Advisory Guidance on Domain Naming for Authorized Agents Operating Under Us Money Transmitter Licenses in Online Businesses

Comprehensive Shifts in the Sponsorship Dynamics of Money Services Businesses (MSBs) in the U.S. Traditional Models and the Inception of Regulatory Revisions Historically, the establishment and operation of money services businesses in the United States allowed for a relatively straightforward model for agents to function under established entities. Take, for instance, a licensed entity named “Acme Money Transfer”, which could smoothly run its operations using a dedicated domain, such as “acmemoneytransfer.com”. New entrants (i.e. authorized agents of Acme), like an illustrative agent named Peter, had the capacity to form their own platforms, for example, “petermoneytransfer.com”, while being formally affiliated with Acme, providing services with pertinent disclaimers highlighting Acme’s provision. However, the waters have been stirred by a tangible regulatory change emanating initially from California, fundamentally altering the permissible domain structures for agents. ...