money transmitter
Maryland Money Transmitter Laws & Licensing
Complete guide to money transmitter licensing in Maryland. Covers application requirements, surety bond amounts, net worth minimums, FinCEN registration, and key statutes governing money transmission in Maryland.
Maryland money transmitter requirements at a glance
| Surety 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 |
|---|---|
| Net worth requirement | $150,000, plus $10,000 for each additional licensed location or authorized delegate, capped at $500,000 |
| Renewal cadence | Annual |
| FinCEN MSB registration | Required |
Application process
To obtain a money transmitter license in Maryland, applicants generally need to submit a completed application to the Maryland DLLR, 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 Maryland 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 Maryland 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). Maryland may have specific requirements for cryptocurrency and virtual currency businesses.
Key statutes
- Net worth requirement (Md. Code, Fin. Inst. § 12-406) . Requires net worth of at least $150,000, plus $10,000 for each licensed location or authorized delegate, up to a maximum of $500,000.
- Maryland Financial Institutions Article - Maryland Money Transmission Act (Md. Code, Fin. Inst. § 12-412) . Sets the money transmission surety bond at the greater of $150,000 or 100% of average daily money transmission liability in the State, up to a maximum of $2,000,000.
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
