Virginia's new money transmitter chapter also codified exemptions in Section 6.2-1923. The exemptions are important because many licensing decisions turn on carve-outs for payment system operators, agent-of-payee structures, and similar arrangements.
What changed
The new chapter expressly lists exemptions from licensure, including certain payment-system operator and agent-of-payee arrangements. This gives companies a new statutory basis for exemption analysis under Virginia law.
Compliance perspective
Businesses that previously treated Virginia as a gray area should document exemption positions carefully under the new chapter language. Payments companies and platforms should test each flow against the actual statutory exemptions before concluding they can operate unlicensed.
Key date
Effective date: July 1, 2026.
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