title: United States – Louisiana Payments Regulation Monitor | World Payments Monitor canonical: https://payments.gi/jurisdictions/united-states-louisiana/ date_modified: 2026-10-21 publisher: Asymmetric Intelligence # United States – Louisiana US-LA schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-21 · 14 modules · 62 sourced findings · 159 sources in the cumulative register 14 Modules baseline.modules[] 62 Findings modules[].findings[] 35 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 – Louisiana is covered once, on the [United States](https://payments.gi/jurisdictions/united-states/) page. This page covers United States – Louisiana’s own layer: its own law, regulators and enforcement. ## Jurisdiction brief ###### Latest update · 18 October 2026 #### Lead Signal Louisiana has repealed and replaced its money-transmission licensing regime: the Louisiana Money Transmission Act (Act 888/HB1230) repeals Chapter 13 of Title 6 (R.S. 6:1031-1072) and takes effect 1 July 2026, administered by the Office of Financial Institutions through the Nationwide Multistate Licensing System. The Act defines money transmission broadly, requires licensees to submit quarterly call reports and annual audited financial statements, retain records for at least five years, and file reports required under the Bank Secrecy Act and other anti-money-laundering laws. This is a structural market-access development for non-bank payment institutions and EMIs operating in or into Louisiana, replacing a regime that had stood since 1966. #### Other Developments **Virtual Currency Businesses Act sunset repealed.** Act 923 (SB163), effective 1 August 2026, repeals the 1 July 2027 sunset date previously contained in the VCBA and adds a federal-preemption-trigger clause under which VCBA provisions would become null and void to the extent preempted by a future federal licensure law, effective the last day of the calendar year that federal law takes effect. This removes what had been a built-in expiry on Louisiana's standalone virtual-currency licensing framework. **Virtual-currency-kiosk refund and disclosure rules tightened.** Act 482 (SB287), effective 1 August 2026, requires virtual-currency-kiosk operators that were not properly licensed at the time of a transaction to allow the user a full refund at the operator's cost, with acknowledgement required within 10 business days and the refund completed within 90 calendar days, alongside a requirement to provide toll-free live customer support. #### Cross-Monitor Connections The same Louisiana Money Transmission Act and VCBA developments are tracked by the Financial Integrity Monitor from an AML/CTF-architecture perspective and by the Crypto Monitor from a crypto-licensing perspective; this brief addresses the market-access and digital-money structural reading specific to the payments lens. #### Outlook Louisiana's new money-transmission and virtual-currency regimes both converge with the dominant multistate CSBS Model Act framework rather than diverging from it, which should reduce jurisdictional-divergence risk for non-bank payment and crypto licensees operating across multiple US states. Whether this convergence was already reflected in a prior cycle's record for Louisiana has not been confirmed, as prior-cycle content was not available to this research pass. _4 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 Louisiana has replaced the statutory backbone of its money-transmission licensing regime. HB 1230 (Act 888), signed into law on June 9, 2026, enacts the Louisiana Money Transmission Act, adopting the CSBS Model Money Transmission Modernization Act and superseding the state's Sale of Checks and Money Transmission Act (La. R.S. 6:1031 et seq.), previously administered by the Louisiana Office of Financial Institutions via NMLS with a $25,000 minimum surety bond and $100,000 net-worth threshold, effective July 1, 2026. Existing licensees are protected from the new requirements until renewal or twelve months after the effective date, whichever is later. The replacement aligns Louisiana with the CSBS model framework now adopted across most other US states, a step that in principle reduces multistate licensing friction for payment service providers and e-money issuers operating on NMLS rails. A second material item this cycle corrects the record rather than announcing new policy. Senate Bill 254 had been tracked as a pending 2026-session bill targeting debit-card surcharges; it was in fact signed into law by Governor Landry on June 2, 2026, as Act 751, prohibiting retail businesses from imposing surcharges on debit-card transactions, effective August 1, 2026, with civil penalties of up to $500 per incident enforceable by the Attorney General. Debit-card surcharging was already barred under the federal Dodd-Frank prohibition; Act 751 now codifies that prohibition directly in Louisiana law. Louisiana separately permits credit-card surcharging of up to 4% (3% for Visa transactions), subject to federal card-network caps and signage and receipt disclosure requirements. #### Other Developments Louisiana's Virtual Currency Business Act continues to expand in scope. The VCBA (Act 341 of 2020, amended by Act 331 of 2023) makes Louisiana one of a small number of US states with a stand-alone virtual-currency licensing statute, and the first based on the Uniform Regulation of Virtual-Currency Businesses Act, with NMLS applications accepted from January 2023 and the regime fully effective July 1, 2023. HB 483 (Act 369), signed June 20, 2025, extended VCBA licensing to owners, operators and facilitators of virtual-currency kiosk machines. On payments infrastructure, at least eleven Louisiana-headquartered banks and credit unions are now live on the Federal Reserve's FedNow instant-payments network; the state runs no sandbox, open-banking mandate, or CBDC pilot, so its innovation posture rests entirely on federal rail adoption. The state's banking structure continues to consolidate. OFI's Active Banks Directory recorded 80 state-chartered banking entities as of its June 2026 update, against a backdrop of continuing community-bank mergers such as BancPlus/First Trust Corporation. Three further bank and credit-union transactions surfaced this cycle: Keesler Federal Credit Union's completed merger with Jefferson Financial Federal Credit Union, effective July 1, 2025; the shareholder-approved merger of MC Bancshares, Inc. into DMMS Purchaser, Inc., targeted for Q2 2026 closing with deal value undisclosed; and Catalyst Bancorp, Inc.'s announced all-cash acquisition of Lakeside Bancshares, Inc. for approximately $41.1 million, expected to close in Q3 2026. On operational resilience, Louisiana has no bespoke state regime; money transmitters, as GLBA-covered financial institutions, must maintain FTC Safeguards Rule information-security programs, layered with the state's own breach-notification statute requiring notice to affected individuals and the Attorney General within 60 days of discovery. On corridor dynamics, Louisiana's outbound remittance flow to Latin America and the Caribbean is assessed at roughly $206 million, a small slice of the approximately $170 billion the US-LAC corridor carried in 2024, served chiefly by Western Union, MoneyGram, Viamericas and Remitly. On litigation and redress, the Louisiana Unfair Trade Practices and Consumer Protection Law continues to provide the state's principal private right of action and Attorney General enforcement track for unfair or deceptive payments practices, and Louisiana accountholders who held Capital One 360 Savings accounts between September 2019 and June 2025 are due distributions from a $425 million federal class-action settlement, scheduled around July 21, 2026. Consumer redress for authorised-push-payment-style fraud remains channelled through LUTPA private actions, criminal restitution, and DOJ-led imposter-scam alerts rather than any PSR-style mandatory reimbursement scheme, which Louisiana does not have. #### Cross-Monitor Connections This cycle's AML/CFT signal for Louisiana is a proxy rather than a direct finding: a Sentinel.gi payments-context feed for US-LA was not retrievable, so the federal Bank Secrecy Act/FinCEN regime is carried as the baseline governing Louisiana-licensed money transmitters and virtual-currency businesses, including a pending April 2026 FinCEN proposal to require continuously current risk-based AML/CFT programs under the AML Act of 2020. Analysis of illicit-finance exposure specific to Louisiana's virtual-currency