title: United States – Virginia Payments Regulation Monitor | World Payments Monitor canonical: https://payments.gi/jurisdictions/united-states-virginia/ date_modified: 2026-10-21 publisher: Asymmetric Intelligence # United States – Virginia US-VA schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-21 · 14 modules · 62 sourced findings · 134 sources in the cumulative register 14 Modules baseline.modules[] 62 Findings modules[].findings[] 37 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 – Virginia is covered once, on the [United States](https://payments.gi/jurisdictions/united-states/) page. This page covers United States – Virginia’s own layer: its own law, regulators and enforcement. ## Jurisdiction brief ###### Latest update · 11 October 2026 #### Lead Signal Virginia's Money Transmission Modernization Act, Chapter 19.1 of Title 6.2 of the Code of Virginia, took effect on 1 July 2026, replacing the prior Chapter 19 licensing regime in its entirety. The new regime introduces tiered tangible-net-worth thresholds starting at 100,000 dollars and scaling with the size of a licensee's asset base, a revised bond formula, and integration into the Nationwide Multistate Licensing System. The implementing administrative regulation, 10VAC5-120, has been the subject of a proposed amendment by the State Corporation Commission's Bureau of Financial Institutions, filed under Case No. BFI-2026-00008 with a recommended effective date aligned to the statute, though a final-adoption order confirming the amendment has not been independently retrieved; current-text revision dates are consistent with adoption having occurred. The same statutory overhaul carries a second, distinct effect for digital-money classification. Va. Code § 6.2-1922 defines money in terms that exclude virtual currency, a direct statutory exclusion confirmed from the primary text itself. This creates a classification boundary: a business transmitting virtual currency alone, without any fiat, stored-value or payment-instrument component, falls outside the Chapter 19.1 money-transmitter licensing perimeter. Virginia has separately enacted, but not yet brought into force, a standalone Virtual Currency Kiosk License under a new Chapter 22.2 pursuant to HB665, aimed at kiosk operators specifically; that licence does not take effect until 1 July 2027. #### Other Developments **A tiered capital and bonding structure replaces the prior uniform threshold.** The modernised Chapter 19.1 regime scales its tangible-net-worth requirement with the size of a licensee's business rather than applying a single flat threshold, a design choice consistent with the broader multistate trend toward NMLS-harmonised licensing standards, and it brings Virginia into closer alignment with the licensing architecture used by other NMLS-participating states. **The virtual-currency kiosk licence closes a gap it does not yet close.** Chapter 22.2 was enacted on 13 April 2026 but will not take effect until 1 July 2027, over a year after the general money-transmitter regime's virtual-currency exclusion took effect. This creates a defined interim period during which virtual-currency kiosk operators in Virginia are not reached by either the general money-transmitter licence, from which virtual-currency-only activity is excluded, or the kiosk-specific licence, which is not yet operative. The primary bill text for Chapter 22.2 was not independently retrieved this cycle; its substantive terms were sourced from secondary commentary, and that sourcing limitation is carried forward as an open item. #### Cross-Monitor Connections The licensing-perimeter narrowing created by the Chapter 19.1 virtual-currency exclusion has a direct financial-integrity reading: a definitional carve-out from money-transmitter licensure removes a category of business from the state-level AML-adjacent supervisory gateway, even though such businesses remain subject to federal Bank Secrecy Act and FinCEN money-services-business obligations. That reading is developed in financial-integrity's own treatment of this jurisdiction and is not repeated in full here; the payments-side framing is about market access and licensing classification, not about illicit-finance exposure, which belongs to that monitor's own analysis. #### Outlook The interim period between 1 July 2026 and 1 July 2027 is the window in which Virginia's virtual-currency-only payment and kiosk operators sit outside both the general money-transmitter licensing perimeter and the forthcoming kiosk-specific licence. Confirmation of the SCC's final-adoption order for the 10VAC5-120 amendment, and direct retrieval of the Chapter 22.2 bill text, remain outstanding items that would sharpen the picture of how Virginia intends the transition between these two licensing regimes to operate in practice. _3 earlier updates not shown here._ ###### Standing brief · as of 8 July 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Lead Signal Virginia's 2025 overhaul of the Money Transmitters Act crosses into force this cycle, restructuring licensing economics for every non-bank money transmitter operating in the Commonwealth. The amendment lowers the starting net-worth minimum to $100,000, resets the surety-bond formula to a $100,000-$1M band, and revises permissible-investment obligations, superseding the prior flat $200,000 net-worth minimum, effective July 1, 2026. The change lands atop a licensing architecture that has long been unusually consolidated: Virginia requires money transmission and money order selling to be licensed exclusively under the Virginia Money Transmitters Act (Title 6.2, Chapter 19), administered by the Bureau of Financial Institutions within the State Corporation Commission via NMLS, with no separate EMI or PPI charter available. Because safeguarding of customer funds in Virginia rests on a surety bond rather than a segregation or trust model, and Virginia does not separately mandate liability insurance as a licensing prerequisite, the July 1 recalibration of bond and net-worth thresholds resets the primary consumer-protection buffer for the Commonwealth's non-bank payments sector at the same moment entry costs for new licensees are eased. #### Other Developments Two other Virginia developments reached effective or enforceable status either side of this cycle. SB 1212, codified at Virginia Code § 59.1-608, requires clear and conspicuous total-price disclosure of all mandatory fees and card surcharges in consumer transactions, effective July 1, 2025, and is enforced as a Virginia Consumer Protection Act violation carrying civil penalties and a private right of action for damages. That disclosure duty sits atop the existing card-network surcharge caps of 3% for Visa and 4% for Mastercard, and Virginia imposes no independent state-level surcharge cap of its own, while debit-card surcharging remains illegal nationwide. Separately, HB 798 brings dormant digital assets into Virginia's unclaimed-property escheat regime: cryptocurrency inactive for five years or more is presumed abandoned and must be transferred in-kind to state custody, where it must be held at least one year before any liquidation, effective July 1, 2026. That state-level custody precedent sits against a federal backdrop in which the GENIUS Act establishes the primary regulatory framework for any Virginia-domiciled or Virginia-serving payment-stablecoin issuer, delegating approval to federal banking agencies or qualified state regulators, with implementing regulations generally required by July 18, 2026; Virginia itself has no state-qualified stablecoin-issuer pathway. On the commercial side, Capital One Financial Corp's $35.3 billion acquisition of Discover Financial Services has closed, making the McLean-headquartered lender the largest US credit-card issuer and the sixth-largest US bank, with post-merger integration continuing into 2026 through further workforce reductions at Discover's former Riverwoods headquarters. In litigation, the Supreme Court of Virginia held in Groundworks Operations LLC v. Campbell that the Virginia Wage Payment Act's protections do not extend to commissions, narrowing the statute's reach for payroll-adjacent payment disputes. #### Cross-Monitor Connections Virginia's money transmitter licensees must register as Money Services Businesses with FinCEN via BSA e-filing and maintain an independently reviewed AML/BSA programme as a precondition of state licensing, but no Virginia-specific Sentinel.gi payments-context feed entry was located this cycle; the illicit-finance dimension of that federal overlay is accordingly routed to the Financial Integrity Monitor rather than analysed here. Separately, the Federal Reserve Bank of Richmond's operation of FedNow, national ACH processing, and Fifth District Treasury and master-account settlement services gives Virginia-domiciled institutions structural, direct access to core US settlement infrastructure that in most other jurisdictions runs through correspondent-banking intermediation — a bank-versus-non-bank access asymmetry worth tracking as Virginia's non-bank licensing population grows under the softened 2025 entry thresholds. #### Outlook Three near-term dates anchor the forward calendar: the Money Transmitters Act overhaul and the HB 798 crypto-escheat law