money transmitter
Michigan Money Transmitter Laws & Licensing
Complete guide to money transmitter licensing in Michigan. Covers application requirements, surety bond amounts, net worth minimums, FinCEN registration, and key statutes governing money transmission in Michigan.
Michigan money transmitter requirements at a glance
| Surety 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 |
|---|---|
| Net worth requirement | $100,000 at a single location; operating at more than one location or through authorized delegates, the lesser of $100,000 plus $25,000 per location or delegate and $1,000,000 |
| Renewal cadence | Annual |
| FinCEN MSB registration | Required |
Application process
To obtain a money transmitter license in Michigan, applicants generally need to submit a completed application to the Michigan DIFS, 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 Michigan 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 Michigan 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). Michigan may have specific requirements for cryptocurrency and virtual currency businesses.
Key statutes
- Financial statements; net worth (MCL § 487.1013(1)) . Requires net worth above $100,000 for a single location, and for multiple locations or authorized delegates the lesser of $100,000 plus $25,000 per location or delegate and $1,000,000.
- Michigan Money Transmission Services Act (2006 PA 250) (MCL 487.1011 et seq.) . Requires a money transmission licensee to maintain a surety bond of $500,000 for the first location plus $10,000 per additional location/delegate, capped at $1,500,000.
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