and kiosk-operator population is routed to the Financial Integrity Monitor rather than treated as a WPM conclusion. Separately, Louisiana's community-bank sector — concentrated, small, and rural — sits inside the national correspondent-banking de-risking trend, in which larger correspondent banks curtail relationships with smaller respondent institutions over AML and customer-due-diligence cost concerns. #### Outlook Two dated milestones anchor the near-term horizon. The Louisiana Money Transmission Act enters into force July 1, 2026, with the transition protection for existing licensees running to renewal or twelve months after that date, whichever is later; the debit-card surcharge prohibition under Act 751 takes effect August 1, 2026. Louisiana's regulatory direction this cycle reads as tightening: a modernised licensing framework paired with an expanded Attorney General enforcement toolkit and a newly codified consumer-protection surcharge rule. Absent a resolved direct Sentinel.gi feed, the AML/CFT picture for Louisiana-licensed money transmitters and virtual-currency businesses remains carried at the federal baseline; a subsequent-cycle pull of that feed is the principal outstanding research gap. trust tier: ai_unverified ###### Latest update · 18 October 2026 #### Regulatory Status Louisiana's payments regulatory architecture was materially reshaped this cycle by two convergent developments: the Louisiana Money Transmission Act (Act 888/HB1230), effective 1 July 2026, which repealed the state's 1966 money-transmission licensing framework and replaced it with an NMLS-administered regime requiring quarterly call reports, annual audited financial statements, five-year recordkeeping, and BSA/AML-required report filing; and the repeal of the Virtual Currency Businesses Act's sunset clause via Act 923 (SB163), effective 1 August 2026, which converts the state's standalone virtual-currency licensing regime into standing infrastructure while adding a federal-preemption-trigger clause. A third enactment, Act 482 (SB287), also effective 1 August 2026, tightens refund, acknowledgement and customer-support obligations specific to virtual-currency-kiosk operators. All three developments converge with, rather than diverge from, the dominant multistate CSBS Model Act supervisory framework. #### Outlook The practical supervisory effect of OFI's new multistate-examination and quarterly-reporting powers under the Money Transmission Act, and the durability of the VCBA framework now that its sunset has been removed, are the items to watch as Louisiana's payments and digital-money regimes bed in following their mid-2026 effective dates. _3 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 Louisiana's payments regulatory baseline is undergoing its most significant reset in years. The Louisiana Money Transmission Act (HB 1230/Act 888), signed June 9, 2026, replaces the Sale of Checks and Money Transmission Act effective July 1, 2026, adopting the CSBS Model Money Transmission Modernization Act; existing licensees retain transition protection until renewal or twelve months after the effective date. Fund-safeguarding obligations under R.S. 6:1055 (10-business-day transmission/return) and R.S. 6:1052 (trust-style treatment of revoked-licensee proceeds) continue as the standing conduct baseline. The Virtual Currency Business Act, one of a small number of stand-alone US state virtual-currency licensing regimes, expanded in 2025 to cover kiosk operators. Debit-card surcharging is now barred both federally and, as of August 1, 2026, directly under Louisiana's Act 751, while credit-card surcharging remains permitted up to 4% (3% for Visa). No bespoke state operational-resilience regime exists; Louisiana relies on federal GLBA/FTC Safeguards Rule coverage layered with its own breach-notification statute. At least eleven Louisiana banks and credit unions are live on FedNow, though the state has no sandbox, open-banking mandate, or CBDC pilot. Consumer redress for payments fraud runs through LUTPA, criminal restitution, and DOJ imposter-scam alerts rather than a mandatory reimbursement scheme. AML/CFT oversight of Louisiana money transmitters and virtual-currency businesses is carried, pending a direct Sentinel.gi feed, at the federal BSA/FinCEN baseline. Louisiana's community-bank sector, spanning 80 state-chartered institutions, is both consolidating internally (three bank/credit-union transactions captured this cycle) and exposed to the national correspondent-banking de-risking trend. #### Outlook Two dated milestones will test implementation over the coming year: the Money Transmission Act's entry into force on July 1, 2026, and the Act 751 debit-surcharge prohibition on August 1, 2026. Louisiana's regulatory direction reads as tightening across licensing, surcharge conduct, and enforcement, even as its product-innovation and AML/CFT postures remain dependent on federal rather than state-level infrastructure. 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 Louisiana replaces its 1966 Sale of Checks and Money Transmission Act with the Louisiana Money Transmission Act (Act 888/HB1230), effective 2026-07-01, aligning state money-transmitter licensing with the CSBS Model Money Transmission Modernization Act and NMLS-based administration. Horizon · 2026-07-01 (±quarter) Louisiana Money Transmission Act (HB1230/Act888) enters into force_in_force · TT2_ Horizon · 2027-07-01 (±year) Transition period ends for existing LA money-transmission licensees under new Act_in_force_pending · TT2_ Standing sub-brief · as of 5 July 2026 170 words · last cycle 2026-10-18 #### Licensing, Authorisation & Market Access Louisiana currently licenses money transmission under the Sale of Checks and Money Transmission Act (La. R.S. 6:1031 et seq.), administered by the Louisiana Office of Financial Institutions via NMLS, with a $25,000 minimum surety bond and a $100,000 net-worth threshold. This standing regime is being wholesale-replaced: HB 1230 (Act 888), signed June 9, 2026, enacts the Louisiana Money Transmission Act, adopting the CSBS Model Money Transmission Modernization Act, effective July 1, 2026. Existing licensees are protected from the new requirements until renewal or twelve months after the effective date, whichever is later. The shift aligns Louisiana with the CSBS model framework already adopted by most other US states, reducing multistate licensing friction for NMLS-registered payment service providers and e-money issuers. #### Outlook The Louisiana Money Transmission Act enters into force July 1, 2026, with the transition-protection window closing at renewal or July 1, 2027, whichever is later. Watch for OFI implementing guidance and any NMLS transition filings from existing Louisiana-licensed money transmitters during the twelve-month window. Periodic update · new data 2026-10-18 #### Licensing, Authorisation & Market Access Louisiana has repealed Chapter 13 of Title 6 (R.S. 6:1031-1072), its 1966 money-transmission licensing framework, replacing it with the Louisiana Money Transmission Act (Act 888/HB1230), effective 1 July 2026. The Act is administered by the Office of Financial Institutions through the Nationwide Multistate Licensing System and defines money transmission broadly, including the selling or issuing of payment instruments to a person located in the state. Licensees must submit quarterly call reports and annual audited financial statements, retain records for at least five years, and file reports required under the Bank Secrecy Act and other anti-money-laundering laws. This is a structural market-access development for non-bank payment institutions and EMIs seeking to operate in or into Louisiana: the new NMLS-based process and the quarterly/annual reporting cadence represent a materially more codified application and ongoing-reporting pathway than existed under the prior 1966 statute. The new regime adopts the CSBS Model Money Transmission Modernization Act framework, aligning Louisiana's licensing architecture with the dominant multistate supervisory model used by the majority of other US states rather than introducing a bespoke, divergent standard. For a non-bank payment institution or EMI already licensed under the Model Act framework elsewhere, this convergence should reduce the incremental compliance burden of adding Louisiana to a multistate licensing footprint, since the underlying reporting, recordkeeping and examination expectations are now substantially harmonised with the multistate norm rather