Texas Banking Commissioner Charles G. Cooper imposed consent orders on two cryptocurrency companies in September 2026 for unlicensed money transmission involving stablecoins. The firms, OKX, Inc. and Triple A Technologies Pte Ltd., were found to have carried out money transmission activities in Texas without a license required under the Texas Finance Code.
On Sept. 11, the Commissioner entered a consent order against OKX, formerly known as OkCoin USA, Inc., assessing a $95,000 monetary penalty. On Sept. 23, a consent order was entered against Triple A, assessing a $20,000 penalty.
Unlicensed Money Transmission Activities
According to the Commissioner, both companies engaged in the receipt and transmission of stablecoins without a money transmission license. Triple A allegedly processed payments that allowed its merchant partners to accept and send stablecoins and other non-convertible cryptocurrencies.
The firms resolved the matters without admitting or denying the Commissioner’s factual findings or any violation of law.
Details of the Allegations
OKX, a Delaware corporation based in San Jose, California, operates a cryptocurrency trading and third-party exchange services platform. The Commissioner found that, between 2018 and 2024, OKX received sovereign currency and stablecoins for transmission from Texas customers and provided custody services for digital assets and stablecoins.
The consent order tracks changes in Texas law during the relevant period. Until Sept. 1, 2023, money transmission was regulated under Chapter 151 of the Texas Finance Code, which prohibited engaging in the business of money transmission without a license.
Effective Sept. 1, 2023, the Money Services Modernization Act (MSMA) changed the definition of money transmission.
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Applying both the former and current statutes, the Department concluded that OKX conducted money transmission in Texas without a license or exemption. As of the consent order’s effective date, OKX’s application for a money transmission license was pending.
OKX must refrain from conducting money transmission in Texas unless licensed. The order does not prohibit OKX from obtaining a license in the future but allows the Department to pursue enforcement for other unknown violations.
Triple A, a Singapore-based payment processing company, faced similar allegations. The Commissioner found that Triple A provided services allowing merchants to accept and send stablecoins and other non-convertible cryptocurrencies.
A license application by Triple A’s subsidiary was accepted in October 2025.
The order does not prevent its subsidiary from operating while licensed.
Federal and State Regulatory Overlap
The GENIUS Act, enacted in 2025, introduces federal oversight for stablecoin issuers but does not preempt state money transmission requirements. Companies like OKX and Triple A, which act as exchanges, custodians, or payment processors, may remain subject to state licensing rules. This dual regulatory framework requires careful monitoring of both federal and state developments.
Factors Influencing Enforcement Outcomes
The Commissioner’s decisions in these cases considered multiple factors, including the seriousness of violations, compliance history, and good-faith efforts to comply. Both OKX and Triple A faced penalties despite pending license applications, indicating that prior unlicensed activity can still result in enforcement actions. The Commissioner also weighed transaction volume, the duration of unlicensed operations, and other company-specific factors.
