Conduct, Safeguarding & Financial Promotions

Safeguarding across the bloc rests on client-fund segregation/trust mechanisms rather than a harmonised EU-style CASS regime. South Africa's new framework for the first time enables non-banks to hold client funds with segregation and minimum capital; Nigeria… Full module →

The PSP regime pairs licensing with conduct and safeguarding obligations: no overdrafts/interest, bank guarantees/professional liability insurance, transparent contracts and secure authentication.

Safeguarding for PSPCPs is strict: 100% of customer funds must be held at all times in peso sight accounts at Argentine financial institutions, individualised per customer, available on demand and segregated from the PSP's own funds. PSPs may not treat… Full module →

APAC safeguarding mechanisms are typically segregation/trust/bank-guarantee for non-bank PSPs, supervised by the national authority. Singapore mandates safeguarding of customer monies under the PS Act; India requires escrow-only settlement; Australia's… Full module →

Australia's Corporations Amendment (Digital Assets Framework) Bill 2025 has received Royal Assent, extending the AFSL licensing perimeter to digital asset platforms and tokenised custody platforms, running alongside the Treasury Laws Amendment (Payments… Full module →

Safeguarding of payment-service-user and e-money-holder funds is anchored in ZaDiG 2018 Art.18/19 and the E-GeldG 2010. Conduct supervision of banks, payment institutions and e-money institutions has been centralised since 2025 in a dedicated FMA division… Full module →

Customer fund safeguarding for MFS/PSP operates through a bank-custody model (Trust Fund/mobile-account float held with scheduled banks) rather than a segregated-trust EMI model. Conduct oversight runs through Bangladesh Bank's Customer Interest Protection… Full module →

Safeguarding requirements remain largely PSD2-aligned; PSD3 adds an option for PIs to safeguard customer funds directly at a central bank (at that bank's discretion), mitigating fund-concentration risk.

Brazil's safeguarding regime requires payment institutions to segregate client/end-user funds from proprietary assets and supports traceability and auditability; e-money balances are held in payment accounts with prudential treatment. BCB Rule 80/2021 sets… Full module →

Safeguarding for Bulgarian PIs/EMIs follows the PSD2/EMD2-aligned segregation model under the PSPSA. PSD3/PSR reform will add a central-bank safeguarding option and merge the EMI category into 'payment institution authorised to issue e-money'; Bulgaria has… Full module →

Conduct and consumer-facing obligations for payment institutions sit across several instruments: the NBC's dedicated Prakas on Resolution of Consumer Complaints, a 2021 circular tightening KYC and tiered daily transaction limits for PSPs and Bakong… Full module →

Consumer/conduct protection rests on the CEMAC-wide Regulation No 01/20/CEMAC/UMAC/COBAC (2020) on protection of banking-product consumers, layered on Cameroon's national Consumer Protection Law (2011) and Banking Secrecy Law (2003). Safeguarding of e-money… Full module →

The Bank of Canada announced on June 12, 2026 that it will begin publishing Notices of Violation (NOVs) against PSPs, introducing a new public-enforcement-transparency mechanism into the RPAA conduct regime.

Conduct and safeguarding obligations for Alberta-touching payment activity are set federally via the RPAA safeguarding-of-funds framework and provincially via the Gift Card Regulation and High-Cost Credit Regulation under the Consumer Protection Act.

Conduct and safeguarding for BC-touching payment activity is set primarily at the federal level via the RPAA's end-user fund safeguarding framework (in force since September 8, 2025) and the FCAC-overseen Code of Conduct for the Credit and Debit Card… Full module →

Bank of Canada published its final safeguarding-of-funds supervisory guideline clarifying PSP fund-protection obligations for nonbank PIs/EMIs serving New Brunswick end-users.

PSP safeguarding obligations operative since September 8, 2025; Bank of Canada will begin publishing RPAA Notices of Violation from June 12, 2026, materially increasing conduct transparency.

Safeguarding of end-user funds under the RPAA became a binding obligation as of September 8, 2025, per the Bank of Canada's final safeguarding guideline; conduct/consumer-facing protections in Quebec run in parallel through the Consumer Protection Act (Bill… Full module →

CMF's Autenticación Reforzada de Clientes (ARC, NCG N°538) mandate took effect 1 August 2026, eliminating printed coordinate-card authentication except for a supervised, reported carve-out for digitally-excluded client groups; carve-out transactions are not… Full module →

Safeguarding rests on mandatory 100% centralised deposit of customer reserve funds with PBOC/designated banks, cleared via NetsUnion (NUCC); conduct duties codified in the 2024 Implementation Rules; draft antitrust regime remains unresolved.

