title: United States – Georgia Payments Regulation Monitor | World Payments Monitor canonical: https://payments.gi/jurisdictions/united-states-georgia/ date_modified: 2026-10-21 publisher: Asymmetric Intelligence # United States – Georgia US-GA schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-21 · 14 modules · 59 sourced findings · 228 sources in the cumulative register 14 Modules baseline.modules[] 59 Findings modules[].findings[] 150 Tier-1 sources run_metadata.t1_source_count Confidence mix (sums to 14 rendered modules; click to filter) No modules moved this cycle. ** United States federal law** that applies in United States – Georgia is covered once, on the [United States](https://payments.gi/jurisdictions/united-states/) page. This page covers United States – Georgia’s own layer: its own law, regulators and enforcement. ## Jurisdiction brief ###### Latest update · 18 October 2026 #### Lead Signal Georgia's Department of Banking and Finance entered a Consent Order with Coinme, Inc. on 2026-10-07, coordinated with 33 other state and territorial regulators. The order requires cessation of all Georgia virtual-currency kiosk operations before 2027-01-01, retention of an independent consultant to review Coinme's BSA/AML program, and a 2.5 million dollar multistate settlement. Coinme holds NMLS registration (NMLS #1185542), meaning this is an enforcement action against a licensed money-transmission business found deficient in its compliance program, not a case of operating entirely outside the licensing perimeter. That distinction matters because the same cycle also surfaces a Georgia DBF Order to Cease and Desist against Polar Tensor US, finalized 2026-09-17, for operating an online virtual-currency trading platform in Georgia with no license at all, in violation of O.C.G.A. section 7-1-681. Together, the two actions show DBF exercising its money-transmission licensing authority across the full spectrum of non-compliance, from unlicensed market entry to licensed-but-deficient AML practice, within the Sale of Payment Instruments and Money Transmission Act framework codified at O.C.G.A. section 7-1-680 et seq. #### Other Developments **Coinme settlement terms detail a defined compliance pathway.** Beyond the kiosk-cessation requirement, the Consent Order's independent BSA/AML program review creates an external, regulator-mandated benchmark against which Coinme's ongoing compliance program will be measured, with the multistate nature of the settlement meaning findings from that review carry potential relevance to the 33 other coordinating regulators as well. **Polar Tensor matter confirms active perimeter policing of unlicensed virtual-currency platforms.** The Polar Tensor cease-and-desist, though finalized eleven days before the current recency anchor, is carried forward as directly relevant backfill: it demonstrates that DBF's money-transmission licensing perimeter is being actively enforced against online virtual-currency trading platforms with no Georgia license, not merely against licensed-but-deficient operators like Coinme. #### Cross-Monitor Connections The Coinme Consent Order's independent BSA/AML program review requirement sits directly at the boundary between payments licensing and financial-crime compliance; the underlying AML program adequacy question is a matter for financial-integrity monitoring rather than payments-market analysis, and is tracked there. This brief notes the licensing and market-access dimension of the action, the fact that a licensed money-transmission business faces a defined compliance pathway and operational cessation deadline, without re-analysing the AML program findings themselves. #### Outlook With the Coinme kiosk-cessation deadline set for 2027-01-01 and the independent BSA/AML review still pending, the licensing and market-access picture for virtual-currency kiosk operators in Georgia will likely remain unsettled through the first quarter of 2027. The Polar Tensor cease-and-desist, now final and closed, stands as a marker of how DBF treats unlicensed virtual-currency money transmission, and the coordinated, multistate nature of the Coinme settlement suggests other kiosk and exchange operators licensed in Georgia should expect continued active supervisory attention to BSA/AML program adequacy as a condition of maintaining market access. _5 earlier updates not shown here._ ###### Standing brief · as of 6 August 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Lead Signal Georgia's Department of Banking and Finance has closed out a multi-chapter rulemaking cycle affecting the state's licensing and market-access perimeter for payments firms. The department's 2026 final rulemaking package became effective July 6, 2026, adopting new Rule 80-3-1-.07. The state's own primary rules record — the Georgia Secretary of State's official compilation — is consistent with the DBF 2026 package taking effect, corroborating the effective date independently of the specialist-vendor reporting that first surfaced it. The statutory foundation underneath the money-transmission piece of that package is unchanged this cycle: anyone transmitting money or monetary value for Georgia consumers must be licensed by the DBF absent a narrow exemption, with applications routed through the Nationwide Multistate Licensing System. What is new is the package's reach beyond money transmission alone — it extends into merchant-acquirer limited-purpose bank rules and adjacent installment-lending and litigation-financing chapters within the same filing. That reach is itself the signal. The filing has been assessed as unusually broad relative to typical single-topic state rulemakings, and read against that breadth, it looks less like an isolated money-transmission adjustment than a consolidation of state-level oversight capacity spanning the non-bank payments perimeter and adjacent consumer-credit activity in a single regulatory action. The package's own instrument-level detail, notably the text of the newly adopted rule, has not yet been independently confirmed beyond this scope-level and effective-date picture. #### Other Developments Away from the licensing chapter, Georgia's conduct-and-safeguarding regime for non-bank money transmitters — a distinct module from the market-access rulemaking above — continues on its existing terms this cycle. Licensees must maintain sufficient collected funds in a clearing account, file quarterly outstanding-transaction reports within 45 days via NMLS, and maintain a surety bond up to a statutory $2,000,000 cap. Those conditions apply to licensed non-bank transmitters specifically; the department's depository-institution and merchant-acquirer limited-purpose bank provisions, folded into the same 2026 omnibus filing, sit under separate bank-regulatory rules rather than the non-bank safeguarding framework described here. On product innovation, the picture is comparatively stable. No state-specific stablecoin or prepaid carve-out identified this cycle; Georgia's regime remains procedurally standard NMLS-routed, DBF-administered relative to peer states, with this cycle's point of distinction being the unusual scope of the omnibus filing rather than any new instrument-specific treatment. That relative quiet on the product side is itself informative: it suggests the department's 2026 attention has gone toward consolidating licensing and safeguarding machinery across adjacent categories rather than toward new-instrument regulation. #### Cross-Monitor Connections No cross-monitor signal was flagged for this cycle. The sibling illicit-finance monitor has no active linkage recorded against this US-GA licensing and safeguarding development at this time, and none of the developments described above extend beyond the payments-regulatory perimeter into illicit-finance analysis. #### Outlook Full regulatory text of new Rule 80-3-1-.07 was not independently retrieved this cycle, leaving the precise operative detail behind the effective-date and scope findings above pending confirmation against primary text. The next scheduled inflection point for this jurisdiction is the 2027-period Georgia money-transmitter / merchant-acquirer limited-purpose bank licence renewal cycle, which will be the first renewal cycle to run under the amended 2026 rule chapters. trust tier: ai_unverified ###### Latest update · 8 September 2026 #### Regulatory Status Georgia's Department of Banking and Finance directly regulates money-transmission activity in the state, and on June 16, 2026 finalized a rule package implementing HB 945's virtual-currency kiosk statute (O.C.G.A. §§ 7-1-699.9, 7-1-699.10). The finalized conditions require standardised quarterly kiosk-location reporting via NMLS, mandate that consumer refunds be paid in fiat currency with a choice of refund method, and condition continued kiosk operation on maintaining a contractual relationship with an