than idiosyncratic to Louisiana. #### Outlook Whether this new Louisiana licensing architecture had already been captured in a prior World Payments Monitor cycle has not been confirmed, as prior-cycle content was unavailable to this research pass. The practical effect of OFI's new quarterly call-report and multistate-examination powers on non-bank payment licensees' day-to-day compliance burden is the item to watch as the new regime beds in following its 1 July 2026 effective date. **4 earlier distinct update(s)** Periodic update · new data 2026-10-11 #### Licensing, Authorisation & Market Access Louisiana has modernised its money-transmission licensing framework through a new Money Transmission Act (HB 1230), signed 9 June 2026 and effective 1 July 2026. The Act replaces the states 1966 Sale of Checks and Money Transmission Act and adopts the Conference of State Bank Supervisors Model Money Transmission Modernization Act, the harmonised licensing template that a majority of US states have by now adopted in some form. For nonbank payment institutions and e-money issuers licensed, or seeking licensure, in Louisiana, the practical effect is a tightened and modernised NMLS-based licensing regime that aligns the states requirements more closely with the multistate standard other licensees already navigate elsewhere in the country. The substantive requirements introduced are not merely procedural. Licensees must now maintain NMLS-based licensing, file quarterly call reports to OFI, submit annual audited financial statements, and retain records for five years including BSA/AML-related filings. Minimum tangible net worth and surety-bond requirements are understood to have been raised alongside these reporting duties, raising the overall prudential floor for the states licensee population. For a nonbank payment institution or e-money issuer, this bundle of changes functions as a market-access tightening: the standard required to obtain and retain a Louisiana money-transmission licence has risen, even though the categories of permitted activity have not themselves changed. The rollout, however, is managed through a transitional provision that matters as much as the substantive changes themselves. Existing Sale-of-Checks-Act licensees are not required to meet the new Acts requirements, where they conflict with the prior regime, until the later of their next license renewal or twelve months from the 1 July 2026 effective date. That gives OFI and the roughly 160 licensees it is understood to supervise a staggered migration path rather than a single hard compliance date, reducing the risk of an abrupt compliance shock across the licensee population even as the underlying standard is raised. No bank-versus-nonbank split is material to how this Act operates: the new requirements apply specifically to the nonbank money-transmission licence population that Louisianas statute has always targeted, and the modernisation brings that regime into closer alignment with model state law rather than altering the boundary between bank and nonbank payment models in the state. #### Outlook The transitional compliance deadline for existing licensees falls at the later of license renewal or twelve months post-effective date, placing the practical compliance horizon around Q3 2027 as currently scheduled. Whether OFI issues implementing guidance specifying the exact net-worth and bonding thresholds that apply during the transition period, and how quickly incumbent licensees elect to renew early rather than wait out the full twelve-month window, are the two variables most likely to shape how the modernised licensing regime actually lands across Louisianas nonbank payment-institution population over the coming year. Periodic update · new data 2026-09-22 #### Licensing, Authorisation & Market Access Louisiana enacted a comprehensive modernization of its money-transmission licensing regime this cycle. Act 888 (HB 1230), the Louisiana Money Transmission Act, repeals the state's 1966 Sale of Checks and Money Transmission Act in its entirety and enacts a new licensing, renewal, reporting, and examination framework aligned with the Conference of State Bank Supervisors' Model Money Transmission Modernization Act, administered on an NMLS-based platform. The Act takes effect July 1, 2026, and applies to non-bank payment institutions and e-money-type licensees operating as money transmitters in the state, administered by the Louisiana Office of Financial Institutions. This is a structural market-access change rather than an incremental amendment: the prior statute is replaced wholesale, and licensees must now operate under the new framework's licensing, renewal, and reporting mechanics from the effective date forward. This structural replacement raises the bar for market entry for new money-transmission licensees seeking to operate in Louisiana, since applicants must meet the new Act's requirements from the outset rather than under the superseded 1966 framework. The modernization aligns Louisiana with the growing number of US states that have adopted the CSBS model framework, improving consistency for multistate non-bank payment institutions operating across state lines, though this specific alignment benefit is realized primarily through the multistate-examination provisions addressed separately. #### Outlook Watch for OFI's implementing guidance or licensing-application updates operationalizing the new NMLS-based framework, and for confirmation of transition arrangements for licensees holding legacy licenses issued under the repealed 1966 statute. Periodic update · new data 2026-09-08 #### Licensing, Authorisation & Market Access Louisiana's new Money Transmission Act (House Bill 1230 / Act 888) establishes that a person may not engage in the business of money transmission, or advertise, solicit, or hold itself out as providing money transmission, unless licensed or covered by a statutory exemption. The Louisiana Office of Financial Institutions gains expanded authority to coordinate with other state and federal regulators, participate in multistate supervisory processes, and use the Nationwide Multistate Licensing System for licensing, reporting, and criminal-history background checks, aligning Louisiana's market-access architecture with the Conference of State Bank Supervisors' Model Money Transmission Modernization Act. The Act sets an annual license renewal fee of eight hundred dollars, plus one hundred dollars per additional location, capped at six thousand dollars, and requires licensees to meet financial-responsibility standards including tangible net worth and a surety bond. For a non-bank payment institution or e-money issuer, this is the definitive market-access gate for Louisiana operation: the fee structure and NMLS-based process determine the practical cost and administrative pathway of entry, distinct from the bank-charter route. #### Outlook Existing licensees transition to the new regime at renewal or within twelve months of the effective date, whichever is earlier, with the transition window running into the third quarter of 2027; this near-term period will show whether the CSBS-aligned framework produces the intended reduction in multistate licensing friction for non-bank applicants. Periodic update · new data 2026-08-11 #### Licensing, Authorisation & Market Access Louisiana's money-transmission licensing framework underwent its most significant structural change in sixty years this cycle. The Louisiana Money Transmission Act (House Bill 1230 / Act 888), effective July 1, 2026, replaces the 1966 Sale of Checks and Money Transmission Act and moves licensing and supervision of money transmitters to the Nationwide Multistate Licensing System under the Office of Financial Institutions — a direct, Tier-1, High-confidence development sourced from the Office of Financial Institutions itself and corroborated by independent legal commentary from the National Law Review and Orrick InfoBytes. The Act imposes quarterly call-report obligations, five-year record-retention duties, Bank Secrecy Act and anti-money-laundering reporting requirements, and tangible net worth and surety bond financial-responsibility standards on licensees, with automatic license revocation available in specified circumstances — a materially higher compliance bar than the statute it replaces. Critically for market participants, existing licensees under the prior Sale of Checks and Money Transmission Act framework are not subject to new or conflicting LMTA requirements