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US-FL (US-FL) · Module W7 · Derived Confidence: Confirmed

US-FL: Legal & Litigation

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Florida's existing Control of Money Laundering in Money Services Business Act (Chapter 560) has been amended to bring payment stablecoin issuance explicitly within AML recordkeeping/reporting scope, with unlicensed issuance criminalized.

Standing sub-brief · as of 5 July 2026157 words · last cycle 2026-08-05

Legal & Litigation

The Office of Financial Regulation issued a final order on 13 March 2026 approving a consent agreement with a Delaware-based software company found to have operated as an unlicensed money transmitter in Florida from January 2011 to August 2025; the company agreed to pay a $155,000 fine and to comply with Chapter 560 going forward, an enforcement precedent illustrating OFR's active posture against unlicensed money transmission. Separately, a Miami-Dade-headquartered bank faces a derivative lawsuit, pending in the Southern District of Florida, concerning board decisions on correspondent banking, including the 2017 opening of a correspondent account for Banco de Venezuela despite competitor de-risking amid sanctions pressure.

Outlook

Watch for the outcome of the Edge Act derivative suit in the Southern District of Florida, and for whether the OFR consent-order fine level informs future unlicensed-transmission enforcement benchmarks. The sanctions dimension of the correspondent-banking litigation has been flagged to the Financial Intelligence Monitor rather than analysed here.

Periodic update · new data 2026-09-03

Legal & Litigation

The same Florida legislative package that created the OFR stablecoin-issuer licensing regime also amended the Florida Control of Money Laundering in Money Services Business Act (Chapter 560) to bring payment stablecoin issuance within its AML recordkeeping and reporting scope, adding a licence-or-exemption gate with a criminal-penalty backstop for unlicensed issuers (wpm-2026-W7-001). Under the amended money-services-business and financial-institutions codes, unlicensed qualified payment stablecoin issuance now carries possible criminal penalties (wpm-2026-W7-002). Rather than sequencing market-access liberalisation ahead of compliance obligations, Florida calibrated the new licensing pathway and the AML/criminal-penalty tightening within the same legislative instrument, meaning the market-access question and the enforcement-exposure question for any prospective issuer arrive together rather than in separate phases. This positions unlicensed stablecoin issuance in Florida as a criminal, not merely civil or administrative, matter from the point the framework takes effect.

Whether Florida's Attorney General or the Office of Financial Regulation brings an early enforcement action under the new criminal-penalty backstop once the regime is in force from October 1, 2026, would be the clearest signal of how actively the state intends to police the licence-or-exemption gate. No enforcement action has been evidenced this cycle, since the operative provisions are not yet in force.

Sources and findings (5 unique sources · R-3/R-4)
  1. [W7-E1] T1 Derived: Confirmed in_forcehttps://infobytes.orrick.com/2026-03-20/florida-fines-software-company-155k-for-alleged-unlicensed-money-transmission/ re-verified

    <cite index="110-2,110-3">On March 13, 2026, OFR issued a final order approving a consent agreement with a Delaware-based software company, finding it operated as an unlicensed money transmitter in Florida from January 2011 through August 2025</cite>. <cite index="110-5">The company agreed to pay a $155,000 administrative fine and to comply with Chapter 560 going forward</cite>.

  2. [W7-E2] T1 Derived: Confirmed in_forcehttps://www.hudsoncook.com/article/florida-regulator-clarifies-money-transmitter-licensing-exemptions-or-lack-thereof/ re-verified

    <cite index="7-8">The 2023 ruling In Re: Petition For Declaratory Statement Intercam Futures, Inc. shows the scope of a Florida state licence may differ from a federal MSB registration exemption</cite>.

  3. [W7-E3] T2 Derived: Confirmed in_forcehttps://www.govinfo.gov/content/pkg/USCOURTS-flsd-1_22-cv-20201/pdf/USCOURTS-flsd-1_22-cv-20201-3.pdf re-verified

    <cite index="60-13,60-14">A derivative lawsuit against board members of a Miami-Dade-headquartered bank centres on correspondent-banking decisions</cite>, <cite index="60-26">including the Bank's decision to open a correspondent account for Banco de Venezuela in 2017 despite competitors declining to do so amid sanctions pressure</cite>.

  4. [W7-E4] T1 Derived: Confirmed in_forcehttps://www.ftc.gov/business-guidance/blog/2023/04/411-about-ftc-florida-ag-action-against-chargebacks911 re-verified

    <cite index="96-11,96-14">The FTC and Florida Attorney General allege Florida-based Global E-Trading (d/b/a Chargebacks911), its CEO and COO used unfair tactics against consumer chargeback disputes; the case is pending in federal court in Tampa</cite>.

  5. [W7-E5] T2 Derived: Confirmed in_forcehttps://www.sec.gov/Archives/edgar/data/0001424657/000121390025048144/ea024311901ex10-9_cuentas.htm re-verified

    <cite index="88-1,88-2">A Miami-Dade Circuit Court case (No. 23-CA-2134) involving Cuentas Inc. was resolved via a $28,000 settlement payment in full and final satisfaction of a judgment</cite>.