existing third-party blockchain-analysis firm alongside risk-based policies and procedures. DBF's own regulations index separately confirms the same 'DBF Final Rulemaking: 6-16-2026' document. #### Outlook Applying the state's standard 20-day post-filing rulemaking timeline places the rule's in-force date at approximately early July 2026, inside the current window; that estimate is held at Assessed confidence pending an explicit DBF-stated effective date. On this basis Georgia's regulatory trajectory for payments/money-transmission is assessed as tightening. Open items for a future pass include Georgia's positioning on state-level stablecoin certification pathways and the status of a prior conditional bank-charter approval in the state, neither of which could be confirmed against a primary source this cycle. _1 earlier update not shown here._ ###### Standing brief · as of 6 August 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Regulatory Status The U.S. state of Georgia regulates payments-adjacent activity primarily through the Department of Banking and Finance. Anyone transmitting money or monetary value for Georgia consumers must be licensed by the DBF absent a narrow exemption, with licensing administered via NMLS. This cycle's material development is a departmental rulemaking package: the department's 2026 final rulemaking package became effective July 6, 2026, adopting new Rule 80-3-1-.07 and reaching into merchant-acquirer limited-purpose bank rules and installment-loan and litigation-financing provisions within the same filing — a package assessed as unusually broad relative to typical single-topic state rulemakings. The Georgia Secretary of State's rules compilation is consistent with the DBF 2026 package taking effect, corroborating the vendor-reported effective date from a primary source. Safeguarding obligations for licensed non-bank transmitters are unchanged: licensees must maintain sufficient collected funds in a clearing account, file quarterly outstanding-transaction reports within 45 days via NMLS, and maintain a surety bond up to a statutory $2,000,000 cap. On product innovation, no state-specific stablecoin or prepaid carve-out identified this cycle, leaving Georgia's regime procedurally standard NMLS-routed, DBF-administered relative to peer states. #### Outlook Full regulatory text of new Rule 80-3-1-.07 was not independently retrieved this cycle. The next scheduled inflection point is the 2027-period Georgia money-transmitter / merchant-acquirer limited-purpose bank licence renewal cycle, the first renewal cycle to run under the amended 2026 rule chapters. 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 Georgia money transmission licensing is unchanged in structure, but DBF enforcement activity against unlicensed/non-compliant virtual-currency money-transmission businesses intensified in-window: a multistate Consent Order against Coinme (2026-10-07) and a finalized cease-and-desist against Polar Tensor US (final 2026-09-17). Horizon · 2025-07-01 (±quarter) Georgia HB 15 (Title 7 modernization) entered into force_in_force · TT3_ Horizon · 2026-Q3 (±quarter) Georgia VC Kiosk Final Rule enters into force_in_force · TT1_ Horizon · 2025-07-01 (±quarter) Georgia HB 15 (Title 7 modernization) entered into force_in_force · TT3_ Standing sub-brief · as of 6 August 2026 344 words · last cycle 2026-10-18 #### Licensing, Authorisation & Market Access Georgia regulates money transmission under the Sale of Payment Instruments and Money Transmission Act, administered by the Department of Banking and Finance. Anyone transmitting money or monetary value for Georgia consumers must be licensed by the DBF absent a narrow exemption, with applications routed through the Nationwide Multistate Licensing System — a standing statutory basis that is unchanged this cycle, and one that runs through a Money Transmitter License (NMLS-routed, DBF-issued). What has changed is the rulebook sitting on top of that statute. The department's 2026 final rulemaking package became effective July 6, 2026, adopting new Rule 80-3-1-.07 and amending chapters beyond money transmission alone — reaching into merchant-acquirer limited-purpose bank rules and installment-loan and litigation-financing provisions within the same filing. The Georgia Secretary of State's official rules compilation is consistent with the DBF 2026 package taking effect, giving the effective date independent Tier-1 corroboration beyond the specialist-vendor source that first reported it. The filing's breadth is the analytically interesting part. It has been assessed as unusually broad relative to typical single-topic state rulemakings, bundling money-transmission amendments with rules for merchant-acquirer limited-purpose banks and consumer-credit instruments that are not, on their face, part of the same regulatory family as payments licensing. Read that way, the 2026 package looks like an exercise in consolidating the department's oversight machinery across several adjacent non-bank and quasi-bank licensing categories at once, rather than a routine, single-issue update to the money-transmitter rulebook. The bank-versus-nonbank access question stays live within the same filing: money-transmission licensing continues to run through the NMLS-routed, DBF-issued Money Transmitter License, distinct from the merchant-acquirer limited-purpose bank licence category folded into the same rulemaking. #### Outlook Full regulatory text of new Rule 80-3-1-.07 was not independently retrieved this cycle, so the precise operative detail behind the effective-date and scope findings above remains to be confirmed against primary text. The next material checkpoint for this module is the 2027-period Georgia money-transmitter / merchant-acquirer limited-purpose bank licence renewal cycle, which will be the first licensing cycle to operate under the amended 2026 rule chapters. Periodic update · new data 2026-10-18 #### Licensing, Authorisation & Market Access Georgia's money-transmission licensing perimeter for virtual-currency activity, established under the Sale of Payment Instruments and Money Transmission Act at O.C.G.A. section 7-1-680 et seq., saw active enforcement this cycle at both ends of the compliance spectrum. On 2026-10-07, the Georgia Department of Banking and Finance entered a Consent Order with Coinme, Inc. (NMLS #1185542), coordinated with 33 other state and territorial regulators, requiring cessation of all Georgia virtual-currency kiosk operations before 2027-01-01, retention of an independent consultant to review Coinme's BSA/AML program, and a 2.5 million dollar multistate settlement. Because Coinme holds NMLS licensure, this action illustrates that holding a money-transmitter license does not by itself satisfy Georgia's market-access requirements; ongoing compliance-program adequacy, specifically BSA/AML program quality, is treated by DBF as a condition of continued market access, not merely of initial licensing approval. The same reporting window also carries forward a Georgia DBF Order to Cease and Desist against Polar Tensor US, which became final on 2026-09-17. That action addressed the opposite end of the licensing spectrum: Polar Tensor US operated an online virtual-currency trading platform in Georgia without holding any valid money-transmitter license, in violation of O.C.G.A. section 7-1-681. Although finalized eleven days before the current recency anchor, the matter is carried forward here as directly relevant because it demonstrates DBF's willingness to use its cease-and-desist authority against virtual-currency platforms that attempt market entry without licensure at all, a distinct but complementary enforcement posture to the Coinme consent order's focus on a licensed-but-deficient operator. Read together, the two actions describe a licensing and market-access environment in which Georgia's DBF is actively exercising authority across the full range of money-transmission compliance failure: unlicensed market entry (Polar Tensor US) and licensed operation with inadequate ongoing compliance infrastructure (Coinme). For virtual-currency kiosk and exchange operators considering or maintaining Georgia market access, this cycle's developments indicate that licensure is a threshold requirement rather than a safe harbor, and that DBF retains active supervisory and enforcement capacity to revisit a licensed operator's compliance program when deficiencies are identified, up to and including mandating independent program review and market-access restrictions such as the kiosk-cessation requirement imposed on Coinme. The multistate, 34-regulator coordination behind the Coinme Consent Order is itself a market-access-relevant structural feature: a licensing or compliance deficiency identified by one state regulator in this coalition framework can translate into simultaneous consequences, financial settlement