Fordham Law Review Online

The Video Game Industry’s Money Laundering Problem: When Do Game Publishers Become Money Transmitters?

May 1, 2023

In recent years, video game developers have created highly immersive games that feature virtual currencies and items, and players are assigning significant values to them. At the same time, criminals are exploiting these game features to launder money online. The increasing prevalence of this threat raises important questions about game publishers’ legal duties in the United States anti-money laundering (AML) framework. Financial institutions, including money transmitters, are subject to an extensive array of AML compliance requirements. This Essay analyzes the specific game features and publisher policies that are critical to determining whether a game publisher constitutes a money transmitter under current regulations.