US-VA · run world-payments-2026-07-05 v13.3.0
content: ai_generated 128 sources retrieved model claude-sonnet-5 ·

United States – Virginia

US-VA schema world-payments-v1 trajectory: not recorded

Last updated · 14 modules · 59 sourced findings · 128 sources in the cumulative register

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Jurisdiction brief

Lead Signal

Virginia's 2025 overhaul of the Money Transmitters Act crosses into force this cycle, restructuring licensing economics for every non-bank money transmitter operating in the Commonwealth. The amendment lowers the starting net-worth minimum to $100,000, resets the surety-bond formula to a $100,000-$1M band, and revises permissible-investment obligations, superseding the prior flat $200,000 net-worth minimum, effective July 1, 2026. The change lands atop a licensing architecture that has long been unusually consolidated: Virginia requires money transmission and money order selling to be licensed exclusively under the Virginia Money Transmitters Act (Title 6.2, Chapter 19), administered by the Bureau of Financial Institutions within the State Corporation Commission via NMLS, with no separate EMI or PPI charter available. Because safeguarding of customer funds in Virginia rests on a surety bond rather than a segregation or trust model, and Virginia does not separately mandate liability insurance as a licensing prerequisite, the July 1 recalibration of bond and net-worth thresholds resets the primary consumer-protection buffer for the Commonwealth's non-bank payments sector at the same moment entry costs for new licensees are eased.

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Virginia's money-transmitter framework has been comprehensively overhauled: former Chapter 19 of Title 6.2 is repealed effective July 1, 2026 and replaced by new Chapter 19.1, enacted via HB 1942 (2025 Acts of Assembly, c. 214), adopting the CSBS Money Transmission Modernization Act model law; the SCC has begun conforming 10VAC5-120 accordingly.

Standing sub-brief166 words · last cycle wpm-2026-08-06

Licensing, Authorisation & Market Access

Virginia requires money transmission and money order selling to be licensed exclusively under the Virginia Money Transmitters Act, Title 6.2, Chapter 19 of the Code of Virginia, administered by the Bureau of Financial Institutions within the State Corporation Commission via the Nationwide Multistate Licensing System, and the Commonwealth maintains no separate electronic-money-institution or prepaid-instrument charter for non-bank payments activity. A 2025 legislative overhaul of that Act restructures the licensing economics for every existing and prospective licensee, lowering the starting net-worth minimum to $100,000, resetting the surety-bond formula to a band of $100,000 to $1 million, and revising permissible-investment obligations, superseding the prior flat $200,000 net-worth minimum, with the new regime effective July 1, 2026.

Periodic update · new data 2026-08-11 · run wpm-2026-08-06

Licensing, Authorisation & Market Access

Virginia's money-transmission framework underwent a complete legislative replacement this cycle. Chapter 19 of Title 6.2 of the Code of Virginia - the state's money-order-seller and money-transmitter statute - was repealed effective 1 July 2026 under Acts of Assembly 2025, Chapter 214 (HB 1942), and superseded by new Chapter 19.1. The new chapter adopts the CSBS Money Transmission Modernization Act model law and eliminates the standalone money-order-seller licence category that existed under the old statute. Virginia's adoption places it alongside more than thirty other states that have already adopted the MTMA in whole or in part, which should reduce multi-state licensing friction for transmitters that already hold licences across that cohort of states, even as the Commonwealth's own prudential requirements are simultaneously being recalibrated.

That recalibration is concrete and quantified. Chapter 19.1 replaces the prior flat $200,000 net-worth minimum with a tiered structure starting at $100,000, and introduces a surety-bond formula keyed to a transmitter's average daily money-transmission liability rather than a flat bond figure. This is a bank-versus-nonbank-relevant change specifically because it falls on non-bank money transmitters and payment institutions - the entities licensed under this chapter are, by definition, non-bank actors; banks conducting payment activity operate under a different prudential perimeter entirely, and Chapter 19.1's tiered bond and net-worth structure does not touch that separate bank-regulatory track.

