Virginia Money Transmission Modernization Act: Virtual Currency Treatment

Virginia’s Money Transmission Modernization Act implementation, enacted through HB 1942 as 2025 Virginia Acts Chapter 214, creates a new Chapter 19.1 money-transmitter framework for the Commonwealth. As of June 9, 2026, the law is enacted but not yet operative; the codified provisions state that Chapter 19.1 is effective July 1, 2026. The crypto-specific point is narrow but important: the statute defines “virtual currency,” while also stating that “money” does not include virtual currency.

Virginia virtual currency treatment

Chapter 19.1 defines virtual currency as a digital representation of value used as a medium of exchange, unit of account, or store of value, and not money, whether or not denominated in money. The same definition excludes certain merchant rewards value and game-platform value. Separately, the definition of money covers a medium of exchange authorized or adopted by the United States or a foreign government, but expressly excludes virtual currency.

That drafting means this profile should not describe HB 1942 as a stand-alone virtual-currency licensing regime. The statute modernizes Virginia’s money-transmitter law and creates definitions relevant to digital assets, but it does not appear to adopt the optional virtual-currency article from the CSBS model law, which would have defined virtual-currency exchange and transfer activity more directly. Activities involving money, monetary value, payment instruments, stored value, authorized delegates, or other covered transmission functions may still require separate analysis under the statute and other state or federal law.

Core money-transmitter framework

The new chapter requires a person to hold a Virginia money-transmission license before engaging in the business of money transmission, or before advertising, soliciting, or holding itself out as providing money transmission, unless the person qualifies for an exemption or acts within the authorized-delegate structure. Money transmission includes selling or issuing payment instruments, selling or issuing stored value, and receiving money for transmission from a person located in Virginia.

• Licensing: applications are submitted in the form and medium prescribed by the State Corporation Commission, with information on business history, authorized delegates, other state licenses, key individuals, control persons, audited financial statements, and related disclosures.
• Multistate alignment: the Commission may use NMLS and multistate licensing processes to coordinate licensing, supervision, reporting, background checks, fee processing, and examinations.
• Regulatory administration: the Commission has authority to administer, interpret, and enforce Chapter 19.1 and to recover supervisory costs through proportionate fees.

Prudential standards and consumer protection

HB 1942 adds model-law-style prudential standards for licensed money transmitters. A licensee must maintain tangible net worth based on total assets, beginning with the greater of $100,000 or three percent of total assets for licensees with total assets not greater than $100 million. The surety-bond section requires a bond or approved deposit, with the minimum generally tied to 100 percent of average daily money-transmission liability in Virginia, subject to statutory floor and cap amounts.

The permissible-investments framework requires licensees to maintain investments with a market value at least equal to aggregate outstanding money-transmission obligations in all states. In insolvency or similar proceedings, permissible investments are deemed held in trust for purchasers and holders of outstanding obligations. This trust treatment is one of the law’s principal customer-protection mechanisms, although it does not itself resolve how any specific virtual-currency business model should be classified.

Authorized delegates, supervision and enforcement

The statute requires written contracts, policies, risk-based background investigations, and supervision for authorized delegates. Authorized delegates must hold money net of fees in trust for the licensee and may not use subdelegates. The Commission may examine licensees and authorized delegates, coordinate with other regulators, require records, and issue cease-and-desist orders for violations or unsafe and unsound practices.

The delayed effective date gives regulated parties and the Commission time to transition from the existing Chapter 19 framework to Chapter 19.1. For CryptoSlate taxonomy purposes, this profile is best treated as an enacted Virginia act with a future effective date, focused on licensing and payments rather than a comprehensive digital-asset licensing law.