Guest Analysis: The Intersection of Payments and Money Transmission: A Look at The Agent-of-the-Payee Exemption

By Nicole Meisner, Jaffe, Raitt, Heuer & Weiss, P.C. Think you can you avoid money transmitter laws through the agent-of-the-payee exemption? Not so fast. The exemption is not ubiquitous and it’s full of potholes—a recipe for . . .