Financial-consumer conduct is governed primarily by Ley 1328 de 2009 (the financial consumer protection statute) and the SFC's Sistema de Atención al Consumidor Financiero (SAC), with each supervised entity required to have an independent Defensor del… Full module →

Consumer/depositor protection rests on the Deposit Guarantee Fund Law (No. 9816) for private banks, SUGEF's disclosure/advertising regulation (SUGEF 10-07), and general consumer-protection law administered via the National Consumer Commission. State-owned… Full module →

Safeguarding of payment service users' and e-money holders' funds is governed by a dedicated HNB Decision under Article 35/100 of the Electronic Money Act/Payment System Act, alongside a HNB-run complaints and ADR regime and consumer-protection oversight. The… Full module →

CBCS conduct supervision rests on a 2017 complaints-handling Regulation applicable to all supervised institutions, backstopped by a bank deposit guarantee scheme (up to 50,000 XCG per depositor per bank) and a running series of public warning notices. A… Full module →

Safeguarding of user funds (segregation or insurance/guarantee) is mandated under the EMI/PI laws, with CBC adopting EBA safeguarding guidance (EBA/GL/2018/05). In 2025-2026 the CBC issued new directives strengthening EMI/PSP governance, capital and… Full module →

Client-fund safeguarding for Czech PIs/EMIs follows the PSD2/EMD2 segregation model (payment accounts for defined transactions only for PIs; broader e-money storage for EMIs), documented via internal AML/safeguarding policies reviewed by the CNB during… Full module →

Safeguarding of e-money-institution client funds is governed by Executive Order no. 722 of 24/6/2011 on the Safeguarding of Funds Received by Electronic Money Institutions, sitting alongside the Payments Act and the general Financial Business Act… Full module →

Financial-consumer conduct governed by the Reglamento de Protección al Usuario (2015), enforced via SB's ProUsuario; a World-Bank-assisted overhaul was published for consultation March 2026.

The BCE has progressively tightened authorisation and operating requirements for auxiliary payment systems via Resolution BCE-GG-024-2024 and the January 2026 SRP resolution BCE-GG-002-2026.

Conduct and safeguarding flow from Law 194/2020 and CBE rules. Licensed institutions must lodge an irrevocable, unconditional, auto-renewing bank letter of guarantee in favour of the CBE equal to 2% of paid-up/allocated capital, usable by the CBE to impose… Full module →

Safeguarding follows the standard EMD2/PSD2 approach overseen by Finantsinspektsioon with EBA outsourcing guidance adopted; consumer conduct splits between Finantsinspektsioon and the Consumer Protection and Technical Regulatory Authority.

Conduct-of-business rules migrate to the directly-applicable PSR, ending divergent national implementation; fraud-prevention overhaul is the PSR centrepiece requiring payee-name verification; new TSP due-diligence duty for SCA outsourcing.

FIN-FSA and Consumer Ombudsman jointly police conduct/safeguarding/promotions; IPR VoP applies from Oct 2025 to all PSPs, PI/EMI instant-payment deadlines fall Jan/Jul 2027.

Safeguarding for French PIs/EMIs follows PSD2/EMD2 segregation: client funds placed in a dedicated segregated account at a credit institution (or central bank / low-risk liquid assets), separate from the institution's own funds, with changes to the protection… Full module →

Safeguarding of customer/e-money funds is mandated by §§17–18 ZAG: funds must either be segregated in an insolvency-proof trust account or in liquid low-risk assets, or covered by insurance/guarantee from an insurer or credit institution. Conduct rules flow… Full module →

Conduct, safeguarding and promotions sit under Act 987 and a stack of BoG guidelines. E-money float must be denominated in cedis with CDD/KYC tiers; corporate governance, disclosure/transparency and consumer-recourse guidelines bind PSPs and DEMIs. The… Full module →

Safeguarding is governed by the Financial Services (Electronic Money) Regulations 2020 (Regs 31-32: segregation option 1 / insurance-or-guarantee option 2), with safeguarded funds forming a priority asset pool on an insolvency event. Conduct is governed by… Full module →

Safeguarding for PIs/EMIs is set under Law 4021/2011 and BoG Executive Committee Act 164/2/13.2.2019, alongside professional indemnity insurance requirements for PISPs/AISPs under Law 4537/2018. Conduct obligations run via BoG Governor's Act 2501/2002 and the… Full module →