The Virginia State Corporation Commission has begun the administrative work of implementing the new statute. On 4 May 2026, the Commission published proposed amendments to 10VAC5-120 conforming the regulation to Chapter 19.1: updating definitions, licence-application requirements, and the exemption scope under Section 6.2-1923, and delegating administrative powers to the Commissioner of Financial Institutions. These amendments were still pending finalization as of this cycle's observation date, meaning Chapter 19.1 is in force as a statute while its full regulatory implementation remains incomplete.

Scope changes accompany the prudential and administrative ones. Chapter 19.1 excludes virtual currency from the statutory definition of money, which means purely crypto-to-crypto activity falls outside Virginia's money-transmitter licensure requirement altogether. At the same time, the chapter expands the definition of money transmission to explicitly include payroll processing, bringing a category of commercial-payments activity within the licensing perimeter that had not previously been named in the statute. These two changes move in opposite directions on the same underlying question of what counts as money transmission in Virginia, and firms operating in either space have direct cause to re-examine their licensing position against the new statutory language.

For an operator evaluating entry into Virginia's money-transmission market for the first time, the new regime is, on balance, a lower-friction proposition than the one it replaced, precisely because MTMA harmonization means a licence built to the model-law template can be leveraged across the growing cohort of adopting states with less bespoke compliance work per state. That efficiency gain is offset, though not eliminated, by the tiered net-worth and bond requirements, which mean the specific capital and surety obligations a new entrant faces will depend on its projected average daily transmission liability rather than a single flat figure applicable to every licensee regardless of size. The virtual-currency exclusion also has an entry-pathway dimension worth stating plainly: a firm whose Virginia-facing activity is limited to crypto-to-crypto transactions does not need a Virginia money-transmitter licence to conduct that specific activity under Chapter 19.1's current definition, though any fiat-denominated leg of a broader payments business would still fall within the licensing perimeter as before.

None of the developments described here were sourced from a single outlet: the repeal and the SCC's conforming amendments both trace to Tier 1 primary sources - the Code of Virginia itself and the Virginia Register of Regulations - while the MTMA-adoption characterization, the tiered bond mechanics, and the virtual-currency scope change rest on Tier 4 secondary analysis that has not yet been corroborated against the enacted statutory text directly.

Outlook

The item to watch is finalization of the Commission's conforming amendments to 10VAC5-120, expected within roughly the next two quarters. Until those amendments finalize, the practical licensing experience for new applicants and the precise application of the tiered bond formula to existing licensees both remain incompletely specified at the regulatory level, even though Chapter 19.1 itself has been in force since 1 July 2026.

Sources and findings (6)
  1. T1https://law.lis.virginia.gov/vacode/title6.2/chapter19/section6.2-1901/
  2. T1https://www.scc.virginia.gov/regulated-industries/bureau-of-financial-institutions/
  3. T3https://fraxtional.co/feeds/blog/va-money-transmitter-license
  4. T3https://www.bondexchange.com/virginia-money-transmitter-bond-a-comprehensive-guide/
  5. T3https://fraxtional.co/feeds/blog/va-money-transmitter-license
  6. T3https://fraxtional.co/feeds/blog/va-money-transmitter-license

#

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.

Standing sub-brief134 words · last cycle wpm-2026-07-08

Conduct, Safeguarding & Financial Promotions

Virginia's safeguarding of money-transmission customer funds rests on a surety bond rather than a segregation or trust model, compensating the public if a licensee fails to comply, and the Commonwealth does not separately mandate liability insurance as a licensing prerequisite. Separately, Virginia Code § 59.1-608 (enacted via SB 1212) requires clear and conspicuous total-price disclosure of all mandatory fees and card surcharges in consumer transactions, effective July 1, 2025, enforced as a Virginia Consumer Protection Act violation carrying civil penalties and a private right of action for damages.

