title: US-GA — Conduct, Safeguarding & Financial Promotions (W1b) | World Payments Monitor canonical: https://payments.gi/jurisdictions/united-states-georgia/w1b/ ### W1b Conduct, Safeguarding & Promotions Probable re-verified 2026-10-18 · changed 2026-07-05 Safeguarding rests on a surety-bond-plus-liquid-clearing-account model. Georgia enacted its first comprehensive privacy statute, SB 111 (Act 462), signed May 11, 2026, with substantive provisions effective July 1, 2026. A contested 'debanking' bill (SB57/SB341) status is unverified for the 2026 session. A surety-bond-minimum discrepancy ($100,000 vs $250,000) is flagged pending reconciliation. Horizon · 2026-07-01 In force (commenced) Georgia SB 111 (Consumer Privacy Protection Act, Act 462) substantive provisions enter into force_In force (commenced)_ Standing sub-brief · as of 6 August 2026 180 words · last cycle 2026-08-05 #### Conduct, Safeguarding & Promotions Georgia's safeguarding regime for licensed non-bank money transmitters continues on established terms this cycle. Licensees must maintain sufficient collected funds in a clearing account, file quarterly outstanding-transaction reports within 45 days via NMLS, and maintain a surety bond up to a statutory $2,000,000 cap. The bond may be increased by the Department based on quarterly outstandings, subject to a $2,000,000 statutory cap; funds also held in a clearing account. This module is distinct from the licensing and market-access rulemaking discussed under W1a: safeguarding conditions attach to the operational conduct of already-licensed non-bank transmitters rather than to the authorisation gateway itself, and they apply specifically to non-bank money transmitters rather than to depository institutions, which sit under separate bank-regulatory safekeeping rules within the same 2026 omnibus filing. No financial-promotion enforcement action was identified for Georgia this cycle. #### Outlook No forward-dated safeguarding change was identified for this jurisdiction this cycle. The module's next checkpoint is procedural rather than substantive: continued monitoring of quarterly outstanding-transaction filings under the existing bond framework as the broader 2026 rule package beds in. no periodic updates on record for this sub-brief ** Sources and findings (4 unique sources · R-3/R-4)** 1. [W1b-E1] T1 Derived: Confirmed in_force [Collapsed 2× uses https://dbf.georgia.gov/information-newly-approved-money-transmitter-licensees](https://dbf.georgia.gov/information-newly-approved-money-transmitter-licensees) re-verified 2026-07-05 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. 2. [W1b-E2] T1 Derived: Confirmed [in_force https://dbf.georgia.gov/money-service-businesses/msb-frequently-asked-questions](https://dbf.georgia.gov/money-service-businesses/msb-frequently-asked-questions) re-verified 2026-07-05 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. 3. [W1b-E4] T2 Derived: Confirmed [draft_no_legal_force https://www.recordinglaw.com/us-laws/data-privacy-laws/georgia-data-privacy-laws/](https://www.recordinglaw.com/us-laws/data-privacy-laws/georgia-data-privacy-laws/) re-verified 2026-07-05 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. 4. [W1b-E5] T3 Derived: Probable [in_force https://www.hklaw.com/en/insights/publications/2025/06/georgia-governor-updates-legislation-impacting-banking-and-financial](https://www.hklaw.com/en/insights/publications/2025/06/georgia-governor-updates-legislation-impacting-banking-and-financial) re-verified 2026-07-05 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.