Digital Asset Filings
Cryptocurrency Licensing
Licensing and state filings for cryptocurrency exchanges, custodial wallets, stablecoin issuers, brokers, and ATM operators. We map the requirements, file the applications, and keep you in good standing as the rules change.
- All 50 states
- Specialist support
- Human review on every filing
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Digital Asset Filings
Do cryptocurrency businesses need a license?
In most states, yes. Exchanges, custodial wallet providers, brokers, stablecoin issuers, and ATM operators that hold or transfer digital assets on behalf of others are generally treated as money transmitters and need a money transmitter license in each state where their customers live. A few states run dedicated digital asset regimes on top of or instead of that: New York requires a BitLicense from its Department of Financial Services, Louisiana operates a separate Virtual Currency Business License, and California's Digital Financial Assets Law takes effect July 1, 2026. Most digital asset businesses also register with FinCEN as a money services business and build an anti-money-laundering program, since there is no single federal license that covers nationwide operation.
- Do Cryptocurrency Businesses Need to Be Licensed?
- In most states, yes. Cryptocurrency exchanges, custodial wallet providers, brokers, and businesses that facilitate the buying, selling, or transfer of digital assets on behalf of others are generally required to hold money transmitter licenses. Some states have additional or alternative licensing categories specific to virtual currency.
- What Is the New York BitLicense?
- The BitLicense is a dedicated license issued by the New York Department of Financial Services for businesses engaged in virtual currency activity. It has extensive requirements covering capital, custody, cybersecurity, and compliance, and the application process commonly runs well over a year.
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
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 for the Digital Asset Industry
The cryptocurrency and digital asset industry faces one of the fastest-moving regulatory environments in financial services. Most states treat custody and transfer of digital assets as money transmission and require a money transmitter license. New York runs a dedicated BitLicense regime through its Department of Financial Services, Louisiana operates a separate Virtual Currency Business License, and California has its own Digital Financial Assets Law administered by the Department of Financial Protection and Innovation, effective July 1, 2026. On top of state rules, most digital asset businesses register with FinCEN as a money services business and build a full AML and BSA program. Cornerstone has filed in this space since the early days of state crypto regulation, and we help digital asset companies build properly licensed operations from the ground up.
Built for Your Business
Crypto Exchanges & Trading Platforms
Centralized exchanges and trading platforms that hold customer funds or digital assets, match orders, or facilitate buying and selling are almost always treated as money transmitters, and they trigger the most extensive state licensing footprint.
- Money transmitter license applications in all required states
- New York BitLicense filings where applicable
- FinCEN money services business registration
- Surety bond and net worth planning per state
- AML and BSA program development
- State examination preparation and response
Custodial Wallet Providers
Wallet providers that hold private keys or take control of customer assets are generally regulated as money transmitters. Non-custodial wallets where the user keeps sole control of keys are treated differently and may fall outside transmission rules in many states.
- Custody classification analysis (custodial vs non-custodial)
- Money transmitter and virtual currency license filings
- Cybersecurity and key management policy review
- Consumer disclosure and asset segregation filings
- Multi-state license sequencing
Stablecoin Issuers
Issuers of fiat-backed or asset-backed stablecoins face a layered set of requirements covering reserve backing, redemption rights, and money transmission. Several states have published specific guidance for stablecoin activity, and New York reviews stablecoins under its virtual currency framework.
- Issuer classification and reserve structure review
- Money transmitter and BitLicense filings
- Reserve attestation and redemption policy support
- State-specific stablecoin guidance analysis
- Ongoing reporting and examination readiness
Crypto Brokers & OTC Desks
Brokers and over-the-counter desks that buy and sell digital assets on behalf of clients, or that route customer funds, are typically money transmitters. Activity that touches securities or commodities can add federal registration on top of state licensing.
- Money transmitter license applications
- OTC settlement flow and custody analysis
- Coordination on securities or commodities exposure
- AML and customer identification program build
- Renewal and ongoing filing calendar management
Crypto ATMs & Kiosk Operators
Operators of cryptocurrency ATMs and kiosks convert cash to digital assets and back, which is money transmission in most states. Kiosk operators also face location-by-location registration, signage, and consumer disclosure rules.