Conduct and safeguarding of SVF licensees are governed by HKMA guidelines issued under s.54 PSSVFO. SVF licensees must maintain AML/CFT systems and meet supervisory expectations set out in the Guideline on Supervision of SVF Licensees. There is no single… Full module →

Buy-now-pay-later ('halasztott fizetés') services are moving out of a regulatory grey zone into Hungarian statute via an Amendment Act transposing EU Consumer Credit Directive 2 (Directive (EU) 2023/2225); reported to enter into force 20 November 2026… Full module →

Conduct-of-business and safeguarding obligations for Icelandic PSPs/EMIs sit within Act 114/2021's PSD2-derived framework, supplemented by GDPR-based data-protection duties and Consumer Agency oversight of general consumer legislation, with FME/CBI… Full module →

Customer-fund safeguarding for both PAs and non-bank PPI issuers rests on a mandatory escrow account held with a single scheduled commercial bank, with no co-mingling, day-end balance floors, and quarterly statutory-auditor certification. For escrow purposes… Full module →

Safeguarding of consumer funds is a CBI 'key priority': PI/EMI firms must segregate consumer funds in a separate account with an EEA-authorised bank OR cover them with an insurance/guarantee policy, per PSD2/EMD2 as implemented through the PSR 2018, EMR 2011… Full module →

Conduct and safeguarding for Class 8 licenceholders sit under the Financial Services Rule Book (FSRB) made under FSA08, supervised by the IOMFSA with a risk-based, proportionate inspection regime; there is no standalone Consumer Duty-style rulebook comparable… Full module →

Safeguarding for Italian IPs/IMELs that also conduct non-payment business is achieved via a mandatory ring-fenced 'patrimonio destinato' under Art.114-terdecies TUB. Conduct and transparency supervision sits with Banca d'Italia under the TUB's transparency… Full module →

Conduct and safeguarding obligations for PIs/EMIs are set at the UEMOA level. Payment institutions must join the regional Professional Association of Payment and Electronic Money Institutions within one month of approval; e-money float must be segregated and… Full module →

Safeguarding for non-bank FTSPs is achieved primarily through a Performance Security Deposit (cash deposit with the Legal Affairs Bureau), with bank performance bonds and trust arrangements as alternatives; crypto/EPI custody requires segregation. The FSA… Full module →

Conduct regulation is being substantially rebuilt under the pending New Banking Law, which introduces behavioural supervision, mandatory suitability/disclosure duties, and a unified pretrial dispute-resolution ombudsman. Agent liability and joint-and-several… Full module →

Safeguarding of customer/e-money funds in Kenya is achieved through a mandatory trust structure: PSPs must establish a trust with a CBK-licensed bank to hold customer funds, supported by a trust deed required under the NPS Act. Conduct and consumer… Full module →

Conduct and consumer-facing safeguarding obligations for payment/financial services flow from the Decree on Consumer Protection regarding Financial Services No. 225/GOV (2020), which elaborates the Law on Commercial Banks' complaint-handling duties, plus… Full module →

Member-state conduct/safeguarding regimes attach to the licence. In Brazil, PIs may freely move balances customers hold on prepaid payment accounts and fund their settlement (PI) accounts at the BCB, with consumer-protection/transparency rules applying; the… Full module →

Safeguarding mandated under Section 38 (EMD2 Art.10 transposition) via segregation or insurance/guarantee, daily reconciliation, annual external audit; CRPC handles general consumer law, Latvijas Banka handles financial conduct/fund-protection as 2026… Full module →

Safeguarding of client funds is mandated for PIs/EMIs under the ZDG/EGG regime with prior FMA notification of material changes; conduct oversight sits with the same integrated FMA supervisor responsible for prudential matters. Financial-promotion enforcement… Full module →

PSD3/PSR provisional agreement (27 Nov 2025) sets a migration path for Lithuanian EMIs/PIs into a unified 'payment institution authorised to issue e-money' category ahead of ~2027 entry into force; near-term operational obligations include a corporate-tax… Full module →

CSSF governance/risk-management convergence for PI/EMI moved into force this cycle: the compliance deadline under Circular CSSF 26/906 (consolidating central administration, internal governance and risk-management requirements) fell due 30 June 2026, and a… Full module →

Client-fund safeguarding for Macau payment institutions is structurally embedded in the licence-tiering itself (the 'non-bank credit institution' route triggers when funds are invested/used) rather than a standalone safeguarding rulebook. Conduct/complaint… Full module →

BNM's Technology Requirements Policy Document (TR PD) — a four-tier technology-governance framework for payment regulatees — was issued March 2026 (substantive effect 12 March 2027), overlapping the existing RMiT regime and newly capturing licensed… Full module →

Malta EMIs must safeguard client e-money funds directly with EU credit institutions (FIR/03 bars intermediaries), with mandatory reconciliations and an annual safeguarding audit. DORA has applied to Malta-licensed EMIs/PIs since 17 January 2025.

