The update establishes certification and licensing procedures for US money transmitter licensees under Nebraska state law, directly addressing money transmitter regulatory compliance and oversight.
Low confidence — requires human review. While the update involves enforcement-adjacent licensing procedures, it is primarily a prospective compliance requirement rather than an enforcement action against a specific entity.
Specialism
The Nebraska Department of Banking and Finance is establishing certification procedures to verify that money transmitter licensees and applicants are not controlled by foreign adversaries, which constitutes a supervisory control mechanism and licensing requirement for payment firms.
The order explicitly threatens license revocation for non-compliance within 60 days, making enforcement action a secondary consideration, though the primary focus is supervisory certification rather than a specific enforcement action already taken.
2026-07-31 16:07:32·pdonofrio@vixio.com
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TITLE: Nebraska Department of Banking and Finance Adopts Certification Procedures for Money Transmitter Foreign Adversary Control
BODY:
On July 30, 2026, the Nebraska Department of Banking and Finance (Department) issued an order adopting certification procedures for money transmitter licensees and applicants regarding foreign adversary control, pursuant to amendments to the Nebraska Money Transmitters Act (Neb. Rev. Stat. §§ 8-2701 to 8-2754).
The order establishes requirements under Neb. Rev. Stat. § 8-2750 and § 8-2751, which require applicants, licensees, key individuals, and persons in control to demonstrate they are not foreign adversary persons as defined in the Act. The Department presumes that failure to establish non-foreign adversary status indicates character and fitness concerns that would not serve the public interest in permitting money transmission services in Nebraska. The Department has developed a Certification Form to request information sufficient to demonstrate compliance with these provisions. Existing money transmitter licensees must complete the Certification Form within 60 days of receipt from the Department and upload the completed form into their Nationwide Multistate Licensing System (NMLS) record. Applicants with pending money transmitter license applications must complete and upload the Certification Form into their NMLS record before the Department will conduct a full licensing review. Licensees failing to provide requested information within 60 days or those the Department reasonably suspects are foreign adversary persons may face license revocation proceedings.
The order remains in effect until subsequently modified or vacated by the Director. Existing licensees should anticipate receiving the Certification Form from the Department and ensure timely completion and submission to maintain compliance with Nebraska money transmitter regulations.
Docusign Envelope ID: E5E80D39-4291-86D5-835F-CC1DAA55C5A5 S T A T E O F N E B R A S K A Department of Banking & Finance IN THE MATTER OF: ) ORDER ADOPTING CERTIFICATION ) PROCEDURES FOR MONEY Foreign Adversary Certification ) TRANSMITTER LICENSEES AND ) APPLICANTS REGARDING ) FOREIGN ADVERSARY CONTROL THIS MATTER comes before the Nebraska Department of Banking and Finance (“Department”), by and through its Director, pursuant to its authority under the Nebraska Money Transmitters Act, Neb. Rev. Stat. §§ 8-2701 to 8-2754 (Cum. Supp. 2024; Supp. 2025; LB 717, 2026; LB 838, 2026) (the “Act”); l. Neb. Rev. Stat. § 8-2750(1)(a) (LB 838, 2026) provides that if an applicant or any key individual or person in control of the applicant fails to establish that such applicant, key individual, or person in control is not a foreign adversary person, as defined in the Act, the Director shall presume that the character and general fitness of such persons indicate that it is not in the interest of the public to permit the applicant to engage in money transmission. 2. Neb. Rev. Stat. § 8-2750(1)(c) (LB 838, 2026) provides that if a licensee or authorized delegate or any key individual or persons in control of a licensee or responsible person in control of the authorized delegate fails to establish that such licensee, authorized delegate, key individual, or person in control is not a foreign adversary person, as defined in the Act, the Director shall presume that the character and general fitness of such persons indicate that it is not in the interest of the public to permit such persons to provide money transmission services in Nebraska. Docusign Envelope ID: E5E80D39-4291-86D5-835F-CC1DAA55C5A5 3. Neb. Rev. Stat. § 8-2751 LB 838, 2026) provides that the Director shall send a written request to each licensee and applicant that requests supplemental information necessary for the Director to investigate and determine compliance with Section 8-2750 and its related provisions. 4. Neb. Rev. Stat. § 8-2751 further provides that for any licensee that fails to provide such requested information within sixty days after receipt of such request or that the Director has reasonable suspicion to believe is a foreign adversary person or has any key individual or person in control that is a foreign adversary person, the Director shall institute proceedings to revoke such licensee’s Money Transmitter license. 5. Neb. Rev. Stat. § 8-2751 requires the Director to prescribe forms and instructions and to issue an order governing applications under the Act to require information sufficient to show that the applicant is not a foreign adversary person. IT IS THEREFORE ORDERED as follows: 1. The Department has developed a Certification Form for use in requesting information sufficient to demonstrate that a licensee, applicant, and any related key individuals or persons in control are not foreign adversary persons. Such form is available on the Department’s website or will be made available upon request. Such form may be updated from time to time by the Department. 2. Existing Money Transmitter licensees are required to complete this Certification Form within sixty (60) days of receipt from the Department, and to upload such completed form into the licensee’s Nationwide Multistate Licensing System (“NMLS”) record. 3. Applicants with a pending Money Transmitter License application are required to complete this Certification Form and to upload such completed form into the applicant’s NMLS record before such pending application will be reviewed in full for a licensing determination. 2 Docusign Envelope ID: E5E80D39-4291-86D5-835F-CC1DAA55C5A5 4. This Order shall remain in effect until subsequently modified or vacated by Order of the Director. 5. The effective date of this Order shall be the date of the Director’s signature. 30th DATED this ___ day of July, 2026. STATE OF NEBRASKA DEPARTMENT OF BANKING AND FINANCE By: ______________________________________ Kelly Lammers, Director 1526 K St., Suite 300 Lincoln, Nebraska 68508 (402) 471-2171 3