Cryptocurrency Licensing

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.

Most states regulate crypto under their existing money transmitter statutes. A handful have built purpose-made frameworks for digital assets.

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.

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.