- Money transmitter license filings per state
- Kiosk location registration and disclosure compliance
- Surety bond procurement
- AML transaction monitoring program support
- Annual reporting and renewal management
The State-by-State Map for Digital Assets
There is no single federal license that lets a crypto business operate nationwide. Each state decides for itself whether your activity counts as money transmission, and a few states run dedicated virtual currency regimes on top of, or instead of, their money transmitter law. That means a digital asset company expanding across the country is really running dozens of separate applications, each with its own fees, bonds, net worth tests, and timelines.
The first job is mapping which states apply to your specific model. A non-custodial software wallet has a very different footprint than a custodial exchange that holds customer dollars and coins. We help build that map before any paperwork is filed, with an independent licensing attorney confirming the classification, so you focus on the states where licensing typically applies and avoid filing where an exemption may be available.
Money Transmission Versus Dedicated Virtual Currency Regimes
Most states regulate crypto under their existing money transmitter statutes. A handful have built purpose-made frameworks for digital assets.
Money Transmitter Licenses
The default path in most states. If you hold, transfer, or exchange digital assets on behalf of others, you generally need a money transmitter license in each state where your customers are located.
New York BitLicense
New York requires a dedicated BitLicense from its Department of Financial Services for virtual currency business activity. It is the most demanding crypto regime in the country and is treated as its own application track.
Louisiana Virtual Currency Business License
Louisiana operates a separate Virtual Currency Business License under its Department of Financial Institutions, distinct from its money transmitter law, with its own application and surety requirements.
California Digital Financial Assets Law
California's Digital Financial Assets Law creates a dedicated license administered by the Department of Financial Protection and Innovation, separate from the state Money Transmission Act, with a compliance deadline of July 1, 2026 for businesses serving California residents.
Special Purpose and Limited Charters
Some states offer limited or special purpose options for certain activities. We analyze whether any apply to your model before defaulting to a full money transmitter filing.
AML, BSA, and FinCEN Registration
Almost every digital asset business that touches customer funds is a money services business under federal law. That means registering with FinCEN within 180 days of starting activity and standing up a written anti-money-laundering program. State regulators expect to see that program before they approve a license, so the federal and state tracks have to move together.
A workable AML and BSA program covers a designated compliance officer, written policies, customer identification and know-your-customer procedures, transaction monitoring, suspicious activity reporting, and independent testing. We help build the program so it satisfies both FinCEN and the states reviewing your applications, rather than bolting it on after the fact.
Building a Program That Survives Examinations
Getting licensed is the start, not the finish. State regulators examine licensed crypto businesses, request periodic reports, and expect updated policies when your products or controls change. New York in particular holds BitLicense holders to ongoing cybersecurity, capital, and reporting standards.
Cornerstone keeps your filings current after approval. We track renewal deadlines, file change-of-control and material-change notices, manage surety bond riders as requirements move, and prepare you for supervisory examinations. With Atlas, you can see the status of every license, every due date, and every open task in one place, and you get a dedicated specialist who knows your file and the regulators reviewing it.
Checklist
Cryptocurrency Licensing checklist
Regulatory Mapping
We map which states typically classify activities like yours as money transmission, which run dedicated virtual currency regimes, and where federal registration may apply, with an independent licensing attorney confirming the classification for your specific model.
Exemption Analysis
We analyze available exemptions and determine if your business model, including non-custodial designs, qualifies for any state-specific carve-outs before you file.
License Applications
We prepare and file money transmitter and virtual-currency-specific applications, including the New York BitLicense, the Louisiana Virtual Currency Business License, and the California Digital Financial Assets Law license where they apply.
AML & BSA Program
We help build your FinCEN money services business registration, AML and BSA program, cybersecurity framework, and consumer protection policies so they pass state review.
Ongoing Filings
After approval we manage renewals, change notices, surety bond riders, periodic reports, and examination readiness so you stay in good standing as the rules evolve.
FAQ
Frequently Asked Questions
Related Pages
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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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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.
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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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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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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.
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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.
