Arkansas Uniform Money Services Act Virtual Currency Amendments

Act 532 added a definition of “virtual currency” as a digital representation of value used as a medium of exchange, unit of account, or store of value, and not recognized as legal tender by the U.S. Treasury. The definition excludes software, protocols, and certain distributed-ledger verification uses when the virtual currency is not used as a medium of exchange.

The act amended “money transmission” to include receiving money, virtual currency, or monetary value for transmission. It also added exclusions for limited merchant or rewards value, game-platform value, and certain ledger-authentication uses. The result is a perimeter update: the law does not create a standalone crypto charter, but it integrates virtual-currency transmission into Arkansas’s money services regime.

Act 532 also updated licensing review provisions. Applicants must provide information about responsible individuals and disciplinary, litigation, bankruptcy, and receivership history. Officers, directors, responsible individuals, and owner applicants may be subject to identity information and criminal-background checks, and the act bars specified covered persons from appearing on OFAC sanctions and Executive Order 13224-related lists. Quarterly reporting provisions were amended to include virtual currency sold in Arkansas and virtual currency currently outstanding.

The recordkeeping provision was amended to require five-year records for compliance review, including records of virtual-currency obligations sold or paid. The act added written physical security and cybersecurity policy requirements for money transmitters and currency exchangers that are licensed or required to be licensed under the chapter. It also created a virtual-currency-specific permissible-investment rule: a licensee transmitting virtual currency must hold like-kind virtual currency of the same volume as the amount obligated to consumers, in lieu of ordinary permissible investments for that obligation.

Act 532 applies at the Arkansas state level and is administered through the Arkansas Securities Commissioner and the Arkansas Securities Department. The Department’s public money-services page states that a Money Transmitter License is required for persons engaging in money transmission activity in Arkansas and describes that activity as including receiving money, virtual currency, or monetary value for transmission. The current compiled Money Services Act, effective August 5, 2025, retains a virtual-currency definition and a like-kind virtual-currency holding rule while reflecting later amendments.

• January 19, 2021: SB 150 was filed in the Arkansas Senate.
• March 3, 2021: The Senate passed the bill and transmitted it to the House.
• March 29, 2021: The House passed the bill and returned it to the Senate.
• April 1, 2021: Act 532 was approved.
• July 28, 2021: Effective date inferred for 2021 Arkansas acts without an emergency clause or specified effective date, subject to editor verification against Attorney General Opinion No. 2021-029.

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