both take effect July 1, 2026, and GENIUS Act implementing regulations are due July 18, 2026. Two items remain unresolved and warrant continued monitoring: the final enacted or vetoed status of SB 1252, a proposed 12% interest-rate cap with anti-evasion provisions targeting bank-fintech and earned-wage-access lending partnerships introduced in January 2025, and the durability of the Capital One-Discover integration as workforce reductions continue at the former Discover headquarters. Absent a dedicated state APP-fraud reimbursement scheme or a payments-specific operational-resilience regime, Virginia consumers and infrastructure remain reliant on federal Regulation E and on the physical resilience of the PJM grid serving the Loudoun County data-center cluster, respectively, as the Commonwealth's principal residual exposures. trust tier: ai_unverified ###### Latest update · 11 October 2026 #### Regulatory Status Virginia's payments regulatory landscape moved through a confirmed structural transition this cycle. Chapter 19.1 of Title 6.2 of the Code of Virginia, the Money Transmission Modernization Act, took effect on 1 July 2026 and replaced the prior Chapter 19 regime in full, introducing tiered tangible-net-worth thresholds from 100,000 dollars, a revised bond formula, and Nationwide Multistate Licensing System integration. The same statute, at § 6.2-1922, defines money to exclude virtual currency, creating a licensing-perimeter boundary under which virtual-currency-only transmission activity, lacking any fiat or stored-value leg, falls outside Chapter 19.1 licensure. A separate Virtual Currency Kiosk License under a new Chapter 22.2, enacted pursuant to HB665 on 13 April 2026, will license kiosk operators specifically, but is not yet effective; its commencement date is 1 July 2027. Virginia's State Corporation Commission, through its Bureau of Financial Institutions, is the supervisory authority for both the general money-transmitter regime and the forthcoming kiosk licence. The Bureau's proposed implementing-regulation amendment to 10VAC5-120, filed under Case No. BFI-2026-00008, appears from current-text revision dates to be consistent with adoption aligned to the 1 July 2026 statutory commencement, though a confirmatory final-adoption order was not independently retrieved this cycle. #### Outlook The period between 1 July 2026 and 1 July 2027 is Virginia's defined interim window for virtual-currency kiosk classification, during which such activity sits outside both the general money-transmitter perimeter and the forthcoming kiosk-specific licence. Confirmation of the Bureau's final-adoption order and direct retrieval of the Chapter 22.2 bill text are the two outstanding evidentiary items most likely to sharpen this jurisdiction's regulatory picture in the next cycle. _3 earlier updates not shown here._ ###### Standing brief · as of 8 July 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Regulatory Status Virginia's payments regulatory posture is assessed as ELEVATED and tightening, anchored by active legislative modernization across licensing, disclosure and digital-asset custody: the 2025 Money Transmitters Act overhaul and the HB 798 crypto-escheat law both took effect July 1, 2026, while Capital One-Discover integration continues. Non-bank payments activity is licensed exclusively under the Virginia Money Transmitters Act, Title 6.2, Chapter 19, administered by the Bureau of Financial Institutions within the State Corporation Commission via NMLS, with no separate EMI or PPI charter, and the 2025 overhaul lowers the starting net-worth minimum to $100,000 and resets the surety-bond formula to $100,000-$1M. Customer-fund safeguarding rests on that surety bond rather than a segregation or trust model, while SB 1212 has required clear total-price and surcharge disclosure since July 2025, enforced as a Consumer Protection Act violation with a private right of action. On digital assets, HB 798 brings dormant cryptocurrency into the Commonwealth's unclaimed-property escheat regime effective July 1, 2026, against a federal backdrop in which the GENIUS Act's implementing regulations for payment-stablecoin issuers are due July 18, 2026. Commercially, Capital One Financial Corp's closed $35.3 billion acquisition of Discover Financial Services has made the McLean-headquartered lender the largest US credit-card issuer, with post-merger integration still generating workforce reductions in 2026. Structurally, the Federal Reserve Bank of Richmond gives Virginia-domiciled institutions direct access to FedNow, national ACH processing, and master-account settlement, reducing reliance on correspondent-banking intermediation relative to non-bank licensees. Residual gaps remain: no payments-specific operational-resilience regime addresses the Loudoun County data-center grid-concentration exposure, SB 1252's fintech-lending usury-cap status is unresolved, no state APP-fraud reimbursement scheme supplements federal Regulation E, and no Virginia-specific Sentinel.gi feed entry was located for AML/CFT this cycle. #### Outlook The near-term calendar is dominated by three dates already in force or imminent — the MTA overhaul and HB 798 (July 1, 2026) and the GENIUS Act implementing-regulation deadline (July 18, 2026) — after which the collection is expected to stabilise pending SB 1252's final disposition. Continued Capital One-Discover workforce integration and the softened 2025 entry thresholds for money transmitters are the two developments most likely to reshape Virginia's payments landscape over the coming cycles. 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 Virginia repealed its legacy money-transmitter statute (Title 6.2, Chapter 19) in full and replaced it, effective July 1, 2026, with Chapter 19.1, adopting the CSBS Money Transmission Modernization Act (MTMA) model. Net worth, surety bond, permissible-investment, control-threshold, and reporting standards all changed; existing licensees were automatically deemed licensed under the new chapter. Horizon · 2026-07-01 (±quarter) Virginia Money Transmitters Act 2025 overhaul in force_in_force_pending · TT3_ Standing sub-brief · as of 8 July 2026 166 words · last cycle 2026-10-11 #### Licensing, Authorisation & Market Access Virginia requires money transmission and money order selling to be licensed exclusively under the Virginia Money Transmitters Act, Title 6.2, Chapter 19 of the Code of Virginia, administered by the Bureau of Financial Institutions within the State Corporation Commission via the Nationwide Multistate Licensing System, and the Commonwealth maintains no separate electronic-money-institution or prepaid-instrument charter for non-bank payments activity. A 2025 legislative overhaul of that Act restructures the licensing economics for every existing and prospective licensee, lowering the starting net-worth minimum to $100,000, resetting the surety-bond formula to a band of $100,000 to $1 million, and revising permissible-investment obligations, superseding the prior flat $200,000 net-worth minimum, with the new regime effective July 1, 2026. #### Outlook With the overhaul now in force, licensing costs for new non-bank entrants are lower at the point of entry even as the bond formula scales with transmitted-funds volume, a combination that merits tracking for its effect on Virginia's non-bank licensee population over the coming reporting cycles. Periodic update · new data 2026-10-11 #### Licensing, Authorisation & Market Access Virginia's money-transmitter licensing regime underwent a comprehensive modernisation with the 1 July 2026 commencement of Chapter 19.1 of Title 6.2 of the Code of Virginia, which replaced the prior Chapter 19 regime in its entirety. The new regime introduces tiered tangible-net-worth thresholds beginning at 100,000 dollars and scaling upward with the size of a licensee's asset base, replacing what had been a more uniform capital requirement. A revised bond formula accompanies the net-worth tiers, and the regime is integrated into the Nationwide Multistate Licensing System, the shared licensing infrastructure used across most US states for money-transmitter and related non-bank licensure. This is a non-bank payment-institution and e-money-institution matter specifically: Chapter 19.1 governs the licensing pathway for non-bank money transmitters operating in Virginia, and the modernisation does not alter the separate prudential and chartering framework that applies to bank-chartered entities, which access payment rails through their banking charters rather than through the Chapter 19.1 MTL pathway. For the non-bank population this regime governs, the shift to NMLS-integrated, tiered-threshold licensing brings Virginia into closer alignment with the licensing architecture already used in many other NMLS-participating states, which may reduce friction for multistate money-transmitter applicants who previously had to reconcile Virginia's older framework against the NMLS-harmonised requirements used elsewhere. A material open item concerns the administrative-level implementation of this statutory change. The State Corporation Commission's Bureau of Financial Institutions proposed amendments to its implementing regulation, 10VAC5-120, under Case No. BFI-2026-00008, with a recommended