- AlabamaRegulator: Alabama Securities CommissionLicense: yesBond: 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
- AlaskaRegulator: Alaska Department of Commerce, Community, and Economic Development, Division of Banking and SecuritiesLicense: yesBond: $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
- ArizonaRegulator: Arizona Department of Insurance and Financial InstitutionsLicense: yesBond: 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
- ArkansasRegulator: Arkansas Securities DepartmentLicense: yesBond: 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
- CaliforniaRegulator: California Department of Financial Protection and Innovation (DFPI)License: yesBond: $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
- ColoradoRegulator: Colorado Department of Regulatory Agencies, Division of BankingLicense: yesBond: 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
- ConnecticutRegulator: Connecticut Department of BankingLicense: yesBond: 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
- DelawareRegulator: Delaware Office of the State Bank CommissionerLicense: yesBond: $25,000, plus $5,000 for each location in excess of one, not to exceed $250,000 total
- District of ColumbiaRegulator: District of Columbia Department of Insurance, Securities and BankingLicense: yesBond: $50,000, increased by $10,000 per additional location, not to exceed $250,000 total
- FloridaRegulator: Florida Office of Financial RegulationLicense: yesBond: 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)
- GeorgiaRegulator: Georgia Department of Banking and FinanceLicense: yesBond: $250,000 minimum; the Department may require additional coverage, capped at $2,000,000
- HawaiiRegulator: Department of Commerce and Consumer Affairs, Division of Financial InstitutionsLicense: yesBond: $100,000 for the initial 12 months of licensure; commissioner may increase up to a maximum of $500,000 based on impaired financial condition
- IdahoRegulator: Idaho Department of FinanceLicense: yesBond: $10,000, increased by $5,000 per additional location/authorized representative, up to a maximum of $500,000
- IllinoisRegulator: Illinois Department of Financial and Professional Regulation, Division of Financial InstitutionsLicense: yesBond: 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
- IndianaRegulator: Indiana Department of Financial InstitutionsLicense: yesBond: 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
- IowaRegulator: Iowa Division of BankingLicense: yesBond: 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
- KansasRegulator: Office of the State Bank CommissionerLicense: yesBond: 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)
- KentuckyRegulator: Kentucky Department of Financial InstitutionsLicense: yesBond: At least $500,000; commissioner may increase up to a maximum of $5,000,000 based on financial condition, net worth, or transaction volume
- LouisianaRegulator: Louisiana Office of Financial InstitutionsLicense: yesBond: 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
- MaineRegulator: Bureau of Consumer Credit ProtectionLicense: yesBond: $100,000
- MarylandRegulator: Office of the Commissioner of Financial RegulationLicense: yesBond: 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
- MassachusettsRegulator: Massachusetts Division of BanksLicense: yesBond: 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
- MichiganRegulator: Department of Insurance and Financial Services (DIFS)License: yesBond: $500,000 for the first location, plus $10,000 for each additional location and authorized delegate, up to a maximum of $1,500,000
- MinnesotaRegulator: Minnesota Department of CommerceLicense: yesBond: 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
- MississippiRegulator: Mississippi Department of Banking and Consumer FinanceLicense: yesBond: 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)
- MissouriRegulator: Missouri Division of FinanceLicense: yesBond: 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
- MontanaRegulator: Montana Division of BankingLicense: noBond: Not required (no state license needed)
- NebraskaRegulator: Nebraska Department of Banking and FinanceLicense: yesBond: 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
- NevadaRegulator: State of Nevada Department of Business and Industry, Financial Institutions DivisionLicense: yesBond: Greater of $100,000 or 100% of average daily money transmission liability in Nevada (most recently completed quarter), capped at $500,000
- New HampshireRegulator: New Hampshire Banking DepartmentLicense: yesBond: 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
- New JerseyRegulator: New Jersey Department of Banking and InsuranceLicense: yesBond: 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.
