 2026-07-05 2. T3 [https://www.intermexonline.com/](https://www.intermexonline.com/) retrieved 2026-07-05 3. T3 [https://refreshmiami.com/news/felix-is-turning-whatsapp-into-a-remittance-engine-for-400000-immigrants/](https://refreshmiami.com/news/felix-is-turning-whatsapp-into-a-remittance-engine-for-400000-immigrants/) retrieved 2026-07-05 4. T3 [https://www.macroglobal.co.uk/blog/financial-technology/money-transmitter-license-mtl-us-states/](https://www.macroglobal.co.uk/blog/financial-technology/money-transmitter-license-mtl-us-states/) retrieved 2026-07-05 5. T3 [https://www.bankdirectoriesonline.com/cms-bankshow/Florida+International+Bankers+Association.html](https://www.bankdirectoriesonline.com/cms-bankshow/Florida+International+Bankers+Association.html) retrieved 2026-07-05 ### W6 Industry Structure & Commercial Probable confirmed 2026-07-05 Florida's payments/fintech industry is structured around a Miami-centred hub of private, often venture-backed remittance and crypto-payments firms operating alongside a base of 663 OFR-licensed money-services businesses, with large listed money-transfer operators and card networks also present. Standing sub-brief · as of 5 July 2026 106 words · last cycle 2026-07-05 #### Industry Structure & Commercial Dynamics Florida's non-bank payments industry is substantial in scale: the Office of Financial Regulation licensed 663 money services businesses operating 42,846 authorised locations and branches as of January 2025. This licensed base underpins the corridor and remittance activity tracked elsewhere in this brief and provides the structural backdrop against which the new stablecoin-issuer and VC-kiosk regimes will be layered. #### Outlook No material change to Florida's MSB market-structure count was identified this cycle beyond the January 2025 baseline figure. Watch for whether the stablecoin-issuer licensing pathway, once substantive requirements take effect in October 2026, expands the licensed population beyond the existing 663-MSB base. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://www.flsenate.gov/Session/Bill/2026/198/Analyses/2026s00198.rc.PDF](https://www.flsenate.gov/Session/Bill/2026/198/Analyses/2026s00198.rc.PDF) 2. T2 [https://thedialogue.org/blogs/2025/04/the-state-of-the-remittance-industry-and-an-outlook-for-2025](https://thedialogue.org/blogs/2025/04/the-state-of-the-remittance-industry-and-an-outlook-for-2025) retrieved 2026-07-05 3. T4 [https://apidots.com/blog/florida-fintech-growth/](https://apidots.com/blog/florida-fintech-growth/) retrieved 2026-07-05 4. T4 [https://builtin.com/companies/location/miami/type/fintech-companies](https://builtin.com/companies/location/miami/type/fintech-companies) retrieved 2026-07-05 ### W7 Legal & Litigation Confirmed confirmed 2026-07-05 Florida's existing Control of Money Laundering in Money Services Business Act (Chapter 560) has been amended to bring payment stablecoin issuance explicitly within AML recordkeeping/reporting scope, with unlicensed issuance criminalized. Standing sub-brief · as of 5 July 2026 157 words · last cycle 2026-08-05 #### Legal & Litigation The Office of Financial Regulation issued a final order on 13 March 2026 approving a consent agreement with a Delaware-based software company found to have operated as an unlicensed money transmitter in Florida from January 2011 to August 2025; the company agreed to pay a $155,000 fine and to comply with Chapter 560 going forward, an enforcement precedent illustrating OFR's active posture against unlicensed money transmission. Separately, a Miami-Dade-headquartered bank faces a derivative lawsuit, pending in the Southern District of Florida, concerning board decisions on correspondent banking, including the 2017 opening of a correspondent account for Banco de Venezuela despite competitor de-risking amid sanctions pressure. #### Outlook Watch for the outcome of the Edge Act derivative suit in the Southern District of Florida, and for whether the OFR consent-order fine level informs future unlicensed-transmission enforcement benchmarks. The sanctions dimension of the correspondent-banking litigation has been flagged to the Financial Intelligence Monitor rather than analysed here. Periodic update · new data 2026-09-03 #### Legal & Litigation The same Florida