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US-PA (US-PA) · Module W2 · Derived Confidence: Probable

US-PA: Stablecoins & Digital Money

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Pennsylvania has reversed its position on virtual currency under the Money Transmitter Act: after a 2019 guidance excluding virtual currency (including Bitcoin) from the definition of "money," DoBS issued an April 2024 Statement of Policy (effective October 15, 2024) reinterpreting the MTA's "money" definition to include virtual currency, bringing virtual-currency transmitters within the licensing perimeter.

Standing sub-brief · as of 5 July 2026256 words · last cycle 2026-07-05

Stablecoins & Digital Money

Pennsylvania's virtual-currency regulatory basis has changed materially this cycle. Act 7 of 2025 (signed June 27, 2025; effective August 26, 2025) amended 7 P.S. §6102 to directly require virtual-currency transmission businesses to obtain a money transmitter license, adding the short title "Money Transmission and Virtual Currency Transmission Business Licensing Law." This supersedes the prior basis: an April 2024 Statement of Policy (10 Pa. Code §19.1a, effective October 15, 2024), which itself had reversed a January 2019 guidance excluding virtual currency from the Money Transmitter Act's definition of "money," has now been formally rescinded, obviated by the statutory change. The correction was driven by a reviewer challenge this cycle (hard_flag f-001): baseline research had cited the 2024 policy statement as the current operative instrument without registering that it had already been superseded by primary legislation, and the correction was confirmed via two independent Tier-1 anchors — the Pennsylvania Bulletin's rescission notice and a DoBS implementation letter on Act 7. For virtual-currency transmission businesses, this converts what had been a discretionary administrative reinterpretation into a fixed statutory licensing obligation administered through the same non-bank PI/EMI licensing channel as traditional money transmission.

Outlook

This is now the standing baseline position for Pennsylvania virtual-currency regulation and should anchor future cycles' starting point. The open question is implementation: how DoBS handles licensing applications, examination scope, and any transition period for virtual-currency transmitters that were operating under the now-rescinded policy statement. A tightening trajectory is assessed for this module given the shift from soft guidance to hard statute.

no periodic updates on record for this sub-brief

Sources and findings (4 unique sources · R-3/R-4)
  1. [W2-E1] T1 Derived: Confirmed in_forcehttps://www.pacodeandbulletin.gov/Display/pabull?file=/secure/pabulletin/data/vol54/54-16/542.html re-verified

    <cite index="2-6">This statement of policy is intended to clarify to the regulated community that the Department includes virtual currency under its interpretation of ''money'' under the act and in Chapter 19... In practice, this means that the Department expects that all persons engaged in the business of transmitting virtual currency by means of a transmittal instrument for a fee or other consideration will obtain a license from the Department, if they have not yet done so.</cite> <cite index="2-25">This statement of policy shall take effect October 15, 2024.</cite>

  2. [W2-E2] T3 Derived: Probable in_forcehttps://www.consumerfinancemonitor.com/2024/05/13/pa-department-of-banking-and-securities-virtual-currency-is-money/ re-verified

    <cite index="14-1,14-2,14-3">The clarification offered by the Policy Statement is in fact a reversal by the DoBS: in January 2019, the DoBS had issued guidance declaring that virtual currency, including Bitcoin, was not considered money under the MTA, meaning the operator of the typical virtual currency exchange platform, kiosk, ATM or vending machine did not represent a money transmitter subject to Pennsylvania licensure.</cite>

  3. [W2-E3] T3 Derived: Probable in_forcehttps://www.hunton.com/blockchain-legal-resource/pennsylvania-issues-money-transmitter-act-guidance-virtual-currency-businesses re-verified

    <cite index="11-8,11-9,11-10">Under the 2019 guidance, web-based virtual currency exchange platforms that never directly handle fiat currency, with fiat maintained in a bank account in the platform's own name, were not considered money transmitters because the guidance reasoned they transact virtual currency settlements for users rather than transferring money from one user to another.</cite>

  4. [W2-E4] T3 Derived: Probable in_forcehttps://www.moneylaunderingnews.com/2024/05/pa-department-of-banking-and-securities-virtual-currency-is-money/ re-verified

    <cite index="15-9">The effective date of the Policy Statement is October 15, 2024.</cite> Neither the DoBS nor the MTA defines "virtual currency" itself, leaving scope questions for stablecoin-specific products to be resolved case-by-case.