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Digital Asset Compliance

KYC Verification for Crypto Businesses

Every licensed crypto business runs know-your-customer verification, because regulators require it before they grant the license. This guide covers what a compliant crypto KYC program contains, and how state and federal reviewers test it.

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Reviewed by Cornerstone Staff28 years of financial services state licensing experienceLast verified August 6, 2026

Digital Asset Compliance

What KYC verification is required for a crypto business?

A US crypto business that holds or transmits customer assets is generally required to run a risk-based anti-money-laundering program under FinCEN's money services business rules, and that program is expected to include policies and procedures for verifying customer identification to the extent reasonable and practicable for the business's risk. Unlike banks, MSBs are generally not subject to the formal bank Customer Identification Program rule, but specific obligations still drive identity verification in practice: Bank Secrecy Act recordkeeping rules require verified identity for covered transmittals, OFAC screening requires knowing who the customer is, New York's BitLicense regulations spell out customer identification requirements, and state licensing regulators review the written KYC procedures in every money transmitter application. The result is that licensed platforms verify essentially all customers, with name, date of birth, address, and an identification number as the standard baseline.

Is KYC Legally Required for Crypto Exchanges?
Generally yes, for US exchanges. As money services businesses, exchanges are typically required to run risk-based anti-money-laundering programs under FinCEN rules that include reasonable customer identification procedures, and recordkeeping rules, sanctions screening, state licensing reviews, and New York's BitLicense regulations each add verification obligations of their own. MSBs are generally not under the formal bank CIP rule, but as a practical matter licensed custodial exchanges run identity verification. We recommend confirming how these rules apply to your model with a Cornerstone expert or your attorney.
What Information Does Crypto KYC Collect?
The standard baseline is name, date of birth, address, and an identification number such as an SSN or passport number, verified against documents or databases at onboarding. The exact scope is set by the business's risk assessment and the regimes it is licensed under; higher-risk customers face enhanced due diligence, including source-of-funds documentation.

Money transmitter licensing by the numbers

US jurisdictions require a money transmitter license
51 of 52 US jurisdictions require a money transmitter license Source: state regulator statutes compiled in our state-law index, verified August 2026. Money transmitter license state laws
statutory surety bond range across licensing states
$10,000 to $1,000,000 statutory surety bond range across licensing states Source: state regulator statutes compiled in our state-law index, verified August 2026. Money transmitter license state laws

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KYC as a Licensing Requirement, Not a Feature

Know your customer, KYC, is the identity-verification half of the Bank Secrecy Act program every US money services business must run. For a crypto exchange, wallet, or payment platform, the federal requirement is a risk-based one: FinCEN's MSB rules require an AML program with identity-verification procedures reasonable and practicable for the business's risk, and recordkeeping rules, sanctions screening, state money transmitter reviews, and New York's BitLicense regulations layer verification obligations on top. Every state application and BitLicense review examines the written procedures before approving the license. Cornerstone builds these programs as part of licensing engagements, which is the lens of this guide: what the requirements are, what regulators actually check, and how KYC fits into getting and keeping licenses.

What a Compliant Crypto KYC Program Contains

Programs vary with risk profile, but regulators expect the same core elements everywhere.

Identity Verification Procedures

Written, risk-based procedures for verifying customer identity, in practice collecting name, date of birth, address, and an identification number at onboarding, verified through documentary means (government ID) or non-documentary means (database checks, document liveness). The industry borrows the CIP label from banking, but for an MSB the federal requirement is the risk-based program, with prescriptive detail coming from state and NYDFS review.

Sanctions and PEP Screening

Screen every customer against OFAC sanctions lists at onboarding and on an ongoing basis, plus politically-exposed-person screening where risk warrants. Blocked matches must be blocked or rejected and reported.

Risk-Based Customer Due Diligence

Risk-rate customers and apply enhanced due diligence, source-of-funds and source-of-wealth checks, at documented thresholds. High-risk jurisdictions, high volumes, and institutional accounts all trigger deeper review.

Wallet Screening and Blockchain Analytics

The crypto-specific layer: screen deposit and withdrawal addresses against known illicit clusters, mixers, and sanctioned protocols using blockchain analytics tooling. Examiners increasingly ask to see the live integration, not the vendor contract.

Ongoing Monitoring and Refresh

KYC is not one-time. Programs re-verify on risk triggers, keep records for five years, and feed unusual activity into the suspicious activity reporting workflow covered by the AML program.

How Licensing Reviews Test Your KYC

State reviewers read the written program at application time and probe it in deficiency letters: who verifies, with what tools, at what thresholds, and who owns exceptions. New York's BitLicense review goes deeper, examining the program against Part 200's specific requirements and the department's transaction monitoring guidance.

