Brokers & OTC Desks
Crypto Broker & OTC Desk Licensing
Brokers and OTC desks that buy and sell digital assets for clients or route customer funds are usually money transmitters, and activity touching securities or commodities can add federal registration. We scope the full picture and file what applies.
- All 50 states
- Specialist support
- Human review on every filing
Talk to an expert
Tell us about your situation and we will follow up within one business day.
Brokers & OTC Desks
Do crypto brokers and OTC desks need a license?
Generally yes. When you buy and sell crypto on behalf of clients, or route customer funds to settle trades, you are usually a money transmitter in the states where your clients are located, so a broker or over-the-counter desk needs a money transmitter license in each of those states. The assets you trade can add a second layer: activity that touches securities or commodities can require federal registration on top of state money transmission licensing. Brokers and OTC desks also register with FinCEN as a money services business, so the right plan separates the state licensing question from any federal exposure before you file.
- Do I Need Federal Registration as Well as State Licenses?
- Possibly. If the assets you trade implicate securities or commodities rules, federal registration can apply on top of state money transmission licensing. We analyze your specific assets and coordinate the state and federal tracks.
- What Determines How Many States I File In?
- It comes down to where customer funds pass through your desk and where your clients are located. We trace the settlement flow before filing so your licensing footprint matches your actual model.
The Cornerstone Way
A repeatable method, from first filing to every renewal
Faster licenses, less effort on your side, fewer mistakes, and fewer headaches. It is the way we combine experienced specialists, intentional AI, and the Atlas platform across one sequenced process.
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Discover
We connect you with independent attorneys to pin down which licenses you need.
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Prepare
Your licensing specialist assembles each application; our software handles the repetitive work.
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Review
That same specialist reviews every filing before it reaches a regulator.
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Approve
We submit, track each application, and keep you posted until the license is granted.
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Renew
We file every renewal ahead of its deadline in Atlas so licenses stay current.
Anyone can list five steps. Here is what makes ours hold up.
The shortcut
The common approach is to scrape the web for an answer and hope it is current. When the rules change, or the page was wrong to begin with, the mistake surfaces as a deficiency after the filing is in, when it costs the most time.
The Cornerstone Way
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Specialists who know the answer
Decades of licensing specialists, so the answer is right rather than guessed.
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Trusted relationships with the regulator
Direct, trusted relationships with regulators, so we ask the question instead of assuming the answer.
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Living internal checklists
Checklists that update the moment we learn something new, so deficiencies are caught before they happen.
Licensing a Crypto Broker or OTC Desk
Brokers and over-the-counter desks occupy a tricky spot in digital asset regulation. When you buy and sell crypto on behalf of clients, or route customer funds to settle trades, you are generally a money transmitter in the states where your clients are located. At the same time, the assets you trade can matter: activity that touches securities or commodities can add a layer of federal registration on top of state money transmission licensing. The right plan starts by separating those questions, mapping the states that apply, and identifying any federal exposure before you file. Cornerstone scopes both the state and federal picture so your desk launches on solid ground.
When a Broker or Desk Is a Money Transmitter
The key question for a broker or OTC desk is whether customer funds or assets pass through your hands. A desk that takes client dollars, sources the crypto, and settles the trade is moving money on behalf of others, which is money transmission in most states. A pure introducing model that never touches funds has a different profile.
We trace the settlement flow trade by trade so the facts are clear, and an independent licensing attorney confirms where custody and transmission occur and which states require a license. That work comes before any filing so your licensing footprint matches your actual settlement model.
What Regulators Expect From a Broker or Desk
Broker and OTC licensing combines money transmission requirements with attention to settlement flow and any securities or commodities exposure.
Money Transmitter Licenses
Licenses in the states where your clients are located when customer funds or assets pass through your desk during settlement.
Settlement and Custody Analysis
A clear map of how trades are settled and whether the desk takes custody, which determines the licensing footprint.
Securities and Commodities Coordination
Analysis of whether the assets you trade implicate federal securities or commodities registration on top of state licensing.
AML and Customer Identification
A FinCEN money services business registration and an AML program with customer identification and transaction monitoring.
Renewal and Filing Calendar
Ongoing management of renewals and reports so the desk stays in good standing in every state.
Coordinating State Licensing With Federal Exposure
For brokers and desks, the assets traded can be as important as the funds moved. Some digital assets raise securities or commodities questions that bring federal registration into the picture, and that analysis has to run alongside the state money transmission plan rather than after it.
We help identify where federal exposure exists, coordinate with your securities or commodities counsel, and keep the state filings consistent with the federal posture so the two tracks do not work against each other. The goal is one coherent compliance plan covering both the funds you move and the assets you trade.
Keeping a Broker or Desk Licensed
Once licensed, a desk has the same ongoing obligations as other money transmitters: renewals, periodic reports, updated policies when the settlement model changes, and notice of material changes or a change of control. Bond and net worth requirements can move over time.
Cornerstone manages those obligations for you. We track renewal deadlines, file change notices, manage bond riders, and keep your AML program current, with every license and due date visible in Atlas.
Checklist
Crypto Broker & OTC Desk Licensing checklist
Settlement Mapping
We trace how your desk settles trades to help assess where custody and transmission occur and which states require a license, with an independent licensing attorney confirming it.
Federal Exposure Review
We analyze whether the assets you trade implicate securities or commodities registration and coordinate with your counsel.
License Applications
We prepare and file money transmitter applications in the states your settlement model requires.
AML Program Build
We help build your FinCEN registration and AML program with customer identification and transaction monitoring.
Ongoing Filings
After approval we manage renewals, change notices, bond riders, and reports across every state.
FAQ
Frequently Asked Questions
Ready for licensing the Cornerstone way?
Anyone can file paperwork and hand you a license. Licensing the Cornerstone way is the same outcome done right: fewer deficiencies, a faster path to approval, less work on your plate, and renewals that stay managed long after you go live.
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100%
accepted by the second submission
Right the First Time
We prepare and file it correctly the first time, so most applications are accepted on the first submission instead of bouncing back with correction notices. The few that need a second pass are accepted then, with no avoidable back and forth.
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25 to 30x
faster than doing it yourself
Faster to Licensed
Start applications for 12 to 15 states on your own and it crawls. Hand those same states to a Cornerstone Licensing Specialist and they get you licensed 25 to 30 times faster, pursuing every state at once and knowing what each examiner expects.
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97-98.5%
of the work handled for you
Less Work for You
You answer questions once, then Cornerstone generates and files the license. Your part is the few minutes it takes to confirm the details.
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99.995%
on-time submissions in 2025
Renewals That Stay Managed
Every license, bond, and renewal date lives in Atlas and is tracked for you, so nothing lapses once you are approved.
Ready to Apply?
Start Your Application Now
Save and resume from any step. An expert reviews every submission within one business day.
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Stay Ahead of the Rules
Recent rule changes, deadline announcements, and state agency updates we are tracking for you.
No regulatory updates to report right now. Our team is monitoring the agencies and will surface changes here as soon as they land.
License Your Broker or OTC Desk
Contact us to scope your desk's licensing. We will help map where a money transmitter license typically applies and flag any federal securities or commodities exposure for your counsel.