# Crypto Broker & OTC Desk Licensing ## 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. 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. ## 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. ## 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. ## How to get licensed 1. **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. 2. **Federal Exposure Review**, We analyze whether the assets you trade implicate securities or commodities registration and coordinate with your counsel. 3. **License Applications**, We prepare and file money transmitter applications in the states your settlement model requires. 4. **AML Program Build**, We help build your FinCEN registration and AML program with customer identification and transaction monitoring. 5. **Ongoing Filings**, After approval we manage renewals, change notices, bond riders, and reports across every state. ## Frequently asked questions ### Do Crypto Brokers and OTC Desks Need a License? Brokers and OTC desks that buy and sell digital assets for clients, or route customer funds during settlement, are generally money transmitters and need licenses in the states where their clients are located. A pure introducing model that never touches funds has a different profile. ### 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. ### Do OTC Desks Register With FinCEN? Desks that hold or transfer customer funds generally qualify as a money services business and must register with FinCEN, usually within 180 days of starting activity, alongside an AML and customer identification program. ### How Long Does Broker Licensing Take? Standard money transmitter approvals commonly run 3 to 12 months per state. Any federal securities or commodities steps run on their own timeline. We sequence the filings so the desk can begin where it is approved while other reviews continue.