IFPE safeguarding/conduct rests on the Fintech Law and secondary regulations (notably Banxico Circular 12/2018 and the 2021 IFPE Provisions). IFPEs may not pay interest on client balances (Art. 29) and must segregate/manage client electronic funds under… Full module →

Conduct and consumer-protection for payment/credit customers rests on Law 103-12 and consumer-protection Law 31-08, both enforced by Bank Al-Maghrib, which issues transparency, complaint-handling and banking-mediation rules. Customer funds at payment… Full module →

BdM directly supervises market conduct of all credit institutions, financial companies and IMEs via Notices (e.g. 8/GBM/2021 on contractual terms/transparency, 9/GBM/2020 on complaints handling) issued under Law 20/2020. Depositor protection runs through a… Full module →

Safeguarding of MFS customer float is mandated via segregated trust/deposit accounts at partner commercial banks with daily reconciliation duties, tiered KYC limits, and CBM suspension/revocation powers for non-compliance. Post-coup, conduct enforcement has… Full module →

NRB issued a directive under Payment and Settlement Act 2019 s.45 requiring retroactive collection of shareholder/director/senior-management background and beneficial-ownership information for all licensed payment institutions; no corporate insider is exempt.

Safeguarding of payment service users' funds is implemented in the Wft via PSD2/EMD2, with two mechanisms: segregation (a third-party-funds foundation or, since 2022, a quality account) or an insurance/comparable guarantee. AFM supervises conduct and… Full module →

Conduct is governed by the FMC Act 2013 and the CoFI regime (Financial Markets (Conduct of Institutions) Amendment Act 2022), with FMA as conduct regulator requiring fair conduct programmes. There is no EMI-style statutory safeguarding/segregation regime… Full module →

Conduct and safeguarding for Nigerian PSPs flow from the structural rule that only MMOs/PSBs hold customer funds, plus the CBN Consumer Protection Regulation 2019 and Consumer Protection Framework 2016. MMO customer balances are held in nominee/trust-style… Full module →

Safeguarding of client/e-money funds is codified in the Financial Institutions Act (protection of funds, prohibition on paying interest on e-money float, redemption rights) and detailed in the Financial Institutions Regulations; conduct and market-promotion… Full module →

Customer-fund safeguarding via mandatory segregated Trust Account; Branchless Banking Regulations place ultimate agent liability on the principal institution; conduct sits within PS&EFT Act 2007 and SBP's BC&CPD.

Panama has no dedicated conduct-of-business or safeguarding regime for non-bank payment/e-money providers; consumer and conduct protection for banking relationships defaults to the SBP and ACODECO under general banking and consumer-protection law, with AML… Full module →

Safeguarding of e-money funds is via mandatory fideicomiso (trust) arrangements under Ley 29985 art.6, supervised by SBS. Conduct governed by SBS Res. 3274-2017, amended by Res. 01689-2025, backstopped by updated infractions regime under Res. 01029-2026… Full module →

Consumer conduct and safeguarding rest on the Financial Products and Services Consumer Protection Act (RA 11765) administered by the BSP, plus BSP IT-risk and fraud-monitoring requirements (Circular 1140) and fit-and-proper authority over directors/officers… Full module →

Conduct/safeguarding obligations flow from the UUP (PSD2/EMD transposition) under KNF supervision. PSPs must safeguard client funds (segregated accounts / equivalent), maintain AML compliance functions, hold civil-liability insurance/guarantee for PIS, and… Full module →

Safeguarding of PI/EMI client funds follows the PSD2 Article 10 segregation-or-insurance model, supervised by Banco de Portugal alongside its broader banking conduct supervision mandate. BdP has tightened internal-control and governance expectations via… Full module →

PSP customer funds are safeguarded via segregated client-money/escrow accounts; non-bank e-money issuers and merchant acquirers must perform an independent audit on the clients' money (escrow) account every six months and report to QCB. Conduct rules require… Full module →

Conduct and safeguarding for Romanian PIs/EMIs follow PSD2/EMD2 as transposed by Laws 209/2019 and 210/2019, supervised by the BNR. Safeguarding rests on Article 10 PSD2-style segregation (separate account at a credit institution or low-risk liquid assets, or… Full module →

Consumer/conduct supervision sits with the Bank of Russia's Service for Consumer Protection and Financial Inclusion, which handles reactive complaint-driven supervision and proactive identification of unfair market practices (mis-selling, misinformation on… Full module →

Customer-fund safeguarding via trust-account segregation at a licensed Rwandan commercial bank; Reg 54/2022 e-money safeguards; Reg 89/2025 (+ 17 Sept 2025 Directive) FX-promotion conduct enforcement.

