title: US-PA — Conduct, Safeguarding & Financial Promotions (W1b) | World Payments Monitor canonical: https://payments.gi/jurisdictions/united-states-pennsylvania/w1b/ ### W1b Conduct, Safeguarding & Promotions Probable re-verified 2026-10-18 · changed 2026-07-05 Pennsylvania has no dedicated payments-conduct/safeguarding regulator akin to CASS; conduct obligations for money transmitters and payment firms flow through DoBS licensing conditions (BSA/AML/IT/disaster-recovery audit plans, advertising restrictions) and general Commonwealth consumer-protection law (UTPCPL), which the Attorney General's Bureau of Consumer Protection actively enforces, including a dedicated Consumer Financial Protection Unit for financial-services conduct. Standing sub-brief · as of 5 July 2026 181 words · last cycle 2026-07-05 #### Conduct, Safeguarding & Financial Promotions Pennsylvania has no dedicated payments-conduct or safeguarding regulator comparable to the UK's CASS regime. Conduct oversight instead runs through the General-purpose Unfair Trade Practices and Consumer Protection Law (UTPCPL), with the Attorney General's Consumer Financial Protection Unit acting as the de facto state UDAAP analogue for both bank and non-bank payment providers. This is a structural feature rather than a live development this cycle — no new safeguarding rulemaking was identified for Pennsylvania — but it is analytically important: absent a dedicated conduct/safeguarding rulebook, both bank-PSPs and non-bank PI/EMI-type licensees are held to the same general consumer-protection standard, with enforcement intensity depending on the Attorney General's litigation priorities rather than a standing supervisory rulebook. #### Outlook With no PA-specific safeguarding instrument on the horizon, the practical safeguard for Pennsylvania payment-service users remains general UTPCPL enforcement plus federal consumer-protection law. Future cycles should watch whether the Consumer Financial Protection Unit's enforcement docket begins to name payments-specific conduct failures, which would be the clearest signal of a de facto (if not de jure) safeguarding regime emerging through case law. no periodic updates on record for this sub-brief ** Sources and findings (4 unique sources · R-3/R-4)** 1. [W1b-E1] T3 Derived: Probable [in_force https://moneytransmitterlaw.com/state-laws/pennsylvania/](https://moneytransmitterlaw.com/state-laws/pennsylvania/) re-verified 2026-07-05 Applicants must submit an internal audit plan, policies, procedures and schedule for all compliance issues including, but not limited to, PATRIOT ACT/Bank Secrecy Act, anti-money laundering, information technology, and disaster recovery. 2. [W1b-E2] T1 Derived: Confirmed [in_force https://www.pacodeandbulletin.gov/Display/pacode?file=%2Fsecure%2Fpacode%2Fdata%2F010%2Fchapter19%2Fchap19toc.html&d=](https://www.pacodeandbulletin.gov/Display/pacode?file=%2Fsecure%2Fpacode%2Fdata%2F010%2Fchapter19%2Fchap19toc.html&d=) re-verified 2026-07-05 Licensees may advertise their activities in such form as they desire, but in no instance shall any reference to supervision or licensing be made other than by a Department-prescribed phrase, and agents and subagents shall clearly indicate the name of the licensee in a sign publicly displayed in the place of business. 3. [W1b-E3] T3 Derived: Probable [in_force https://www.cohenseglias.com/news-article/pa-unfair-trade-practices-and-consumer-protection-law-investigations-frequently-asked-questions/](https://www.cohenseglias.com/news-article/pa-unfair-trade-practices-and-consumer-protection-law-investigations-frequently-asked-questions/) re-verified 2026-07-05 The Pennsylvania Office of Attorney General (OAG), Public Protection Division, Bureau of Consumer Protection is the primary government agency that enforces the UTPCPL. During an investigation, the OAG will typically present the company with a proposed settlement agreement called an Assurance of Voluntary Compliance (AVC). 4. [W1b-E4] T3 Derived: Probable [in_force https://www.sidley.com/en/insights/newsupdates/2025/07/pennsylvania-leads-consumer-financial-protection-in-the-new-era-of-federalism](https://www.sidley.com/en/insights/newsupdates/2025/07/pennsylvania-leads-consumer-financial-protection-in-the-new-era-of-federalism) re-verified 2026-07-05 In 2017, then-Attorney General Josh Shapiro created the Consumer Financial Protection Unit within the Office of Attorney General, dubbed Pennsylvania's "mini-CFPB," established in part due to an expected pullback in federal consumer financial enforcement.