legislative package that created the OFR stablecoin-issuer licensing regime also amended the Florida Control of Money Laundering in Money Services Business Act (Chapter 560) to bring payment stablecoin issuance within its AML recordkeeping and reporting scope, adding a licence-or-exemption gate with a criminal-penalty backstop for unlicensed issuers (wpm-2026-W7-001). Under the amended money-services-business and financial-institutions codes, unlicensed qualified payment stablecoin issuance now carries possible criminal penalties (wpm-2026-W7-002). Rather than sequencing market-access liberalisation ahead of compliance obligations, Florida calibrated the new licensing pathway and the AML/criminal-penalty tightening within the same legislative instrument, meaning the market-access question and the enforcement-exposure question for any prospective issuer arrive together rather than in separate phases. This positions unlicensed stablecoin issuance in Florida as a criminal, not merely civil or administrative, matter from the point the framework takes effect. #### Outlook Whether Florida's Attorney General or the Office of Financial Regulation brings an early enforcement action under the new criminal-penalty backstop once the regime is in force from October 1, 2026, would be the clearest signal of how actively the state intends to police the licence-or-exemption gate. No enforcement action has been evidenced this cycle, since the operative provisions are not yet in force. **Sources and findings (5)** 1. T1 [https://infobytes.orrick.com/2026-03-20/florida-fines-software-company-155k-for-alleged-unlicensed-money-transmission/](https://infobytes.orrick.com/2026-03-20/florida-fines-software-company-155k-for-alleged-unlicensed-money-transmission/) retrieved 2026-07-05 2. T1 [https://www.hudsoncook.com/article/florida-regulator-clarifies-money-transmitter-licensing-exemptions-or-lack-thereof/](https://www.hudsoncook.com/article/florida-regulator-clarifies-money-transmitter-licensing-exemptions-or-lack-thereof/) retrieved 2026-07-05 3. T2 [https://www.govinfo.gov/content/pkg/USCOURTS-flsd-1_22-cv-20201/pdf/USCOURTS-flsd-1_22-cv-20201-3.pdf](https://www.govinfo.gov/content/pkg/USCOURTS-flsd-1_22-cv-20201/pdf/USCOURTS-flsd-1_22-cv-20201-3.pdf) retrieved 2026-07-05 4. T1 [https://www.ftc.gov/business-guidance/blog/2023/04/411-about-ftc-florida-ag-action-against-chargebacks911](https://www.ftc.gov/business-guidance/blog/2023/04/411-about-ftc-florida-ag-action-against-chargebacks911) retrieved 2026-07-05 5. T2 [https://www.sec.gov/Archives/edgar/data/0001424657/000121390025048144/ea024311901ex10-9_cuentas.htm](https://www.sec.gov/Archives/edgar/data/0001424657/000121390025048144/ea024311901ex10-9_cuentas.htm) retrieved 2026-07-05 ### W8 Merchant Acquiring & Risk Probable confirmed 2026-07-05 Florida has no bespoke statutory chargeback-dispute regime; merchant-acquiring risk controls flow from card-network rules plus general consumer/telemarketing statutes, with a high-profile Florida-based chargeback-management firm the subject of federal/state enforcement over chargeback-manipulation tactics affecting high-risk-merchant risk management. Standing sub-brief · as of 5 July 2026 107 words · last cycle 2026-07-05 #### Merchant Acquiring & Risk Global E-Trading LLC, doing business as Chargebacks911 and based in Florida, is subject to a joint FTC/Florida Attorney General enforcement action, pending in federal court in Tampa, alleging use of prepaid-gift-card microtransactions to falsely reduce merchants' chargeback rates and evade bank and card-company scrutiny. Florida has no bespoke statutory chargeback-dispute regime distinct from card-network rules and federal Regulation E, leaving scheme rules and this kind of case-by-case enforcement as the operative merchant-acquiring-risk framework. #### Outlook The Chargebacks911 case remains the key merchant-acquiring-risk enforcement signal to track; its outcome may clarify regulatory tolerance for chargeback-rate-management practices that intersect with card-scheme compliance obligations tracked in W4. no periodic updates on record for this sub-brief ** Sources and findings (3)** 1. T1 [https://www.ftc.gov/business-guidance/blog/2023/04/411-about-ftc-florida-ag-action-against-chargebacks911](https://www.ftc.gov/business-guidance/blog/2023/04/411-about-ftc-florida-ag-action-against-chargebacks911) retrieved 