Start Your Business
How to Start a Crypto Business
Launching a crypto exchange, wallet, or digital asset platform in the United States means FinCEN registration, state money transmitter licensing, and frameworks like the New York BitLicense. This founder's guide walks you through each step, and our specialists run the filings when you are ready.
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How do you start a crypto business in the US?
To start a crypto business in the United States, you map which regulators apply to your product, form and capitalize your entity, register with FinCEN as a money services business, build a Bank Secrecy Act and anti-money-laundering program backed by blockchain analytics, and get licensed in every state where your customers live before you onboard them. Custodial exchanges, wallets, and payment platforms are generally treated as money transmitters in most states, and New York (BitLicense), Louisiana, and California run dedicated digital asset regimes on top of that. As of 2026, there is no single federal license that covers nationwide operation, so a full footprint can require several million dollars in capital, bonds, and filings staff.
- Do I Need a License to Run a Crypto Business in the US?
- In most cases, yes. Custodial exchanges, wallet providers, and payment platforms that hold or transmit crypto for customers are generally treated as money services businesses at the federal level and money transmitters at the state level. New York, California, and Louisiana have additional licensing regimes specific to digital assets. Pure non-custodial software has historically faced lighter state exposure, but the legal landscape continues to evolve and should be reviewed by counsel.
- How Much Does It Cost to Launch a Licensed US Crypto Business?
- A nationwide licensing footprint, including the BitLicense or a trust charter, the California Digital Financial Assets Law license, and the patchwork of state money transmitter licenses, can require several million dollars in capital, surety bonds, application fees, legal fees, and filings staff before the first customer is onboarded. Many founders pursue a phased approach, starting in one or two anchor states and expanding over time.
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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Prepare
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We file every renewal ahead of its deadline in Atlas so licenses stay current.
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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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Your Roadmap to Launching a US Crypto Business
The United States does not have a single, unified federal license for cryptocurrency businesses. Instead, crypto founders navigate a patchwork. It includes federal registration with FinCEN, state-by-state money transmitter licensing, and state-specific frameworks like the New York BitLicense and the Louisiana Virtual Currency Businesses Act. On top of all that sits a thick layer of Bank Secrecy Act obligations. This guide covers the key steps to launching a properly licensed digital asset business, whether you are building a centralized exchange, a custodial wallet, a payment app, or a tokenization platform. We recommend consulting with an attorney and a Cornerstone expert for guidance tailored to your specific business model.
Mapping the US Crypto Regulatory Landscape
Cryptocurrency businesses in the United States often face oversight from several regulators at once, depending on the products they offer. Knowing which regulators apply to you is the first step in building a workable filings strategy.
Several federal agencies play a role. The Financial Crimes Enforcement Network (FinCEN) treats most businesses that exchange, transmit, or administer convertible virtual currency as money services businesses (MSBs). Those businesses must register and run a Bank Secrecy Act (BSA) program. The Securities and Exchange Commission (SEC) views many tokens as securities, which can pull token issuers, broker-dealers, and trading platforms into the securities framework. The Commodity Futures Trading Commission (CFTC) treats Bitcoin and Ether as commodities and regulates derivatives on digital assets. The Internal Revenue Service treats virtual currency as property for tax purposes, which has filing implications for both the business and its customers.
States add another layer. Most regulate the receipt, holding, and transmission of fiat and digital assets on behalf of others through their money transmitter laws. A growing number have updated those statutes to address virtual currency directly, or have enacted standalone digital asset frameworks. Cornerstone helps crypto founders build a regulatory map specific to their product surface area before they file the first application.
FinCEN MSB Registration and the BSA Program
Most US-based crypto exchanges, custodial wallet providers, and payment platforms register with FinCEN as money services businesses. Registration is filed on FinCEN Form 107 and is typically renewed every two years. The registration itself is straightforward. The obligations that come with it are extensive.
A crypto MSB is generally expected to run a written BSA/AML program sized to its risk profile. The core pillars usually include a designated BSA officer with day-to-day responsibility for the program. They include written policies and procedures for customer identification and transaction monitoring. They also include ongoing employee training, independent testing or audit on a regular cadence, and a documented risk assessment that is updated as the business changes.
Reporting obligations sit on top of the program. These include Currency Transaction Reports for cash transactions above $10,000 and Suspicious Activity Reports when activity meets the reporting thresholds. They also include recordkeeping for transmittals of funds and certain virtual currency transactions under the Recordkeeping and Travel Rules. Crypto businesses also screen counterparties against the sanctions lists maintained by the Office of Foreign Assets Control (OFAC), and they block or reject transactions that hit a match.