No periodic updates recorded against this sub-brief.

Sources and findings (5)
  1. T3https://www.bondexchange.com/virginia-money-transmitter-bond-a-comprehensive-guide/
  2. T1https://law.lis.virginia.gov/vacodeupdates/title59.1/section59.1-608/
  3. T3https://merchantcostconsulting.com/lower-credit-card-processing-fees/virginia-surcharge-laws/
  4. T1https://www.scc.virginia.gov/regulated-industries/bureau-of-financial-institutions/
  5. T1https://law.lis.virginia.gov/vacodefull/title6.2/chapter21/

#

Virginia has no bespoke stablecoin-issuer licensing regime; digital-asset activity is governed by the federal GENIUS Act framework and Virginia's HB 798 unclaimed-property update covering digital assets, effective July 1, 2026.

Horizon · 2026-07-01 (±quarter)HB 798 unclaimed digital-assets law in forcein_force · TT3
Horizon · 2026-07-18 (±quarter)GENIUS Act implementing regulations deadlineproposed · TT1
Standing sub-brief143 words · last cycle wpm-2026-07-08

Stablecoins & Digital Money

Virginia's HB 798 brings dormant digital assets into the Commonwealth's unclaimed-property escheat regime: cryptocurrency inactive for five years or more is presumed abandoned and must be transferred in-kind to state custody, where it must be held at least one year before any liquidation, effective July 1, 2026. That state-level action sits against a federal backdrop in which the GENIUS Act establishes the primary regulatory framework for any Virginia-domiciled or Virginia-serving payment-stablecoin issuer, delegating approval to federal banking agencies or qualified state regulators, with implementing regulations generally required by July 18, 2026; no Virginia-specific state-qualified stablecoin-issuer pathway yet exists.

No periodic updates recorded against this sub-brief.

Sources and findings (5)
  1. T3https://www.theblock.co/post/397484/virginia-approves-bill-unclaimed-crypto-assets
  2. T3https://bitcoinmagazine.com/news/virginia-enacts-law-state-crypto
  3. T3https://www.gibsondunn.com/digital-assets-recent-updates-april-2026/
  4. T1https://www.wiley.law/alert-Building-a-Digital-Asset-Regulatory-Framework-The-GENIUS-Act-and-Next-Steps
  5. T1https://occ.treas.gov/news-issuances/bulletins/2026/bulletin-2026-3.html

#

Virginia has no payments-specific operational-resilience regime analogous to DORA; resilience oversight runs through the Secretary of Public Safety and Homeland Security (as Chief Resilience Officer) and university-partnered cybersecurity research (Commonwealth Cyber Initiative). The state's acute exposure is physical/critical-infrastructure concentration risk from its globally significant data-center cluster in Loudoun County ("Data Center Alley"), which underpins much of the mid-Atlantic's digital and payments infrastructure and has already produced a near-blackout grid event.

Open gap — wpm-int-3No Virginia-specific payments-sector operational-resilience regulation analogous to DORA/critical-third-party outsourcing rules was identified.no under-indexing note recorded
Standing sub-brief100 words · last cycle wpm-2026-07-08

Operational Resilience & Critical Infrastructure

Virginia has no payments-specific operational-resilience regime analogous to the EU's DORA, so the closest identified proxy is physical: Loudoun County's 'Data Center Alley' concentrates 143 or more data centers whose grid dependency exposes payments-adjacent digital infrastructure to concentration risk, illustrated by a July 2024 near-blackout of 1.5 gigawatts that revealed structural mismatch with aging PJM transmission infrastructure.

No periodic updates recorded against this sub-brief.

