Relating to the operations of the Financial Crimes Intelligence Center.
ModeratePlan for compliance
Low Cost
Effective:2025-09-01
Enforcing Agencies
Texas Department of Licensing and Regulation (TDLR) • Financial Crimes Intelligence Center (FCIC)
01
Compliance Analysis
Key implementation requirements and action items for compliance with this legislation
Implementation Timeline
Effective Date: September 1, 2025
Compliance Deadline: September 1, 2025 (Definitions apply immediately; internal reporting protocols must be active).
Agency Rulemaking: The Texas Commission of Licensing and Regulation (TCLR) is mandated to adopt rules "as soon as practicable" after the effective date.
*Regulatory Gray Zone:* Between Sept 1, 2025, and final rule adoption, the specific definition of "other acts" constituting payment fraud will remain undefined.
Immediate Action Plan
Update IRPs: Revise corporate fraud reporting protocols to include check and wire fraud submissions to the FCIC starting Q3 2025.
Review Insurance: Consult with your broker to determine if participation in the FCIC intelligence network qualifies your organization for reduced premiums on Crime/Cyber liability policies.
Monitor Rulemaking: Assign counsel to track TCLR dockets post-September 2025 to comment on the definition of "other acts" of payment fraud.
Prepare Grant Strategy: If you are a fuel retailer or high-risk merchant, prepare a needs assessment for security equipment to be ready when grant applications open in 2026.
Operational Changes Required
Contracts
Data Sharing Agreements: If your organization intends to share proprietary fraud data with the FCIC, review agreements immediately. Under Sec. 426.053(c), shared data becomes the "intellectual property of the center." You must carve out protections for customer PII before transmission.
Grant Agreements: Entities applying for fraud deterrence grants (Sec. 426.102) must prepare for strict state contracting requirements regarding equipment procurement and audit rights.
Vendor Service Level Agreements (SLAs): Update contracts with security vendors to require monitoring of and patching against threats identified in FCIC intelligence alerts.
Hiring/Training
Fraud Team Retraining: Front-line staff (tellers, store managers) and security personnel must be retrained on the expanded statutory definition of "Payment Fraud." They must know how to preserve evidence for check and wire fraud, not just physical skimmers.
Liaison Designation: You must appoint a specific Compliance or Security Officer to serve as the intake point for FCIC intelligence alerts to ensure they are not lost in general inboxes.
Reporting & Record-Keeping
Incident Response Plans (IRP): Update your IRPs. Current protocols likely route skimmer data to TDLR/FCIC; you must now integrate workflows to report check fraud and unauthorized wire transfers to the FCIC.
Grant Auditing: If state funds are used for security upgrades, maintain a segregated ledger for these expenditures to survive a TDLR audit.
Fees & Costs
No New State Fees: The bill does not impose new licensing fees.
Operational Costs: Expect minor administrative costs associated with updating reporting software and personnel training.
Funding Opportunity: The bill authorizes grants to local law enforcement and "other partners" (potentially businesses) for fraud deterrence, contingent on legislative appropriation.
Strategic Ambiguities & Considerations
The "Catch-All" Definition: Sec. 426.001(4-b)(D) allows the Commission to define "any other act" as payment fraud via rulemaking.
*Risk:* The agency could unilaterally expand reporting requirements to include cryptocurrency disputes or P2P (Zelle/Venmo) fraud without further legislative input.
"Sensitive" Information: The FCIC may withhold information deemed "sensitive." The statute lacks criteria for this classification, creating a risk that businesses provide data to the state but receive no actionable intelligence in return.
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Information presented is for general knowledge only and is provided without warranty, express or implied. Consult qualified government affairs professionals and legal counsel before making compliance decisions.
The Financial Crimes Intelligence Center (FCIC) was established in 2021 to combat the growing issue of card skimming, particularly at motor fuel devices (gas pumps). As financial crimes have surged in recent years, the FCIC's role has expanded significantly beyond its original purpose. The current statutory framework limits the FCIC's scope to card skimming, creating a need for legislative action to support its broader efforts in fighting financial and organized crime.
S.B. 1499 expands the statutory mission of the FCIC to include payment fraud, ensuring the center can continue its work against a broader range of financial crimes. The bill reflects the FCIC's increasing role in tackling various forms of payment fraud�including check fraud, unauthorized electronic fund transfers, and other fraudulent payment schemes.
As proposed, S.B. 1499 amends current law relating to the operations of the Financial Crimes Intelligence Center.
RULEMAKING AUTHORITY
Rulemaking authority previously granted to the Texas Commission of Licensing and Regulation is modified in SECTION 1 (Section 426.002, Occupations Code) of this bill.
