title: US-GA — Legal & Litigation (W7) | World Payments Monitor canonical: https://payments.gi/jurisdictions/united-states-georgia/w7/ ### W7 Legal & Litigation Probable re-verified 2026-10-18 · changed 2026-09-28 DBF actively enforces money transmission licensure and BSA/AML-adjacent obligations, exemplified by the November 2025 revocation of Fortress Trust's license and a January 2026 cease-and-desist against an unlicensed virtual-currency kiosk operator. Separately, the Northern District of Georgia federal courts have handled a major payments-adjacent Ponzi scheme prosecution, and the legislature is weighing a contested 'debanking' private-right-of-action bill. Standing sub-brief · as of 7 July 2026 140 words · last cycle 2026-09-28 #### Legal & Litigation DBF issued a Final Order of Revocation of Fortress Trust, LLC's Georgia money transmitter licence on November 24, 2025, for insolvency and unsafe or unsound operation, specifically the firm's failure to maintain the operational liquidity or resources needed to fulfil outstanding obligations. Separately, Todd Burkhalter, founder and CEO of Drive Planning LLC, pleaded guilty to wire fraud in what the US Attorney for the Northern District of Georgia described as likely the largest Ponzi scheme in Georgia history, involving more than 2,000 victims and hundreds of millions of dollars in losses. #### Outlook Both matters are consistent with DBF's historical practice of linking licence revocation to prudential and BSA-adjacent failures, and with continued federal prosecutorial activity against payments-adjacent fraud schemes originating in the state; further developments in the Drive Planning matter (sentencing, restitution) are a standing watch item. Periodic update · new data 2026-09-28 #### Legal & Litigation Georgia's third-party litigation-finance regulatory regime tightened further this cycle. The foundational prohibition, established under SB 69's 2025 Georgia Courts Access and Consumer Protection Act, bars anyone affiliated with a foreign government, foreign adversary, foreign person, foreign principal, or sovereign wealth fund from registering as a litigation financier or entering into a litigation-financing agreement in the state. HB 945, enacted in 2026, builds on that foundation by creating an annual re-registration requirement for litigation financiers at $1,000 per year, set at half the $2,000 initial registration fee, giving the Department of Banking and Finance a recurring supervisory touchpoint rather than a one-time registration check. HB 945 also extended cease-and-desist authority to DBF over non-compliant litigation financiers, aligning the enforcement mechanism available for litigation-finance registration violations with the cease-and-desist powers the department already exercises over unlicensed money transmitters. This gives Georgia a comparable enforcement toolkit across both its money-transmission and litigation-finance oversight regimes. The combined effect of the foreign-ownership prohibition, the new annual re-registration cadence, and the extended cease-and-desist authority is a materially more supervised litigation-finance sector than existed before this legislative cycle, with recurring compliance costs now built into the registration structure itself rather than being limited to a single up-front fee. The first annual re-registration cycle under the new $1,000-per-year fee structure will be a useful data point for gauging compliance burden and market attrition in Georgia's litigation-finance sector. Also worth watching is whether DBF's newly extended cease-and-desist authority produces its first enforcement action against a non-compliant financier, which would test the practical reach of the foreign-ownership prohibition established under SB 69. **1 earlier distinct update(s)** Periodic update · new data 2026-08-25 #### Legal & Litigation Georgia Senate Bill 341, an updated private-right-of-action debanking bill, raises the covered-institution asset threshold from one billion dollars to two billion dollars and adds an Attorney General investigatory role. It retains private-right-of-action language opposed by the Georgia Bankers Association. Industry tracking as of this cycle shows the bill as a carryover item without confirmed final passage; the finding rests on a single Tier 2 industry-association tracker, and the primary legislative record has not been independently verified this cycle. This is a legal-and-litigation-exposure question for Georgia-chartered and Georgia-operating banks rather than a licensing or market-access question: the private-right-of-action provision, if retained through final passage, would create a new litigation channel for covered institutions rather than a supervisory or licensing change. SB 341's final disposition, passage, failure, or further carryover, is the variable to track. If it passes with the current private-right-of-action language and the two-billion-dollar asset threshold intact, Georgia-operating banks above that threshold face materially higher debanking-dispute litigation exposure than under the prior one-billion-dollar threshold; if it fails or carries over again, no near-term change to that exposure follows. **Sources and findings (5 unique sources · R-3/R-4)** 1. [W7-E1] T1 Derived: Confirmed [in_force https://dbf.georgia.gov/press-releases/2025-11-24/final-order-revocation-money-transmitter-license-issued-fortress-trust](https://dbf.georgia.gov/press-releases/2025-11-24/final-order-revocation-money-transmitter-license-issued-fortress-trust) re-verified 2026-07-05 On November 24, 2025, DBF issued a Final Order of Revocation of Money Transmitter License to Fortress Trust, LLC, on grounds of insolvency and operating in an unsafe or unsound manner by failing to maintain operational liquidity and resources to fulfill outstanding obligations. 2. [W7-E2] T1 Derived: Confirmed [in_force https://dbf.georgia.gov/press-releases/2026-01-16/order-cease-and-desist-issued-virtual-assets-llc-dba-crypto-dispensers](https://dbf.georgia.gov/press-releases/2026-01-16/order-cease-and-desist-issued-virtual-assets-llc-dba-crypto-dispensers) re-verified 2026-07-05 A Cease-and-Desist Order against Virtual Assets LLC dba Crypto Dispensers became final on January 16, 2026, for operating an unlicensed online virtual currency trading platform in violation of O.C.G.A. § 7-1-681. 3. [W7-E3] T3 Derived: Probable [in_force https://approvedlicensing.com/georgia-department-of-banking-and-finance-revokes-money-transmitter-license/](https://approvedlicensing.com/georgia-department-of-banking-and-finance-revokes-money-transmitter-license/) re-verified 2026-07-05 DBF has a track record of revoking money transmitter licenses for BSA-related failures, including a Final Order against a Florida-based transmitter and two officers for failing to timely file suspicious activity reports and conduct required background checks on covered employees. 4. [W7-E4] T1 Derived: Confirmed [in_force https://www.justice.gov/usao-ndga/pr/financial-advisor-pleads-guilty-orchestrating-massive-380-million-ponzi-scheme](https://www.justice.gov/usao-ndga/pr/financial-advisor-pleads-guilty-orchestrating-massive-380-million-ponzi-scheme) re-verified 2026-07-05 Todd Burkhalter, founder/CEO of Georgia-based Drive Planning LLC, pleaded guilty to wire fraud for what the US Attorney for the Northern District of Georgia called likely the largest Ponzi scheme in Georgia history, involving over 2,000 victims and hundreds of millions of dollars in losses. 5. [W7-E5] T3 Derived: Probable [draft_no_legal_force https://thecurrentga.org/2025/03/07/georgia-legislature-crossover-day/](https://thecurrentga.org/2025/03/07/georgia-legislature-crossover-day/) re-verified 2026-07-05 Senate Bill 57, seeking to outlaw ideological 'debanking' by financial institutions and essential-service providers, stalled in the 2025 session amid Republican concerns over the mechanism but remains available for the 2026 session as part of Georgia's biennial legislative cycle.