and operational restriction, across the broader coalition's jurisdictions. This raises the practical stakes of maintaining money-transmission licensing compliance in any single coalition member state, since findings are not necessarily contained to that one jurisdiction's enforcement action alone. #### Outlook The Coinme Consent Order's kiosk-cessation deadline of 2027-01-01 and its still-pending independent BSA/AML program review mean the licensing and market-access status of Georgia virtual-currency kiosk operations remains an active, evolving matter rather than a closed one. Firms licensed to conduct virtual-currency money transmission in Georgia should expect that DBF's demonstrated willingness to revisit licensed operators' compliance programs, evidenced by the Coinme action, alongside its continued willingness to act against unlicensed platforms, evidenced by the now-final Polar Tensor US order, together signal sustained active supervisory engagement with the licensing perimeter through the period ahead. Whether the independent BSA/AML review of Coinme's program surfaces findings that prompt further market-access conditions, or whether other coalition-member regulators take parallel action, remains to be seen as the review proceeds. **5 earlier distinct update(s)** Periodic update · new data 2026-09-28 #### Licensing, Authorisation & Market Access Georgia's Department of Banking and Finance finalized its 2026 omnibus rulemaking package with an effective date of July 6, 2026. The package adopted new Rule 80-3-1-.07 and restructured the money-transmission, merchant-acquirer, and litigation-financier chapters of the state's regulatory code in a single coordinated cycle, rather than through piecemeal amendment. This is a market-access-relevant development for any bank, non-bank payment institution, or e-money issuer with money-transmission activity touching Georgia, since the restructured chapters govern the licensing pathway itself. Alongside the substantive licensing restructuring, DBF adopted a companion penalty rule, 80-3-4-.01, effective the same date, introducing daily fines for two distinct categories of non-compliance: unlicensed money-transmission activity, and licensing or financial-requirement failures by already-licensed entities. The daily-fine structure is a meaningfully different enforcement mechanic from a one-time penalty, since it compounds with the duration of non-compliance, raising the practical cost of delayed remediation for both unlicensed operators and licensees who fall out of compliance with financial-requirement conditions. Taken together, the two rules represent a single-cycle overhaul of both the licensing framework and its enforcement teeth for money transmission in Georgia, distinguishing licensed bank and non-bank payment activity from the enforcement exposure now attached to operating outside that licensing perimeter. #### Outlook The near-term question for market participants is how DBF applies the new daily-fine mechanic in practice, and whether early enforcement actions under Rule 80-3-4-.01 target unlicensed activity, licensee financial-requirement lapses, or both. The restructured licensing chapters should also be watched for their treatment of virtual-currency-kiosk operators specifically, given the parallel HB 945 consumer-protection regime that layers additional obligations onto that same operator population. Periodic update · new data 2026-09-14 #### Licensing, Authorisation & Market Access Georgia's payments-licensing perimeter for virtual-currency businesses tightened materially this cycle through a rulemaking package finalized by the Department of Banking and Finance. The package, adopted June 16, 2026 and effective July 6, 2026, amended Rules 80-1-1-.11, 80-1-8-.01 and 80-2-12-.02 and added a new Rule 80-3-4-.01. The centerpiece of the new rule is a graduated administrative-fine schedule for virtual-currency kiosk operators, including a one-thousand-dollar-per-day penalty for unlicensed activity, alongside separate penalties tied to NMLS-update failures, bonding shortfalls, and net-worth deficiencies. This is entirely a non-bank payment-institution and e-money-institution development: Georgia's licensing architecture for virtual currency has always been folded into the general money-transmitter statute rather than carved out as a separate license class, and this rulemaking operates within that same architecture rather than creating a new one. The practical effect is to give DBF a standing, codified enforcement tool against unlicensed virtual-currency kiosk operation, where previously the regulator's primary tool was case-by-case cease-and-desist action. A Georgia Secretary of State rules-compilation tracking source corroborates that the package took effect on the stated schedule, providing independent confirmation of the effective date beyond the primary vendor-summary sourcing. The rulemaking's scope extending across three amended rules in addition to the new one suggests DBF used this cycle to make a broader set of adjustments to its licensing and supervisory framework, touching points beyond the kiosk-specific fine schedule alone, though the kiosk provision is the most concrete and market-relevant element identified this cycle. For non-bank payment institutions and e-money institutions operating or considering operating virtual-currency kiosk services in Georgia, this rulemaking raises the compliance stakes attached to licensing status specifically, since the cost of operating without a license is now a defined, per-day, escalating figure rather than an open-ended enforcement risk. Firms already licensed and in good standing face no new substantive obligation from this rule beyond the existing bond, net-worth, and NMLS-reporting requirements the rule's penalty provisions are designed to enforce. #### Outlook Assessed as probable, DBF will use the new Rule 80-3-4-.01 fine schedule as its primary enforcement mechanism against future unlicensed virtual-currency kiosk activity, reducing the regulator's reliance on individualized cease-and-desist proceedings for this specific channel going forward. The rulemaking's tightening trajectory is consistent with a broader pattern of Georgia closing enforcement gaps within its existing general money-transmission framework rather than legislating a bespoke virtual-currency licensing regime; no indication of such a bespoke regime emerging was identified this cycle. The most significant open item for market-access assessment purposes is independent retrieval of the Georgia Secretary of State's primary rules-compilation text, since current findings rely on tier-3 vendor summaries corroborated by a T2/T3 secondary tracking source rather than the primary rule text itself; this remains recorded as a sourcing gap to close in a future cycle rather than a substantive uncertainty about whether the rule took effect. Periodic update · new data 2026-09-08 #### Licensing, Authorisation & Market Access [2026-06-16, US-GA] DBF finalized a virtual-currency kiosk operator rule package under HB 945 (O.C.G.A. §§ 7-1-699.9, 7-1-699.10): (i) standardised 'Georgia VC Kiosk Location Report' filings via NMLS within 45 days of quarter-end, naming the kiosk owner if different from the operator; (ii) consumer refunds under § 7-1-699.9 must be paid in fiat currency, with at least electronic/wire transfer and paper-check options offered; (iii) kiosk operation is conditioned on a contractual relationship with an existing third-party blockchain-analysis firm and risk-based policies and procedures. DBF's regulations index corroborates the adopted 'DBF Final Rulemaking: 6-16-2026' document. Applying the state's standard 20-day post-filing timeline (O.C.G.A. § 50-13-6) places the in-force date at approximately early July 2026 (Assessed, not DBF-stated). #### Outlook Confirmation of DBF's own stated effective date would move the in-force estimate from Assessed to Confirmed; absent that, the rule is tracked as in force from early Q3 2026, marking a tightening of Georgia's non-bank money-transmitter perimeter for VC kiosk operators. Periodic update · new data 2026-08-25 #### Licensing, Authorisation & Market Access Georgia's Department of Banking and Finance finalized a 2026 omnibus rulemaking package, effective 6 July 2026, amending banking, credit-union, money-transmission, MALPB, and instalment-loan rules together with newly-added litigation-financing rules, and adopting a new Rule 80-3-1-.07. This class-fix rulemaking event spans multiple regulatory categories in a single instrument, distinguishing it from a single-topic rule change. Alongside the omnibus rulemaking, House Bill 945, effective 1 July 2026, gave the Department new authority to issue cease-and-desist orders against unregistered litigation-finance providers, with judicial review, and created financial-exploitation account-hold procedures for eligible