effective date aligned to the 1 July 2026 statutory commencement. Current-text revision dates on the regulation, most recently 23 September 2026, are consistent with the amendment having been adopted, but a confirmatory final-adoption order was not independently retrieved this cycle. Until that order is located and confirmed, the precise administrative detail of how the Bureau intends to apply tiered thresholds, bonding requirements and NMLS integration in practice carries a degree of residual uncertainty, even though the underlying statutory change itself is well evidenced directly from the Code of Virginia. The practical consequence for market-access planning is that applicants and existing licensees transitioning from the old Chapter 19 regime to the new Chapter 19.1 regime should expect the statutory thresholds and NMLS integration to be operative from 1 July 2026, while treating the fine administrative detail of the Bureau's implementing rule as provisional pending confirmation of final adoption. This is a licensing-required-and-actively-enforced environment undergoing a structural tightening and modernisation exercise, not a jurisdiction newly introducing licensing where none existed before; Virginia has licensed money transmitters under some form of Chapter 19 or 19.1 continuously, and the current cycle is best read as a substantial refresh of an established regime rather than a new regulatory gateway. #### Outlook Confirmation of the Bureau of Financial Institutions' final-adoption order for the 10VAC5-120 amendment is the principal outstanding item for this module. Once confirmed, the administrative detail of tiered-threshold application and bonding calculation will be fully evidenced from a primary source, completing the picture of a modernisation that is already confirmed at the statutory level as having taken effect on 1 July 2026. **3 earlier distinct update(s)** Periodic update · new data 2026-09-28 #### Licensing, Authorisation & Market Access Virginia's money-transmitter licensing framework underwent a wholesale statutory replacement this cycle. House Bill 1942 (2025 Acts of Assembly, Chapter 214) repealed Chapter 19 of Title 6.2 in its entirety and enacted a new Chapter 19.1, effective July 1, 2026, confirmed directly on primary statutory text. The revised regime brings Virginia into closer alignment with the CSBS Money Transmission Modernization Act model used by an increasing number of US states, a structural convergence likely to ease multistate compliance for licensees already operating under similar standards elsewhere while simultaneously tightening scrutiny of who may acquire control of a licensee. Key prudential standards changed under the new chapter, though at varying confidence levels. Tangible net worth is now the greater of $100,000 or 3 percent of total assets under GAAP, sliding upward above $100 million in total assets, replacing what was previously a flat minimum threshold; this figure is sourced from a single secondary legal-commentary summary rather than independently confirmed against final statutory text this cycle, and is assessed at Probable confidence accordingly. The surety-bond requirement is similarly revised to the greater of $100,000 or 100 percent of a licensee's average daily money-transmission liability in Virginia, capped at $1,000,000 under the renumbered Section 6.2-1951, also at Probable confidence on the same secondary-source basis. The acquisition-of-control threshold is now set at 25 percent, with a new formal pre-approval process required for any entity seeking to cross that threshold with respect to a Virginia-licensed non-bank money transmitter; this pre-approval gate is a non-bank PI/EMI-layer control specifically, distinct from the separate supervisory pathways applicable to bank-chartered entities conducting payment activity in the Commonwealth. Transition treatment for incumbents was addressed directly: any business licensed under the legacy Chapter 19 as of June 30, 2026 was automatically deemed licensed under the new Chapter 19.1 on July 1, 2026, with no re-application required, a continuity provision that limits near-term market-access disruption even as the substantive prudential and control-disclosure standards shift materially. Separately, the new chapter defines virtual currency for the first time in Virginia's money-transmission code but expressly excludes it from the statutory definition of money, a definitional choice confirmed on primary statutory text that has direct consequences for which digital-asset business models require licensure at all, addressed in full by the jurisdiction's crypto-monitor coverage rather than re-analysed here. #### Outlook The most concrete near-term test of the new regime will be the first control-acquisition applications processed under the 25 percent pre-approval threshold and the first enhanced quarterly reports of condition filed under the new reporting standard. Primary statutory confirmation of the specific net-worth and surety-bond dollar figures, currently resting on a single secondary source, remains an open research item; independent verification against the enacted bill text or the Bureau of Financial Institutions' own published guidance would raise confidence on those two figures from Probable toward Confirmed. Periodic update · new data 2026-08-26 #### Licensing, Authorisation & Market Access Effective July 1, 2026, Virginia Chapter 19.1 replaced Chapter 19 of Title 6.2 in its entirety, adopting the Conference of State Bank Supervisors' Money Transmission Modernization Act model law. The replacement is comprehensive rather than incremental: it rewrites definitions, scope, licensing procedures, net-worth and surety-bond standards, permissible-investment rules, authorized-delegate oversight requirements, acquisition-of-control procedures, reporting obligations, consumer-protection provisions, and multistate coordination mechanisms in a single statutory act. For the non-bank payment-institution and money-transmitter population licensed under Title 6.2 — a population that sits outside the bank regulatory perimeter by definition — this is the most consequential Virginia-specific licensing development of the cycle. A further scope-defining provision within the same chapter excludes virtual currency from the statutory definition of "money." The practical effect is that a platform dealing exclusively in virtual currency, without a fiat-currency leg, falls outside Chapter 19.1's money-transmission licensure requirement entirely, regardless of transaction volume. This carve-out narrows the population of entities that must hold a Virginia money-transmitter licence, even as the state simultaneously modernizes and tightens the licensing standards that do apply to the remaining, fiat-inclusive population. For existing Chapter 19 licensees, the reset creates immediate transition-compliance priorities. Incumbents must assess their standing against the new net-worth and surety-bond requirements, update authorized-delegate contracts and oversight policies, and evaluate their ownership and control structures against the newly codified 25 percent control threshold, which now triggers a pre-approval requirement for any acquisition of control over a licensed entity. The implementing-regulation layer is also moving. The Virginia State Corporation Commission's Bureau of Financial Institutions has proposed conforming amendments to 10VAC5-120, under Case No. BFI-2026-00008, that update regulatory definitions to match the new statute, specify licence-application requirements, clarify the exemptions available under the statute's exemption provision, prescribe the methods by which a licensee may demonstrate compliance with the net-worth requirement, and delegate certain SCC authority to the Commissioner of Financial Institutions. This development is assessed at HIGH impact in this cycle's structured review, and it applies exclusively to the non-bank payment-institution and money-transmitter licensing population; bank-chartered entities offering payment services in Virginia continue to operate under separate federal and state banking law and are unaffected by Chapter 19.1's reset. The reset also has multistate-coordination implications, since the CSBS model law that Chapter 19.1 adopts is designed to interoperate with the same model law as enacted in other U.S. states, which in principle should streamline multistate licensing applications for money transmitters operating across state lines. #### Outlook The transition period between the July 1, 2026 statutory effective date and the eventual finalization of the SCC's conforming regulatory amendments is the near-term risk window for licensees: obligations under the new statute are already in force, while several of the practical mechanics for satisfying them remain subject to a rulemaking still in progress under Case No. BFI-2026-00008. New entrants evaluating Virginia market access should note that the virtual-currency exclusion from "money" changes the calculus for crypto-native business models specifically: a pure virtual-currency platform may find it does not need a Virginia money-transmitter licence at all, while a platform with any fiat-currency leg remains squarely within Chapter 19.1's scope. Periodic update · new data 2026-08-11 #### Licensing, Authorisation & Market Access Virginia's money-transmission framework underwent a complete legislative replacement this cycle. Chapter 19 of Title 6.2 of the Code of Virginia - the state's money-order-seller and money-transmitter statute - was repealed effective 1 July 2026 under Acts of Assembly 2025, Chapter 214 (HB 1942), and superseded by new Chapter 19.1. The new chapter adopts the CSBS Money Transmission Modernization Act model law and eliminates the standalone money-order-seller licence category that existed under the old statute. Virginia's adoption places it alongside more than thirty other states that have already adopted the MTMA in whole or in part, which should reduce multi-state licensing friction for transmitters that already hold licences across that cohort of states, even as the Commonwealth's own prudential requirements are simultaneously being recalibrated. That recalibration is concrete and quantified. Chapter 19.1 replaces the prior flat $200,000 net-worth minimum with a tiered structure starting at $100,000, and introduces a surety-bond formula keyed to a transmitter's average daily money-transmission liability rather than a flat bond figure. This is a bank-versus-nonbank-relevant change specifically because it falls on non-bank money transmitters and payment institutions - the entities licensed under this chapter are, by definition, non-bank actors; banks conducting payment activity operate under a different prudential perimeter entirely, and Chapter 19.1's tiered bond and net-worth structure does not touch that separate bank-regulatory track. The Virginia State Corporation Commission has begun the administrative work of implementing the new statute. On 4 May 2026, the Commission published proposed amendments to 10VAC5-120 conforming the regulation to Chapter 19.1: updating definitions, licence-application requirements, and the exemption scope under Section 6.2-1923, and delegating administrative powers to the Commissioner of Financial Institutions. These amendments were still pending finalization as of this cycle's observation date, meaning Chapter 19.1 is in force as a statute while its full regulatory implementation remains incomplete. Scope changes accompany the prudential and administrative ones. Chapter 19.1 excludes virtual currency from the statutory definition of money, which means purely crypto-to-crypto activity falls outside Virginia's money-transmitter licensure requirement altogether. At the same time, the chapter expands the definition of money transmission to explicitly include payroll processing, bringing a category of commercial-payments activity within the licensing perimeter that had not previously been named in the statute. These two changes move in opposite directions on the same underlying question of what counts as money transmission in Virginia, and firms operating in either space have direct cause to re-examine their licensing position against the new statutory language. For an operator evaluating entry into Virginia's money-transmission market for the first time, the new regime is, on balance, a lower-friction proposition than the one it replaced, precisely because MTMA harmonization means a licence built to the model-law template can be leveraged across the growing cohort of adopting states with less bespoke compliance work per state. That efficiency gain is offset, though not eliminated, by the tiered net-worth and bond requirements, which mean the specific capital and surety obligations a new entrant faces will depend on its projected average daily transmission liability rather than a single flat figure applicable to every licensee regardless of size. The virtual-currency exclusion also has an entry-pathway dimension worth stating plainly: a firm whose Virginia-facing activity is limited to crypto-to-crypto transactions does not need a Virginia money-transmitter licence to conduct that specific activity under Chapter 19.1's current definition, though any fiat-denominated leg of a broader payments business would still fall within the licensing perimeter as before. None of the developments described here were sourced from a single outlet: the repeal and the SCC's conforming amendments both trace to Tier 1 primary sources - the Code of Virginia itself and the Virginia Register of Regulations - while the MTMA-adoption characterization, the tiered bond mechanics, and the virtual-currency scope change rest on Tier 4 secondary analysis that has not yet been corroborated against the enacted statutory text directly. #### Outlook The item to watch is finalization of the Commission's conforming amendments to 10VAC5-120, expected within roughly the next two quarters. Until those amendments finalize, the practical licensing experience for new applicants and the precise application of the tiered bond formula to existing licensees both remain incompletely specified at the regulatory level, even though Chapter 19.1 itself has been in force since 1 July 2026. **Sources and findings (6)** 1. T1 [https://law.lis.virginia.gov/vacode/title6.2/chapter19/section6.2-1901/](https://law.lis.virginia.gov/vacode/title6.2/chapter19/section6.2-1901/) retrieved 2026-07-05 2. T1 [https://www.scc.virginia.gov/regulated-industries/bureau-of-financial-institutions/](https://www.scc.virginia.gov/regulated-industries/bureau-of-financial-institutions/) retrieved 2026-07-05 3. T3 [https://fraxtional.co/feeds/blog/va-money-transmitter-license](https://fraxtional.co/feeds/blog/va-money-transmitter-license) retrieved 2026-07-05 4. T3 [https://www.bondexchange.com/virginia-money-transmitter-bond-a-comprehensive-guide/](https://www.bondexchange.com/virginia-money-transmitter-bond-a-comprehensive-guide/) retrieved 2026-07-05 5. T3 [https://fraxtional.co/feeds/blog/va-money-transmitter-license](https://fraxtional.co/feeds/blog/va-money-transmitter-license) retrieved 2026-07-05 6. T3 [https://fraxtional.co/feeds/blog/va-money-transmitter-license](https://fraxtional.co/feeds/blog/va-money-transmitter-license) retrieved 2026-07-05 ### W1b Conduct, Safeguarding & Promotions Confirmed confirmed 2026-07-05 Virginia has no dedicated e-money safeguarding regime; consumer protection runs through the surety bond mechanism plus VCPA enforcement. A mandatory-fee/surcharge disclosure statute (SB 1212) took effect July 1, 2025. Standing sub-brief · as of 8 July 2026 134 words · last cycle 2026-07-08 #### Conduct, Safeguarding & Financial Promotions Virginia's safeguarding of money-transmission customer funds rests on a surety bond rather than a segregation or trust model, compensating the public if a licensee fails to comply, and the Commonwealth does not separately mandate liability insurance as a licensing prerequisite. Separately, Virginia Code § 59.1-608 (enacted via SB 1212) requires clear and conspicuous total-price disclosure of all mandatory fees and card surcharges in consumer transactions, effective July 1, 2025, enforced as a Virginia Consumer Protection Act violation carrying civil penalties and a private right of action for damages. #### Outlook The absence of a segregation or trust requirement, combined with a private right of action now attached to fee-disclosure violations under SB 1212, makes Virginia's conduct regime one to watch as enforcement activity accumulates under the new total-price disclosure standard. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T3 [https://www.bondexchange.com/virginia-money-transmitter-bond-a-comprehensive-guide/](https://www.bondexchange.com/virginia-money-transmitter-bond-a-comprehensive-guide/) retrieved 2026-07-05 2. T1 [https://law.lis.virginia.gov/vacodeupdates/title59.1/section59.1-608/](https://law.lis.virginia.gov/vacodeupdates/title59.1/section59.1-608/) retrieved 2026-07-05 3. T3 [https://merchantcostconsulting.com/lower-credit-card-processing-fees/virginia-surcharge-laws/](https://merchantcostconsulting.com/lower-credit-card-processing-fees/virginia-surcharge-laws/) retrieved 2026-07-05 4. T1 [https://www.scc.virginia.gov/regulated-industries/bureau-of-financial-institutions/](https://www.scc.virginia.gov/regulated-industries/bureau-of-financial-institutions/) retrieved 2026-07-05 5. T1 [https://law.lis.virginia.gov/vacodefull/title6.2/chapter21/](https://law.lis.virginia.gov/vacodefull/title6.2/chapter21/) retrieved 2026-07-05 ### W2 Stablecoins & Digital Money Probable confirmed 2026-07-05 Virginia Chapter 19.1 excludes virtual currency from statutory 'money'; a not-yet-effective Virtual Currency Kiosk License (Chapter 22.2, eff. 1 Jul 2027) will licence kiosk operators specifically. No stablecoin-specific regime exists; token characterisation remains federal. Horizon · 2026-07-01 (±quarter) HB 798 unclaimed digital-assets law in force_in_force · TT3_ Horizon · 2026-07-18 (±quarter) GENIUS Act implementing regulations deadline_proposed · TT1_ Horizon · 2026-07-18 (±quarter) GENIUS Act implementing regulations deadline_proposed · T_ Horizon · 2026-07-01 (±quarter) Virginia HB 798 crypto unclaimed-property law in force_in_force_pending · TT3_ Horizon · 2026-07-18 (±quarter) GENIUS Act implementing regulations deadline_in_force_pending · TT1_ Standing sub-brief · as of 8 July 2026 143 words · last cycle 2026-10-11 #### Stablecoins & Digital Money Virginia's HB 798 