2026-07-05 2. T1 [https://pinellas.gov/recognize-and-avoid-telemarketing-fraud/](https://pinellas.gov/recognize-and-avoid-telemarketing-fraud/) retrieved 2026-07-05 3. T1 [https://www.ftc.gov/system/files/documents/cases/first_data_filed_complaint.pdf](https://www.ftc.gov/system/files/documents/cases/first_data_filed_complaint.pdf) retrieved 2026-07-05 ### W9 Product Innovation & Market Development Probable confirmed 2026-07-05 Florida combines sustained state-level fintech-innovation institutions (Blockchain Task Force, OFR Office of Fintech Policy) with 2026 product-enabling legislation for stablecoin issuance and government use, and an active private-sector product pipeline in cross-border/remittance fintech centred on Miami. Standing sub-brief · as of 5 July 2026 97 words · last cycle 2026-07-05 #### Product Innovation & Market Development Félix, a Miami-based remittance fintech, operates a WhatsApp-native remittance product requiring no app download, using stablecoins behind the scenes to improve cost and speed on the US-Mexico, Guatemala and Honduras corridors. Its emergence sits alongside the state's own Stablecoin Pilot Program for government fee payments, illustrating parallel public- and private-sector stablecoin product innovation emerging from Florida. #### Outlook Watch for continued scaling of stablecoin-enabled remittance products such as Félix's as the state's stablecoin-issuer licensing regime comes into substantive force in October 2026, and for whether incumbent MTOs respond with their own stablecoin-rail integrations. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T2 [https://practiceguides.chambers.com/practice-guides/blockchain-crypto-assets-2026/usa-florida/trends-and-developments](https://practiceguides.chambers.com/practice-guides/blockchain-crypto-assets-2026/usa-florida/trends-and-developments) retrieved 2026-07-05 2. T1 [https://flvoicenews.com/florida-lawmakers-approve-stablecoin-pilot-program-allowing-digital-payments-for-state-fees/](https://flvoicenews.com/florida-lawmakers-approve-stablecoin-pilot-program-allowing-digital-payments-for-state-fees/) retrieved 2026-07-05 3. T3 [https://refreshmiami.com/news/felix-is-turning-whatsapp-into-a-remittance-engine-for-400000-immigrants/](https://refreshmiami.com/news/felix-is-turning-whatsapp-into-a-remittance-engine-for-400000-immigrants/) retrieved 2026-07-05 4. T1 [https://www.aarp.org/states/florida/florida-house-bill-505-virtual-currency-kiosks/](https://www.aarp.org/states/florida/florida-house-bill-505-virtual-currency-kiosks/) retrieved 2026-07-05 ### W10 Consumer Protection & APP Fraud Confirmed confirmed 2026-07-05 Florida consumer protection for payments rests on the general FDUTPA/FTSA private-enforcement framework plus newly enacted virtual-currency-kiosk-specific fraud protections (transaction limits, mandatory warnings, conditional refunds); Florida has not enacted a dedicated authorized-push-payment reimbursement mandate comparable to the UK's PSR regime. Horizon · 2027-01-01 (±quarter) Florida VC-kiosk consumer-protection provisions (limits/refunds) in force_in_force_pending · TT1_ Standing sub-brief · as of 5 July 2026 126 words · last cycle 2026-09-21 #### Consumer Protection & APP Fraud HB505 introduces new consumer-fraud protections for virtual-currency kiosks: daily transaction limits of $2,000 for new customers and $10,000 for existing customers, and mandatory full refunds within 72 hours for fraud losses, responding to more than $33 million in FBI/FTC-reported Florida kiosk-fraud losses between January 2020 and December 2025. These protections have staged effective dates: the consumer-protection provisions take effect 1 January 2027, distinct from the 1 March 2027 operator-registration requirement. Florida has not enacted a dedicated authorised-push-payment fraud mandatory-reimbursement regime comparable to the UK's Payment Systems Regulator model. #### Outlook The kiosk consumer-protection provisions take effect 1 January 2027; watch for OFR guidance on implementation ahead of that date and for whether kiosk-fraud loss figures continue to climb before the protections activate. Periodic update · new data 2026-09-22 #### Consumer