adults; this establishes litigation finance as a new nonbank category within the Department's supervisory perimeter. Separately, and on a dashboard rather than standing-brief footing, the Department finalized a cease-and-desist against Virtual Assets LLC, doing business as Crypto Dispensers, on 16 January 2026, for engaging in money transmission via an online virtual-currency trading platform without a Georgia money transmitter licence, confirming that the existing money-transmission licensing perimeter continues to be actively enforced against nonbank virtual-currency operators alongside the broader 2026 framework refresh. #### Outlook Watch for implementing guidance or enforcement activity under the new Rule 80-3-1-.07, and for the first litigation-finance licence applications or enforcement actions under the Department's new House Bill 945 authority, as the near-term indicators of how actively this expanded nonbank perimeter will be used. Periodic update · new data 2026-08-11 #### Licensing, Authorisation & Market Access Georgia's money-transmission licensing framework moved administratively this cycle when the Department of Banking and Finance's 2026 final rulemaking package became effective July 6, 2026. The package amended money-transmission rules together with rules governing merchant-acquirer limited-purpose banks and adopted new Rule 80-3-1-.07. This finding rests on a Tier 4 vendor report but is corroborated directly by Georgia's official Department 80 rules compilation, maintained by the Secretary of State's office, which shows the rules current through filings made to July 20, 2026, a currency date consistent with the DBF package's confirmed effective date. The statutory foundation beneath this rulemaking activity is unchanged: the Sale of Payment Instruments and Money Transmission Act, codified at O.C.G.A. §7-1-680 et seq., continues to require that anyone transmitting money or monetary value for Georgia consumers hold a Department of Banking and Finance license, absent a narrow statutory exemption, with applications routed through the Nationwide Multistate Licensing System. Nothing in this cycle's evidence indicates the licensing requirement itself, the exemption scope, or the NMLS application channel changed; the confirmed development is procedural and administrative rather than a change to who must be licensed. Beneath the licensing headline sit the operational conditions that define what holding a Georgia money-transmitter license actually requires on an ongoing basis. Licensees must maintain sufficient collected funds in a clearing account at all times, must file quarterly outstanding-transaction reports within forty-five days through the Nationwide Multistate Licensing System, and must maintain a surety bond, which the Department may increase based on the licensee's quarterly outstanding-transaction volume, subject to a statutory cap of two million dollars. These three mechanics, the clearing-account requirement, the quarterly reporting cadence, and the scalable-but-capped bond, together constitute the practical safeguarding regime a Georgia-licensed money transmitter operates under, distinct from and in addition to the initial licensing bar itself. The fact that the same 2026 rulemaking filing amended both the money-transmission rule set and the merchant-acquirer limited-purpose bank rule set is itself worth noting independent of the specific rule text, since it means licensees and applicants tracking only the money-transmission chapter of Georgia's rules could miss a concurrent change to the adjacent merchant-acquirer framework administered by the same Department. That structural pairing, both licensing populations sitting under the Department of Banking and Finance's Department 80 rules compilation, is consistent with Georgia's general approach of housing non-bank payment-services licensing and bank-adjacent merchant-acquiring oversight within a single regulator, rather than splitting them across separate agencies as some other states do. For an operator carrying, or applying for, a Georgia money-transmitter license, the practical implication this cycle is continuity of underlying obligation paired with confirmed administrative movement: the licensing bar, the exemption structure, and the safeguarding mechanics all remain as previously understood, but the new Rule 80-3-1-.07 and the concurrent merchant-acquirer amendment are open items whose substantive content should be confirmed directly against the Department's published rule text before being treated as settled. The bank-PSP versus non-bank-PI/EMI distinction remains material framing for this module even where the confirmed development applies generically: Georgia's money-transmission licensing regime is a non-bank licensing framework, applicable to money-service businesses rather than depository institutions, while the merchant-acquirer limited-purpose bank rules amended in the same filing sit on the bank-adjacent side of the same Department's rulemaking authority. #### Outlook The substantive text of newly adopted Rule 80-3-1-.07 was not independently retrieved this cycle and is the most concrete open item for the next review: confirming its content is necessary before the procedural detail of what changed for licensees beyond the confirmed July 6, 2026 effective date can be fully assessed. Beyond that specific gap, the structural question worth tracking across subsequent cycles is whether the Department's practice of amending money-transmission and merchant-acquirer limited-purpose bank rules within a single filing continues, since that would offer further evidence of coordinated oversight across the two licensing tracks. No additional licensing, safeguarding, or enforcement development for Georgia's payments market was located this cycle beyond the DBF package itself. **Sources and findings (6)** 1. T1 [https://dbf.georgia.gov/money-transmission](https://dbf.georgia.gov/money-transmission) retrieved 2026-07-05 2. T1 [https://dbf.georgia.gov/money-transmission](https://dbf.georgia.gov/money-transmission) retrieved 2026-07-05 3. T1 [https://dbf.georgia.gov/money-service-businesses/money-transmitters/new-money-transmitter-applicant](https://dbf.georgia.gov/money-service-businesses/money-transmitters/new-money-transmitter-applicant) retrieved 2026-07-05 4. T1 [https://rules.sos.ga.gov/gac/80](https://rules.sos.ga.gov/gac/80) retrieved 2026-07-05 5. T3 [https://www.hklaw.com/en/insights/publications/2025/06/georgia-governor-updates-legislation-impacting-banking-and-financial](https://www.hklaw.com/en/insights/publications/2025/06/georgia-governor-updates-legislation-impacting-banking-and-financial) retrieved 2026-07-05 6. T3 [https://www.jwsuretybonds.com/blog/georgia-money-transmitter-license](https://www.jwsuretybonds.com/blog/georgia-money-transmitter-license) retrieved 2026-07-05 ### W1b Conduct, Safeguarding & Promotions Confirmed confirmed 2026-07-05 Safeguarding rests on a surety-bond-plus-liquid-clearing-account model. Georgia enacted its first comprehensive privacy statute, SB 111 (Act 462), signed May 11, 2026, with substantive provisions effective July 1, 2026. A contested 'debanking' bill (SB57/SB341) status is unverified for the 2026 session. A surety-bond-minimum discrepancy ($100,000 vs $250,000) is flagged pending reconciliation. Horizon · 2026-07-01 (±quarter) Georgia SB 111 (Consumer Privacy Protection Act, Act 462) substantive provisions enter into force_in_force · TT3_ Standing sub-brief · as of 6 August 2026 180 words · last cycle 2026-08-05 #### Conduct, Safeguarding & Promotions Georgia's safeguarding regime for licensed non-bank money transmitters continues on established terms this cycle. Licensees must maintain sufficient collected funds in a clearing account, file quarterly outstanding-transaction reports within 45 days via NMLS, and maintain a surety bond up to a statutory $2,000,000 cap. The bond may be increased by the Department based on quarterly outstandings, subject to a $2,000,000 statutory cap; funds also held in a clearing account. This module is distinct from the licensing and market-access rulemaking discussed under W1a: safeguarding conditions attach to the operational conduct of already-licensed non-bank transmitters rather than to the authorisation gateway itself, and they apply specifically to non-bank money transmitters rather than to depository institutions, which sit under separate bank-regulatory safekeeping rules within the same 2026 omnibus filing. No financial-promotion enforcement action was identified for Georgia this cycle. #### Outlook No forward-dated safeguarding change was identified for this jurisdiction this cycle. The module's next checkpoint is procedural rather than substantive: continued monitoring of quarterly outstanding-transaction filings under the existing bond framework as the broader 2026 rule package beds in. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T1 [https://dbf.georgia.gov/information-newly-approved-money-transmitter-licensees](https://dbf.georgia.gov/information-newly-approved-money-transmitter-licensees) retrieved 2026-07-05 2. T1 [https://dbf.georgia.gov/money-service-businesses/msb-frequently-asked-questions](https://dbf.georgia.gov/money-service-businesses/msb-frequently-asked-questions) retrieved 2026-07-05 3. T1 [https://dbf.georgia.gov/information-newly-approved-money-transmitter-licensees](https://dbf.georgia.gov/information-newly-approved-money-transmitter-licensees) retrieved 2026-07-05 4. T2 [https://www.recordinglaw.com/us-laws/data-privacy-laws/georgia-data-privacy-laws/](https://www.recordinglaw.com/us-laws/data-privacy-laws/georgia-data-privacy-laws/) retrieved 2026-07-05 5. T3 [https://www.hklaw.com/en/insights/publications/2025/06/georgia-governor-updates-legislation-impacting-banking-and-financial](https://www.hklaw.com/en/insights/publications/2025/06/georgia-governor-updates-legislation-impacting-banking-and-financial) retrieved 2026-07-05 ### W2 Stablecoins & Digital Money Confirmed confirmed 2026-07-05 Georgia has no standalone stablecoin/digital-asset statute; virtual currency money transmission is folded into the general MTL regime under O.C.G.A. § 7-1-690, which directs DBF to enact virtual-currency-specific rules balancing innovation and consumer protection. DBF actively enforces against unlicensed virtual-currency operators, most recently a January 2026 cease-and-desist against a virtual-currency kiosk operator. Rules for e-money institutions and payment institutions · from [Cryptoassets.gi](https://cryptoassets.gi) · verified 2026-10-18 - ** HB 1272 / Act 452, licensing provisions** — A person must hold a DBF-issued license to issue payment stablecoins in Georgia; unlicensed issuance is prohibited. _(commenced future; in force 2027-01-18)_ [source, 2026-05-15](https://infobytes.orrick.com/2026-05-15/georgia-enacts-state-licensing-regime-for-payment-stablecoin-issuers/) - ** O.C.G.A. § 7-11-17** — A licensed stablecoin issuer must maintain 1:1 reserves in eligible assets, publish monthly certified reserve compositions, and hold reserves in statutory trust without pledging or rehypothecating them except narrowly. _(commenced future; in force 2027-01-18)_ [source, 2026-06-11](https://www.eversheds-sutherland.com/en/united-states/insights/georgia-charts-a-course-on-stablecoin-licensing-what-it-means-for-payments-companies) _ Not yet covered by Cryptoassets.gi for this jurisdiction: how a fiat-referenced token is classified (e-money, stablecoin, e-money token or asset-referenced token) and the tests that decide it; systemic stablecoin regimes: recognition, backing-asset rules and the joint central bank and conduct regulator regime; cross-border market access for stablecoin and e-money activity between neighbouring regimes and its expiry; what an EMI or PI needs in addition to its licence to offer crypto conversion or stablecoin services, including payment-services treatment of token transfers._ Standing sub-brief · as of 7 July 2026 136 words · last cycle 2026-07-05 #### Stablecoins & Digital Money Georgia has no standalone stablecoin or digital-asset statute; virtual-currency money transmission is folded into the general licensing regime under O.C.G.A. §7-1-690, which directs DBF to enact virtual-currency-specific rules, and the statutory definition of "virtual currency" expressly excludes closed-loop affinity or rewards points. DBF has continued to enforce this framework against unlicensed operators: its Cease-and-Desist Order against Virtual Assets LLC, doing business as Crypto Dispensers, became final on January 16, 2026, for operating an unlicensed online virtual-currency trading platform in violation of O.C.G.A. §7-1-681. #### Outlook Absent a dedicated crypto-asset licence, Georgia's approach channels virtual-currency activity — and virtual-currency enforcement — through the same money-transmission statute as fiat transfers. The Crypto Dispensers action signals DBF is willing to use that channel actively against unlicensed platforms rather than treat digital-asset activity as outside its remit. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://codes.findlaw.com/ga/title-7-banking-and-finance/ga-code-sect-7-1-690.html](https://codes.findlaw.com/ga/title-7-banking-and-finance/ga-code-sect-7-1-690.html) retrieved 2026-07-05 2. T1 [https://law.justia.com/codes/georgia/2022/title-7/chapter-1/article-4/section-7-1-680/](https://law.justia.com/codes/georgia/2022/title-7/chapter-1/article-4/section-7-1-680/) retrieved 2026-07-05 3. T1 [https://dbf.georgia.gov/money-transmission](https://dbf.georgia.gov/money-transmission) retrieved 2026-07-05 4. T1 [https://dbf.georgia.gov/press-releases/2026-01-16/order-cease-and-desist-issued-virtual-assets-llc-dba-crypto-dispensers](https://dbf.georgia.gov/press-releases/2026-01-16/order-cease-and-desist-issued-virtual-assets-llc-dba-crypto-dispensers) retrieved 2026-07-05 ### W3 Operational Resilience & Critical Infra Probable confirmed 2026-07-05 Georgia has no standalone payments-specific operational-resilience statute analogous to DORA; resilience oversight flows through DBF's third-party service-provider examination authority over state-chartered banks/credit unions and federal FFIEC/BSA-linked cyber-incident reporting obligations. No GA-specific critical-third-party payments infrastructure regime was located beyond this bank-service-contract framework. 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 7 July 2026 95 words · last cycle 2026-07-05 #### Operational Resilience & Critical Infrastructure Georgia has no standalone payments-specific operational-resilience statute comparable to the EU's DORA. Oversight instead runs through DBF's examination authority over third-party service providers to state-chartered banks and credit unions under O.C.G.A. §7-1-72, with deference to FFIEC-member-agency examinations on a 24-month lookback basis, and state-chartered credit unions carry a 72-hour cyber-incident notification requirement under 12 CFR Part 748. #### Outlook No Georgia-specific critical-third-party payments-infrastructure regime was identified beyond this bank-service-contract framework; resilience oversight for Georgia's payments sector remains a function of federal banking-agency examination cycles rather than a dedicated state payments-resilience rulebook. no periodic updates on record for this sub-brief ** Sources and findings (3)** 1. T1 [https://dbf.georgia.gov/document/document/2023-dbf-final-rulemaking-7-7-23-0/download](https://dbf.georgia.gov/document/document/2023-dbf-final-rulemaking-7-7-23-0/download) retrieved 2026-07-05 2. T1 [https://dbf.georgia.gov/document/document/2023-dbf-final-rulemaking-7-7-23-0/download](https://dbf.georgia.gov/document/document/2023-dbf-final-rulemaking-7-7-23-0/download) retrieved 2026-07-05 3. T1 [https://dbf.georgia.gov/document/document/2023-dbf-final-rulemaking-7-7-23-0/download](https://dbf.georgia.gov/document/document/2023-dbf-final-rulemaking-7-7-23-0/download) retrieved 2026-07-05 ### W4 Scheme & Network Compliance Confirmed confirmed 2026-07-05 Georgia is one of a small group of US states (with New York, New Jersey, Nevada, South Dakota, Nebraska) that caps card surcharges at the merchant's actual cost of acceptance and separately regulates 'convenience fees,' layered atop card-network (Visa/Mastercard) surcharge-cap rules and federal PCI DSS expectations enforced contractually by acquirers/networks rather than by state statute. Standing sub-brief · as of 7 July 2026 105 words · last cycle 2026-07-05 #### Scheme & Network Compliance Georgia caps merchant credit-card surcharges and convenience fees at the actual cost of acceptance under O.C.G.A. §13-1-15, enforced by the Attorney General's Consumer Protection Division on the disclosure side, placing Georgia alongside New York, New Jersey, Nevada, South Dakota and Nebraska among states with an actual-cost surcharge ceiling; this state rule sits layered under card-network surcharge caps of 3% for Visa and 4% for Mastercard. #### Outlook The interaction between the state's actual-cost statute and network-level percentage caps means merchants in Georgia face the more restrictive of the two ceilings in practice; no change to this dual-layer structure was identified this cycle. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://law.justia.com/codes/georgia/title-13/chapter-1/section-13-1-15/](https://law.justia.com/codes/georgia/title-13/chapter-1/section-13-1-15/) retrieved 2026-07-05 2. T3 [https://merchantcostconsulting.com/lower-credit-card-processing-fees/georgia-surcharge-laws/](https://merchantcostconsulting.com/lower-credit-card-processing-fees/georgia-surcharge-laws/) retrieved 2026-07-05 3. T3 [https://merchantcostconsulting.com/lower-credit-card-processing-fees/credit-card-surcharge-laws-by-state/](https://merchantcostconsulting.com/lower-credit-card-processing-fees/credit-card-surcharge-laws-by-state/) retrieved 2026-07-05 4. T1 [https://consumered.georgia.gov/ask-ed/2021-03-03/credit-card-surcharges](https://consumered.georgia.gov/ask-ed/2021-03-03/credit-card-surcharges) retrieved 2026-07-05 ### W5 Payment Corridor Dynamics Probable confirmed 2026-07-05 Georgia functions primarily as a domestic processing hub rather than a distinct cross-border corridor node: Atlanta-based processors clear a large share of total US card volume, and state-licensed money transmitters (Western Union, MoneyGram, Remitly, etc.) serve outbound remittance corridors from Georgia's immigrant communities. No DBF- or Fed Atlanta-published state-specific corridor/remittance-flow breakdown was located. Standing sub-brief · as of 7 July 2026 93 words · last cycle 2026-07-05 #### Payment Corridor Dynamics Georgia functions both as a domestic processing hub — Georgia-headquartered processors reportedly clear roughly 70% of global card transaction volume — and as an outbound remittance origination point via Georgia-licensed money transfer operators including Western Union, MoneyGram, Remitly, Ria and Intermex, serving the US-Latin America and Caribbean corridor where roughly ten firms manage approximately 80% of flows. #### Outlook No state-disaggregated corridor dataset was located to quantify Georgia's specific share of these flows independent of national aggregates; this remains a standing data gap for corridor-level monitoring of the state's remittance role. no periodic updates on record for this sub-brief ** Sources and findings (2)** 1. T3 [https://georgia.org/center-of-innovation/georgia-world-leader-fintech](https://georgia.org/center-of-innovation/georgia-world-leader-fintech) retrieved 2026-07-05 2. T3 [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 ### W6 Industry Structure & Commercial Confirmed confirmed 2026-07-05 Georgia — branded 'Transaction Alley' — hosts one of the world's densest concentrations of payment processors and card acquirers, anchored by Global Payments (Atlanta) and the former TSYS (Columbus), alongside Fiserv/First Data, FIS, Worldpay, NCR and InComm. The sector underwent major 2025-2026 restructuring via the Global Payments/Worldpay/FIS three-way transaction. Standing sub-brief · as of 7 July 2026 141 words · last cycle 2026-07-05 #### Industry Structure & Commercial Dynamics Georgia — branded "Transaction Alley" — hosts a dense concentration of payment processors and card acquirers, including seven of the nine largest US card acquirers and six of the ten largest US processors headquartered in-state, anchored historically by Global Payments in Atlanta and the former TSYS in Columbus. The sector underwent major restructuring via the completed three-way transaction among Global Payments, Worldpay and FIS, finalized in January 2026, which the interpreter's structural analysis treats as reshaping the competitive landscape distinct from the discrete deal mechanics recorded under commercial intelligence. #### Outlook Further consolidation among the remaining processor and acquirer base is plausible following this restructuring, though no additional transactions were identified this cycle; the structural effect of the completed deal — concentrated market power among fewer, larger entities — is the central W6 watch item going forward. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T3 [https://georgia.org/industries/technology/fintech](https://georgia.org/industries/technology/fintech) retrieved 2026-07-05 2. T3 [https://blog.equinix.com/blog/2019/05/08/what-makes-atlanta-the-fintech-capital-of-the-world/](https://blog.equinix.com/blog/2019/05/08/what-makes-atlanta-the-fintech-capital-of-the-world/) retrieved 2026-07-05 3. T1 [https://www.sec.gov/Archives/edgar/data/0001123360/000112336026000004/exhibit99120251231.htm](https://www.sec.gov/Archives/edgar/data/0001123360/000112336026000004/exhibit99120251231.htm) retrieved 2026-07-05 4. T3 [https://www.ajc.com/business/2026/01/georgia-is-a-payments-giant-a-blockbuster-deal-in-that-world-is-complete/](https://www.ajc.com/business/2026/01/georgia-is-a-payments-giant-a-blockbuster-deal-in-that-world-is-complete/) retrieved 2026-07-05 ### W7 Legal & Litigation Confirmed confirmed 2026-07-05 DBF actively enforces money transmission licensure and BSA/AML-adjacent obligations, exemplified by the November 2025 revocation of Fortress Trust's license and a January 2026 cease-and-desist against an unlicensed virtual-currency kiosk operator. Separately, the Northern District of Georgia federal courts have handled a major payments-adjacent Ponzi scheme prosecution, and the legislature is weighing a contested 'debanking' private-right-of-action bill. Standing sub-brief · as of 7 July 2026 140 words · last cycle 2026-09-28 #### Legal & Litigation DBF issued a Final Order of Revocation of Fortress Trust, LLC's Georgia money transmitter licence on November 24, 2025, for insolvency and unsafe or unsound operation, specifically the firm's failure to maintain the operational liquidity or resources needed to fulfil outstanding obligations. Separately, Todd Burkhalter, founder and CEO of Drive Planning LLC, pleaded guilty to wire fraud in what the US Attorney for the Northern District of Georgia described as likely the largest Ponzi scheme in Georgia history, involving more than 2,000 victims and hundreds of millions of dollars in losses. #### Outlook Both matters are consistent with DBF's historical practice of linking licence revocation to prudential and BSA-adjacent failures, and with continued federal prosecutorial activity against payments-adjacent fraud schemes originating in the state; further developments in the Drive Planning matter (sentencing, restitution) are a standing watch item. Periodic update · new data 2026-09-28 #### Legal & Litigation Georgia's third-party litigation-finance regulatory regime tightened further this cycle. The foundational prohibition, established under SB 69's 2025 Georgia Courts Access and Consumer Protection Act, bars anyone affiliated with a foreign government, foreign adversary, foreign person, foreign principal, or sovereign wealth fund from registering as a litigation financier or entering into a litigation-financing agreement in the state. HB 945, enacted in 2026, builds on that foundation by creating an annual re-registration requirement for litigation financiers at $1,000 per year, set at half the $2,000 initial registration fee, giving the Department of Banking and Finance a recurring supervisory touchpoint rather than a one-time registration check. HB 945 also extended cease-and-desist authority to DBF over non-compliant litigation financiers, aligning the enforcement mechanism available for litigation-finance registration violations with the cease-and-desist powers the department already exercises over unlicensed money transmitters. This gives Georgia a comparable enforcement toolkit across both its money-transmission and litigation-finance oversight regimes. The combined effect of the foreign-ownership prohibition, the new annual re-registration cadence, and the extended cease-and-desist authority is a materially more supervised litigation-finance sector than existed before this legislative cycle, with recurring compliance costs now built into the registration structure itself rather than being limited to a single up-front fee. #### Outlook The first annual re-registration cycle under the new $1,000-per-year fee structure will be a useful data point for gauging compliance burden and market attrition in Georgia's litigation-finance sector. Also worth watching is whether DBF's newly extended cease-and-desist authority produces its first enforcement action against a non-compliant financier, which would test the practical reach of the foreign-ownership prohibition established under SB 69. **1 earlier distinct update(s)** Periodic update · new data 2026-08-25 #### Legal & Litigation Georgia Senate Bill 341, an updated private-right-of-action debanking bill, raises the covered-institution asset threshold from one billion dollars to two billion dollars and adds an Attorney General investigatory role. It retains private-right-of-action language opposed by the Georgia Bankers Association. Industry tracking as of this cycle shows the bill as a carryover item without confirmed final passage; the finding rests on a single Tier 2 industry-association tracker, and the primary legislative record has not been independently verified this cycle. This is a legal-and-litigation-exposure question for Georgia-chartered and Georgia-operating banks rather than a licensing or market-access question: the private-right-of-action provision, if retained through final passage, would create a new litigation channel for covered institutions rather than a supervisory or licensing