money transmitter
Illinois Money Transmitter Laws & Licensing
Complete guide to money transmitter licensing in Illinois. Covers application requirements, surety bond amounts, net worth minimums, FinCEN registration, and key statutes governing money transmission in Illinois.
Illinois money transmitter requirements at a glance
| Surety 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 |
|---|---|
| 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
Illinois money transmitters are licensed by the Division of Financial Institutions at the Illinois Department of Financial and Professional Regulation. The Uniform Money Transmission Modernization Act (205 ILCS 658, Public Act 103-0991) governs the requirements.
Post security of the greater of $100,000 or 100% of your average daily money transmission liability in Illinois for the most recently completed quarter, capped at $2,000,000 (205 ILCS 658/10-2). IDFPR told licensees on September 30, 2025 that the bond must be filed electronically in NMLS and calculated under 10-2(b) to be eligible for the 2026 renewal. Maintain tangible net worth of at least $100,000 or the sliding-scale amount for larger balance sheets (205 ILCS 658/10-1).
You also provide audited financial statements, run a full BSA/AML program, register with FinCEN as a money services business, and pass background checks for all control persons.
Renewals
Money transmitter licenses in Illinois 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 Illinois 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). Illinois may have specific requirements for cryptocurrency and virtual currency businesses.
Key statutes
- Uniform Money Transmission Modernization Act, surety bond (205 ILCS 658/10-2) . Requires security of the greater of $100,000 or 100% of the licensee's average daily money transmission liability in Illinois for the most recently completed quarter, up to a maximum of $2,000,000.
- Uniform Money Transmission Modernization Act, net worth (205 ILCS 658/10-1) . Requires tangible net worth of the greater of $100,000 or 3% of total assets for the first $100 million, 2% of additional assets to $1 billion, and 0.5% above $1 billion.
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