After licensure, examinations sample real files. The findings that recur are predictable: onboarding flows that skip verification for referred customers, screening lists that are not refreshed, thresholds in the policy that the platform does not actually enforce, and no documented exception handling. A program that matches its own paper is most of the battle.

The importance of KYC and AML for crypto exchanges is ultimately commercial as well as legal: banking partners run their own diligence on your program, and a weak one costs you accounts even where regulators have not caught up.

KYC in Context: The Rest of the Compliance Stack

KYC verification is the front door of a larger Bank Secrecy Act program. Behind it sit transaction monitoring, suspicious activity reporting, Travel Rule compliance, independent testing, and a designated compliance officer, the components covered in our crypto AML and BSA compliance guide. And the whole program exists in service of licensing: it is what lets a state grant a money transmitter license and what a BitLicense examination tests.

Cornerstone's role is the integration: we build the KYC and AML program as part of the licensing project, so the written program, the production tooling, and the applications tell one consistent story. That is materially faster than retrofitting compliance after a regulator or bank flags the gap.

FAQ

Frequently Asked Questions

Related Pages

Crypto AML & BSA Compliance Cryptocurrency Licensing Crypto Exchange Licensing Money Transmitter Compliance Officer

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Money transmitter regulations by state

Money transmitter regulations by state

We are refreshing our state-by-state summaries for money transmitter. Browse the states we have published below.

