money transmitter
Puerto Rico Money Transmitter Laws & Licensing
Complete guide to money transmitter licensing in Puerto Rico. Covers application requirements, surety bond amounts, net worth minimums, FinCEN registration, and key statutes governing money transmission in Puerto Rico.
Puerto Rico money transmitter requirements at a glance
| Surety bond | $25,000 |
|---|---|
| Minimum net worth | $100,000 |
| Renewal cadence | Annual |
| FinCEN MSB registration | Required |
Application process
To obtain a money transmitter license in Puerto Rico, applicants generally need to submit a completed application to the Puerto Rico 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 Puerto Rico 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 Puerto Rico 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). Puerto Rico may have specific requirements for cryptocurrency and virtual currency businesses.
