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Safeguarding rests on a surety-bond-plus-liquid-clearing-account model. Georgia enacted its first comprehensive privacy statute, SB 111 (Act 462), signed May 11, 2026, with substantive provisions effective July 1, 2026. A contested 'debanking' bill (SB57/SB341) status is unverified for the 2026 session. A surety-bond-minimum discrepancy ($100,000 vs $250,000) is flagged pending reconciliation.
This module is distinct from the licensing and market-access rulemaking discussed under W1a: safeguarding conditions attach to the operational conduct of already-licensed non-bank transmitters rather than to the authorisation gateway itself, and they apply specifically to non-bank money transmitters rather than to depository institutions, which sit under separate bank-regulatory safekeeping rules within the same 2026 omnibus filing. No financial-promotion enforcement action was identified for Georgia this cycle.
Outlook
No forward-dated safeguarding change was identified for this jurisdiction this cycle. The module's next checkpoint is procedural rather than substantive: continued monitoring of quarterly outstanding-transaction filings under the existing bond framework as the broader 2026 rule package beds in.
no periodic updates on record for this sub-brief
Sources and findings (4 unique sources · R-3/R-4)
- [W1b-E1] T1 Derived: Confirmed in_force Collapsed 2× useshttps://dbf.georgia.gov/information-newly-approved-money-transmitter-licensees re-verified
Licensees must at all times maintain collected funds on deposit in a clearing account sufficient to transmit money and/or pay for outstanding transactions, with quarterly reporting of outstandings within 45 days of quarter-end.
- [W1b-E2] T1 Derived: Confirmed in_forcehttps://dbf.georgia.gov/money-service-businesses/msb-frequently-asked-questions re-verified
The minimum surety bond for money transmitters is $250,000, functioning as a three-party instrument between surety, licensee and Department to ensure obligations owed to payment-instrument holders are met; additional coverage may be required up to a $2,000,000 cap based on quarterly outstandings.
- [W1b-E4] T2 Derived: Confirmed draft_no_legal_forcehttps://www.recordinglaw.com/us-laws/data-privacy-laws/georgia-data-privacy-laws/ re-verified
Governor Kemp signed Senate Bill 111, the Georgia Consumer Privacy Protection Act (Act 462), on May 11, 2026, giving residents rights to access, correct, delete and opt out of data sales/targeted advertising, applicable to businesses processing personal data of 175,000+ Georgia residents (or 25,000+ if 50%+ revenue from data sales) with over $25 million in revenue.
- [W1b-E5] T3 Derived: Probable in_forcehttps://www.hklaw.com/en/insights/publications/2025/06/georgia-governor-updates-legislation-impacting-banking-and-financial re-verified
Pending 'debanking' legislation (SB 57, updated as SB 341) would bar banks/credit unions over $1-2 billion in assets and payment processors handling over $1 billion in annual transactions from denying essential financial services based on customers' exercise of constitutional rights, creating a private right of action; SB 341 adds an Attorney General investigatory role.