- New MexicoRegulator: New Mexico Regulation and Licensing Department, Financial Institutions DivisionLicense: yesBond: 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
- New YorkRegulator: New York State Department of Financial ServicesLicense: yesBond: 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
- North CarolinaRegulator: North Carolina Office of the Commissioner of BanksLicense: yesBond: $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)
- North DakotaRegulator: North Dakota Department of Financial InstitutionsLicense: yesBond: 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
- OhioRegulator: Ohio Department of Commerce, Division of Financial InstitutionsLicense: yesBond: 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
- OklahomaRegulator: Oklahoma State Banking DepartmentLicense: yesBond: $50,000 plus $10,000 per authorized-delegate location, not exceeding a total of $500,000
- OregonRegulator: Oregon Department of Consumer and Business Services, Division of Financial RegulationLicense: yesBond: $25,000, increased by $5,000 per additional location/authorized delegate (amount otherwise set by rule/Director)
- PennsylvaniaRegulator: Pennsylvania Department of Banking and SecuritiesLicense: yesBond: Bond in the penal sum of $1,000,000 (department may require additional bond based on average daily outstanding transmission balance)
- Puerto RicoRegulator: Puerto Rico Office of the Commissioner of Financial Institutions (OCIF)License: yesBond: $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)
- Rhode IslandRegulator: Rhode Island Department of Business Regulation, Division of BankingLicense: yesBond: $50,000 (currency transmission licensees); department may accept an alternative security form if a surety bond is not commercially available at reasonable cost
- South CarolinaRegulator: South Carolina Attorney General (Commissioner under the South Carolina Uniform Money Services Act)License: yesBond: 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
- South DakotaRegulator: South Dakota Division of BankingLicense: yesBond: 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
- TennesseeRegulator: Tennessee Department of Financial InstitutionsLicense: yesBond: Greater of $50,000 or 100% of average daily money transmission liability in Tennessee (most recent calendar quarter), capped at $800,000
- TexasRegulator: Texas Department of BankingLicense: yesBond: 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
- UtahRegulator: Utah Department of Financial InstitutionsLicense: yesBond: Flat minimum surety bond of $50,000
- VermontRegulator: Vermont Department of Financial RegulationLicense: yesBond: Greater of $100,000 or 100% of average daily money transmission liability in Vermont (most recent 3 months), capped at $2,000,000
- VirginiaRegulator: Virginia State Corporation Commission, Bureau of Financial InstitutionsLicense: yesBond: 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
- WashingtonRegulator: Washington State Department of Financial InstitutionsLicense: yesBond: Surety bond based on prior year's money transmission and payment instrument dollar volume; minimum $10,000, not to exceed $550,000
- West VirginiaRegulator: West Virginia Division of Financial InstitutionsLicense: yesBond: $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
- WisconsinRegulator: Wisconsin Department of Financial InstitutionsLicense: yesBond: Greater of $100,000 or 100% of average daily money transmission liability in Wisconsin (most recent 3 months), capped at $500,000
- WyomingRegulator: Wyoming Division of BankingLicense: yesBond: $10,000 or 2.5 times outstanding payment instruments, whichever is greater, not to exceed $500,000
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Stay Ahead of the Rules
Recent rule changes, deadline announcements, and state agency updates we are tracking for you.
- Action Multistate Settlement Aug 19, 2026
August 2026 Monthly Settlement with NewRez LLC
State financial regulators announced a nearly $15. 5 million settlement with NewRez LLC related to improperly charged insurance.
- Watch New York DFS NY Aug 19, 2026
DFS Pre-Proposed Amendment to 23 NYCRR 400
The DFS posted a pre-proposed second amendment to 23 NYCRR 400 on August 13, 2026; comments are due by August 24, 2026.
- Action NMLS Aug 19, 2026
New NMLS Information Requests and Notification Changes
August 2026 updates include new Information Requests and notification options for individuals within the NMLS system.
- Watch FinCEN Aug 19, 2026
FinCEN Proposed Rule for AML/CFT Reforms
On April 7, 2026, FinCEN proposed reforms to AML/CFT program requirements affecting MSBs and financial institutions.
- Action California DFPI CA Aug 18, 2026
California Debt Collection Licensing Act Updates
California continues to enforce its Debt Collection Licensing Act, maintaining rigorous licensing and examination protocols for debt collectors and debt buyers. The DFPI supervises compliance closely.
Get Your Crypto Business Licensed
Contact us to scope your cryptocurrency licensing. We specialize in helping digital asset companies navigate state licensing, BitLicense, and federal registration.