until license renewal or twelve months from the effective date, whichever is later. This grandfathering provision gives incumbent non-bank payment institutions and money transmitters — this is squarely a nonbank_pi_emi matter, since the LMTA governs money transmitters rather than depository institutions — a defined transition runway rather than an immediate compliance cliff, while still setting a clear endpoint by which full compliance is required. Louisiana's adoption of a framework closely modeled on the Conference of State Bank Supervisors' Model Money Transmission Modernization Act aligns the state with the prevailing multistate licensing approach, which should reduce, though not eliminate, historical divergence in licensing treatment for cross-state payment processors and money-services businesses operating in Louisiana. #### Outlook The next structural checkpoint is the grandfather transition deadline: existing licensees must reach full LMTA compliance at renewal or by July 2027, whichever is earlier under the statute's terms, and that deadline is the clearest scheduled event for this module going forward. Market-access implications for new entrants are already live, since new money-transmitter license applicants in Louisiana are subject to the LMTA's full requirements, including the NMLS-based application process, with no grandfathering benefit available to firms that were not already licensed under the prior regime. **Sources and findings (6)** 1. T1 [https://ofi.la.gov/non-depository/money-orders-transmitters/](https://ofi.la.gov/non-depository/money-orders-transmitters/) retrieved 2026-07-05 2. T2 [https://cornerstonelicensing.com/money-transmitter-laws/louisiana-money-transmitter-regulations/](https://cornerstonelicensing.com/money-transmitter-laws/louisiana-money-transmitter-regulations/) retrieved 2026-07-05 3. T2 [https://www.mondaq.com/unitedstates/financial-services/1808274/louisiana-enacts-comprehensive-money-transmission-law-mirroring-laws-in-other-states](https://www.mondaq.com/unitedstates/financial-services/1808274/louisiana-enacts-comprehensive-money-transmission-law-mirroring-laws-in-other-states) retrieved 2026-07-05 4. T2 [https://www.sheppard.com/insights/blogs/louisiana-enacts-comprehensive-money-transmission-law-mirroring-laws-in-other-states](https://www.sheppard.com/insights/blogs/louisiana-enacts-comprehensive-money-transmission-law-mirroring-laws-in-other-states) retrieved 2026-07-05 5. T1 [https://ofi.la.gov/non-depository/virtual-currency-business-activity/](https://ofi.la.gov/non-depository/virtual-currency-business-activity/) retrieved 2026-07-05 6. T3 [https://www.suretybonds.com/states/louisiana/money-transmitter-bond](https://www.suretybonds.com/states/louisiana/money-transmitter-bond) retrieved 2026-07-05 ### W1b Conduct, Safeguarding & Promotions Confirmed confirmed 2026-07-05 Louisiana's conduct/safeguarding regime for payments rests on trust-fund treatment of transmitted proceeds under the Sale of Checks and Money Transmission Act, a statutory 10-business-day transmission/return obligation, an explicit anti-forfeiture protection for consumer funds seized under onerous user agreements, and the general Louisiana Unfair Trade Practices and Consumer Protection Law (LUTPA) as the backstop conduct standard, enforced concurrently by OFI and the Attorney General. Standing sub-brief · as of 5 July 2026 117 words · last cycle 2026-09-21 #### Conduct, Safeguarding & Financial Promotions Louisiana's fund-safeguarding baseline rests on statute rather than a bespoke safeguarding rulebook: money transmitters must transmit or return consumer funds within 10 business days of receipt under R.S. 6:1055, and R.S. 6:1052 assigns the trust-style proceeds of revoked licensees to the OFI commissioner. The Louisiana Unfair Trade Practices and Consumer Protection Law (LUTPA) backstops these obligations, giving the commissioner and private plaintiffs recourse against unfair fund-seizure practices. #### Outlook This conduct baseline is not itself being replaced by HB1230/Act888, but the incoming Money Transmission Act's broader enforcement toolkit (see W1a, W7) will sit alongside the existing R.S. 6:1052/6:1055 safeguarding obligations. Monitor OFI rulemaking for any conduct-specific implementing rules issued alongside the new Act. Periodic update · new data 2026-09-22 #### Conduct, Safeguarding & Financial Promotions Louisiana's money-transmission conduct and safeguarding standard tightened materially this cycle under the same Act 888 (HB 1230) modernization. The Louisiana Money Transmission Act adds net-worth, bonding, and audited-financial-statement requirements for licensees, a materially stricter safeguarding-adjacent standard than the prior regime imposed. The Office of Financial Institutions' examination and complaint-handling authority is expanded under the new framework, and an examination fee of $50 per hour per examiner is now set in statute, giving the regulator a defined cost-recovery mechanism for its expanded oversight activity. Separately, the prior delivery-of-funds statutory requirement for money transmitters, which governed how licensees had to handle customer funds pending transmission, is repealed in its entirety and replaced under the new Act's framework. This is a structural rather than incremental change to the conduct standard non-bank payment institutions must meet in Louisiana, and it should be read alongside the new bonding and net-worth requirements as a coordinated tightening of the safeguarding regime applicable to non-bank money-transmission licensees specifically, distinct from the bank-supervisory framework that governs depository institutions. #### Outlook Non-bank money-transmission licensees operating in Louisiana should assess their bonding, net-worth, and audited-financial-statement posture against the new requirements ahead of enforcement of the modernized framework, and should watch for OFI guidance clarifying the operational mechanics of the replacement delivery-of-funds framework. **Sources and findings (6)** 1. T1 [https://ofi.la.gov/ofi-docs/SaleOfChecksMoneyTransmittersStatutes.pdf](https://ofi.la.gov/ofi-docs/SaleOfChecksMoneyTransmittersStatutes.pdf) retrieved 2026-07-05 2. T1 [https://codes.findlaw.com/la/revised-statutes/la-rev-stat-tit-6-sect-1055/](https://codes.findlaw.com/la/revised-statutes/la-rev-stat-tit-6-sect-1055/) retrieved 2026-07-05 3. T1 [https://codes.findlaw.com/la/revised-statutes/la-rev-stat-tit-6-sect-1055/](https://codes.findlaw.com/la/revised-statutes/la-rev-stat-tit-6-sect-1055/) retrieved 2026-07-05 4. T1 [https://legis.la.gov/Legis/Law.aspx?d=104025](https://legis.la.gov/Legis/Law.aspx?d=104025) retrieved 2026-07-05 5. T1 [https://ag.louisiana.gov/Division/PublicProtection](https://ag.louisiana.gov/Division/PublicProtection) retrieved 2026-07-05 6. T2 [https://www.mondaq.com/unitedstates/financial-services/1808274/louisiana-enacts-comprehensive-money-transmission-law-mirroring-laws-in-other-states](https://www.mondaq.com/unitedstates/financial-services/1808274/louisiana-enacts-comprehensive-money-transmission-law-mirroring-laws-in-other-states) retrieved 2026-07-05 ### W2 Stablecoins & Digital Money Confirmed confirmed 2026-07-05 Louisiana operates a stand-alone virtual currency licensing regime under the Virtual Currency Business Act (VCBA, Act 341 of 2020, as amended by Act 331 of 2023), the second such state-level regime in the US after New York's BitLicense and the first based on the Uniform Law Commission's URVCBA. OFI began accepting applications via NMLS from January 2023, with the regime fully effective July 1, 2023, and further expanded in 2025 to cover virtual-currency kiosks. Standing sub-brief · as of 5 July 2026 128 words · last cycle 2026-10-18 #### Stablecoins & Digital Money Louisiana's Virtual Currency Business Act (Act 341 of 2020, amended by Act 331 of 2023) requires licensure of virtual-currency business activity in the state; it was the second US state stand-alone virtual-currency law and the first based on the Uniform Regulation of Virtual-Currency Businesses Act, with NMLS applications accepted from January 2023 and the regime fully effective July 1, 2023. HB 483 (Act 369), signed June 20, 2025, extended VCBA licensure to owners, operators and facilitators of virtual-currency kiosk machines operating in Louisiana. #### Outlook Louisiana's continued willingness to expand VCBA scope, most recently to kiosk operators, signals sustained state-level appetite for direct oversight of virtual-currency