Conduct and safeguarding for KSA PSPs sit within the Implementing Regulation of the Law of Payments and Payment Services, which includes dedicated parts on consumer protection, financial inclusion, e-money issuance/redemption, outsourcing and risk. EMIs must… Full module →

EMI safeguarding via Instruction n°008-05-2015 (75% demand-deposit float rule); 2025 Banking Law adds Financial Innovation Laboratory and agent framework.

Serbia's Law on Interchange Fees and Special Operating Rules for Card-based Payment Transactions is subject to a new NBS-prepared draft amendment (mid-2026) introducing interchange fee caps for domestic and international card transactions, part of the… Full module →

Safeguarding of customer monies for MPIs is achieved via a bank/financial-institution undertaking or guarantee, a trust account deposit, or other MAS-prescribed means. MPIs face base-capital and security-deposit obligations, fit-and-proper criteria, and… Full module →

NBS enforces conduct and consumer-protection rules on top of the PSD2/EMD2 licensing perimeter, including fund-safeguarding (own-funds floor for EMIs) and active sanctioning of unfair commercial/fee practices at supervised banks and financial intermediaries… Full module →

Safeguarding follows the standard PSD2/EMD2 segregation model (client funds held in a separate account with an authorised credit institution or invested in liquid assets), supervised by Banka Slovenije; limited-network and telecom exclusions from ZPlaSSIED… Full module →

Conduct and consumer-protection supervision is split under the Twin Peaks model: the SARB Prudential Authority (PA) is the prudential supervisor and the Financial Sector Conduct Authority (FSCA) is the market-conduct authority, both operating under the… Full module →

Safeguarding for prepaid/e-money was materially strengthened by the EFTA amendment (passed Aug 2023) and Enforcement Decree, effective 15 September 2024: prepayment providers must separately manage 100% of advance payments via trust or payment-guarantee… Full module →

RD 712/2010 safeguarding template plus BdE/SEPBLAC June-2025 proportionality guidance on account restriction/closure.

Market-conduct supervision was formalised for the first time in Sri Lanka via the Financial Consumer Protection Regulations No. 01 of 2023, administered by CBSL's FCRD; retail-payment-service PSPs offering payment initiation/account-information services must… Full module →

Safeguarding of client funds is a mandatory business-plan element for PIs/EMIs under FI's FFFS 2010:3/2018:4/2011:49 regulatory code. Conduct rules extend to online payment-method display (2020 amendment to the Payment Services Act) and, from 2026, a full… Full module →

Conduct and client-onboarding rules flow from the Financial Services Act (FinSA/FIDLEG) (client segmentation, suitability, prospectus) and AMLA. Safeguarding is not via an EU-style segregation/insurance regime: FinTech-licensed deposits are NOT covered by… Full module →

Stored electronic-payment funds must be held in bank-provided dedicated escrow accounts under the E-Payment Act, financial consumer conduct is governed separately by the Financial Consumer Protection Act, and the FSC has taken direct enforcement action… Full module →

Safeguarding of customer e-money in Tanzania is structured around a mandatory trust arrangement: non-bank e-money issuers must establish a separate legal entity (a trust) and maintain a trust account for customer funds under the Payment System (Electronic… Full module →

Under the Emergency Decree, banks, e-money providers, digital-asset operators and telcos carry joint/pro-rata liability for technology-crime losses absent demonstrated compliance. BOT has added youth-specific transfer caps (rollout Sep-Oct 2026) atop the… Full module →

Payment institutions' conduct, safeguarding and consumer-protection obligations are set out in BCT Circular 2018-16, which mandates professional liability insurance/bank guarantee cover, tiered payment-account ceilings, a ring-fenced 'compte global' held with… Full module →

Safeguarding under Law No. 6493 requires e-money issuers to convert received funds into e-money without delay and to hold customer funds in segregated, blocked bank accounts at Law No. 5411 banks during the term of use, separate from the institution's own… Full module →

