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The Law Offices of Alan Abergel, P.C. (“LOAA”) represents fintech companies, money services businesses (MSBs), and financial services firms in Texas and nationwide in money transmitter licensing, regulatory compliance, and enforcement matters.
Attorney Alan Abergel is licensed by both the State Bar of Texas and the State Bar of California. LOAA also provides California money transmitter licensing and compliance services.
Under Chapter 151 of the Texas Finance Code, a person or business must obtain a license to engage in money services business activities in Texas.
Texas recognizes two primary Money Services Business license types:
Money Transmission License
Currency Exchange License
A Money Transmission License is required to engage in activities such as:
Receiving money for transmission
Issuing or selling prepaid access, money orders, checks, or traveler’s checks
Third-party bill payment services
Currency transportation
Currency exchange (if combined with other MSB activities)
A Currency Exchange License is required if the business engages solely in currency exchange.
The Texas Department of Banking regulates money services businesses under the Texas Money Services Act and related administrative rules in Title 7, Chapter 33 of the Texas Administrative Code.
Regulated money services activities include:
Currency exchange
Money transmission (in-person and online)
Currency transportation
Money orders
Traveler’s checks
Third-party bill payment services
Open-loop gift cards
Stored value products (not issued by insured financial institutions)
Texas licensing requirements apply even if the business has no physical presence in Texas but offers services to Texas customers.
LOAA provides legal services to money transmission businesses and fintech companies, including:
Assistance in obtaining a Texas money transmitter license
Assistance in obtaining a Texas currency exchange license
Legal opinions on whether a money transmitter license is required for a specific business model
Advice on Texas and federal money transmission laws and regulations
Representation in acquisition-of-control filings
FinCEN MSB registration and required regulatory filings
Corporate formation (corporations and LLCs) and governance documentation
Drafting and revising money transmission agreements, disclosures, and terms of service
Drafting AML/BSA compliance policies and OFAC policies
Mergers and acquisitions of money transmission businesses
Legal compliance and licensing for Bitcoin and virtual currency businesses
Securities law compliance counseling for money transmitters raising capital
Financial Crimes Enforcement Network (FinCEN) enforcement defense
Assistance with money transmitter licenses applications in all 50 U.S. states
LOAA advises fintech companies, digital wallet providers, and virtual currency businesses on licensing and compliance issues involving:
Bitcoin and virtual currency transmission
Stored value and prepaid products
Digital wallets and payment platforms
Nationwide state money transmitter licensing strategies
The firm assists companies in structuring business models to comply with state and federal MSB regulatory frameworks.
Money transmission businesses must maintain robust compliance programs. LOAA assists with:
AML and BSA compliance programs
OFAC sanctions compliance
Customer identification and KYC policies
Regulatory disclosures and consumer agreements
Multi-state licensing and compliance strategy
LOAA represents money services businesses in:
Texas Department of Banking investigations and enforcement actions
Administrative proceedings and licensing disputes
Regulatory audits and compliance examinations
The firm advises clients on regulatory response strategies and risk mitigation in enforcement matters.
LOAA provides transactional, compliance, administrative, and civil regulatory defense services to money transmission businesses.
No criminal defense services are provided.
“I engaged Alan to help me through the complexities of obtaining my Lenders License. He was very knowledgeable about the process and provided me with a high level of service. I worked quickly getting him all the information needed and he worked at my pace. He was responsive to e-mails and questions and followed up with the DFPI to make sure everything was filed correctly. I had read online that this process could take as long as 6 months however Alan completed the assignment in less than 3 I will be retaining his services in the future to ensure my company remains in compliance."
--Petroleum Realty Group Inc.
"I hired Alan to represent me as a mortgage broker before the California Department of Real Estate. I couldn't be more pleased with Alan's services from start to finish. Alan was clear and concise. Alan's communication throughout the process was professional. I received the results I hoped for. Thank you Alan. I'll definitely recommend you to ALL and use your services again in the future shall I need anything!"
-Anonymous
"Very helpful in assisting in obtaining an OCCC Texas Motor Vehicle Sales Finance License. Very knowledgeable in answering all questions the OCCC asked for on their questionnaire. Highly recommended and would re-hire for any future assistance regarding motor vehicle and finance business. God Bless!"
-Raul