businesses distinct from federal money-transmission licensing. Watch for further VCBA scope amendments or enforcement actions against unlicensed kiosk operators. Periodic update · new data 2026-10-18 #### Stablecoins & Digital Money Louisiana's Virtual Currency Businesses Act had its sunset clause repealed this cycle. Act 923 (SB163), effective 1 August 2026, removes the 1 July 2027 sunset date previously contained in the VCBA and adds a federal-preemption-trigger clause, under which VCBA provisions would become null and void to the extent preempted by a future federal virtual-currency licensure law, effective the last day of the calendar year that federal law takes effect. This converts Louisiana's standalone VASP-style licensing regime from a time-limited framework into standing state infrastructure for digital-money businesses operating with Louisiana residents. Alongside the sunset repeal, Act 482 (SB287), also effective 1 August 2026, tightens consumer-facing obligations specific to virtual-currency kiosks. Where a kiosk owner or operator was not properly licensed at the time of a transaction, the statute requires the operator to permit the user to cancel the transaction and receive a full refund at the operator's own expense; the operator must acknowledge the refund request within 10 business days and complete the refund within 90 calendar days, and must provide toll-free live customer support to users. These are concrete, dated operational obligations specific to the kiosk channel of virtual-currency business activity, distinct from the general VCBA licensing-trigger requirement. #### Outlook With the VCBA sunset removed, Louisiana's digital-money licensing framework should now be treated as a durable feature of the state's regulatory landscape rather than a pilot scheme with a fixed expiry, subject to the new federal-preemption trigger should Congress enact its own virtual-currency licensure framework. The practical compliance impact of the kiosk-specific refund and disclosure duties on the existing kiosk operator base remains to be observed as the 1 August 2026 effective date takes hold. **Sources and findings (6)** 1. T1 [https://ofi.la.gov/non-depository/virtual-currency-business-activity/](https://ofi.la.gov/non-depository/virtual-currency-business-activity/) retrieved 2026-07-05 2. T1 [https://ofi.la.gov/non-depository/virtual-currency-business-activity/](https://ofi.la.gov/non-depository/virtual-currency-business-activity/) retrieved 2026-07-05 3. T3 [https://www.cooley.com/news/insight/2022/2022-11-21-louisianas-virtual-currency-licensing-law-taking-effect-finally](https://www.cooley.com/news/insight/2022/2022-11-21-louisianas-virtual-currency-licensing-law-taking-effect-finally) retrieved 2026-07-05 4. T3 [https://natlawreview.com/article/louisiana-serves-new-virtual-currency-business-law-cajun-style](https://natlawreview.com/article/louisiana-serves-new-virtual-currency-business-law-cajun-style) retrieved 2026-07-05 5. T1 [https://ofi.la.gov/messages/virtual-currency-businesses-act-2023-legislation/](https://ofi.la.gov/messages/virtual-currency-businesses-act-2023-legislation/) retrieved 2026-07-05 6. T3 [https://www.hunton.com/blockchain-legal-resource/louisiana-adopts-virtual-currency-business-act](https://www.hunton.com/blockchain-legal-resource/louisiana-adopts-virtual-currency-business-act) retrieved 2026-07-05 ### W3 Operational Resilience & Critical Infrastructure Probable confirmed 2026-07-05 Louisiana does not maintain a bespoke state-level operational-resilience regime for payments firms; resilience obligations flow chiefly from the federal Gramm-Leach-Bliley Act (GLBA) Safeguards Rule applicable to money transmitters as "financial institutions," layered with Louisiana's own Database Security Breach Notification Law requiring notification to affected individuals and the Attorney General within specific timeframes. 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 73 words · last cycle 2026-07-05 #### Operational Resilience & Critical Infrastructure Louisiana has no bespoke state operational-resilience regime for payments. Money transmitters, as GLBA-covered financial institutions, must maintain FTC Safeguards Rule information-security programs, and Louisiana's own breach-notification statute (R.S. 51:3071) requires notice to affected individuals and the Attorney General within 60 days of discovery. #### Outlook Absent state-level resilience rulemaking, Louisiana's operational-resilience posture will continue to track federal GLBA/FTC Safeguards Rule developments and any amendments to the state breach-notification statute. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T2 [https://www.dwt.com/gcp/states/louisiana](https://www.dwt.com/gcp/states/louisiana) retrieved 2026-07-05 2. T3 [https://pivitstrategy.com/louisiana-cybersecurity-laws-you-should-know-2026/](https://pivitstrategy.com/louisiana-cybersecurity-laws-you-should-know-2026/) retrieved 2026-07-05 3. T1 [https://www.ftc.gov/business-guidance/privacy-security/gramm-leach-bliley-act](https://www.ftc.gov/business-guidance/privacy-security/gramm-leach-bliley-act) retrieved 2026-07-05 4. T2 [https://cdp.cooley.com/ftc-adds-new-data-breach-reporting-obligations-under-safeguards-rule/](https://cdp.cooley.com/ftc-adds-new-data-breach-reporting-obligations-under-safeguards-rule/) retrieved 2026-07-05 5. T3 [https://natlawreview.com/article/think-you-are-not-subject-gramm-leach-bliley-act-because-you-are-not-financial](https://natlawreview.com/article/think-you-are-not-subject-gramm-leach-bliley-act-because-you-are-not-financial) retrieved 2026-07-05 ### W4 Scheme & Network Compliance Probable confirmed 2026-07-05 Louisiana permits credit-card surcharging (subject to the federal 4%/3%-Visa cap and card-network rules). Debit-card surcharging, barred under Visa/Mastercard network rules and the federal Dodd-Frank prohibition, is now also directly codified in Louisiana law: SB254 was signed into law by Governor Landry on June 2, 2026 as Act 751, prohibiting retail debit-card surcharges effective August 1, 2026, with civil penalties up to $500 per incident enforceable by the Attorney General. The state itself continues to impose convenience fees for card payment of taxes. Horizon · 2026-08-01 (±quarter) Louisiana debit-card surcharge prohibition (SB254/Act751) takes effect_in_force_pending · TT3_ Standing sub-brief · as of 5 July 2026 97 words · last cycle 2026-07-05 #### Scheme & Network Compliance Louisiana permits credit-card surcharging up to 4% (3% for Visa transactions), subject to federal card-network caps and signage/receipt disclosure rules; debit-card surcharging is separately barred under federal Dodd-Frank rules. Correcting a prior baseline error, Senate Bill 254 was signed into law by Governor Landry on June 2, 2026, as Act 751, prohibiting retail debit-card surcharges effective August 1, 2026, with civil penalties of up to $500 per incident enforceable by the Attorney General. #### Outlook Act 751 takes effect August 1, 2026; watch for AG enforcement activity and merchant-compliance guidance ahead of that date. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T3 [https://www.nickel.com/surcharge-laws/louisiana](https://www.nickel.com/surcharge-laws/louisiana) retrieved 2026-07-05 2. T3 [https://www.kplctv.com/2026/04/01/that-extra-charge-your-receipt-could-be-illegal-louisiana-bill-targets-illegal-debit-card-fees/](https://www.kplctv.com/2026/04/01/that-extra-charge-your-receipt-could-be-illegal-louisiana-bill-targets-illegal-debit-card-fees/) retrieved 2026-07-05 3. T1 [https://www.legis.la.gov/Legis/ViewDocument.aspx?d=1351321](https://www.legis.la.gov/Legis/ViewDocument.aspx?d=1351321) retrieved 2026-07-05 4. 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 ### W5 Payment Corridor Dynamics Probable confirmed 2026-07-05 Louisiana sits within the broader US-to-Latin America/Caribbean (US-LAC) remittance corridor, which carried roughly $170 billion in 2024 (about 80% originating from the US), served by MTOs such as Western Union, MoneyGram, Viamericas, and Remitly; instant-payments infrastructure (Fed's FedNow) is spreading through Louisiana community banks and credit unions as a domestic real-time rail underpinning both retail and cross-border payment innovation. Standing sub-brief · as of 5 July 2026 66 words · last cycle 2026-07-05 #### Payment Corridor Dynamics The US-to-Latin-America/Caribbean remittance corridor carried approximately $170 billion in 2024 (about 80% originating from the US), served chiefly by Western Union, MoneyGram, Viamericas and Remitly; Louisiana-specific outbound flow to the region is recorded at roughly $206 million. #### Outlook No Louisiana-specific corridor policy change is on record this cycle; the state's remittance flows will continue to track broader US-LAC corridor volume and provider trends. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. 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 2. T3 [https://www.sharemoney.com/us/en/state/louisiana](https://www.sharemoney.com/us/en/state/louisiana) retrieved 2026-07-05 3. T3 [https://www.nerdwallet.com/banking/learn/banks-that-use-fednow](https://www.nerdwallet.com/banking/learn/banks-that-use-fednow) retrieved 2026-07-05 4. T3 [https://www.felixpago.com/en/guides/money-transfers](https://www.felixpago.com/en/guides/money-transfers) retrieved 2026-07-05 ### W6 Industry Structure & Commercial Probable confirmed 2026-07-05 Louisiana's payments-adjacent industry structure is anchored by a dense community/regional bank sector (Hancock Whitney, Gulf Coast Bank & Trust, b1BANK, Home Bank-type institutions) undergoing active in-state consolidation, alongside a small but notable New Orleans/Baton Rouge fintech cluster (B2B payments network Baton/TreviPay, consumer-lending fintech Republic Finance, merchant-services providers) rather than large national payments-scheme headquarters presence. Standing sub-brief · as of 5 July 2026 55 words · last cycle 2026-07-05 #### Industry Structure & Commercial Dynamics OFI's Active Banks Directory recorded 80 state-chartered banking entities in Louisiana as of its June 2026 update, reflecting a community/regional-bank-dominated, payments-adjacent industry structure that continues to consolidate, illustrated by the BancPlus/First Trust Corporation merger. #### Outlook Expect continued community-bank consolidation in Louisiana; see W13 for the specific transactions captured this cycle. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T3 [https://www.privsource.com/acquisitions/financial-services/state/louisiana](https://www.privsource.com/acquisitions/financial-services/state/louisiana) retrieved 2026-07-05 2. T3 [https://www.cbinsights.com/company/baton-financial](https://www.cbinsights.com/company/baton-financial) retrieved 2026-07-05 3. T3 [https://builtin.com/companies/location/new-orleans/type/fintech-companies](https://builtin.com/companies/location/new-orleans/type/fintech-companies) retrieved 2026-07-05 4. T1 [https://ofi.la.gov/depository/banks/active-banks-directory/](https://ofi.la.gov/depository/banks/active-banks-directory/) retrieved 2026-07-05 ### W7 Legal & Litigation Probable confirmed 2026-07-05 Louisiana payments-adjacent litigation runs chiefly through LUTPA's private right of action and Attorney General enforcement track, supplemented by federal consumer class actions reaching Louisiana account-holders (e.g., the Capital One 360 Savings settlement) and the state's criminal bank-fraud statute; the incoming Louisiana Money Transmission Act (effective July 1, 2026) materially expands the commissioner's civil enforcement toolkit against unlicensed and non-compliant money transmission activity. Standing sub-brief · as of 5 July 2026 98 words · last cycle 2026-07-05 #### Legal & Litigation The Louisiana Unfair Trade Practices and Consumer Protection Law (LUTPA, R.S. 51:1401 et seq.) provides a private right of action and Attorney General enforcement track for unfair or deceptive payments-related practices. Separately, Louisiana Capital One 360 Savings customers who held accounts between September 2019 and June 2025 qualify for payments from a $425 million federal class-action settlement, with distributions scheduled around July 21, 2026. #### Outlook Watch for Capital One 360 settlement distributions around July 21, 2026, and for the incoming Louisiana Money Transmission Act's expanded civil enforcement toolkit (see W1a) feeding into future LUTPA-adjacent enforcement. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T3 [https://973thedawg.com/capital-one-lawsuit-settlement/](https://973thedawg.com/capital-one-lawsuit-settlement/) retrieved 2026-07-05 2. T3 [https://legalclarity.org/louisiana-consumer-protection-laws-key-provisions-and-practices/](https://legalclarity.org/louisiana-consumer-protection-laws-key-provisions-and-practices/) retrieved 2026-07-05 3. T1 [https://codes.findlaw.com/la/revised-statutes/la-rev-stat-tit-14-sect-71-1/](https://codes.findlaw.com/la/revised-statutes/la-rev-stat-tit-14-sect-71-1/) retrieved 2026-07-05 4. T2 [https://www.sheppard.com/insights/blogs/louisiana-enacts-comprehensive-money-transmission-law-mirroring-laws-in-other-states](https://www.sheppard.com/insights/blogs/louisiana-enacts-comprehensive-money-transmission-law-mirroring-laws-in-other-states) retrieved 2026-07-05 ### W8 Merchant Acquiring & Risk Probable confirmed 2026-07-05 Merchant acquiring in Louisiana operates under the general federal/card-network interchange and surcharge framework rather than a bespoke state acquiring regime; local acquiring is served by a mix of national ISOs/PSPs and Louisiana-based merchant-services providers, with the state's own permissive surcharge stance (up to 4%/3%-Visa) shaping small-merchant risk and pricing practice. Standing sub-brief · as of 5 July 2026 79 words · last cycle 2026-08-05 #### Merchant Acquiring & Risk Louisiana merchant acquiring operates under general federal and card-network interchange rules with no bespoke state acquiring regime; local independent sales organisations and payment service providers commonly use Interchange+ pricing, giving merchants the option to absorb or surcharge card-processing costs of 2-4% within applicable state and network surcharge limits. #### Outlook Merchant-facing surcharge practice will need to account for the incoming debit-card surcharge prohibition (Act 751, effective August 1, 2026; see W4) alongside existing credit-card surcharge caps. Periodic update · new data 2026-08-11 #### Merchant Acquiring & Risk The Louisiana Department of Revenue's litigation against VGW (operator of Chumba Casino) and WOW Vegas, seeking approximately forty-four million dollars in alleged unpaid sales taxes tied to virtual-currency transactions on their sweepstakes-model platforms, is this cycle's clearest merchant-acquiring and risk-adjacent development. This is an Assessed-confidence finding sourced from a single Tier 3 outlet this cycle, so the specific tax-liability figures and legal theory should be treated as provisional pending further corroboration, but the underlying fact pattern — a state tax authority testing the characterization of virtual-currency-denominated sweepstakes transactions for sales-tax purposes — has direct relevance for acquirers and payment facilitators processing for similar high-risk-merchant categories. A sales-tax characterization finding against these platforms would have downstream implications for how such transactions are classified in merchant-category and risk-scoring frameworks used by acquirers serving the sweepstakes-casino vertical generally, not solely the two named platforms. #### Outlook Watch for the resolution or further procedural development of the Department of Revenue's litigation against VGW and WOW Vegas, since a ruling on the sales-tax characterization question would be the clearest signal of how virtual-currency sweepstakes transactions are likely to be treated for tax and, by extension, merchant-risk-classification purposes going forward. Acquirers and payment facilitators with exposure to the sweepstakes-casino merchant category more broadly should treat this litigation as a leading indicator rather than a Louisiana-specific curiosity. **Sources and findings (3)** 1. T3 [https://www.getflexpoint.com/credit-card-surcharging-us-states/louisiana](https://www.getflexpoint.com/credit-card-surcharging-us-states/louisiana) retrieved 2026-07-05 2. T3 [https://www.valuedmerchants.com/louisiana-merchant-services](https://www.valuedmerchants.com/louisiana-merchant-services) retrieved 2026-07-05 3. T3 [https://www.inven.ai/company-lists/top-25-fintech-companies-in-louisiana](https://www.inven.ai/company-lists/top-25-fintech-companies-in-louisiana) retrieved 2026-07-05 ### W9 Product Innovation & Market Development Probable confirmed 2026-07-05 Product innovation in Louisiana payments is led by community-bank instant-payments adoption via the Federal Reserve's FedNow Service and B2B invoice-payments network technology developed in-state (Baton/TreviPay); Louisiana