Sources and findings (5)
  1. T1https://www.pshs.virginia.gov/homeland-security/
  2. T3https://broadbandbreakfast.com/data-center-boom-in-virginias-data-center-alley-raises-infrastructure-concerns/
  3. T3https://www.globaldatacenterhub.com/p/when-15-gigawatts-vanished-what-the
  4. T3https://www.belfercenter.org/research-analysis/data-centers-texas-virginia-comparison
  5. T3https://news.vt.edu/articles/2026/03/cci-cybersecurity-critical-infrastructure.html

#

Virginia does not regulate card-scheme rulebooks directly, but it does regulate merchant-facing scheme economics through its 2025 surcharge-disclosure statute and maintains a long-standing state credit-card crimes code governing acquirer/issuer/cardholder fraud. Card-network surcharge caps (Visa 3%, Mastercard 4%) and PCI DSS remain scheme-set rather than state-set standards applicable in Virginia as in all US states.

Standing sub-brief124 words · last cycle wpm-2026-07-08

Scheme & Network Compliance

Virginia's SB 1212 total-price transparency requirement sits atop existing card-network surcharge caps of 3% for Visa and 4% for Mastercard, and the Commonwealth imposes no independent state-level surcharge cap of its own, while debit-card surcharging remains illegal nationwide. Standing alongside that overlay, Virginia Code Title 18.2, Chapter 6, Article 6 criminalises unauthorized presentment of credit or debit card transactions to an issuer or acquirer, reaching Class 5 felony level where fraudulent intent is present and a Class 1 misdemeanor otherwise.

No periodic updates recorded against this sub-brief.

Sources and findings (4)
  1. T3https://merchantcostconsulting.com/lower-credit-card-processing-fees/credit-card-surcharge-laws-by-state/
  2. T3https://merchantcostconsulting.com/lower-credit-card-processing-fees/virginia-surcharge-laws/
  3. T1https://law.lis.virginia.gov/vacodefull/title18.2/chapter6/article6/
  4. T3https://intellipay.com/surcharge-compliance-mistakes-fines/

#

Virginia is not itself a distinct cross-border payments corridor jurisdiction, but it hosts the Federal Reserve Bank of Richmond, headquarters of the Fifth Federal Reserve District and a key national hub for FedNow instant payments, ACH and Treasury payment processing — making Virginia structurally central to US domestic payment-rail dynamics even absent its own corridor-specific regulation.

Standing sub-brief85 words · last cycle wpm-2026-07-08

Payment Corridor Dynamics

Virginia's structural role in US domestic payment corridors runs through the Federal Reserve Bank of Richmond rather than through any Virginia-specific corridor regulation: Richmond operates the FedNow instant-payments service, which has run since July 2023, alongside national ACH processing and Fifth District Treasury and payment infrastructure.

Outlook

Virginia's corridor position is structural rather than event-driven this cycle; the Richmond Fed's continued FedNow and ACH operation should be read as a stable baseline against which any future instant-payments expansion elsewhere would be benchmarked.

No periodic updates recorded against this sub-brief.

Sources and findings (4)
  1. T1https://www.richmondfed.org/payments_services/financial_services
  2. T1https://www.federalreserve.gov/aboutthefed/federal-reserve-system-richmond.htm
  3. T1https://www.richmondfed.org/payment_services/overview?from=/payments_services/overview
  4. T1https://www.richmondfed.org/payment_services/overview?from=/payments_services/overview

#

Virginia's payments industry structure is anchored by Capital One Financial (McLean), now the largest US credit-card issuer following its $35.3bn Discover acquisition, and the Federal Reserve Bank of Richmond.

Standing sub-brief89 words · last cycle wpm-2026-07-08

Industry Structure & Commercial Dynamics

Capital One Financial Corp, headquartered in McLean, closed its $35.3 billion acquisition of Discover Financial Services this cycle, making Capital One the largest US credit-card issuer and the sixth-largest US bank, and reshaping the industry structure around which Virginia's commercial payments footprint is anchored alongside the Richmond Fed.

Outlook

With integration of Discover's card network and workforce now underway, Capital One's scale advantage is likely to keep reshaping US card-issuing competitive dynamics well beyond this reporting cycle, with Virginia's commercial footprint the direct beneficiary.