  • Alabama
    Regulator: Alabama Securities Commission
    License: yes
    Bond: Not less than $100,000, or the average daily outstanding money-received-for-transmission obligations in Alabama plus 50% of average daily outstanding payment-instrument and stored-value obligations in Alabama, whichever is greater; commission may raise to a maximum of $5,000,000
    Open Alabama guide Official regulator site
  • Alaska
    Regulator: Alaska Department of Commerce, Community, and Economic Development, Division of Banking and Securities
    License: yes
    Bond: $25,000 plus $5,000 for each location, not exceeding a total addition of $125,000 (base + additions); department may raise to a maximum of $500,000 based on financial condition
    Open Alaska guide Official regulator site
  • Arizona
    Regulator: Arizona Department of Insurance and Financial Institutions
    License: yes
    Bond: Greater of $25,000 or 100% of the licensee's average daily money transmission liability in Arizona (most recent three-month period), up to a maximum of $500,000; $25,000 if tangible net worth exceeds 10% of total assets
    Open Arizona guide Official regulator site
  • Arkansas
    Regulator: Arkansas Securities Department
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in Arkansas (most recent three-month period), up to a maximum of $500,000; $100,000 if tangible net worth exceeds 10% of total assets
    Open Arkansas guide Official regulator site
  • California
    Regulator: California Department of Financial Protection and Innovation (DFPI)
    License: yes
    Bond: $250,000 to $7,000,000 for receiving money for transmission; selling or issuing payment instruments or stored value carries a separate $500,000 to $2,000,000 bond, and the two are cumulative
    Open California guide Official regulator site
  • Colorado
    Regulator: Colorado Department of Regulatory Agencies, Division of Banking
    License: yes
    Bond: Greater of $250,000 or 100% of the licensee's average daily money transmission liability in Colorado (most recent three-month period), up to a maximum of $1,000,000
    Open Colorado guide Official regulator site
  • Connecticut
    Regulator: Connecticut Department of Banking
    License: yes
    Bond: Non-virtual-currency transmitters: not less than $300,000 (avg weekly transmissions < $300,000), $500,000 ($300,000-$500,000), or $1,000,000 (> $500,000); virtual-currency transmitters: amount set by the commissioner
    Open Connecticut guide Official regulator site
  • Delaware
    Regulator: Delaware Office of the State Bank Commissioner
    License: yes
    Bond: $25,000, plus $5,000 for each location in excess of one, not to exceed $250,000 total
    Open Delaware guide Official regulator site
  • District of Columbia
    Regulator: District of Columbia Department of Insurance, Securities and Banking
    License: yes
    Bond: $50,000, increased by $10,000 per additional location, not to exceed $250,000 total
    Open District of Columbia guide Official regulator site
  • Florida
    Regulator: Florida Office of Financial Regulation
    License: yes
    Bond: Amount specified by rule, but not less than $50,000 and not exceeding $2,000,000 (rule allows for financial condition, number of locations, and anticipated volume)
    Open Florida guide Official regulator site
  • Georgia
    Regulator: Georgia Department of Banking and Finance
    License: yes
    Bond: $250,000 minimum; the Department may require additional coverage, capped at $2,000,000
    Open Georgia guide Official regulator site
  • Hawaii
    Regulator: Department of Commerce and Consumer Affairs, Division of Financial Institutions
    License: yes
    Bond: $100,000 for the initial 12 months of licensure; commissioner may increase up to a maximum of $500,000 based on impaired financial condition
    Open Hawaii guide Official regulator site
  • Idaho
    Regulator: Idaho Department of Finance
    License: yes
    Bond: $10,000, increased by $5,000 per additional location/authorized representative, up to a maximum of $500,000
    Open Idaho guide Official regulator site
  • Illinois
    Regulator: Illinois Department of Financial and Professional Regulation, Division of Financial Institutions
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in Illinois for the most recently completed quarter, capped at $2,000,000
    Open Illinois guide Official regulator site
  • Indiana
    Regulator: Indiana Department of Financial Institutions
    License: yes
    Bond: Greater of $300,000 or the licensee's average daily money transmission liability in Indiana for the most recent calendar quarter, capped at $500,000
    Open Indiana guide Official regulator site
  • Iowa
    Regulator: Iowa Division of Banking
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in Iowa for the most recent 3-month period, capped at $500,000
    Open Iowa guide Official regulator site
  • Kansas
    Regulator: Office of the State Bank Commissioner
    License: yes
    Bond: Greater of $200,000 or 100% of the licensee's average daily money transmission liability in Kansas for the most recent 3-month period, capped at $1,000,000 (or $200,000 if tangible net worth exceeds 10% of total assets)
    Open Kansas guide Official regulator site
  • Kentucky
    Regulator: Kentucky Department of Financial Institutions
    License: yes
    Bond: At least $500,000; commissioner may increase up to a maximum of $5,000,000 based on financial condition, net worth, or transaction volume
    Open Kentucky guide Official regulator site
  • Louisiana
    Regulator: Louisiana Office of Financial Institutions
    License: yes
    Bond: Minimum $100,000, up to a maximum of $500,000, or a higher amount deemed appropriate by the Commissioner up to a maximum of $1,000,000
    Open Louisiana guide Official regulator site
  • Maine
    Regulator: Bureau of Consumer Credit Protection
    License: yes
    Bond: $100,000
    Open Maine guide Official regulator site
  • Maryland
    Regulator: Office of the Commissioner of Financial Regulation
    License: yes
    Bond: Greater of $150,000 or 100% of the applicant's average daily money transmission liability in the State for the most recent quarter, capped at $2,000,000
    Open Maryland guide Official regulator site
  • Massachusetts
    Regulator: Massachusetts Division of Banks
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in Massachusetts over the most recently completed three months, capped at $500,000
    Open Massachusetts guide Official regulator site
  • Michigan
    Regulator: Department of Insurance and Financial Services (DIFS)
    License: yes
    Bond: $500,000 for the first location, plus $10,000 for each additional location and authorized delegate, up to a maximum of $1,500,000
    Open Michigan guide Official regulator site
  • Minnesota
    Regulator: Minnesota Department of Commerce
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in Minnesota (most recent 3-month period), capped at $500,000
    Open Minnesota guide Official regulator site
  • Mississippi
    Regulator: Mississippi Department of Banking and Consumer Finance
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in Mississippi (most recent 3-month period), capped at $500,000 (commissioner may raise up to $1,000,000)
    Open Mississippi guide Official regulator site
  • Missouri
    Regulator: Missouri Division of Finance
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in Missouri (most recent 3-month period), capped at $500,000