Safeguarding under the NPSA operates via a 100%-backed trust/special account model: e-money issuers must hold customer funds one-for-one in liquid assets in a trust account (non-bank issuers) or special account (financial institutions), supervised by BoU. The… Full module →

Consumer/conduct oversight sits with the NBU's Office for Financial Services Consumer Rights Protection (formal mandate since a 2019 law made Ukraine the 120th country to protect financial-services consumers); safeguarding of consumer funds for non-financial… Full module →

Onshore conduct and safeguarding flow from the SVF Regulation and RPSCS Regulation, supervised by the CBUAE Consumer Protection function. SVF licensees must protect customer float (segregation / additional capital floor mechanisms), maintain an Additional… Full module →

On 30 June 2026 the FCA published its final cryptoasset rules and guidance (including stablecoin issuance), completing its Crypto Roadmap. Rules apply to firms authorised under FSMA on/after 25 October 2027; the authorisation gateway opens 30 September 2026… Full module →

The US lacks a unified safeguarding regime equivalent to UK CASS or EEA PSD2. State MTLs impose 'permissible investments' requirements: licensees must hold qualifying liquid assets equal to outstanding payment obligations, backed by surety bonds and minimum… Full module →

HB303 (Cryptocurrency Kiosk Fraud Prevention Act) was enacted and signed by Governor Kay Ivey, effective October 1, 2026, imposing receipts, refund mechanisms, consumer support lines, fraud warnings, $1,000/day-$10,000/month transaction caps, and… Full module →

Safeguarding runs through statutory trust/permissible-investments rules (AS 06.55.501 et seq.), with strict segregation of customer funds from licensee assets — including virtual currency, which cannot be rehypothecated. DBS actively enforces this: it denied… Full module →

Arizona's safeguarding regime requires authorized delegates to hold transmitted funds in trust for the licensee, mandates GAAP-audited annual financials, and requires quarterly Reports of Condition. Consumer-facing conduct rules require licensees to disclose… Full module →

Arkansas Act 347 (HB 1517), signed 20 March 2025, establishes a standalone EWA regulatory regime; providers are deemed not to be lending/money-transmission/debt-collection if compliant. A federal EWA framework bill (Earned Wage Access Consumer Protection Act)… Full module →

California protects payment-service users through a net-worth/surety-bond safeguarding model under the MTA and a broad conduct regime under the California Consumer Financial Protection Law (CCFPL), which empowers the DFPI to police unlawful, unfair, deceptive… Full module →

Colorado's money-transmission safeguarding regime relies on permissible-investment/surety-bond trust protection for payment-instrument holders, coupled with MTMA customer-protection provisions (timely forwarding, receipts, refunds, plain-language disclosure)… Full module →

Sec. 36a-613 imposes detailed pre-account and pre-transaction disclosure duties on virtual-currency kiosk operators, extended by PA 25-66 to all virtual-currency transmitters and now under active enforcement (March 2026 licence suspension).

Safeguarding for money transmitters is achieved through mandatory surety bonds/irrevocable letters of credit and statutory receipt/disclosure duties (5 Del.C. §§ 2309, 2313). Conduct and promotions are policed generally through the Consumer Fraud Act… Full module →

DC's conduct/safeguarding regime rests on MTA bonding/net-worth requirements plus the general Consumer Protection Procedures Act (CPPA); DISB's Enforcement and Consumer Protection Division investigates conduct violations, and the OAG has begun actively… Full module →

Florida enacted the first comprehensive US state-level licensing framework for payment stablecoin issuers (HB 175 / companion SB 314, now Ch. 2026-176), integrated into the existing Chapter 560 money-services-business regime and aligned with the federal… Full module →

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… Full module →

Safeguarding of transmitted funds rests on HRS 489D's permissible-investments/statutory-trust and bonding requirements, with authorized-delegate contract discipline and a full formal-enforcement toolkit (cease-and-desist, consent orders, civil/criminal… Full module →

Idaho's safeguarding mechanism for money transmitters is a scaled security device (surety bond, irrevocable letter of credit, or similar), not a UK/EU-style client-money segregation or trust regime. Conduct/promotions are governed generically by the Idaho… Full module →

IDFPR's conduct and safeguarding framework combines a Dodd-Frank-styled Consumer Financial Protection Law giving IDFPR UDAAP-style enforcement powers over unlicensed and licensed financial-services providers, with DACPA-specific customer-asset-safeguard… Full module →

Conduct/safeguarding obligations sit in the MTMA plus the new Indiana Earned Wage Access Act (EWAA), effective 2026-01-01.

