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Money Transmission Licensing

Licensing for Currency Exchangers

Exchanging one currency for another is its own regulated category at the federal level and is licensed in many states, sometimes under the money transmission statute and sometimes under a separate currency exchange law. Here is how the map fits together.

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

Money Transmission Licensing

Does a currency exchange business need a license?

A currency exchange business generally needs to register with FinCEN as a money services business if it exchanges more than $1,000 in currency for any one person in a day, and many states additionally license currency exchange, either under their money transmitter statute or under a separate currency exchange law. A business that only exchanges currency face to face, without sending money anywhere, has a narrower map than a transmitter, but most modern exchange operations also offer remittance or hold customer funds, which typically brings the full money transmitter licensing analysis into play. Which regime applies in which state is a state-by-state legal determination based on the actual services offered.

I Only Exchange Cash at a Storefront. Do I Still Need to Register?
If you exchange more than $1,000 in currency for one person in a day, you are generally a dealer in foreign exchange under FinCEN's rules and register as an MSB with a BSA and AML program. State requirements depend on where you operate: some states license standalone exchange, others do not. The narrow model is real but worth confirming state by state.
Does Offering Wires or Remittance Change My Licensing?
Typically yes, substantially. Sending converted funds to a third party is money transmission, which brings the state-by-state money transmitter map, surety bonds, and net worth requirements into play on top of any exchange-specific rules. See /remittance-money-transmitter-license for how the remittance side is analyzed.

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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Two Overlapping Regimes, One Storefront

Currency exchange looks simple at the counter: dollars in, pesos out. Legally it sits at the intersection of two regimes. Federally, dealing in foreign exchange is its own money services business category with its own registration threshold. At the state level, some states license currency exchange under the money transmitter statute, some under a dedicated currency exchange law, and some not at all unless transmission is also involved. Businesses that both exchange and send money, which describes most modern exchange houses, typically face the full transmission map too. This page is general compliance information, not legal advice: the conclusion for a specific business depends on its activities and each state's statute, and we confirm classification with an independent licensing attorney before any filing.

Why Is Currency Exchange a Regulated Activity?

Cash-intensive currency exchange has long been treated as a money laundering risk channel, which is why both federal and state regimes attach to it independently of transmission.

Federal dealer status has a specific threshold

FinCEN's rules generally make a business a dealer in foreign exchange, and therefore an MSB, when it exchanges more than $1,000 in currency for one person in one day. Registration and a BSA and AML program follow; see /msb-registration.

Some states license exchange on its own

A number of states operate dedicated currency exchange licenses covering the exchange counter itself, with their own fees, bonds, and examinations, separate from transmission.

Other states fold exchange into transmission

Several statutes define money transmission to include receiving money for exchange, so the exchange activity itself is licensed under the money transmitter law.

Cash reporting applies regardless

Currency transaction reports above $10,000, suspicious activity reports, and OFAC screening apply to exchange desks whether or not a state license is required.

When Does an Exchange Business Also Become a Money Transmitter?

The pure exchange counter, where a customer walks in, converts cash, and walks out with cash, is the narrowest version of the model, and some businesses genuinely stay inside it. Most do not. The moment the business wires converted funds to a recipient abroad, holds converted balances for later use, or moves money between customers, it is receiving money for transmission, and the state-by-state money transmitter map applies alongside the exchange rules.

In practice that describes the majority of exchange houses and every fintech FX product we see: multi-currency accounts, cross-border payout after conversion, and rate-lock features all involve holding or transmitting customer funds. For those models, the exchange license question rides on top of the standard transmission program covered at /money-transmitter-license, with costs at /money-transmitter-license-cost and every state's requirements at /mtl-state-laws. The classification work is deciding which of your product's flows trigger which regime in which state, and documenting it.

How to Start a Currency Exchange Business

Starting a currency exchange business follows a predictable sequence once you know which regimes attach to your model. First, pin down the flows: pure over-the-counter exchange, exchange plus remittance, or an FX fintech holding multi-currency balances, because each lands differently on the map above. Second, register with FinCEN as a money services business if you will pass the dealer threshold, and stand up the written risk-based BSA and AML program under 31 CFR 1022.210 before you open, since it generally functions as a condition of operating rather than paperwork to backfill. Third, get the state authority your footprint requires: a standalone currency exchange license where a state offers one, or the full money transmitter license wherever your model includes sending funds or holding customer balances.

The practical advice mirrors what we tell money transfer founders at /how-to-start-a-money-transmitter-business: treat licensing as the critical path, sequence your states deliberately, and budget for bonds and net worth before signing a lease. A currency exchange business that stays strictly over the counter can launch on a much lighter licensing footprint than a transmitter, which is exactly why the flow-of-funds analysis is worth doing carefully up front.

What Do Regulators Look At in an Exchange Business?

Whether the review is a state exchange license, a transmission license, or a federal examination, the focus areas repeat.

Cash handling and reporting discipline

Structuring detection, currency transaction report completeness, and how the counter identifies customers at the exchange thresholds.

Rate transparency and consumer disclosure

Several states regulate posted rates and receipts for exchange transactions, and consumer complaints about spreads draw examiner attention.

Where converted funds rest

Multi-currency balances and pre-funded payout accounts are analyzed as held customer funds, with safeguarding and permissible investment implications.

Sanctions exposure of corridors and counterparties

FX counterparties, correspondent accounts, and the corridors served are screened against OFAC requirements, and examiners expect the program to address them explicitly.

FAQ

Frequently Asked Questions

Related Pages

Who Needs a Money Transmitter License Money Transmitter License Remittance Money Transmitter Licenses MSB Registration

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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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