brings dormant digital assets into the Commonwealth's unclaimed-property escheat regime: cryptocurrency inactive for five years or more is presumed abandoned and must be transferred in-kind to state custody, where it must be held at least one year before any liquidation, effective July 1, 2026. That state-level action sits against a federal backdrop in which the GENIUS Act establishes the primary regulatory framework for any Virginia-domiciled or Virginia-serving payment-stablecoin issuer, delegating approval to federal banking agencies or qualified state regulators, with implementing regulations generally required by July 18, 2026; no Virginia-specific state-qualified stablecoin-issuer pathway yet exists. #### Outlook Virginia has no state-qualified payment-stablecoin issuer pathway of its own, so any future framework would sit downstream of the federal GENIUS Act implementing rules due July 18, 2026, making that federal deadline the near-term marker to watch for this domain. Periodic update · new data 2026-10-11 #### Stablecoins & Digital Money Virginia's Chapter 19.1 recodification of its money-transmission statute carries a confirmed, directly sourced classification effect for digital money. Va. Code § 6.2-1922 defines money in terms that exclude virtual currency; the statutory language states plainly that money does not include virtual currency. The direct consequence is that a business whose Virginia activity consists of transmitting virtual currency alone, with no accompanying fiat, stored-value or payment-instrument leg, falls outside the Chapter 19.1 money-transmitter licensing perimeter as a matter of statutory definition, not administrative discretion. This definitional boundary does not leave virtual-currency activity in Virginia permanently unaddressed. A separate instrument, the Virtual Currency Kiosk License created under a new Chapter 22.2 pursuant to HB665, was enacted on 13 April 2026 specifically to license kiosk operators, a discrete and identifiable category of virtual-currency business. However, Chapter 22.2 does not take effect until 1 July 2027, a full year after the Chapter 19.1 exclusion commenced on 1 July 2026. The combined effect of these two dates is an interim period, running from mid-2026 to mid-2027, during which virtual-currency kiosk operators in Virginia are reached by neither the general money-transmitter licence, from which their virtual-currency-only activity is excluded, nor the kiosk-specific licence, which has not yet come into force. For market participants and product-design teams, this creates a genuine, time-bound classification question rather than a permanent regulatory gap: any product or service in Virginia whose structure is virtual-currency-only, without a fiat or stored-value component, should be assessed against the current absence of a licensing requirement during this specific window, bearing in mind that the kiosk-specific requirement will become operative on a known future date. Products that retain any fiat, stored-value or payment-instrument element continue to sit inside the general Chapter 19.1 licensing perimeter throughout this period and are unaffected by the virtual-currency exclusion. The evidentiary basis for the Chapter 22.2 kiosk licence's substantive terms should be stated precisely: this cycle's sourcing for the kiosk licence's terms came from secondary commentary rather than from the enacted bill text itself, which was not independently retrieved. The fact of enactment and the 1 July 2027 effective date are treated as probable rather than confirmed on this basis, pending direct retrieval of the primary legislative text. By contrast, the virtual-currency exclusion itself is sourced directly from the current Code of Virginia text and is treated as confirmed. This is not a stablecoin-specific regime in the sense of a framework addressing reserve backing, redemption rights or issuer licensure for fiat-referenced tokens; Virginia's Chapter 19.1 and Chapter 22.2 provisions address the money-transmission and kiosk-licensing classification of virtual currency generally, not a dedicated stablecoin-issuance framework. Readers looking for a Virginia-specific stablecoin-issuer licensing regime, as distinct from the money-transmission classification boundary described here, will not find one in this cycle's findings. #### Outlook The interim window between 1 July 2026 and 1 July 2027 is the period in which Virginia's virtual-currency kiosk activity sits in a defined classification gap between two licensing instruments. Direct retrieval of the Chapter 22.2 bill text would convert the current probable-confidence finding on the kiosk licence's substantive terms into a confirmed one, and would clarify whether any interim compliance expectations apply to kiosk operators ahead of the 2027 effective date. **Sources and findings (5)** 1. T3 [https://www.theblock.co/post/397484/virginia-approves-bill-unclaimed-crypto-assets](https://www.theblock.co/post/397484/virginia-approves-bill-unclaimed-crypto-assets) retrieved 2026-07-05 2. T3 [https://bitcoinmagazine.com/news/virginia-enacts-law-state-crypto](https://bitcoinmagazine.com/news/virginia-enacts-law-state-crypto) retrieved 2026-07-05 3. T3 [https://www.gibsondunn.com/digital-assets-recent-updates-april-2026/](https://www.gibsondunn.com/digital-assets-recent-updates-april-2026/) retrieved 2026-07-05 4. T1 [https://www.wiley.law/alert-Building-a-Digital-Asset-Regulatory-Framework-The-GENIUS-Act-and-Next-Steps](https://www.wiley.law/alert-Building-a-Digital-Asset-Regulatory-Framework-The-GENIUS-Act-and-Next-Steps) retrieved 2026-07-05 5. T1 [https://occ.treas.gov/news-issuances/bulletins/2026/bulletin-2026-3.html](https://occ.treas.gov/news-issuances/bulletins/2026/bulletin-2026-3.html) retrieved 2026-07-05 ### W3 Operational Resilience & Critical Infrastructure Probable confirmed 2026-07-05 Virginia has no payments-specific operational-resilience regime analogous to DORA; resilience oversight runs through the Secretary of Public Safety and Homeland Security (as Chief Resilience Officer) and university-partnered cybersecurity research (Commonwealth Cyber Initiative). The state's acute exposure is physical/critical-infrastructure concentration risk from its globally significant data-center cluster in Loudoun County ("Data Center Alley"), which underpins much of the mid-Atlantic's digital and payments infrastructure and has already produced a near-blackout grid event. 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 8 July 2026 100 words · last cycle 2026-07-08 #### Operational Resilience & Critical Infrastructure Virginia has no payments-specific operational-resilience regime analogous to the EU's DORA, so the closest identified proxy is physical: Loudoun County's 'Data Center Alley' concentrates 143 or more data centers whose grid dependency exposes payments-adjacent digital infrastructure to concentration risk, illustrated by a July 2024 near-blackout of 1.5 gigawatts that revealed structural mismatch with aging PJM transmission infrastructure. #### Outlook With no payments-specific resilience regime on the horizon and grid capacity constraints in Data Center Alley well documented, the physical-infrastructure exposure identified this cycle should be treated as a standing structural risk rather than a one-off event. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T1 [https://www.pshs.virginia.gov/homeland-security/](https://www.pshs.virginia.gov/homeland-security/) retrieved 2026-07-05 2. T3 [https://broadbandbreakfast.com/data-center-boom-in-virginias-data-center-alley-raises-infrastructure-concerns/](https://broadbandbreakfast.com/data-center-boom-in-virginias-data-center-alley-raises-infrastructure-concerns/) retrieved 2026-07-05 3. T3 [https://www.globaldatacenterhub.com/p/when-15-gigawatts-vanished-what-the](https://www.globaldatacenterhub.com/p/when-15-gigawatts-vanished-what-the) retrieved 2026-07-05 4. T3 [https://www.belfercenter.org/research-analysis/data-centers-texas-virginia-comparison](https://www.belfercenter.org/research-analysis/data-centers-texas-virginia-comparison) retrieved 2026-07-05 5. T3 [https://news.vt.edu/articles/2026/03/cci-cybersecurity-critical-infrastructure.html](https://news.vt.edu/articles/2026/03/cci-cybersecurity-critical-infrastructure.html) retrieved 2026-07-05 ### W4 Scheme & Network Compliance Probable confirmed 2026-07-05 Virginia does not regulate card-scheme rulebooks directly, but it does regulate merchant-facing scheme economics through its 2025 surcharge-disclosure statute and maintains a long-standing state credit-card crimes code governing acquirer/issuer/cardholder fraud. Card-network surcharge caps (Visa 3%, Mastercard 4%) and PCI DSS remain scheme-set rather than state-set standards applicable in Virginia as in all US states. Standing sub-brief · as of 8 July 2026 124 words · last cycle 2026-07-08 #### Scheme & Network Compliance Virginia's SB 1212 total-price transparency requirement sits atop existing card-network surcharge caps of 3% for Visa and 4% for Mastercard, and the Commonwealth imposes no independent state-level surcharge cap of its own, while debit-card surcharging remains illegal nationwide. Standing alongside that overlay, Virginia Code Title 18.2, Chapter 6, Article 6 criminalises unauthorized presentment of credit or debit card transactions to an issuer or acquirer, reaching Class 5 felony level where fraudulent intent is present and a Class 1 misdemeanor otherwise. #### Outlook Enforcement of SB 1212 as a Consumer Protection Act violation, paired with a private right of action, gives acquirers and merchants a concrete near-term compliance incentive that is likely to generate the first wave of Virginia-specific surcharge-disclosure case activity. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. 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 2. T3 [https://merchantcostconsulting.com/lower-credit-card-processing-fees/virginia-surcharge-laws/](https://merchantcostconsulting.com/lower-credit-card-processing-fees/virginia-surcharge-laws/) retrieved 2026-07-05 3. T1 [https://law.lis.virginia.gov/vacodefull/title18.2/chapter6/article6/](https://law.lis.virginia.gov/vacodefull/title18.2/chapter6/article6/) retrieved 2026-07-05 4. T3 [https://intellipay.com/surcharge-compliance-mistakes-fines/](https://intellipay.com/surcharge-compliance-mistakes-fines/) retrieved 2026-07-05 ### W5 Payment Corridor Dynamics Confirmed confirmed 2026-07-05 Virginia is not itself a distinct cross-border payments corridor jurisdiction, but it hosts the Federal Reserve Bank of Richmond, headquarters of the Fifth Federal Reserve District and a key national hub for FedNow instant payments, ACH and Treasury payment processing — making Virginia structurally central to US domestic payment-rail dynamics even absent its own corridor-specific regulation. Standing sub-brief · as of 8 July 2026 85 words · last cycle 2026-07-08 #### Payment Corridor Dynamics Virginia's structural role in US domestic payment corridors runs through the Federal Reserve Bank of Richmond rather than through any Virginia-specific corridor regulation: Richmond operates the FedNow instant-payments service, which has run since July 2023, alongside national ACH processing and Fifth District Treasury and payment infrastructure. #### Outlook Virginia's corridor position is structural rather than event-driven this cycle; the Richmond Fed's continued FedNow and ACH operation should be read as a stable baseline against which any future instant-payments expansion elsewhere would be benchmarked. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://www.richmondfed.org/payments_services/financial_services](https://www.richmondfed.org/payments_services/financial_services) retrieved 2026-07-05 2. T1 [https://www.federalreserve.gov/aboutthefed/federal-reserve-system-richmond.htm](https://www.federalreserve.gov/aboutthefed/federal-reserve-system-richmond.htm) retrieved 2026-07-05 3. T1 [https://www.richmondfed.org/payment_services/overview?from=/payments_services/overview](https://www.richmondfed.org/payment_services/overview?from=/payments_services/overview) retrieved 2026-07-05 4. T1 [https://www.richmondfed.org/payment_services/overview?from=/payments_services/overview](https://www.richmondfed.org/payment_services/overview?from=/payments_services/overview) retrieved 2026-07-05 ### W6 Industry Structure & Commercial Probable confirmed 2026-07-05 Virginia's payments industry structure is anchored by Capital One Financial (McLean), now the largest US credit-card issuer following its $35.3bn Discover acquisition, and the Federal Reserve Bank of Richmond. Standing sub-brief · as of 8 July 2026 89 words · last cycle 2026-07-08 #### Industry Structure & Commercial Dynamics Capital One Financial Corp, headquartered in McLean, closed its $35.3 billion acquisition of Discover Financial Services this cycle, making Capital One the largest US credit-card issuer and the sixth-largest US bank, and reshaping the industry structure around which Virginia's commercial payments footprint is anchored alongside the Richmond Fed. #### Outlook With integration of Discover's card network and workforce now underway, Capital One's scale advantage is likely to keep reshaping US card-issuing competitive dynamics well beyond this reporting cycle, with Virginia's commercial footprint the direct beneficiary. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T3 [https://virginiabusiness.com/35b-capital-one-discover-merger/](https://virginiabusiness.com/35b-capital-one-discover-merger/) retrieved 2026-07-05 2. T3 [https://patch.com/illinois/deerfield/capital-one-laying-nearly-1-2k-workers-former-discover-hq-riverwoods](https://patch.com/illinois/deerfield/capital-one-laying-nearly-1-2k-workers-former-discover-hq-riverwoods) retrieved 2026-07-05 3. T1 [https://www.capitalone.com/about/corporate-information/corporate-offices/](https://www.capitalone.com/about/corporate-information/corporate-offices/) retrieved 2026-07-05 4. T3 [https://leadiq.com/c/federal-reserve-bank-of-richmond/5a1d8a062400002400635eac](https://leadiq.com/c/federal-reserve-bank-of-richmond/5a1d8a062400002400635eac) retrieved 2026-07-05 ### W7 Legal & Litigation Probable confirmed 2026-07-05 Virginia's Attorney General maintains an active payments/fintech-adjacent enforcement posture through multistate consumer-protection settlements (notably the ACI Worldwide/Speedpay ACH-error settlement and its long-running Predatory Lending Unit actions) and the VCPA. State courts have also recently narrowed the reach of Virginia's wage-payment "wage theft" statute, a ruling with implications for payroll-adjacent payment disputes. Standing sub-brief · as of 8 July 2026 120 words · last cycle 2026-07-08 #### Legal & Litigation The Supreme Court of Virginia held in Groundworks Operations LLC v. Campbell, decided December 30, 2025, that the Virginia Wage Payment Act's 'wage theft' protections do not extend to commissions, narrowing the statute's scope for payroll and payment disputes. In a legacy but still-standing enforcement matter, ACI Worldwide settled with the Virginia Attorney General and other states for $10 million (Virginia's share $247,018.82) over a 2021 Speedpay ACH platform testing error that risked unauthorized withdrawal of $2.3 billion from mortgage-holder accounts. #### Outlook Both matters are settled or decided rather than pending, so the near-term watch item is whether the Supreme Court's narrower reading of the Wage Payment Act is challenged or extended in subsequent Virginia payroll-payment litigation. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T3 [https://wjla.com/news/local/virginia-attorney-general-jason-miyares-part-of-multi-state-10-million-settlement-with-aci-worldwide-corp-over-unauthorized-mortgage-payments-error-automated-clearing-house-speedpay-platform-october-2023](https://wjla.com/news/local/virginia-attorney-general-jason-miyares-part-of-multi-state-10-million-settlement-with-aci-worldwide-corp-over-unauthorized-mortgage-payments-error-automated-clearing-house-speedpay-platform-october-2023) retrieved 2026-07-05 2. T3 [https://www.consumerfinancialserviceslawmonitor.com/2017/02/virginia-ag-reaches-settlement-agreement-with-cashcall/](https://www.consumerfinancialserviceslawmonitor.com/2017/02/virginia-ag-reaches-settlement-agreement-with-cashcall/) retrieved 2026-07-05 3. T1 [https://www.oag.state.va.us/media-center/news-releases/2619-october-5-2023-attorney-general-miyares-announces-49-5-million-multistate-settlement-with-blackbaud-for-data-breach-impacting-thousands-of-nonprofits-and-millions-of-consumers](https://www.oag.state.va.us/media-center/news-releases/2619-october-5-2023-attorney-general-miyares-announces-49-5-million-multistate-settlement-with-blackbaud-for-data-breach-impacting-thousands-of-nonprofits-and-millions-of-consumers) retrieved 2026-07-05 4. T3 [https://www.gentrylocke.com/article/employers-win-round-one-virginias-wage-theft-statute-does-not-include-commissions-will-it-last/](https://www.gentrylocke.com/article/employers-win-round-one-virginias-wage-theft-statute-does-not-include-commissions-will-it-last/) retrieved 2026-07-05 5. T1 [https://www.scc.virginia.gov/consumers/consumer-investments/regulatory-activity/](https://www.scc.virginia.gov/consumers/consumer-investments/regulatory-activity/) retrieved 2026-07-05 ### W8 Merchant Acquiring & Risk Probable confirmed 2026-07-05 Virginia has no bespoke merchant-acquiring licensing regime or high-risk-MCC statute; acquiring activity is governed by the state's general credit-card crimes code (acquirer/issuer definitions and fraud offences) and, since July 2025, by the SB 1212 total-price/surcharge disclosure requirement that directly affects acquirer-merchant fee pass-through practices. Standing sub-brief · as of 8 July 2026 75 words · last cycle 2026-07-08 #### Merchant Acquiring & Risk Virginia has no bespoke merchant-acquiring licensing regime and no dedicated high-risk-MCC statute; acquiring activity is instead governed by the general credit-card crimes code in Title 18.2 together with the SB 1212 fee-disclosure overlay, which affects how acquirers and merchants pass through processing fees. #### Outlook Absent a bespoke acquiring statute, Virginia's merchant-acquiring risk framework will likely keep evolving indirectly, through fee-disclosure enforcement under SB 1212 rather than through any dedicated high-risk-merchant rulemaking. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://law.lis.virginia.gov/vacode/title18.2/chapter6/section18.2-191/](https://law.lis.virginia.gov/vacode/title18.2/chapter6/section18.2-191/) retrieved 2026-07-05 2. T1 [https://law.lis.virginia.gov/vacodefull/title18.2/chapter6/article6/](https://law.lis.virginia.gov/vacodefull/title18.2/chapter6/article6/) retrieved 2026-07-05 3. T3 [https://merchantcostconsulting.com/lower-credit-card-processing-fees/virginia-surcharge-laws/](https://merchantcostconsulting.com/lower-credit-card-processing-fees/virginia-surcharge-laws/) retrieved 2026-07-05 4. T3 [https://intellipay.com/surcharge-compliance-mistakes-fines/](https://intellipay.com/surcharge-compliance-mistakes-fines/) retrieved 2026-07-05 ### W9 Product Innovation & Market Development Probable confirmed 2026-07-05 Virginia's new Chapter 19.1 money-transmission regime interacts with the pending federal GENIUS Act stablecoin framework: Virginia excludes virtual currency from its 'money' definition while federal payment-stablecoin issuer standards remain in NPRM stage, creating a transitional dual-track landscape. Standing sub-brief · as of 8 July 2026 136 words · last cycle 2026-08-06 #### Product Innovation & Market Development The Virginia FinTech Regulatory Sandbox Program, established under Code of Virginia § 6.2-2701 et seq., allows the State Corporation Commission to grant participants limited market access to test a financial product or service without first obtaining the otherwise-required licence or authorization, subject to fitness and criminal-history exclusions. SB 1252, introduced in January 2025, proposes a 12% interest-rate cap with anti-evasion provisions targeting bank-fintech and BaaS lending partnerships and earned-wage-access products; the American Fintech Council lobbied for a gubernatorial veto, and the bill's final enacted or vetoed status was not confirmed this cycle. #### Outlook SB 1252's final disposition remains the single most consequential open question for Virginia's fintech-lending and earned-wage-access product landscape, and its resolution — enacted, vetoed, or left to carry over — should be the first item checked next cycle. Periodic update · new data 2026-08-11 #### Product Innovation & Market Development A federal overlay is forming on top of Virginia's money-transmission regime for stablecoin-related activity. The FDIC's Board of Directors approved a notice of proposed rulemaking on 7 April 2026 implementing GENIUS Act requirements and standards, and the OCC issued its own implementing bulletin on 25 February 2026; together the two proposals establish prudential standards - reserves, redemption, capital, and custodial safekeeping - for permitted payment stablecoin issuers. Neither proposal has finalized as of this cycle. The Virginia-specific dimension of this federal development is definitional rather than direct. Virginia's own Chapter 19.1 money-transmission statute, in force from 1 July 2026, excludes virtual currency from its statutory definition of money, meaning the state's money-transmitter licensing regime does not reach purely crypto-to-crypto or virtual-currency-denominated activity. The result is a jurisdictional and regulatory gap between the state and federal layers for VA-touching stablecoin activity specifically: the state regime does not claim it, and the federal regime that will eventually govern payment stablecoin issuance is still in proposed-rule form. This is a durable dual-track landscape rather than a temporary coordination lag, because it follows from a deliberate scope choice in Virginia's own statute rather than from an oversight that either level of government is likely to correct quickly. For a firm issuing or supporting payment stablecoins with Virginia-based customers or operations, the practical consequence is that no single licensing regime currently governs the full stack of that activity end to end. Fiat-denominated money transmission connected to a stablecoin business remains subject to Chapter 19.1 licensure. The stablecoin issuance itself, to the extent it is purely virtual-currency-denominated, falls outside that state licensing perimeter and will eventually be governed by whichever federal framework the FDIC and OCC finalize, though that framework does not yet exist in binding form. The Interpreter's own gap assessment notes that the GENIUS Act's original one-year implementation clock, which began running from the statute's enactment in July 2025, is now expected by industry observers to slip into 2027, with the OCC's comment period on its own proposal having closed 1 May 2026. This is a genuine and disclosed timeline slippage rather than an enforcement failure, and this brief does not characterize it as anything beyond what the underlying federal filings themselves establish: two proposed rules, not yet final, advancing on separate but parallel agency tracks toward the same statutory mandate. It is worth being precise about what this cycle's finding does and does not show. It does not show that Virginia has taken any stablecoin-specific regulatory action; the Commonwealth's only relevant statutory choice is the virtual-currency exclusion embedded in Chapter 19.1, which was enacted as part of the broader money-transmission overhaul rather than as a stablecoin-specific measure. It does show that the federal prudential framework which will eventually govern payment stablecoin issuers nationally, including in Virginia, remains under construction, with two separate agencies each advancing their own proposed rule rather than a single finalized standard. The distinction between the FDIC's and OCC's respective jurisdictions matters here in a way that is easy to elide: the two agencies supervise different categories of depository institutions, and a payment stablecoin issuer's ultimate regulatory home will depend on its own institutional structure and any bank partnerships it maintains. Firms building stablecoin products that touch Virginia should not assume that either agency's proposal alone describes the complete federal standard they will eventually face; both remain live, both remain proposed, and reconciliation between the two has not yet occurred. No Virginia-specific stablecoin legislation or regulatory action was identified this cycle beyond the definitional scope choice already embedded in Chapter 19.1. Confidence in the federal rulemaking finding itself is High, resting on two independent Tier 1 federal primary sources; confidence in the characterization of the resulting dual-track landscape as it applies specifically to Virginia is Assessed, since it follows from combining the federal finding with Virginia's own statutory scope choice rather than from a single source stating the intersection directly. #### Outlook The GENIUS Act implementing rules from the FDIC and OCC are not expected to finalize before the first quarter of 2027. Until they do, VA-touching stablecoin activity will continue to sit in the dual-track landscape described above: outside Virginia's own money-transmission licensing perimeter by statutory design, and governed federally only by proposed rather than binding prudential standards. Watch for either agency finalizing ahead of the other, and for any indication that Virginia intends to revisit its virtual-currency exclusion in light of the federal framework's eventual completion; no such intention has been signaled this cycle. **Sources and findings (4)** 1. T1 [https://www.richmondsunlight.com/bill/2022/hb922/fulltext/](https://www.richmondsunlight.com/bill/2022/hb922/fulltext/) retrieved 2026-07-05 2. T3 [https://www.bankingdive.com/news/colorado-law-virginia-sb1252-legislation-would-impact-fintech-lending/741044/](https://www.bankingdive.com/news/colorado-law-virginia-sb1252-legislation-would-impact-fintech-lending/741044/) retrieved 2026-07-05 3. T1 [https://www.federalregister.gov/documents/2025/12/23/2025-23735/truth-in-lending-regulation-z-non-application-to-earned-wage-access-products](https://www.federalregister.gov/documents/2025/12/23/2025-23735/truth-in-lending-regulation-z-non-application-to-earned-wage-access-products) retrieved 2026-07-05 4. T1 [https://www.richmondfed.org/topics/payments](https://www.richmondfed.org/topics/payments) retrieved 2026-07-05 ### W10 Consumer Protection & APP Fraud Probable confirmed 2026-07-05 Consumer protection for Virginia payments consumers runs primarily through the Virginia Consumer Data Protection Act (VCDPA, effective January 1, 2023, with 2026 definitional amendments) and the Virginia Consumer Protection Act, both AG-enforced with no private right of action for the VCDPA. Virginia has no dedicated APP-fraud reimbursement scheme; unauthorized-transfer protection for consumers rests on federal Regulation E rather than state law. Standing sub-brief · as of 8 July 2026 108 words · last cycle 2026-09-05 #### Consumer Protection & APP Fraud The Virginia Consumer Data Protection Act grants Virginia residents personal-data rights, enforced exclusively by the Attorney General with no private right of action, effective January 1, 2023, though GLBA-covered financial institutions are broadly exempted from its scope. Virginia has no dedicated state-level authorized-push-payment fraud mandatory-reimbursement scheme; unauthorized-transfer consumer protection rests instead on federal Regulation E rather than any bespoke state statute, an