Protection & APP Fraud Florida House Bill 505, pending as of this cycle, would mandate an on-screen fraud-warning disclosure at virtual-currency kiosk terminals before a customer may initiate a transaction. This is a Probable-tier, Tier 1-sourced finding reflecting the bill's pending, not-yet-enacted status. The provision targets a payment channel, physical virtual-currency kiosks, that has drawn national regulatory and law-enforcement attention as a vector for authorised-push-payment-style fraud, where victims are induced to deposit funds into a kiosk under fraudulent pretences. The disclosure mandate is bundled in the same bill as a proposed fee exemption for kiosk-only operators, meaning the consumer-facing protection measure and the operator cost-relief measure are advancing, or stalling, together as a single legislative package rather than as independent initiatives. No other Florida-specific consumer-protection or APP-fraud development was identified in this cycle's evidence. #### Outlook Watch for whether HB 505 is enacted; if it passes, Florida would establish its first kiosk-specific consumer-facing fraud-warning requirement, a narrow but concrete APP-fraud mitigation measure applied to a channel that has otherwise operated without such a disclosure obligation. **2 earlier distinct update(s)** Periodic update · new data 2026-09-14 #### Consumer Protection & APP Fraud Florida's Chapter 2026-178 (HB 505) builds an APP-fraud-style consumer-protection layer directly into the state's new virtual-currency-kiosk framework. The Act mandates on-screen fraud warnings displayed to customers before a transaction, provision of transaction receipts, and daily transaction caps set at $2,000 for new customers and $10,000 for existing customers. Its centrepiece consumer remedy is a conditional full refund: a kiosk operator must refund a customer's first fraudulent kiosk transaction in full within 72 hours, provided the customer reports the alleged fraud to both the business and a law-enforcement or governmental agency within 60 days and supplies supporting proof. These terms were shaped directly by documented county-level fraud data rather than abstract policy design. The Flagler County Sheriff's Office documented over $2.75 million in fraudulent kiosk transfers from county residents, predominantly retirees, over a two-year period, a figure that helped drive the legislative push behind HB 505. Statewide, 2025 figures cited kiosk-related consumer losses at $32.8 million across 1,213 complaints, establishing the scale of the harm the Act was designed to address. Notably, a proposed 24-hour transaction hold did not survive the legislative process, an omission that the interpreter's key judgment attributes to industry pushback moderating the final consumer-protection package relative to its originally proposed form. The resulting statute therefore represents a negotiated compromise: real-time fraud warnings and transaction caps at the point of sale, paired with a retrospective refund mechanism, rather than a preventive transaction-delay mechanism that would have given victims or authorities a window to intervene before funds moved. #### Outlook The consumer-protection provisions take effect January 1, 2027, and their real-world test will be whether the combination of fraud warnings, transaction caps and the 72-hour refund mechanism meaningfully reduces the fraud-loss pattern documented at the county and state level, absent the stronger transaction-hold safeguard that was dropped during negotiation. Periodic update · new data 2026-09-08 #### Consumer Protection & APP Fraud HB 505 imposes a defined set of consumer-protection obligations on Florida virtual-currency-kiosk operators, confirmed at the highest confidence tier in this cycle's evidence. Kiosk operators must issue fraud-warning disclosures, observe daily transaction limits of $2,000 for customers who have used the kiosk for fewer than seven days and $10,000 for all other customers, and refund first-time fraud victims who meet applicable reporting requirements. These mechanisms are structured around the fraud-vector specific to crypto-kiosk transactions, where a victim is typically directed by a scammer to deposit cash into a kiosk for irreversible conversion to crypto, and the