No periodic updates recorded against this sub-brief.

Sources and findings (4)
  1. T3https://virginiabusiness.com/35b-capital-one-discover-merger/
  2. T3https://patch.com/illinois/deerfield/capital-one-laying-nearly-1-2k-workers-former-discover-hq-riverwoods
  3. T1https://www.capitalone.com/about/corporate-information/corporate-offices/
  4. T3https://leadiq.com/c/federal-reserve-bank-of-richmond/5a1d8a062400002400635eac

Virginia's Attorney General maintains an active payments/fintech-adjacent enforcement posture through multistate consumer-protection settlements (notably the ACI Worldwide/Speedpay ACH-error settlement and its long-running Predatory Lending Unit actions) and the VCPA. State courts have also recently narrowed the reach of Virginia's wage-payment "wage theft" statute, a ruling with implications for payroll-adjacent payment disputes.

Standing sub-brief120 words · last cycle wpm-2026-07-08

Legal & Litigation

The Supreme Court of Virginia held in Groundworks Operations LLC v. Campbell, decided December 30, 2025, that the Virginia Wage Payment Act's 'wage theft' protections do not extend to commissions, narrowing the statute's scope for payroll and payment disputes. In a legacy but still-standing enforcement matter, ACI Worldwide settled with the Virginia Attorney General and other states for $10 million (Virginia's share $247,018.82) over a 2021 Speedpay ACH platform testing error that risked unauthorized withdrawal of $2.3 billion from mortgage-holder accounts.

No periodic updates recorded against this sub-brief.

Sources and findings (5)
  1. T3https://wjla.com/news/local/virginia-attorney-general-jason-miyares-part-of-multi-state-10-million-settlement-with-aci-worldwide-corp-over-unauthorized-mortgage-payments-error-automated-clearing-house-speedpay-platform-october-2023
  2. T3https://www.consumerfinancialserviceslawmonitor.com/2017/02/virginia-ag-reaches-settlement-agreement-with-cashcall/
  3. T1https://www.oag.state.va.us/media-center/news-releases/2619-october-5-2023-attorney-general-miyares-announces-49-5-million-multistate-settlement-with-blackbaud-for-data-breach-impacting-thousands-of-nonprofits-and-millions-of-consumers
  4. T3https://www.gentrylocke.com/article/employers-win-round-one-virginias-wage-theft-statute-does-not-include-commissions-will-it-last/
  5. T1https://www.scc.virginia.gov/consumers/consumer-investments/regulatory-activity/

#

Virginia has no bespoke merchant-acquiring licensing regime or high-risk-MCC statute; acquiring activity is governed by the state's general credit-card crimes code (acquirer/issuer definitions and fraud offences) and, since July 2025, by the SB 1212 total-price/surcharge disclosure requirement that directly affects acquirer-merchant fee pass-through practices.

Standing sub-brief75 words · last cycle wpm-2026-07-08

Merchant Acquiring & Risk

Virginia has no bespoke merchant-acquiring licensing regime and no dedicated high-risk-MCC statute; acquiring activity is instead governed by the general credit-card crimes code in Title 18.2 together with the SB 1212 fee-disclosure overlay, which affects how acquirers and merchants pass through processing fees.

Outlook

Absent a bespoke acquiring statute, Virginia's merchant-acquiring risk framework will likely keep evolving indirectly, through fee-disclosure enforcement under SB 1212 rather than through any dedicated high-risk-merchant rulemaking.

No periodic updates recorded against this sub-brief.

Sources and findings (4)
  1. T1https://law.lis.virginia.gov/vacode/title18.2/chapter6/section18.2-191/
  2. T1https://law.lis.virginia.gov/vacodefull/title18.2/chapter6/article6/
  3. T3https://merchantcostconsulting.com/lower-credit-card-processing-fees/virginia-surcharge-laws/
  4. T3https://intellipay.com/surcharge-compliance-mistakes-fines/

#

Virginia's new Chapter 19.1 money-transmission regime interacts with the pending federal GENIUS Act stablecoin framework: Virginia excludes virtual currency from its 'money' definition while federal payment-stablecoin issuer standards remain in NPRM stage, creating a transitional dual-track landscape.