change. #### Outlook SB 341's final disposition, passage, failure, or further carryover, is the variable to track. If it passes with the current private-right-of-action language and the two-billion-dollar asset threshold intact, Georgia-operating banks above that threshold face materially higher debanking-dispute litigation exposure than under the prior one-billion-dollar threshold; if it fails or carries over again, no near-term change to that exposure follows. **Sources and findings (5)** 1. T1 [https://dbf.georgia.gov/press-releases/2025-11-24/final-order-revocation-money-transmitter-license-issued-fortress-trust](https://dbf.georgia.gov/press-releases/2025-11-24/final-order-revocation-money-transmitter-license-issued-fortress-trust) retrieved 2026-07-05 2. T1 [https://dbf.georgia.gov/press-releases/2026-01-16/order-cease-and-desist-issued-virtual-assets-llc-dba-crypto-dispensers](https://dbf.georgia.gov/press-releases/2026-01-16/order-cease-and-desist-issued-virtual-assets-llc-dba-crypto-dispensers) retrieved 2026-07-05 3. T3 [https://approvedlicensing.com/georgia-department-of-banking-and-finance-revokes-money-transmitter-license/](https://approvedlicensing.com/georgia-department-of-banking-and-finance-revokes-money-transmitter-license/) retrieved 2026-07-05 4. T1 [https://www.justice.gov/usao-ndga/pr/financial-advisor-pleads-guilty-orchestrating-massive-380-million-ponzi-scheme](https://www.justice.gov/usao-ndga/pr/financial-advisor-pleads-guilty-orchestrating-massive-380-million-ponzi-scheme) retrieved 2026-07-05 5. T3 [https://thecurrentga.org/2025/03/07/georgia-legislature-crossover-day/](https://thecurrentga.org/2025/03/07/georgia-legislature-crossover-day/) retrieved 2026-07-05 ### W8 Merchant Acquiring & Risk Confirmed confirmed 2026-07-05 Georgia's merchant-acquiring landscape is dominated by home-grown global acquirers, now consolidated further via the Global Payments/Worldpay transaction, operating under Georgia's actual-cost surcharge/convenience-fee disclosure regime enforced by the Attorney General's Consumer Protection Division. Standing sub-brief · as of 7 July 2026 84 words · last cycle 2026-07-05 #### Merchant Acquiring & Risk Georgia's merchant-acquiring sector, already dominated by home-grown global acquirers, has consolidated further via the Global Payments/Worldpay transaction, and operates under the state's actual-cost surcharge and convenience-fee disclosure regime enforced by the Attorney General's Consumer Protection Division. #### Outlook The link between the W4 statutory surcharge framework and the acquiring sector's post-consolidation concentration is the central W8 analytical point this cycle: fewer, larger acquirers now operate under the same actual-cost disclosure obligations as before, raising the stakes of any future compliance lapse. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T3 [https://merchantcostconsulting.com/lower-credit-card-processing-fees/georgia-surcharge-laws/](https://merchantcostconsulting.com/lower-credit-card-processing-fees/georgia-surcharge-laws/) retrieved 2026-07-05 2. T3 [https://blog.equinix.com/blog/2019/05/08/what-makes-atlanta-the-fintech-capital-of-the-world/](https://blog.equinix.com/blog/2019/05/08/what-makes-atlanta-the-fintech-capital-of-the-world/) retrieved 2026-07-05 3. T1 [https://www.sec.gov/Archives/edgar/data/0001123360/000110465926002705/tm262856d1_ex99-1.htm](https://www.sec.gov/Archives/edgar/data/0001123360/000110465926002705/tm262856d1_ex99-1.htm) retrieved 2026-07-05 4. T1 [https://consumered.georgia.gov/ask-ed/2021-03-03/credit-card-surcharges](https://consumered.georgia.gov/ask-ed/2021-03-03/credit-card-surcharges) retrieved 2026-07-05 ### W9 Product Innovation & Market Development Probable confirmed 2026-07-05 Georgia's product-innovation layer is driven by its private-sector fintech density (Transaction Alley) and academic/accelerator infrastructure (Georgia FinTech Academy, ATDC) rather than a state-run regulatory sandbox; adoption of the Federal Reserve's FedNow instant-payments rail among Georgia community banks/credit unions is proceeding cautiously alongside Zelle and RTP. Standing sub-brief · as of 6 August 2026 69 words · last cycle 2026-08-05 #### Product Innovation & Market Development No state-specific stablecoin or prepaid carve-out identified this cycle. Georgia's regime remains procedurally standard NMLS-routed, DBF-administered relative to peer states, distinguished this cycle mainly by the unusual breadth of the 2026 omnibus rulemaking touching adjacent licensing categories rather than by any new instrument-specific treatment. #### Outlook No product-innovation-specific development is currently scheduled for this jurisdiction; monitoring continues for any state-specific instrument carve-outs in future cycles. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T3 [https://www.cuinsight.com/fednow-enters-year-three-with-increasing-users-volumes-and-competition/](https://www.cuinsight.com/fednow-enters-year-three-with-increasing-users-volumes-and-competition/) retrieved 2026-07-05 2. T1 [https://www.frbservices.org/news/fed360/issues/071625/fednow-service-two-years-growth-innovation](https://www.frbservices.org/news/fed360/issues/071625/fednow-service-two-years-growth-innovation) retrieved 2026-07-05 3. T3 [https://georgia.org/industries/technology/fintech](https://georgia.org/industries/technology/fintech) retrieved 2026-07-05 4. T3 [https://atdc.org/industry/fintech/](https://atdc.org/industry/fintech/) retrieved 2026-07-05 5. T1 [https://rules.sos.ga.gov/gac/80](https://rules.sos.ga.gov/gac/80) retrieved 2026-07-05 ### W10 Consumer Protection & APP Fraud Confirmed confirmed 2026-07-05 Georgia lacked a comprehensive consumer privacy statute until Senate Bill 111 (Act 462) was signed May 11, 2026; consumer protection for payments previously rested on the sector-agnostic breach-notification statute (O.C.G.A. § 10-1-912, no fixed notice deadline), federal sectoral regimes (GLBA/HIPAA), and Attorney General enforcement of deceptive-practices and surcharge-disclosure rules. No dedicated APP-fraud reimbursement mandate (as under the UK's PSR) exists in Georgia; fraud recourse relies on federal Reg E/network chargeback mechanisms. Standing sub-brief · as of 7 July 2026 99 words · last cycle 2026-09-28 #### Consumer Protection & APP Fraud Georgia's sector-agnostic breach-notification statute, O.C.G.A. §10-1-912, requires notice "in the most expedient time possible without unreasonable delay," with no fixed deadline, and mandates nationwide consumer-reporting-agency notice where more than 10,000 residents are affected; no dedicated authorised-push-payment fraud reimbursement mandate exists in Georgia, leaving fraud recourse to federal Regulation E and card-network chargeback mechanisms. #### Outlook The new SB 111 privacy statute (see W1b) now sits alongside this older breach-notification framework, layering consumer-protection obligations without yet extending to a dedicated APP-fraud reimbursement scheme; that gap remains a distinguishing feature relative to jurisdictions with mandatory reimbursement regimes. Periodic update · new data 2026-09-28 #### Consumer Protection & APP Fraud House Bill 945, effective July 1, 2026, created a substantive consumer-protection regime for virtual-currency-kiosk operators in Georgia. Operators must display a mandatory fraud-irreversibility warning before transactions and are subject to an aggregated maximum daily transaction limit of $2,500 for new customers and $10,000 for existing customers. These caps function as a direct APP-fraud mitigation mechanism for a payment channel, cash-to-crypto kiosks, that has been repeatedly implicated in elder and vulnerable-victim fraud typologies nationally. Georgia's approach is notable for the direct regional comparison it invites. In the same week Georgia's transaction-cap-and-warning model took effect, Tennessee adopted an outright statewide ban on crypto-ATM installation and use. The two states' same-week, opposite-direction responses to the same underlying fraud concern give the payments-regulation community a live natural experiment in whether disclosure-and-limits regulation or outright prohibition is the more effective consumer-protection instrument for this specific fraud vector. The consumer-protection provisions sit within a nonbank payment-institution and e-money-instrument frame: virtual-currency kiosks function as a prepaid/e-money-adjacent cash-in point, and the daily transaction limits and fraud warnings apply to the operator regardless of whether the underlying money-transmission licence is held by a bank-affiliated or non-bank entity, though in practice Georgia's kiosk operator population is predominantly non-bank. #### Outlook The practical test for Georgia's model will be whether the transaction caps and mandatory warnings measurably reduce elder-fraud losses through kiosk channels