tiered transaction limits are designed to cap the exposure of new or first-time users specifically, who research shows are disproportionately targeted by such schemes. The first-transaction fraud refund obligation is a notably concrete consumer-remedy mechanism, requiring the covered kiosk operator to make the victim whole on the first fraudulent transaction where reporting requirements are satisfied, which functions similarly in principle to authorised-push-payment fraud reimbursement mechanisms seen in other jurisdictions' account-based payment-fraud frameworks, though applied here specifically to the crypto-kiosk channel rather than bank transfers. #### Outlook Watch for the practical implementation of the refund mechanism once HB 505 takes effect on January 1, 2027, including how OFR defines the reporting requirements a victim must satisfy to qualify for the first-transaction refund, and whether kiosk operators' compliance with the disclosure and limit requirements becomes a documented OFR examination focus. **Sources and findings (4)** 1. T1 [https://floridapolitics.com/archives/784938-legislature-passes-virtual-currency-kiosks-measure/](https://floridapolitics.com/archives/784938-legislature-passes-virtual-currency-kiosks-measure/) retrieved 2026-07-05 2. T1 [https://www.flsenate.gov/Session/Bill/2026/505/Analyses/h0505z.IBS.PDF](https://www.flsenate.gov/Session/Bill/2026/505/Analyses/h0505z.IBS.PDF) retrieved 2026-07-05 3. T1 [https://www.myfloridalegal.com/consumer-protection](https://www.myfloridalegal.com/consumer-protection) retrieved 2026-07-05 4. T2 [https://www.mofo.com/resources/insights/241111-uptick-in-florida-telephone-solicitation-act-litigation](https://www.mofo.com/resources/insights/241111-uptick-in-florida-telephone-solicitation-act-litigation) retrieved 2026-07-05 ### W11 AML/CFT & Financial Crime (Sentinel.gi-fed) moved [Sourced from Sentinel.gi ↗](https://sentinel.gi/jurisdictions/united-states-florida/#sec-dom-D7) Confirmed confirmed 2026-07-05 sentinel.wpm-us-fl: Florida's AML/CFT posture for payments rests on the Chapter 560 Control of Money Laundering in Money Services Businesses Act (BSA-aligned recordkeeping and SAR obligations), newly extended to stablecoin issuers, plus a blockchain-analytics mandate for virtual-currency kiosks and a persistent Miami correspondent-banking de-risking/sanctions-exposure dynamic tracked via the FIBA compliance community. Movement — CHANGED Stablecoins added to Florida AML statute_AML perimeter expansion via statutory amendment_ Standing sub-brief · as of 5 July 2026 179 words · last cycle 2026-10-13 #### AML/CFT & Financial Crime This module's intelligence is sourced from the Sentinel.gi feed; WPM carries the finding forward without independent illicit-finance analysis. The Florida Control of Money Laundering in Money Services Business Act requires AML programs, comprising risk assessment, employee training and a compliance officer, for MSB licensees, with SAR filing to FinCEN upon identification of questionable transactions. SB314 extends these Bank Secrecy Act-aligned obligations to stablecoin issuers by adding stablecoins to the statutory definition of monetary value, effective alongside the substantive stablecoin licensing provisions on 1 October 2026. Separately, a Miami-based bank's 2017 opening of a correspondent account for Banco de Venezuela, despite competitor de-risking amid sanctions pressure, later drew regulatory scrutiny via a consent order; the sanctions-evasion dimension of this dynamic has been routed to the Financial Intelligence Monitor as exceeding WPM's payments-instrument scope. #### Outlook The SB314 AML extension to stablecoin issuers takes effect alongside substantive licensing on 1 October 2026. For further analysis of the correspondent-banking sanctions dimension, see the Financial Intelligence Monitor; this module will continue to carry Sentinel.gi-fed findings rather than original illicit-finance conclusions. Periodic update · new data 2026-10-13 #### AML/CFT & Financial Crime Florida's payment-stablecoin framework carries a direct AML dimension distinct from, but commencing alongside, its licensing requirement: the state's Control of Money Laundering in Money Services Business Act was amended to add payment stablecoins to the definition