Iowa's money-transmission conduct regime sits inside Chapter 533C (permissible investments as a safeguarding proxy, timely-transmission and disclosure duties, payroll-processing disclosures) and is layered with the state's general Consumer Fraud Act (Iowa… Full module →

Kansas ties licensee conduct to permissible-investment/trust safeguarding of outstanding transmission liability, a dedicated information-security statute mirroring the federal GLBA Safeguards Rule, a 2024 Earned Wage Access conduct regime under OSBC, and a… Full module →

Kentucky's safeguarding mechanism for money transmitters is trust-fund treatment of agent-commingled proceeds under KRS 286.11-037, backstopped by DFI's complaint/investigation and licence-suspension powers (KRS 286.11-055). General conduct oversight runs… Full module →

Louisiana's conduct/safeguarding regime for payments rests on trust-fund treatment of transmitted proceeds under the Sale of Checks and Money Transmission Act, a statutory 10-business-day transmission/return obligation, an explicit anti-forfeiture protection… Full module →

Maine money transmitters must post a $100,000 flat surety bond and maintain 100% permissible-investment coverage; LD 2080 (2026) additionally bans credit-card funding of online sports-betting and casino accounts, restricting permitted funding methods to debit… Full module →

Maryland's conduct regime for EWA moves from HB1294 (2025, tipping permitted with disclosure) to SB94 (2026, tipping banned), effective October 1, 2026.

Safeguarding under c.169B requires permissible investments equal to 100% of outstanding transmission obligations, held in a defined set of high-quality liquid assets. Consumer-facing conduct is governed by DOB remittance-disclosure rules and a strict… Full module →

Safeguarding rests on a permissible-investments requirement backed by surety bond, with DIFS examination/confidentiality powers under Section 26. The pending MTMA bill would introduce a statutory trust mechanism over permissible investments for customer… Full module →

Minnesota's conduct regime layers virtual-currency-kiosk-specific consumer safeguards (disclosure, refund and transaction-limit rules under Ch. 53B) onto a general Deceptive Trade Practices Act fee-transparency overlay (2025 surcharge disclosure amendment)… Full module →

Safeguarding under Mississippi's money-transmission regime is bond- and permissible-investment-based rather than trust/segregation-based. The 2026 legislative session added the first dedicated conduct/cybersecurity duties for licensees (Data Security for… Full module →

Safeguarding is bond/net-worth based rather than trust/segregation based; conduct/promotions rules newly extended in 2025 via the Virtual Currency Kiosk Consumer Protection Act.

Conduct/safeguarding runs through activity-specific bonding (escrow $100k; debt management $50k) with MUTPCPA as UDAP backstop, strengthened by SB488 (2025).

Safeguarding for Nebraska money transmitters rests on statutory net-worth/permissible-investment requirements plus a surety bond (minimum $100,000, scaling with liability). Conduct obligations include refund processing, receipt requirements, and (as of LB609… Full module →

Safeguarding of transmitted funds in Nevada rests on the NRS 671 surety-bond/permissible-investment regime rather than a segregation-trust mandate; general conduct and promotional practices are policed under NRS Chapter 598, enforced by the Attorney General's… Full module →

Safeguarding under RSA 399-G rests on prudential net-worth and permissible-investment requirements plus the surety bond, with recordkeeping/complaint-handling obligations; the Banking Department retains cease-and-desist, consent-order and revocation powers.

Safeguarding is achieved through a mandatory surety bond/letter-of-credit and net-worth requirements rather than segregation; conduct is policed via the CFA, with the AG signalling aggressive enforcement on fee/disclosure practices.

NM safeguarding mechanism is the statutory security instrument (surety bond/LC) under NMSA 58-32-203, not segregation/trust; general conduct backstop via Unfair Practices Act and Data Breach Notification Act.

New York's AG/Gaming Commission enforcement architecture now explicitly reaches crypto-adjacent platforms and prediction-market derivatives platforms (Kalshi, now escalated to a $36B civil suit) on an unlicensed-gambling theory.

Safeguarding rests on a statutory permissible-investments/trust mechanism plus bond/net-worth backstops; conduct is policed principally via the state's UDTPA (Ch.75) with parallel AG/NCCOB enforcement authority.

