money transmitter
Colorado Money Transmitter Laws & Licensing
Complete guide to money transmitter licensing in Colorado. Covers application requirements, surety bond amounts, net worth minimums, FinCEN registration, and key statutes governing money transmission in Colorado.
Colorado money transmitter requirements at a glance
| Surety 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 |
|---|---|
| Net worth requirement | Greater of $100,000 or a sliding scale of total assets (3% of the first $100 million, 2% of $100 million to $1 billion, 0.5% above $1 billion) |
| Renewal cadence | Annual |
| FinCEN MSB registration | Required |
Application process
To obtain a money transmitter license in Colorado, applicants generally need to submit a completed application to the Colorado Division of Banking, provide a surety bond of $25,000-$500,000, demonstrate minimum net worth of $100,000, provide audited financial statements, implement a comprehensive BSA/AML filings program, and pass background checks for all control persons. Many states now accept applications through NMLS. The application process typically takes 3-12 months depending on the state and complexity of the applicant's business model.
Renewals
Money transmitter licenses in Colorado generally require annual renewal. Renewal typically requires submission of audited financial statements, updated surety bond, quarterly or annual transaction reports, BSA/AML filing documentation, and payment of renewal fees. Some states require call report filings on a quarterly basis throughout the year.
Money transmitters operating in Colorado are also generally expected to register with FinCEN as a money services business (MSB) and implement a comprehensive BSA/AML filings program. This includes appointing a filings officer, developing written policies and procedures, conducting employee training, filing Currency Transaction Reports (CTRs), and submitting Suspicious Activity Reports (SARs). Colorado may have specific requirements for cryptocurrency and virtual currency businesses.
Key statutes
- Money transmitter net worth (HB25-1201) (Colorado Money Transmitters Act, as amended by HB25-1201) . HB25-1201 conformed Colorado to the Money Transmission Modernization Act, including tangible net worth of the greater of $100,000 or the tiered percentage of total assets.
- Colorado Money Transmission Modernization Act (C.R.S. § 11-110-1002) . Sets money transmission surety bond at the greater of $250,000 or 100% of average daily money transmission liability, capped at $1,000,000.
Federal baseline
Federal law applies in every state, not just this one.
- Bank Secrecy Act (31 U.S.C. § 5311) . Federal BSA/AML requirements for money services businesses