of monetary value, prohibiting unlicensed issuance under that AML statute specifically. This means a stablecoin issuer operating without the required licence is exposed on two separate statutory fronts simultaneously — the money-transmitter licensing requirement and the AML monetary-value prohibition — both administered by the same regulator, the Office of Financial Regulation, and both tied to the same October 1, 2026 effective date. This AML extension sits within Florida's existing Chapter 560 enforcement architecture rather than creating a parallel enforcement track, meaning the regulator's established enforcement tools and track record under that chapter now extend to the newly covered stablecoin activity. The broader financial-crime relevance is that this is the first instance of a US state explicitly folding a digital-asset category into its own anti-money-laundering statute's core definitional architecture, rather than relying solely on federal AML frameworks or general money-transmission licensing to capture the activity. #### Outlook How Florida's AML extension interacts in practice with federal AML expectations for payment stablecoins, as those develop under the GENIUS Act framework, is an open structural question. No specific AML enforcement action targeting stablecoin activity under the new provision has been identified, since the provision has only just commenced. **1 earlier distinct update(s)** Periodic update · new data 2026-09-28 #### AML/CFT & Financial Crime This slot is supplied by the financial-integrity consumer, which authors the substantive AML/CFT analysis of Florida's Chapter 560 amendments; no first-party world-payments prose is written here beyond noting that the same legislative package driving the W1a and W2 developments above also carries an AML/CFT dimension tracked separately. #### Outlook See the financial-integrity monitor for the AML/CFT-specific outlook on Florida's Chapter 560 amendments. **Sources and findings (9)** 1. T2 sentinel.https://coinmarketcap.com/academy/article/florida-becomes-first-us-state-to-pass-a-stablecoin-regulatory-bill 2. T? FIM (sentinel.gi) per-JID baseline profile — United States — Florida — Florida operates under the federal BSA/AML architecture (FinCEN, OFAC) with no independent state AML supervisory regime beyond Florida Office of Financial Regulation (OFR) licensing of money services businesses/money transmitters under Ch. 560. Federal beneficial-ownership reporting for Florida-formed entities was eliminated in March 2025. 3. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-005) — Gap: sourcing-thinness 4. T2 FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-003) — Enforcement: U.S. Department of Justice / U.S. Attorney's Office, Southern District of Florida — Close associate of ousted Venezuelan President Nicolás Maduro 5. T2 FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-003) — Sanctions: OFAC listing 6. T1 FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-001) — Enforcement: OFAC — TradeStation Securities, Inc. (Florida-headquartered brokerage) 7. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: regulatory-failure 8. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: legal-gap 9. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-004) — Gap: capacity-deficit ### W12 Correspondent Banking, Settlement & Access Confirmed confirmed 2026-07-05 Florida's correspondent-banking and cross-border settlement access architecture runs through Chapter 663 (International Banking), which lets OFR licence foreign-bank agencies/branches/offices, with Miami serving as a de facto US correspondent-banking hub for Latin America, subject to sanctions-driven de-risking pressure. Standing sub-brief · as of 5 July 2026 148 words · last cycle 2026-07-05 #### Correspondent Banking, Settlement & Access The module's analytical spine is the asymmetry between bank and non-bank access to correspondent infrastructure. Chapter 663, Florida Statutes, authorises Office of Financial Regulation licensing of foreign-bank agency, branch and representative offices in Florida, with capital-equivalency deposits required in Florida or national banks or a Federal Reserve Bank; this is a bank-only access architecture distinct from the non-bank Chapter 560 licensing regime tracked in W1a. The Florida International Bankers Association and the wider Miami correspondent-banking cluster serve as a de facto US correspondent-banking hub for Latin America and a recognised Center for Excellence for AML compliance training across the LatAm/Caribbean correspondent-banking corridor. #### Outlook No material change to Florida's Chapter 663 access architecture was identified this cycle. The sanctions-driven de-risking dynamic around Miami correspondent banking (see W7/W11) bears continued monitoring for its effect on bank-mediated access alongside the non-bank corridor infrastructure tracked in W5. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T1 [https://codes.findlaw.com/fl/title-xxxviii-banks-and-banking/fl-st-sect-663-01/](https://codes.findlaw.com/fl/title-xxxviii-banks-and-banking/fl-st-sect-663-01/) retrieved 2026-07-05 2. T1 [https://myfloridacfo.com/about/about-dfs/commission](https://myfloridacfo.com/about/about-dfs/commission) retrieved 2026-07-05 3. T1 [https://flofr.gov/divisions-offices/division-of-financial-institutions](https://flofr.gov/divisions-offices/division-of-financial-institutions) retrieved 2026-07-05 4. T1 [https://www.leg.state.fl.us/Statutes/index.cfm?App_mode=Display_Statute&URL=0600-0699/0663/0663.html](https://www.leg.state.fl.us/Statutes/index.cfm?App_mode=Display_Statute&URL=0600-0699/0663/0663.html) retrieved 2026-07-05 5. T2 [https://www.govinfo.gov/content/pkg/USCOURTS-flsd-1_22-cv-20201/pdf/USCOURTS-flsd-1_22-cv-20201-3.pdf](https://www.govinfo.gov/content/pkg/USCOURTS-flsd-1_22-cv-20201/pdf/USCOURTS-flsd-1_22-cv-20201-3.pdf) retrieved 2026-07-05 ### W13 Commercial Intelligence (M&A, Investment & Product) limited signal Probable confirmed 2026-07-05 Florida established a state-run pilot allowing certain state fees to be paid using stablecoins via the Department of Financial Services, separate from the OFR-supervised private-issuer licensing regime. Standing sub-brief · as of 5 July 2026 196 words · last cycle 2026-10-13 #### Commercial Intelligence (M&A, Investment & Product) No Florida-specific fintech or payments M&A transaction was identified within the trailing-twelve-month baseline window despite dedicated search, a gap consistent with WPM's known under-indexing of private-company deal activity relative to Miami's dense private fintech cluster. Available commercial signal was organic rather than transactional: Félix, the Miami-based remittance fintech, reported its team doubling from 150 to 300 employees and its user base more than doubling from 175,000 to 400,000 over the trailing twelve months to March 2026, though this growth data does not fit the closed commercial-event enum (M&A, investment, product release, partnership restructuring) and is carried here as contextual background rather than a discrete event. Governor DeSantis and the Florida Legislature signed the stablecoin-issuer and virtual-currency-kiosk bills into law on 27 June 2026, a market-enabling regulatory event for future Florida stablecoin-issuance products, though a legislative signing likewise does not constitute a discrete commercial event under the closed enum. #### Outlook Watch for whether Florida's now-enacted stablecoin framework catalyses a discrete, disclosable M&A or investment transaction once substantive licensing takes effect in October 2026; the current absence of qualifying deal activity is treated as a research gap rather than a null market. Periodic update · new data 2026-10-13 #### Commercial Intelligence & Fintech Miami's fintech sector shows a funding deceleration in 2026 relative to 2025. Miami-based fintech companies reportedly raised $334 million in equity funding across 14 rounds in 2026 year-to-date through September, compared with $367 million raised across 36 rounds over the same period in 2025. Both the total funding amount and, notably, the number of rounds declined substantially, suggesting a market shift toward fewer, larger transactions rather than a broad-based increase in fintech funding activity across the sector. This figure derives from a market-data vendor source rather than from a primary regulatory filing, and should be read with that provenance in mind. Separately, a specific regulatory-commercial intersection event occurred within this cycle's collection