SECTION BY SECTION ANALYSIS
SECTION 1. Transfers Chapter 2312, Occupations Code, to Subtitle B, Title 4, Government Code, redesignates it as Chapter 426, Government Code, and amends it, as follows:
CHAPTER 426. FINANCIAL CRIMES INTELLIGENCE CENTER
SUBCHAPTER A. GENERAL PROVISIONS
Sec. 426.001. DEFINITIONS. Redesignates existing Section 2312.001 as Section 426.001. Defines "check fraud," "electronic fund transfer," "payment fraud," and "unauthorized payment order."
Sec. 426.002. RULES. Redesignates existing Section 2312.002 as Section 426.002 and makes no further changes..
SUBCHAPTER B. PURPOSE AND ADMINISTRATION
Sec. 426.051. FINANCIAL CRIMES INTELLIGENCE CENTER ESTABLISHED. Redesignates existing Section 2312.051 as Section 426.051 and makes no further changes.
Sec. 426.052. PURPOSES OF CENTER. Redesignates existing Section 2312.052 as Section 426.052. Provides that the purposes of the financial crimes intelligence center established under this chapter (center) include to serve as the state's primary entity for the planning, coordination, and integration of law enforcement agencies and other governmental agencies that respond to criminal activity related to payment fraud, rather than card fraud, including through the use of skimmers. Makes a conforming change.
Sec. 426.053. New heading: OPERATION AGREEMENTS AUTHORIZED; DIRECTOR. Redesignates existing Section 2312.053 as Section 426.053. (a) Provides that the Texas Department of Licensing and Regulation (TDLR) is required to enter into an agreement with a law enforcement agency or other governmental agency for the appointment of a director, rather than a chief intelligence coordinator, to supervise and manage the operation of the center.
(b) Makes conforming changes to this subsection.
(c) Makes no changes to this subsection.
Sec. 426.054. POWERS AND DUTIES. Redesignates existing Section 2312.054 as Section 426.054. (a) Makes no changes to this subsection.
(b) Requires the center to assist law enforcement agencies, other governmental agencies, financial institutions, credit card issuers, debit card issuers, payment card networks, institutions of higher education, and merchants in their efforts to develop and implement strategies to take certain measures, including to prevent and respond to payment fraud. Deletes existing text requiring the center to assist certain entities in their efforts to develop and implement strategies to prevent card fraud. Makes nonsubstantive changes.
(c) Makes a conforming change to this subsection.
(d) Makes no changes to this subsection.
Sec. 426.055. ANNUAL REPORT. Redesignates existing Section 2312.055 as Section 426.055. Makes conforming changes.
SUBCHAPTER C. FINANCIAL PROVISIONS
Sec. 426.101. FUNDING. Redesignates existing Section 2312.101 as Section 426.101. Authorizes TDLR to solicit and accept gifts, grants, and other donations to fund, administer, and carry out the purposes of the center, except that TDLR is prohibited from soliciting or accepting a gift, grant, or other donation from a license holder as defined by Section 2310.151 (Definitions), Occupations Code.
Sec. 426.102. AWARD OF GRANTS. Redesignates existing Section 2312.102 as Section 426.102. Authorizes a grant recipient to use grant money for certain purposes, including to provide training opportunities regarding payment fraud and skimmers. Makes conforming changes.
SECTION 2. Requires TCLR, as soon as practicable after the effective date of this Act, to adopt rules necessary to implement the changes in law made by this Act to Chapter 426, Government Code, as transferred, redesignated, and amended by this Act.
SB1499 significantly expands the jurisdiction of the Financial Crimes Intelligence Center (FCIC) beyond credit card skimmers to cover "Payment Fraud" broadly, including check fraud, wire fraud, and unauthorized electronic fund transfers. Effective September 1, 2025, financial institutions, fuel retailers, and merchants must prepare to interface with this centralized state intelligence hub for both mandatory investigations and potential grant funding opportunities. Implementation Timeline Effective Date: September 1, 2025 Compliance Deadline: September 1, 2025 (Definitions apply immediately; internal reporting protocols must be active).
Q
Who authored SB1499?
SB1499 was authored by Texas Senator Robert Nichols during the Regular Session.
Q
When was SB1499 signed into law?
SB1499 was signed into law by Governor Greg Abbott on May 13, 2025.
Q
Which agencies enforce SB1499?
SB1499 is enforced by Texas Department of Licensing and Regulation (TDLR) and Financial Crimes Intelligence Center (FCIC).
Q
How urgent is compliance with SB1499?
The compliance urgency for SB1499 is rated as "moderate". Businesses and organizations should review the requirements and timeline to ensure timely compliance.
Q
What is the cost impact of SB1499?
The cost impact of SB1499 is estimated as "low". This may vary based on industry and implementation requirements.
Q
What topics does SB1499 address?
SB1499 addresses topics including crimes, crimes--against property, crimes--miscellaneous, financial and financial--general.
Legislative data provided by LegiScanLast updated: November 25, 2025
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