State Money Transmitter Treatment of Digital Assets
State money transmitter laws are the dominant licensing layer for crypto businesses in the United States. The treatment varies significantly from state to state, and a business model that is exempt in one state can be a licensed activity in the next. Building a state-by-state matrix early helps avoid expensive mid-launch pivots.
States That Treat Crypto as Money Transmission
A large number of states have either issued guidance or amended their money transmitter statutes to bring custodial crypto activities, exchange services, and fiat on-ramps and off-ramps into the money transmitter framework. In these states, holding customer crypto, facilitating fiat-to-crypto exchanges, or transmitting crypto for customers generally triggers licensing.
States With Dedicated Digital Asset Frameworks
New York operates the BitLicense and a separate trust charter pathway. Louisiana operates the Virtual Currency Businesses Act with its own license. California enacted the Digital Financial Assets Law, which establishes a state-administered license for covered digital asset activities. Other states have passed or are considering similar standalone frameworks.
States With Narrow or No-Action Treatment
A handful of states have indicated that pure peer-to-peer crypto trading or non-custodial software does not trigger money transmission, and some have issued no-action letters for specific business models. These positions can change, so any reliance on a no-action posture should be revisited regularly with counsel.
Multistate Coordination
Most state crypto licensing applications go through the Nationwide Multistate Licensing System (NMLS). The Conference of State Bank Supervisors (CSBS) also coordinates the Money Transmitter Regulators Association multistate examinations and the Money Services Businesses Networked Supervision program, both of which can reduce duplicate regulator outreach once the business is licensed in several states.
The New York BitLicense and Trust Charter
New York remains one of the most consequential states for any crypto business with US customers. That comes down to the size of the market and the depth of the New York Department of Financial Services (NYDFS) framework.
The BitLicense is codified at 23 NYCRR Part 200. It applies to any business engaged in virtual currency business activity involving New York or a New York resident. Covered activity includes receiving virtual currency for transmission, storing or holding it on behalf of others, buying and selling it as a customer business, performing exchange services, and controlling, administering, or issuing a virtual currency.
The application is detailed. It typically requires a thorough business plan and written policies covering AML, cybersecurity, capital adequacy, business continuity and disaster recovery, complaint handling, and consumer protection. It also requires biographical and background materials on each principal, audited financials, fingerprint cards for control persons, and a cybersecurity program that satisfies 23 NYCRR Part 500.
An alternative pathway is the New York limited purpose trust company charter, which several major crypto custodians have used. A trust charter typically carries higher capital and governance expectations than a BitLicense. In return, it lets the business hold customer assets as a fiduciary and passport into other states more easily through trust company recognition. NYDFS also maintains a Greenlist of pre-approved coins. Listing a coin outside the Greenlist generally requires a separate coin-listing approval or self-certification process.
Capital, Surety Bonds, and Permissible Investments
Capital requirements for crypto businesses can be significant, and they typically stack across the states where the business is licensed.
Net Worth Requirements
State minimum net worth requirements for money transmitters and crypto-specific licensees typically range from $100,000 to several million dollars, often scaled to transmission volume. New York and California in particular have set net worth and capital expectations in the millions for larger applicants.
Surety Bond Requirements
Surety bond requirements for crypto-active money transmitters generally range from $25,000 to $2,000,000 per state, with some states scaling the bond to volume. Bond premiums depend on the applicant's credit profile and financial strength, and the aggregate bonding cost across all licensed states is one of the larger fixed expenses of a crypto licensing program.
Permissible Investments and Custody of Customer Assets
Most state money transmitter regimes require licensees to hold permissible investments equal to or exceeding their outstanding transmission obligations. For crypto businesses, states have increasingly clarified that customer virtual currency held in custody counts toward the obligation and must be backed one-for-one with the same kind and amount of virtual currency. NYDFS has issued specific guidance on segregation, sub-custody, and the use of disclosed and undisclosed sub-custodians.
Realistic Cost Estimates
Building a US nationwide crypto licensing footprint, including the BitLicense or trust charter, the California Digital Financial Assets Law license, and the patchwork of money transmitter licenses, can require several million dollars in capital, bonding, application fees, legal fees, and filings staff before the first customer is onboarded.
Building a Crypto-Specific BSA/AML Program
Crypto BSA/AML programs share the same statutory pillars as any other MSB program, but the operational tooling looks very different. Regulators and examiners increasingly expect crypto businesses to use blockchain analytics, address screening, and on-chain transaction monitoring alongside traditional fiat controls.