window: the Florida Office of Financial Regulation entered a consent order on March 13, 2026 fining an unlicensed money-transmission software company $155,000 for alleged unlicensed MSB activity. This is a discrete enforcement event distinct from the broader funding-trend data, illustrating that Florida's money-services licensing regime continues to generate concrete enforcement outcomes against specific commercial actors even as the broader funding environment for the sector softens. #### Outlook Whether Miami's fintech funding pace recovers toward 2025 levels over the remainder of 2026, or whether the shift toward fewer and larger rounds persists, is the clearest open question this cycle's commercial-intelligence signal raises. No further OFR enforcement action beyond the March 2026 consent order was identified within this cycle's window. **1 earlier distinct update(s)** Periodic update · new data 2026-09-03 #### Commercial Intelligence & Fintech Florida's Department of Financial Services has had a pilot approved allowing certain state fees to be paid using stablecoins, distinct from the OFR-supervised private-issuer licensing regime described elsewhere in this brief (wpm-2026-W13-001). The pilot is backed by Chief Financial Officer Blaise Ingoglia and sponsored by Senator Nick DiCeglie and Representative Jeff Holcomb. Financial terms have not been publicly disclosed. Confidence in this characterisation is Low, reflecting single-source, Tier-3 sourcing. #### Outlook Watch for disclosure of the pilot's technical implementation and any financial terms in a subsequent cycle. **Sources and findings (3)** 1. T3 [https://refreshmiami.com/news/felix-is-turning-whatsapp-into-a-remittance-engine-for-400000-immigrants/](https://refreshmiami.com/news/felix-is-turning-whatsapp-into-a-remittance-engine-for-400000-immigrants/) retrieved 2026-07-05 2. T1 [https://infobytes.orrick.com/2026-03-20/florida-fines-software-company-155k-for-alleged-unlicensed-money-transmission/](https://infobytes.orrick.com/2026-03-20/florida-fines-software-company-155k-for-alleged-unlicensed-money-transmission/) retrieved 2026-07-05 3. T1 [https://floridapolitics.com/archives/804440-stablecoin-virtual-currency-kiosk-bills-signed-into-law/](https://floridapolitics.com/archives/804440-stablecoin-virtual-currency-kiosk-bills-signed-into-law/) retrieved 2026-07-05 ** No modules match.** Filters combine as OR inside a group and AND across groups. ## Editorial metadata Provenance only. Nothing below gates publication or affects the render. Editorial metadata for United States – Florida| Field | Value | |---|---| | `trust.lawyer_review.status` | never_reviewed | | `trust.lawyer_review.reviewer` | no reviewer on record | | ` trust.content_source` | ai_generated | ## Provenance and declared absence **Disclosure model:** module cards load OPEN; standing positions render in full; sub-briefs and jurisdiction briefs load as a clamped teaser with an explicit “read full” control carrying the true word count; earlier updates stay collapsed behind a counted summary. No text is hidden without disclosing how much of it there is. **Sentinel-fed modules** receive no special rendering treatment. `sentinel_feed` is an attribution chip only: it does not suppress content, does not generate an absence reason code, and does not exclude the module from any count, filter, search index or export on this page. **Family taxonomy** is renderer-level presentation config, not a JID field. Colour is always duplicated in text and is never the sole carrier of meaning. **Suppressed by doctrine:** derived risk score; per-module RAG traffic light; `derived_scores` = `{"legal_accessibility": {"per_product": {"account_to_account": "regulated", "cards": "regulated", "stablecoin": "emerging-regime"}}}`. **Band honesty:** uncertainty bands are computed against a frozen build clock of 2026-10-21. A year-precision row is never promoted into a tighter band. **Orphan deltas:** 0 cycle_delta row(s) target non-module objects and are listed in the rail rather than attached to a card. **Envelope:** baseline resolved at `jurisdiction_json.baseline`; 14 module(s), 65 finding(s), 132 source(s) in the cumulative register. Think something on this page is wrong? [Report an error](https://payments.gi/legal/#contact).