    Open Missouri guide Official regulator site
  • Montana
    Regulator: Montana Division of Banking
    License: no
    Bond: Not required (no state license needed)
    Open Montana guide Official regulator site
  • Nebraska
    Regulator: Nebraska Department of Banking and Finance
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in Nebraska (most recent 3-month period), capped at $500,000
    Open Nebraska guide Official regulator site
  • Nevada
    Regulator: State of Nevada Department of Business and Industry, Financial Institutions Division
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in Nevada (most recently completed quarter), capped at $500,000
    Open Nevada guide Official regulator site
  • New Hampshire
    Regulator: New Hampshire Banking Department
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in New Hampshire (most recent 3-month period), capped at $500,000
    Open New Hampshire guide Official regulator site
  • New Jersey
    Regulator: New Jersey Department of Banking and Insurance
    License: yes
    Bond: Amount set by the Commissioner by regulation, not less than $100,000 and not more than $1,000,000 (money transmitter). Foreign money transmitters use a volume-based schedule starting at $25,000.
    Open New Jersey guide Official regulator site
  • New Mexico
    Regulator: New Mexico Regulation and Licensing Department, Financial Institutions Division
    License: yes
    Bond: Greater of $300,000 or 1% of the licensee's total yearly dollar volume of money transmission business in New Mexico (or projected first-year volume), up to a maximum of $2,000,000
    Open New Mexico guide Official regulator site
  • New York
    Regulator: New York State Department of Financial Services
    License: yes
    Bond: Set by the Superintendent of Financial Services for each licensee; New York Banking Law Article 13-B fixes no dollar amount, so confirm the required bond with DFS before relying on a figure
    Open New York guide Official regulator site
  • North Carolina
    Regulator: North Carolina Office of the Commissioner of Banks
    License: yes
    Bond: $150,000 base (transmission volume in NC up to $1,000,000); increases with NC transmission volume (e.g., $175,000, $200,000, and higher tiers)
    Open North Carolina guide Official regulator site
  • North Dakota
    Regulator: North Dakota Department of Financial Institutions
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in North Dakota (most recent 3-month period), capped at $500,000
    Open North Dakota guide Official regulator site
  • Ohio
    Regulator: Ohio Department of Commerce, Division of Financial Institutions
    License: yes
    Bond: Security device (surety bond or permitted alternative) of not less than $300,000, up to a maximum of $2,000,000 as the Superintendent finds appropriate
    Open Ohio guide Official regulator site
  • Oklahoma
    Regulator: Oklahoma State Banking Department
    License: yes
    Bond: $50,000 plus $10,000 per authorized-delegate location, not exceeding a total of $500,000
    Open Oklahoma guide Official regulator site
  • Oregon
    Regulator: Oregon Department of Consumer and Business Services, Division of Financial Regulation
    License: yes
    Bond: $25,000, increased by $5,000 per additional location/authorized delegate (amount otherwise set by rule/Director)
    Open Oregon guide Official regulator site
  • Pennsylvania
    Regulator: Pennsylvania Department of Banking and Securities
    License: yes
    Bond: Bond in the penal sum of $1,000,000 (department may require additional bond based on average daily outstanding transmission balance)
    Open Pennsylvania guide Official regulator site
  • Puerto Rico
    Regulator: Puerto Rico Office of the Commissioner of Financial Institutions (OCIF)
    License: yes
    Bond: $500,000 for a single office, increased by $10,000 per additional office or authorized agent (Commissioner may require a higher bond based on business volume/financial condition)
    Open Puerto Rico guide Official regulator site
  • Rhode Island
    Regulator: Rhode Island Department of Business Regulation, Division of Banking
    License: yes
    Bond: $50,000 (currency transmission licensees); department may accept an alternative security form if a surety bond is not commercially available at reasonable cost
    Open Rhode Island guide Official regulator site
  • South Carolina
    Regulator: South Carolina Attorney General (Commissioner under the South Carolina Uniform Money Services Act)
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in South Carolina (most recent 3 months), capped at $500,000; alternatively $100,000 if tangible net worth exceeds 10% of total assets
    Open South Carolina guide Official regulator site
  • South Dakota
    Regulator: South Dakota Division of Banking
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in South Dakota (most recent 3 months), capped at $500,000; alternatively $100,000 if tangible net worth exceeds 10% of total assets
    Open South Dakota guide Official regulator site
  • Tennessee
    Regulator: Tennessee Department of Financial Institutions
    License: yes
    Bond: Greater of $50,000 or 100% of average daily money transmission liability in Tennessee (most recent calendar quarter), capped at $800,000
    Open Tennessee guide Official regulator site
  • Texas
    Regulator: Texas Department of Banking
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in Texas (most recent 3 months), capped at $500,000; alternatively $100,000 if tangible net worth exceeds 10% of total assets
    Open Texas guide Official regulator site
  • Utah
    Regulator: Utah Department of Financial Institutions
    License: yes
    Bond: Flat minimum surety bond of $50,000
    Open Utah guide Official regulator site
  • Vermont
    Regulator: Vermont Department of Financial Regulation
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in Vermont (most recent 3 months), capped at $2,000,000
    Open Vermont guide Official regulator site
  • Virginia
    Regulator: Virginia State Corporation Commission, Bureau of Financial Institutions
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in Virginia for the most recent quarter, capped at $1,000,000; a flat $100,000 where tangible net worth exceeds 10% of total assets
    Open Virginia guide Official regulator site
  • Washington
    Regulator: Washington State Department of Financial Institutions
    License: yes
    Bond: Surety bond based on prior year's money transmission and payment instrument dollar volume; minimum $10,000, not to exceed $550,000
    Open Washington guide Official regulator site
  • West Virginia
    Regulator: West Virginia Division of Financial Institutions
    License: yes
    Bond: $300,000 for money transmission; $100,000 for check or money-order sale or currency exchange; increased by 1% of annual West Virginia volume over $10 million, capped at $1,000,000
    Open West Virginia guide Official regulator site
  • Wisconsin
    Regulator: Wisconsin Department of Financial Institutions
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in Wisconsin (most recent 3 months), capped at $500,000
    Open Wisconsin guide Official regulator site
  • Wyoming
    Regulator: Wyoming Division of Banking
    License: yes
    Bond: $10,000 or 2.5 times outstanding payment instruments, whichever is greater, not to exceed $500,000
    Open Wyoming guide Official regulator site

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