A practical crypto BSA/AML program is generally expected to cover several fronts. It runs risk-based customer due diligence and enhanced due diligence with documented thresholds. It integrates blockchain analytics for wallet screening and source-of-funds checks. It calibrates monitoring rules to typologies common in digital asset abuse, such as mixers and tumblers, sanctioned protocols, darknet exposure, ransomware addresses, and structuring across wallets. It builds Travel Rule capability for transmittals at or above the applicable thresholds. It screens for sanctions and politically exposed persons at onboarding and on an ongoing basis. It also ties a clear SAR investigation and filing workflow to the monitoring output.
The FinCEN Travel Rule, the Treasury sanctions framework, and state-specific examination manuals all reward businesses that can show working controls rather than paper policies. Cornerstone helps crypto businesses select analytics vendors, draft the procedures that wrap around them, and prepare for the BSA examinations that follow licensure.
Custody vs Non-Custodial Models
Whether your business takes custody of customer assets is the single most important business model question for US crypto licensing.
Custodial Models
If your business holds the private keys to customer crypto, controls customer funds, or can move customer assets on its own authority, you are generally a custodian for regulatory purposes. Custody triggers money transmitter licensing in most states, brings the BitLicense or a trust charter into scope in New York, and pulls the business into the customer-protection rules around segregation, books and records, audits, and proof of reserves.
Non-Custodial Software
Pure non-custodial software, where users hold their own keys and the business never controls customer funds, has historically faced lighter state licensing exposure. FinCEN guidance from 2019 distinguishes between developers of wallet software and money transmitters that hold customer value. The legal posture is unsettled and evolving, and any non-custodial product should be reviewed by counsel against the latest state guidance and any pending federal rulemakings.
Hybrid and Embedded Models
Many businesses sit somewhere in between, embedding custody through a third-party custodian, offering optional self-custody, or providing payment rails for merchants. These hybrid models often require careful contractual structuring with a chartered custodian and a clear written record of which entity is performing each licensed activity.
Technology, Security, and Operational Infrastructure
Crypto regulators evaluate technology and security with a level of scrutiny rarely applied to other financial services categories. The application package, the pre-licensing review, and the ongoing examinations all probe the same set of controls.
Custody Architecture
Hot, warm, and cold wallet design, key generation ceremonies, multi-party computation or multi-signature schemes, withdrawal allowlists, address whitelisting, and documented key recovery procedures.
Cybersecurity Program
A written cybersecurity program covering access controls, encryption in transit and at rest, vulnerability and penetration testing, incident response, vendor risk management, and board-level reporting. New York licensees should plan for 23 NYCRR Part 500 from day one.
Blockchain Analytics and Monitoring
Production integrations with at least one major analytics provider for wallet screening, transaction monitoring, and Travel Rule transmission. Examiners often ask to see live dashboards rather than vendor brochures.
Books, Records, and Proof of Reserves
Real-time reconciliation between on-chain holdings and customer ledger balances, periodic attestations, and audit-ready records of every customer transaction. Several state regimes now reference proof of reserves expectations directly.
Business Continuity and Disaster Recovery
Documented business continuity, disaster recovery, and wind-down plans, including arrangements for the orderly return of customer assets if the business ceases operations.
Checklist
How to Start a Crypto Business checklist
Product and Regulatory Scoping
Document each product line, the assets involved, and the customer states you intend to serve. Identify which activities trigger money transmission, securities, commodities, or trust regulation.
Entity Formation and Capitalization
Form the operating entity, secure initial capital sized to your target states, and put governance and board structures in place that examiners will recognize.
FinCEN MSB Registration and BSA Program
Register with FinCEN as a money services business, designate a BSA officer, and stand up the AML, sanctions, and Travel Rule controls before any customer goes live.
State Licensing Strategy
Sequence your state applications, often starting with money transmitter filings through NMLS, the NY BitLicense or trust charter pathway, the California Digital Financial Assets Law license, and the Louisiana Virtual Currency Businesses Act license as applicable.
Custody and Cybersecurity Build-Out
Implement your custody architecture, key management, cybersecurity program (including 23 NYCRR Part 500 where applicable), and blockchain analytics integrations.
Application Filing and Regulator Engagement
File complete applications, respond promptly to deficiency notices, and prepare principals for the interviews and management presentations that several states conduct.
Pre-Launch Examination Readiness
Run an internal mock examination covering AML, custody, cybersecurity, and consumer protection so that the first regulator visit after licensure is uneventful.
Ongoing Filings and Renewals
Stand up the calendar for renewals, call reports, audited financials, coin-listing approvals, and periodic risk assessment updates. Treat the filings program as a permanent operating function, not a launch checklist.
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Frequently Asked Questions
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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.
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