money transmitter
Virginia Money Transmitter Laws & Licensing
Complete guide to money transmitter licensing in Virginia. Covers application requirements, surety bond amounts, net worth minimums, FinCEN registration, and key statutes governing money transmission in Virginia.
Virginia money transmitter requirements at a glance
| Surety bond | Greater of $100,000 or 100% of average daily money transmission liability in Virginia for the most recent quarter, capped at $1,000,000; a flat $100,000 where tangible net worth exceeds 10% of total assets |
|---|---|
| Net worth requirement | Greater of $100,000 or 3% of total assets up to $100 million; $3 million plus 2% of assets above $100 million; $21 million plus 0.5% of assets above $1 billion |
| Renewal cadence | Annual |
| FinCEN MSB registration | Required |
Application process
Virginia money transmitters are licensed by the Bureau of Financial Institutions at the State Corporation Commission. Chapter 19.1 of Title 6.2, enacted by HB 1942 (2025 c. 214), took effect on July 1, 2026 and replaced the previous requirements.
Post security of the greater of $100,000 or 100% of your average daily money transmission liability in Virginia for the most recent quarter, capped at $1,000,000. If your tangible net worth exceeds 10% of total assets, a flat $100,000 satisfies the requirement (Va. Code 6.2-1951). Maintain tangible net worth of at least $100,000 or 3% of total assets up to $100 million, rising to $3 million plus 2% of assets above $100 million and $21 million plus 0.5% above $1 billion (Va. Code 6.2-1950).
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 Virginia 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 Virginia 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). Virginia may have specific requirements for cryptocurrency and virtual currency businesses.
Key statutes
- Money Transmitters, surety bond (effective July 1, 2026) (Va. Code § 6.2-1951) . Sets the security at the greater of $100,000 or 100% of average daily money transmission liability in the Commonwealth, up to $1,000,000, or a flat $100,000 where tangible net worth exceeds 10% of total assets.
- Money Transmitters, net worth (effective July 1, 2026) (Va. Code § 6.2-1950) . Requires tangible net worth of the greater of $100,000 or 3% of total assets up to $100 million, rising to $3 million plus 2% of assets above $100 million and $21 million plus 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