Open gap — wpm-int-1Final enacted/vetoed status of SB 1252 (2025 fintech-lending/EWA 12% usury-cap bill) could not be confirmed this cycle.no under-indexing note recorded
Standing sub-brief136 words · last cycle wpm-2026-08-06

Product Innovation & Market Development

The Virginia FinTech Regulatory Sandbox Program, established under Code of Virginia § 6.2-2701 et seq., allows the State Corporation Commission to grant participants limited market access to test a financial product or service without first obtaining the otherwise-required licence or authorization, subject to fitness and criminal-history exclusions. SB 1252, introduced in January 2025, proposes a 12% interest-rate cap with anti-evasion provisions targeting bank-fintech and BaaS lending partnerships and earned-wage-access products; the American Fintech Council lobbied for a gubernatorial veto, and the bill's final enacted or vetoed status was not confirmed this cycle.

Periodic update · new data 2026-08-11 · run wpm-2026-08-06

Product Innovation & Market Development

A federal overlay is forming on top of Virginia's money-transmission regime for stablecoin-related activity. The FDIC's Board of Directors approved a notice of proposed rulemaking on 7 April 2026 implementing GENIUS Act requirements and standards, and the OCC issued its own implementing bulletin on 25 February 2026; together the two proposals establish prudential standards - reserves, redemption, capital, and custodial safekeeping - for permitted payment stablecoin issuers. Neither proposal has finalized as of this cycle.

The Virginia-specific dimension of this federal development is definitional rather than direct. Virginia's own Chapter 19.1 money-transmission statute, in force from 1 July 2026, excludes virtual currency from its statutory definition of money, meaning the state's money-transmitter licensing regime does not reach purely crypto-to-crypto or virtual-currency-denominated activity. The result is a jurisdictional and regulatory gap between the state and federal layers for VA-touching stablecoin activity specifically: the state regime does not claim it, and the federal regime that will eventually govern payment stablecoin issuance is still in proposed-rule form. This is a durable dual-track landscape rather than a temporary coordination lag, because it follows from a deliberate scope choice in Virginia's own statute rather than from an oversight that either level of government is likely to correct quickly.

For a firm issuing or supporting payment stablecoins with Virginia-based customers or operations, the practical consequence is that no single licensing regime currently governs the full stack of that activity end to end. Fiat-denominated money transmission connected to a stablecoin business remains subject to Chapter 19.1 licensure. The stablecoin issuance itself, to the extent it is purely virtual-currency-denominated, falls outside that state licensing perimeter and will eventually be governed by whichever federal framework the FDIC and OCC finalize, though that framework does not yet exist in binding form.

The Interpreter's own gap assessment notes that the GENIUS Act's original one-year implementation clock, which began running from the statute's enactment in July 2025, is now expected by industry observers to slip into 2027, with the OCC's comment period on its own proposal having closed 1 May 2026. This is a genuine and disclosed timeline slippage rather than an enforcement failure, and this brief does not characterize it as anything beyond what the underlying federal filings themselves establish: two proposed rules, not yet final, advancing on separate but parallel agency tracks toward the same statutory mandate.

It is worth being precise about what this cycle's finding does and does not show. It does not show that Virginia has taken any stablecoin-specific regulatory action; the Commonwealth's only relevant statutory choice is the virtual-currency exclusion embedded in Chapter 19.1, which was enacted as part of the broader money-transmission overhaul rather than as a stablecoin-specific measure. It does show that the federal prudential framework which will eventually govern payment stablecoin issuers nationally, including in Virginia, remains under construction, with two separate agencies each advancing their own proposed rule rather than a single finalized standard.