does not run its own sandbox, open-banking mandate, or CBDC pilot, relying entirely on federal-level infrastructure (FedNow, open-banking rulemaking) for innovation vectors. Standing sub-brief · as of 5 July 2026 84 words · last cycle 2026-08-05 #### Product Innovation & Market Development At least eleven Louisiana-headquartered banks and credit unions have joined the Federal Reserve's FedNow instant-payments network. Louisiana runs no state-level regulatory sandbox, open-banking mandate, or CBDC pilot, so the state's payments-innovation posture rests entirely on federal infrastructure adoption rather than any bespoke state initiative. #### Outlook Absent any state sandbox or open-banking mandate, Louisiana's product-innovation trajectory will continue to be defined by the pace of FedNow adoption among state-chartered banks and credit unions; monitor for any future state-level sandbox proposals. Periodic update · new data 2026-08-11 #### Product Innovation & Market Development The Louisiana Gaming Control Board's December 2025 warning-letter position — that sports-event prediction-market contracts are illegal gambling under Louisiana law regardless of Commodity Futures Trading Commission licensure — remains the defining product-access constraint on prediction-market platforms operating, or seeking to operate, in Louisiana this cycle. The Board's position explicitly forecloses a CFTC-preemption defense: it treats the product as gaming rather than as a federally regulated derivatives instrument, foreclosing the argument that federal licensure supersedes state gambling law. This is an Assessed-confidence finding sourced from a single Tier 3 outlet this cycle; no LGCB primary rulemaking or enforcement text was directly retrieved for the payments angle, so the practical enforcement mechanics against payment flows specifically remain based on secondary industry reporting rather than a primary regulatory document. For payment processors and acquirers, this narrows the set of defensible routing positions for platforms offering event-contract products to Louisiana residents: a platform's federal CFTC registration does not, on the Board's stated position, provide a basis for continuing to process Louisiana-resident transactions if the underlying product is treated as illegal gambling under state law. This is a discrete, bounded product-access constraint rather than a broader Louisiana payments-market development, and it should be tracked specifically in relation to prediction-market and event-contract products rather than generalized to other payments-innovation categories. #### Outlook Watch for whether the jurisdictional friction between the Louisiana Gaming Control Board's state-law illegality position and federal Commodity Futures Trading Commission licensing claims escalates into litigation, which would be the clearest signal of how durable the Board's foreclosure of a CFTC-preemption defense actually is in practice. Any Louisiana litigation on this question would also be instructive for payment processors assessing routing risk for similar products in other states with comparable state-federal jurisdictional tension. **Sources and findings (4)** 1. T3 [https://www.nerdwallet.com/banking/learn/banks-that-use-fednow](https://www.nerdwallet.com/banking/learn/banks-that-use-fednow) retrieved 2026-07-05 2. T3 [https://www.independentbanker.org/w/5-ways-community-banks-can-take-advantage-of-fednow](https://www.independentbanker.org/w/5-ways-community-banks-can-take-advantage-of-fednow) retrieved 2026-07-05 3. 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 4. T3 [https://www.trevipay.com/resource-center/blog/trevipay-announces-acquisition-of-baton-financial-services-inc/](https://www.trevipay.com/resource-center/blog/trevipay-announces-acquisition-of-baton-financial-services-inc/) retrieved 2026-07-05 ### W10 Consumer Protection & APP Fraud Probable confirmed 2026-07-05 Louisiana has no PSR-style mandatory authorized-push-payment (APP) fraud reimbursement regime (a UK-specific construct not present in the US federal or Louisiana state frameworks); consumer protection instead relies on LUTPA's private right of action and AG enforcement, the criminal bank-fraud restitution statute, DOJ-led elder-fraud/imposter-scam alerts specific to Louisiana's federal districts, and emerging 2026 state legislative activity targeting illegal debit-card surcharge fees. Standing sub-brief · as of 5 July 2026 73 words · last cycle 2026-07-05 #### Consumer Protection & APP Fraud Louisiana has no PSR-style mandatory authorised-push-payment fraud reimbursement regime. Consumer redress instead relies on LUTPA private actions and Attorney General enforcement, the criminal bank-fraud restitution statute, and DOJ-led elder-fraud and imposter-scam alerts specific to Louisiana's federal districts. #### Outlook Without a mandatory reimbursement framework, Louisiana APP-fraud victims will continue to depend on LUTPA, criminal restitution, and DOJ awareness campaigns; monitor for any legislative proposals modelled on PSR-style reimbursement mandates. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T3 [https://legalclarity.org/louisiana-consumer-protection-laws-key-provisions-and-practices/](https://legalclarity.org/louisiana-consumer-protection-laws-key-provisions-and-practices/) retrieved 2026-07-05 2. T1 [https://www.justice.gov/usao-mdla/pr/middle-district-louisiana-raises-awareness-government-imposter-scams](https://www.justice.gov/usao-mdla/pr/middle-district-louisiana-raises-awareness-government-imposter-scams) retrieved 2026-07-05 3. T1 [https://www.justice.gov/usao-wdla/pr/fraud-alert-scammers-claiming-be-department-justice-and-preying-elderly](https://www.justice.gov/usao-wdla/pr/fraud-alert-scammers-claiming-be-department-justice-and-preying-elderly) retrieved 2026-07-05 4. T1 [https://codes.findlaw.com/la/revised-statutes/la-rev-stat-tit-14-sect-71-1/](https://codes.findlaw.com/la/revised-statutes/la-rev-stat-tit-14-sect-71-1/) retrieved 2026-07-05 5. T3 [https://www.kplctv.com/2026/04/01/that-extra-charge-your-receipt-could-be-illegal-louisiana-bill-targets-illegal-debit-card-fees/](https://www.kplctv.com/2026/04/01/that-extra-charge-your-receipt-could-be-illegal-louisiana-bill-targets-illegal-debit-card-fees/) retrieved 2026-07-05 ### W11 AML/CFT & Financial Crime [Sourced from Sentinel.gi ↗](https://sentinel.gi/jurisdictions/united-states-louisiana/#sec-dom-D7) Probable confirmed 2026-07-05 A dedicated Sentinel.gi payments-context AML/CFT position for US-LA was not retrievable within this collection run; this module is populated with the federal Bank Secrecy Act (BSA)/FinCEN posture that governs Louisiana-licensed money transmitters and virtual-currency businesses as the available proxy baseline, pending a direct Sentinel.gi feed pull in a subsequent run. Standing sub-brief · as of 5 July 2026 123 words · last cycle 2026-07-05 #### AML/CFT & Financial Crime A direct Sentinel.gi payments-context AML/CFT feed for Louisiana was not retrievable this cycle. The federal Bank Secrecy Act/FinCEN regime is therefore carried as the proxy baseline governing Louisiana-licensed money transmitters and virtual-currency businesses, including a pending FinCEN proposal (April 2026) requiring continuously current risk-based AML/CFT programs under the AML Act of 2020. Analysis of illicit-finance exposure specific to Louisiana's virtual-currency and kiosk-operator population is routed to the Financial Integrity Monitor rather than treated as a WPM conclusion; see the Sentinel.gi feed for that analysis. #### Outlook A direct Sentinel.gi feed pull for Louisiana is the principal outstanding research item for this module; pending that, the federal BSA/FinCEN proxy baseline, including the April 2026 continuous-currency AML/CFT proposal, remains the governing framework. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 sentinel.proxy://www.fdic.gov/banker-resource-center/anti-money-laundering-countering-financing-terrorism-amlcft 2. T? FIM (sentinel.gi) per-JID baseline profile — United States — Louisiana — Louisiana AML/CTF sits inside the federal BSA/AML framework administered by FinCEN/OFAC, with the state Office of Financial Institutions (OFI) supervising state-chartered banks, money transmitters and sharing OFAC compliance information under a standing MOU. Louisiana has no independent state beneficial-ownership registry; federal CTA reporting for domestic entities was suspended in March 2025. 3. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: sourcing-thinness 4. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: regulatory-failure ### W12 Correspondent Banking, Settlement & Access Probable confirmed 2026-07-05 Louisiana's payments-settlement access runs through the standard US federal rails (Fedwire, FedNow, ACH) and correspondent banking relationships maintained by its large community-bank sector; the state is exposed to the national "de-risking" trend in which larger correspondent banks curtail relationships with smaller respondent institutions over AML/CDD cost and risk concerns, a dynamic of particular relevance given Louisiana's high concentration of small, rural community banks. Standing sub-brief · as of 5 July 2026 87 words · last cycle 2026-09-21 #### Correspondent Banking, Settlement & Access Louisiana's 80 state-chartered banks, concentrated in a disaster-prone, small and rural community-bank sector, are exposed to the national correspondent-banking de-risking trend, in which larger correspondent banks curtail relationships with smaller respondent institutions over AML and customer-due-diligence cost concerns. This bank-access asymmetry — large correspondent banks versus small respondent community banks — is the structural spine of Louisiana's correspondent-banking exposure. #### Outlook Monitor for any correspondent-relationship terminations affecting Louisiana's small and rural banks, and for federal policy responses to the broader national de-risking trend. Periodic update · new data 2026-09-22 #### Correspondent Banking, Settlement & Access The analytical spine of this module for Louisiana this cycle is a bank-versus-non-bank access development specific to regulatory coordination rather than direct correspondent-banking access. Act 888 (HB 1230), the Louisiana Money Transmission Act, grants the Commissioner of the Louisiana Office of Financial Institutions authority to participate in multistate examinations of money-transmission licensees, including the ability to serve as lead investigative state. This is a supervisory-access and coordination change, not a direct change to correspondent-banking relationships between banks and non-bank payment institutions, but it strengthens the state's cross-jurisdictional supervisory reach over the non-bank payment-institution population it licenses. For non-bank money-transmission licensees operating across multiple states, this development means Louisiana's regulator now has an enhanced formal mechanism to coordinate examination activity with peer-state regulators, potentially reducing duplicative examination burden for multistate licensees over time, though the practical effect depends on how actively the Commissioner exercises the new lead-investigative-state role. This sits within the broader bank-versus-non-bank asymmetry that defines this module: banks access the payment system through direct correspondent and settlement relationships governed by a different supervisory architecture, while non-bank money-transmission licensees rely on state-level licensing and, increasingly, coordinated multistate examination as their primary access-governance mechanism. #### Outlook Watch for confirmation of how frequently and in what circumstances the Louisiana Commissioner exercises the new multistate lead-investigative-state authority, and for any parallel supervisory-coordination developments among peer states adopting similar CSBS-model frameworks. **1 earlier distinct update(s)** Periodic update · new data 2026-09-08 #### Correspondent Banking, Settlement & Access The new Louisiana Money Transmission Act layers Bank Secrecy Act reporting duties, five-year recordkeeping, and quarterly call-report obligations onto licensees, alongside financial-responsibility requirements including tangible net worth and surety bonds. The Act's automatic-revocation mechanic is the module's analytical spine this cycle: a license may be automatically revoked, without further act of the commissioner, in specified circumstances including a licensee's failure to furnish a replacement surety bond within a defined window after a cancellation notice. This is a structurally different risk from a discretionary enforcement action — it removes commissioner discretion once the statutory trigger is met, meaning a non-bank licensee's settlement and correspondent access can lapse on a bond-administration failure rather than a conduct-based finding. This sits squarely within the bank-PSP versus non-bank-PI/EMI access asymmetry that defines this module: bank-chartered entities typically retain direct settlement rail access, while non-bank licensees remain dependent on correspondent relationships that can be disrupted by exactly this kind of automatic, non-discretionary licensing event. #### Outlook Watch for whether any Louisiana-licensed non-bank transmitter experiences an automatic-revocation trigger during the transition window running into the third quarter of 2027, and for whether correspondent banks adjust onboarding diligence in response to the new bond-administration-linked revocation mechanic. **Sources and findings (4)** 1. T1 [https://www.congress.gov/crs-product/IF10873](https://www.congress.gov/crs-product/IF10873) retrieved 2026-07-05 2. T3 [https://acceleronbank.com/articles/correspondent-banking-de-risk](https://acceleronbank.com/articles/correspondent-banking-de-risk) retrieved 2026-07-05 3. T3 [https://www.cpiai.com/post/risk-resilience-and-regional-banking-how-community-banks-support-louisiana-s-economy-and-why-ris](https://www.cpiai.com/post/risk-resilience-and-regional-banking-how-community-banks-support-louisiana-s-economy-and-why-ris) retrieved 2026-07-05 4. T1 [https://ofi.la.gov/depository/banks/active-banks-directory/](https://ofi.la.gov/depository/banks/active-banks-directory/) retrieved 2026-07-05 ### W13 Commercial Intelligence (M&A, Investment & Product) Probable confirmed 2026-07-05 Within the trailing 12 months (July 2025-July 2026), Louisiana's commercial-intelligence signal in payments/financial-services M&A is dominated by community-bank and credit-union consolidation rather than standalone payments-fintech deals; no major Louisiana-headquartered payments-fintech funding round or acquisition was identified in this window, which is itself a notable data point given the state's small fintech base. Standing sub-brief · as of 5 July 2026 152 words · last cycle 2026-07-05 #### Commercial Intelligence Three bank/credit-union transactions were captured this cycle. Keesler Federal Credit Union completed its merger with Jefferson Financial Federal Credit Union, with Keesler as the surviving institution effective July 1, 2025. MC Bancshares, Inc. shareholders approved a proposed merger with DMMS Purchaser, Inc. (led by Daryl Byrd/DMMS Holdings LLC); the combined entity is expected to continue operating as MC Bank, with closing targeted for Q2 2026 subject to regulatory approval, deal value not publicly disclosed. Catalyst Bancorp, Inc. signed a definitive agreement to acquire Lakeside Bancshares, Inc. in an all-cash transaction valued at approximately $41.1 million, with Lakeside merging into Catalyst Bank and closing expected in Q3 2026. No standalone Louisiana payments-fintech funding round or acquisition was identified in the trailing 12 months. #### Outlook Watch for the MC Bancshares/DMMS Purchaser closing (targeted Q2 2026) and the Catalyst Bancorp/Lakeside Bancshares closing (targeted Q3 2026); Louisiana's commercial-intelligence profile remains bank/credit-union-consolidation-led rather than fintech-venture-led. no periodic updates on record for this sub-brief ** Sources and findings (3)** 1. T3 [https://www.privsource.com/acquisitions/financial-services/state/louisiana](https://www.privsource.com/acquisitions/financial-services/state/louisiana) retrieved 2026-07-05 2. T3 [https://www.privsource.com/acquisitions/financial-services/state/louisiana](https://www.privsource.com/acquisitions/financial-services/state/louisiana) retrieved 2026-07-05 3. T3 [https://www.privsource.com/acquisitions/financial-services/state/louisiana](https://www.privsource.com/acquisitions/financial-services/state/louisiana) 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 – Louisiana| 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"}}}`. **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:** 1 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), 62 finding(s), 159 source(s) in the cumulative register. Think something on this page is wrong? [Report an error](https://payments.gi/legal/#contact).