Federal GENIUS Act implementation racing 18 July 2026 statutory deadline: joint FinCEN/OFAC AML-sanctions proposed rule (8 Apr 2026), FDIC custody rule (comments due 9 Jun 2026), Treasury 'substantially similar' NPRM gating state-qualified issuers including… Full module →

Safeguarding of customer funds under the Ohio MTL regime rests on the permissible-investments/trust mechanism (ORC 1315.06) plus the security device (ORC 1315.07), with continuing licensee duties under ORC 1315.05. The Superintendent holds graduated… Full module →

Safeguarding for Oklahoma money transmitters rests on the surety-bond model rather than segregation/trust requirements. Conduct and disclosure obligations have been substantially modernized in 2025-2026 via the digital asset kiosk law (consumer… Full module →

Oregon closed a state-chartered-bank interest-rate-export (DIDMCA) loophole via HB 4116 (2026), reinforcing its 36% consumer-finance interest-rate cap against internet lenders partnering with out-of-state banks; DFR separately secured a $900,000 restitution… Full module →

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… Full module →

Conduct and safeguarding obligations for RI currency transmission licensees are codified in RI Gen. Laws 19-14.3-3.5 through 3.9, covering mandatory customer disclosures, prohibited acts (fraud, BSA/EFTA non-compliance, deceptive advertising), and… Full module →

Safeguarding for SC-licensed money transmitters rests on a surety-bond/net-worth regime rather than segregation-of-funds trust. Conduct/promotions rules are emerging fastest around VC kiosks via pending Bill 4592.

Safeguarding for South Dakota money transmitters rests on a tiered surety bond plus a statutory trust/permissible-investments requirement matching outstanding transmission liabilities. Consumer-facing conduct is anchored by the 36% APR rate cap on… Full module →

Safeguarding in Tennessee runs through the MTMA's net-worth/surety-bond regime (not trust/segregation-style safeguarding as in EMI regimes). Conduct and promotions oversight blends TDFI licensing conditions with the Tennessee Consumer Protection Act, enforced… Full module →

Texas has no segregation/trust-account safeguarding regime akin to EU/UK client-money rules; consumer protection is instead delivered through minimum net-worth and surety-bond requirements, TDB supervisory oversight, and marketing/advertising restrictions… Full module →

Safeguarding for Utah money transmitters rests on minimum net worth plus a surety bond, with DFI discretion to compel deposits if a licensee is unsafe or unsound. Conduct/promotions oversight for consumer fees (including surcharges) sits with the Division of… Full module →

Vermont safeguards customer funds via statutory trust over permissible investments (eff. July 2024), mandatory surety bond, and prudential net-worth standards, plus new 2025 kiosk fraud-refund obligations.

Virginia has no dedicated e-money safeguarding regime; consumer protection runs through the surety bond mechanism plus VCPA enforcement. A mandatory-fee/surcharge disclosure statute (SB 1212) took effect July 1, 2025.

Washington's conduct regime centres on a named Responsible Individual per licensee, mandatory permissible-investment/safeguarding of customer funds, a statutory refund right, and federal Regulation E remittance-transfer disclosure obligations layered on top… Full module →

Safeguarding for WV payments licensees is delivered through the statutory surety-bond/permissible-investment mechanism rather than a segregation-of-funds trust regime. Conduct enforcement runs through the Commissioner's cease-and-desist, consent-order and… Full module →

Safeguarding rests on a surety bond/permissible-investments model, with new consumer conduct obligations on virtual currency kiosk operators via 2025 Act 226.

Wyoming's safeguarding regime for money transmitters rests on permissible-investment requirements (cash, CDs, securities, Treasuries) equal to outstanding obligations, backed by a surety bond, with annual audited statements. For SPDI/bank digital-asset… Full module →

Safeguarding of IEDE customer funds is legally mandated via segregated trust-style accounts at licensed IIFs (Ley 19.210 art. 5), with fiduciary responsibility on the IEDE and BCU discretion over liquid-asset placement. Conduct/promotions oversight sits with… Full module →

Conduct and safeguarding obligations sit mainly in SUDEBAN's fintech resolution (performance bonds, risk-management controls) and a dedicated banking-complaints reconsideration body (Defensoría del Cliente y Usuario Bancario). Broader price/consumer-fairness… Full module →

Safeguarding for e-money is delivered via a 1:1 payment-assurance (escrow) account model: e-wallet providers must hold a payment-assurance account at an associated bank and may not receive cash directly from customers. Decree 52/2024 introduced Vietnam's… Full module →

Conduct/safeguarding rules sit in BoZ directives under BFSA s.167 and NPSA-derived e-money directives, supplemented by a weak voluntary Bankers Association Code; BoZ consumer-protection capacity remains thin.