The distinction between the FDIC's and OCC's respective jurisdictions matters here in a way that is easy to elide: the two agencies supervise different categories of depository institutions, and a payment stablecoin issuer's ultimate regulatory home will depend on its own institutional structure and any bank partnerships it maintains. Firms building stablecoin products that touch Virginia should not assume that either agency's proposal alone describes the complete federal standard they will eventually face; both remain live, both remain proposed, and reconciliation between the two has not yet occurred. No Virginia-specific stablecoin legislation or regulatory action was identified this cycle beyond the definitional scope choice already embedded in Chapter 19.1. Confidence in the federal rulemaking finding itself is High, resting on two independent Tier 1 federal primary sources; confidence in the characterization of the resulting dual-track landscape as it applies specifically to Virginia is Assessed, since it follows from combining the federal finding with Virginia's own statutory scope choice rather than from a single source stating the intersection directly.

Outlook

The GENIUS Act implementing rules from the FDIC and OCC are not expected to finalize before the first quarter of 2027. Until they do, VA-touching stablecoin activity will continue to sit in the dual-track landscape described above: outside Virginia's own money-transmission licensing perimeter by statutory design, and governed federally only by proposed rather than binding prudential standards. Watch for either agency finalizing ahead of the other, and for any indication that Virginia intends to revisit its virtual-currency exclusion in light of the federal framework's eventual completion; no such intention has been signaled this cycle.

Sources and findings (4)
  1. T1https://www.richmondsunlight.com/bill/2022/hb922/fulltext/
  2. T3https://www.bankingdive.com/news/colorado-law-virginia-sb1252-legislation-would-impact-fintech-lending/741044/
  3. T1https://www.federalregister.gov/documents/2025/12/23/2025-23735/truth-in-lending-regulation-z-non-application-to-earned-wage-access-products
  4. T1https://www.richmondfed.org/topics/payments

#

Consumer protection for Virginia payments consumers runs primarily through the Virginia Consumer Data Protection Act (VCDPA, effective January 1, 2023, with 2026 definitional amendments) and the Virginia Consumer Protection Act, both AG-enforced with no private right of action for the VCDPA. Virginia has no dedicated APP-fraud reimbursement scheme; unauthorized-transfer protection for consumers rests on federal Regulation E rather than state law.

Open gap — wpm-int-5No dedicated state-level APP-fraud mandatory reimbursement scheme distinct from federal Regulation E was identified for Virginia consumers.no under-indexing note recorded
Standing sub-brief108 words · last cycle wpm-2026-07-08

Consumer Protection & APP Fraud

The Virginia Consumer Data Protection Act grants Virginia residents personal-data rights, enforced exclusively by the Attorney General with no private right of action, effective January 1, 2023, though GLBA-covered financial institutions are broadly exempted from its scope. Virginia has no dedicated state-level authorized-push-payment fraud mandatory-reimbursement scheme; unauthorized-transfer consumer protection rests instead on federal Regulation E rather than any bespoke state statute, an under-indexed area meriting continued attention.

No periodic updates recorded against this sub-brief.

Sources and findings (5)
  1. T1https://www.oag.state.va.us/consumer-protection/files/tips-and-info/Virginia-Consumer-Data-Protection-Act-Summary-2-2-23.pdf
  2. T3https://virginia-vcdpa.org/the-virginia-consumer-data-protection-act-summary/
  3. T3https://www.egnyte.com/guides/governance/virginia-consumer-data-protection-act
  4. T1https://law.lis.virginia.gov/vacode/title40.1/chapter3/section40.1-29/
  5. T3https://www.consumerfinancialserviceslawmonitor.com/wp-content/uploads/sites/501/2016/05/Consumer-Financial-Regulation-Virginia-w-002-2382.pdf

#

W11 baseline content for US-VA is Sentinel.gi-fed per methodology; a dedicated Sentinel.gi payments-context feed entry specific to US-VA was not located in this collection pass. The applicable AML/CFT overlay for Virginia payments activity remains the federal Bank Secrecy Act regime: Virginia money transmitters must independently register as Money Services Businesses with FinCEN and maintain an independently reviewed AML/BSA programme as a state-licensing precondition.

