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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.

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  • Human review on every filing

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

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.

  1. Discover

    We connect you with independent attorneys to pin down which licenses you need.

  2. Prepare

    Your licensing specialist assembles each application; our software handles the repetitive work.

  3. Review

    That same specialist reviews every filing before it reaches a regulator.

  4. Approve

    We submit, track each application, and keep you posted until the license is granted.

  5. 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

  • Specialists who know the answer

    Decades of licensing specialists, so the answer is right rather than guessed.

  • Trusted relationships with the regulator

    Direct, trusted relationships with regulators, so we ask the question instead of assuming the answer.

  • Living internal checklists

    Checklists that update the moment we learn something new, so deficiencies are caught before they happen.

99.995% On-time submissions in 2025. Filed correctly and on time, so you start operating sooner without avoidable back and forth.

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

01

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.

02

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.

03

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.

04

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.

05

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

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.

  • 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.

  • 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.

  • 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.

  • 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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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
  • 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
  • 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
  • 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
  • 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
  • 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
  • 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
  • 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
  • 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
  • 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)
  • 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
  • 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
  • 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
  • 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
  • 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
  • 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
  • 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)
  • 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
  • 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
  • Maine
    Regulator: Bureau of Consumer Credit Protection
    License: yes
    Bond: $100,000
  • 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
  • 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
  • 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
  • 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
  • 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)
  • 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
  • Montana
    Regulator: Montana Division of Banking
    License: no
    Bond: Not required (no state license needed)
  • 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
  • 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
  • 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
  • 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.
  • 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
  • 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
  • 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)
  • 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
  • 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
  • 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
  • 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)
  • 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)
  • 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)
  • 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
  • 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
  • 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
  • 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
  • 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
  • Utah
    Regulator: Utah Department of Financial Institutions
    License: yes
    Bond: Flat minimum surety bond of $50,000
  • 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
  • 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
  • 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
  • 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
  • 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
  • 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
Regulatory Watch

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.