under-indexed area meriting continued attention. #### Outlook With no state APP-fraud reimbursement mandate and no private right of action under the VCDPA, Virginia consumers facing unauthorized-transfer losses or data-handling disputes remain dependent on federal remedies, a gap worth flagging for continued monitoring. Periodic update · new data 2026-08-26 #### Consumer Protection & APP Fraud Virginia enacted Chapter 22.2, the Virtual Currency Kiosks framework, via HB665/SB489. The statute creates a dedicated licensing and consumer-protection regime for virtual-currency kiosk operators, setting daily transaction limits of 2,000 dollars for new users and 5,000 dollars for existing users, a 10,000-dollar monthly cap across all users, a fee cap of 18 percent per transaction, mandatory identity verification, and a requirement for BSA/AML-compliant programs using blockchain-analytics technology. The statute also prohibits kiosk operators from using the terms "ATM" or "automated teller machine" to describe these devices. A dated correction belongs on record here: several secondary sources, including industry-law-firm trackers, reported Chapter 22.2 as effective in 2026, but the enrolled bill's second enactment clause fixes the licensing provisions' effective date at July 1, 2027, with the State Corporation Commission required to begin accepting licence applications by March 1, 2027. This is a Tier 1, primary-source correction of a Tier 3 discrepancy, and it is the more consequential fact for any operator or reader planning against this framework's actual compliance timeline. #### Outlook Kiosk operators and prospective entrants should plan against the corrected 2027 effective date, not the earlier 2026 date circulating in some secondary commentary. The SCC's license-application window opens March 1, 2027, four months ahead of the July 1, 2027 licensing effective date, giving operators a defined runway to prepare license applications once the window opens. **Sources and findings (5)** 1. T1 [https://www.oag.state.va.us/consumer-protection/files/tips-and-info/Virginia-Consumer-Data-Protection-Act-Summary-2-2-23.pdf](https://www.oag.state.va.us/consumer-protection/files/tips-and-info/Virginia-Consumer-Data-Protection-Act-Summary-2-2-23.pdf) retrieved 2026-07-05 2. T3 [https://virginia-vcdpa.org/the-virginia-consumer-data-protection-act-summary/](https://virginia-vcdpa.org/the-virginia-consumer-data-protection-act-summary/) retrieved 2026-07-05 3. T3 [https://www.egnyte.com/guides/governance/virginia-consumer-data-protection-act](https://www.egnyte.com/guides/governance/virginia-consumer-data-protection-act) retrieved 2026-07-05 4. T1 [https://law.lis.virginia.gov/vacode/title40.1/chapter3/section40.1-29/](https://law.lis.virginia.gov/vacode/title40.1/chapter3/section40.1-29/) retrieved 2026-07-05 5. T3 [https://www.consumerfinancialserviceslawmonitor.com/wp-content/uploads/sites/501/2016/05/Consumer-Financial-Regulation-Virginia-w-002-2382.pdf](https://www.consumerfinancialserviceslawmonitor.com/wp-content/uploads/sites/501/2016/05/Consumer-Financial-Regulation-Virginia-w-002-2382.pdf) retrieved 2026-07-05 ### W11 AML/CFT & Financial Crime [Sourced from Sentinel.gi ↗](https://sentinel.gi/jurisdictions/united-states-virginia/#sec-dom-D7) Uncertain confirmed 2026-07-05 W11 baseline content for US-VA is Sentinel.gi-fed per methodology; a dedicated Sentinel.gi payments-context feed entry specific to US-VA was not located in this collection pass. The applicable AML/CFT overlay for Virginia payments activity remains the federal Bank Secrecy Act regime: Virginia money transmitters must independently register as Money Services Businesses with FinCEN and maintain an independently reviewed AML/BSA programme as a state-licensing precondition. Standing sub-brief · as of 8 July 2026 87 words · last cycle 2026-07-08 #### AML/CFT & Financial Crime Virginia money transmitter licensees must register as a Money Services Business with FinCEN via BSA e-filing and maintain an independently reviewed AML/BSA programme as a precondition of state licensing; no Virginia-specific Sentinel.gi payments-context feed entry was located this cycle, so this dashboard entry carries the federal BSA/MSB overlay only. #### Outlook This module remains thin-coverage until a Virginia-specific Sentinel.gi feed is identified; the illicit-finance dimension of Virginia money-transmitter AML exposure has been routed to the Financial Integrity Monitor and should not be re-analysed here. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T3 [https://surety1.com/bond_info/virginia-money-transmitter-bond/](https://surety1.com/bond_info/virginia-money-transmitter-bond/) retrieved 2026-07-05 2. T? FIM (sentinel.gi) per-JID baseline profile — United States — Virginia — Virginia operates under the federal BSA/AML framework administered by FinCEN (headquartered in Vienna, VA) and OFAC, supplemented by state money-transmitter licensing through the SCC Bureau of Financial Institutions (Richmond). The Eastern District of Virginia (Alexandria) is a principal DOJ national-security prosecution venue for sanctions-evasion and crypto cases. No state-level beneficial-ownership registry exists; federal BOI reporting for domestic entities was suspended in 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: enforcement-absence 5. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: legal-gap ### W12 Correspondent Banking, Settlement & Access Confirmed confirmed 2026-07-05 Virginia is host to the Federal Reserve Bank of Richmond, which provides master-account settlement, ACH operation, and Treasury/government payment services across the Fifth District — giving Virginia-domiciled institutions direct structural access to core U.S. settlement infrastructure rather than reliance on correspondent-banking intermediation for domestic settlement. Standing sub-brief · as of 8 July 2026 108 words · last cycle 2026-07-08 #### Correspondent Banking, Settlement & Access Virginia's structural spine in correspondent banking is the bank-versus-non-bank access asymmetry: the Federal Reserve Bank of Richmond provides master-account settlement, national ACH operation, Discount Window liquidity access, and Treasury payment services across the Fifth District, giving Virginia-domiciled banks direct structural access to core US settlement infrastructure that reduces reliance on correspondent intermediation in ways non-bank licensees cannot replicate. #### Outlook Because this access runs through the Richmond Fed rather than a Virginia-specific settlement scheme, the module's forward trajectory tracks Federal Reserve infrastructure policy rather than state rulemaking, and the bank-versus-non-bank asymmetry should widen as non-bank licensing activity grows under the softened 2025 entry thresholds. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://www.richmondfed.org/payment_services/overview?from=/payments_services/overview](https://www.richmondfed.org/payment_services/overview?from=/payments_services/overview) retrieved 2026-07-05 2. T1 [https://www.richmondfed.org/payment_services](https://www.richmondfed.org/payment_services) retrieved 2026-07-05 3. T1 [https://www.richmondfed.org/banking](https://www.richmondfed.org/banking) retrieved 2026-07-05 4. T1 [https://www.richmondfed.org/payments_services/overview](https://www.richmondfed.org/payments_services/overview) ### W13 Commercial Intelligence (M&A, Investment & Product) Probable confirmed 2026-07-05 The dominant trailing-12-month commercial event tied to Virginia is Capital One's $35.3bn acquisition of Discover Financial Services, closed 2025, with continuing 2026 post-merger layoffs. Standing sub-brief · as of 8 July 2026 108 words · last cycle 2026-07-08 #### Commercial Intelligence (M&A, Investment & Product) The dominant trailing-12-month commercial event tied to Virginia is Capital One Financial Corp's completed $35.3 billion acquisition of Discover Financial Services, a disclosed-value deal forming the largest US credit-card issuer and the nation's sixth-largest bank. Post-merger integration continued into 2026 with further workforce reductions: Capital One laid off 1,139 workers at Discover's former Riverwoods headquarters in early March 2026, on top of roughly 600 in late 2025. #### Outlook No additional Virginia-headquartered fintech funding rounds or product launches were identified within the trailing-12-month window beyond the Capital One-Discover transaction, a possible under-indexing of private-company and early-stage signal that should be re-tested next cycle. no periodic updates on record for this sub-brief ** Sources and findings (2)** 1. T3 [https://virginiabusiness.com/35b-capital-one-discover-merger/](https://virginiabusiness.com/35b-capital-one-discover-merger/) retrieved 2026-07-05 2. T4 [https://finance.yahoo.com/news/editorial-discover-takeover-capital-one-110000922.html](https://finance.yahoo.com/news/editorial-discover-takeover-capital-one-110000922.html) 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 – Virginia| 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` = `{}`. **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), 134 source(s) in the cumulative register. Think something on this page is wrong? [Report an error](https://payments.gi/legal/#contact).