relative to Tennessee's prohibition-based approach, a comparison likely to draw attention from other states considering their own kiosk-specific consumer-protection frameworks over the coming year. **Sources and findings (5)** 1. T2 [https://www.recordinglaw.com/us-laws/data-privacy-laws/georgia-data-privacy-laws/](https://www.recordinglaw.com/us-laws/data-privacy-laws/georgia-data-privacy-laws/) retrieved 2026-07-05 2. T1 [https://law.justia.com/codes/georgia/title-10/chapter-1/article-34/section-10-1-912/](https://law.justia.com/codes/georgia/title-10/chapter-1/article-34/section-10-1-912/) retrieved 2026-07-05 3. T2 [https://practiceguides.chambers.com/practice-guides/data-protection-privacy-2026/usa-georgia/trends-and-developments/O24534](https://practiceguides.chambers.com/practice-guides/data-protection-privacy-2026/usa-georgia/trends-and-developments/O24534) retrieved 2026-07-05 4. T1 [https://consumered.georgia.gov/ask-ed/2021-03-03/credit-card-surcharges](https://consumered.georgia.gov/ask-ed/2021-03-03/credit-card-surcharges) retrieved 2026-07-05 5. T1 [https://law.georgia.gov/press-releases/2026-03-03/carr-secures-over-50-million-consumers-and-taxpayers-2025](https://law.georgia.gov/press-releases/2026-03-03/carr-secures-over-50-million-consumers-and-taxpayers-2025) retrieved 2026-07-05 ### W11 AML/CFT & Financial Crime [Sourced from Sentinel.gi ↗](https://sentinel.gi/jurisdictions/united-states-georgia/#sec-dom-D7) Probable confirmed 2026-07-05 sentinel.-fed position: Georgia MSBs (money transmitters, check cashers) sit within the federal Bank Secrecy Act/FinCEN AML perimeter, with DBF layering state recordkeeping, SAR-adjacent, and large-currency-transaction rules atop it. DBF's recent enforcement actions (Fortress Trust revocation, Crypto Dispensers cease-and-desist) demonstrate an active supervisory posture at the licensing/AML boundary, consistent with historical precedent of BSA-linked license revocations. Standing sub-brief · as of 7 July 2026 124 words · last cycle 2026-07-05 #### AML/CFT & Financial Crime This module's intelligence is sourced from the Sentinel.gi feed. Per that feed, Georgia's money-service businesses sit within the federal Bank Secrecy Act/FinCEN AML perimeter, with DBF layering state large-currency-transaction, recordkeeping and SAR-adjacent rules (Rules 80-3-6-.01 to -.04) on top; DBF's recent enforcement actions — the Fortress Trust revocation and the Crypto Dispensers cease-and-desist — demonstrate an active supervisory posture at the licensing/AML boundary. For original illicit-finance analysis of these dynamics, see the Sentinel.gi feed and the related FIM cross-reference; this brief does not perform independent AML analysis. #### Outlook Continued DBF enforcement at the licensing/AML boundary is likely, consistent with the pattern already evident in the Fortress Trust and Crypto Dispensers matters; readers seeking deeper illicit-finance analysis should consult Sentinel.gi directly. no periodic updates on record for this sub-brief ** Sources and findings (6)** 1. T1 sentinel.dbf.georgia.gov/press-releases/2025-11-24/final-order-revocation-money-transmitter-license-issued-fortress-trust 2. T? FIM (sentinel.gi) per-JID baseline profile — United States — Georgia — Georgia operates under the federal BSA/AML framework administered by FinCEN and OFAC, with state-level MSB/money-transmitter licensing through the Georgia Department of Banking and Finance. Georgia has no independent beneficial-ownership registry; it relies entirely on the federal Corporate Transparency Act, which was narrowed in March 2025 to exempt domestic reporting companies. Georgia's low-cost, fast-formation LLC regime and its concentration of national payment processors ('Transaction Alley') create structural exposure alongside active federal enforcement. 3. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: sourcing-thinness 4. T1 FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-001) — Sanctions: OFAC divergence 5. T1 FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-003) — Sanctions: national listing 6. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: legal-gap ### W12 Correspondent Banking, Settlement & Access Confirmed confirmed 2026-07-05 Georgia's settlement/correspondent-banking access runs through the Federal Reserve Bank of Atlanta (Sixth District, headquartered in Atlanta), which supervises state member banks, operates the nationwide payment system including FedNow, and runs a community-development function addressing CRA-linked access for underserved communities. No Georgia-specific de-risking dataset was located. Standing sub-brief · as of 7 July 2026 131 words · last cycle 2026-07-05 #### Correspondent Banking, Settlement & Access The Federal Reserve Bank of Atlanta, covering the Sixth District and headquartered in Georgia, supervises regional and community banking organizations, operates FedNow and the nationwide payment system, and runs a CRA-linked community-development function. This federal-anchored structure means direct settlement access in Georgia runs primarily through bank charters and Federal Reserve relationships, while non-bank payment institutions rely on correspondent or partner-bank arrangements to reach the same settlement rails — the structural access asymmetry that frames this module nationally. No Georgia-specific correspondent-banking de-risking dataset was located to quantify how that asymmetry plays out for Georgia-based non-bank PSPs specifically. #### Outlook Absent a Georgia-specific de-risking dataset, this module's Georgia coverage remains anchored to the Atlanta Fed's general supervisory and settlement functions; closing that data gap is a standing research priority. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://www.federalreserve.gov/aboutthefed/federal-reserve-system-atlanta.htm](https://www.federalreserve.gov/aboutthefed/federal-reserve-system-atlanta.htm) retrieved 2026-07-05 2. T1 [https://www.atlantafed.org/what-we-do/banking-supervision-and-lending/banking-supervision-resources](https://www.atlantafed.org/what-we-do/banking-supervision-and-lending/banking-supervision-resources) retrieved 2026-07-05 3. T1 [https://www.atlantafed.org/community-development/about-us](https://www.atlantafed.org/community-development/about-us) retrieved 2026-07-05 4. T1 [https://dbf.georgia.gov/document/document/2023-dbf-final-rulemaking-7-7-23-0/download](https://dbf.georgia.gov/document/document/2023-dbf-final-rulemaking-7-7-23-0/download) retrieved 2026-07-05 ### W13 Commercial Intelligence (M&A, Investment & Product) Confirmed confirmed 2026-07-05 The trailing-12-month window is dominated by the completion of the three-way Global Payments/Worldpay/FIS transaction, the largest recent restructuring of Georgia's payments industry, alongside continued DBF regulatory-driven market entries/exits (Fortress Trust, Crypto Dispensers) that reshape the state's licensed-entity landscape. Standing sub-brief · as of 7 July 2026 141 words · last cycle 2026-07-05 #### Commercial Intelligence Global Payments completed its acquisition of Worldpay from FIS and GTCR on January 12, 2026, at a net purchase price of $22.7 billion and total transaction value of $24.25 billion including tax assets, and divested its Issuer Solutions business (the former TSYS franchise) to FIS as part of the same restructuring, transforming Global Payments into what the company describes as a "pure-play, commerce solutions provider." FIS completed its acquisition of that Issuer Solutions business for an enterprise value of $13.5 billion and sold its remaining 45% minority stake in Worldpay to Global Payments, also on January 12, 2026. #### Outlook This completed three-way restructuring is the dominant W13 event of the period and reshapes commercial dependency across Georgia's card-acquiring and processing landscape for merchants and issuers alike; no further M&A, funding-round or product-launch events were identified for Georgia this cycle. no periodic updates on record for this sub-brief ** Sources and findings (2)** 1. T1 [https://www.sec.gov/Archives/edgar/data/0001123360/000110465926002705/tm262856d1_ex99-1.htm](https://www.sec.gov/Archives/edgar/data/0001123360/000110465926002705/tm262856d1_ex99-1.htm) retrieved 2026-07-05 2. T1 [https://www.fisglobal.com/about-us/media-room/press-release/2026/fis-completes-strategic-acquisition-of-global-payments-issuer-solutions-business](https://www.fisglobal.com/about-us/media-room/press-release/2026/fis-completes-strategic-acquisition-of-global-payments-issuer-solutions-business) 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 – Georgia| 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:** 2 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), 59 finding(s), 228 source(s) in the cumulative register. Think something on this page is wrong? [Report an error](https://payments.gi/legal/#contact).