Open gap — wpm-int-2No dedicated Sentinel.gi payments-context feed entry specific to US-VA was located; W11 content relies on the general federal BSA/MSB overlay only.no under-indexing note recorded
Standing sub-brief87 words · last cycle wpm-2026-07-08

AML/CFT & Financial Crime

Virginia money transmitter licensees must register as a Money Services Business with FinCEN via BSA e-filing and maintain an independently reviewed AML/BSA programme as a precondition of state licensing; no Virginia-specific Sentinel.gi payments-context feed entry was located this cycle, so this dashboard entry carries the federal BSA/MSB overlay only.

Outlook

This module remains thin-coverage until a Virginia-specific Sentinel.gi feed is identified; the illicit-finance dimension of Virginia money-transmitter AML exposure has been routed to the Financial Integrity Monitor and should not be re-analysed here.

No periodic updates recorded against this sub-brief.

Sources and findings (2)
  1. T3https://fraxtional.co/feeds/blog/va-money-transmitter-license
  2. T3https://surety1.com/bond_info/virginia-money-transmitter-bond/

#

Virginia is host to the Federal Reserve Bank of Richmond, which provides master-account settlement, ACH operation, and Treasury/government payment services across the Fifth District — giving Virginia-domiciled institutions direct structural access to core U.S. settlement infrastructure rather than reliance on correspondent-banking intermediation for domestic settlement.

Standing sub-brief108 words · last cycle wpm-2026-07-08

Correspondent Banking, Settlement & Access

Virginia's structural spine in correspondent banking is the bank-versus-non-bank access asymmetry: the Federal Reserve Bank of Richmond provides master-account settlement, national ACH operation, Discount Window liquidity access, and Treasury payment services across the Fifth District, giving Virginia-domiciled banks direct structural access to core US settlement infrastructure that reduces reliance on correspondent intermediation in ways non-bank licensees cannot replicate.

No periodic updates recorded against this sub-brief.

Sources and findings (4)
  1. T1https://www.richmondfed.org/payment_services/overview?from=/payments_services/overview
  2. T1https://www.richmondfed.org/payment_services
  3. T1https://www.richmondfed.org/banking
  4. T1https://www.richmondfed.org/payments_services/overview

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The dominant trailing-12-month commercial event tied to Virginia is Capital One's $35.3bn acquisition of Discover Financial Services, closed 2025, with continuing 2026 post-merger layoffs.

Open gap — wpm-int-4No additional Virginia-headquartered fintech funding rounds or product launches beyond the Capital One-Discover transaction were identified within the trailing 12-month W13 baseline window.Possible under-indexing of private-company/early-stage Virginia fintech signal per methodology bias-correction guidance.
Standing sub-brief108 words · last cycle wpm-2026-07-08

Commercial Intelligence (M&A, Investment & Product)

The dominant trailing-12-month commercial event tied to Virginia is Capital One Financial Corp's completed $35.3 billion acquisition of Discover Financial Services, a disclosed-value deal forming the largest US credit-card issuer and the nation's sixth-largest bank. Post-merger integration continued into 2026 with further workforce reductions: Capital One laid off 1,139 workers at Discover's former Riverwoods headquarters in early March 2026, on top of roughly 600 in late 2025.

No periodic updates recorded against this sub-brief.

Sources and findings (2)
  1. T3https://virginiabusiness.com/35b-capital-one-discover-merger/
  2. T4https://finance.yahoo.com/news/editorial-discover-takeover-capital-one-110000922.html
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Editorial metadata for United States – Virginia
FieldValue
trust.lawyer_review.statusnever_reviewed
trust.lawyer_review.reviewernot recorded
trust.content_sourceai_generated

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