money transmitter
Wisconsin Money Transmitter Laws & Licensing
Complete guide to money transmitter licensing in Wisconsin. Covers application requirements, surety bond amounts, net worth minimums, FinCEN registration, and key statutes governing money transmission in Wisconsin.
Wisconsin money transmitter requirements at a glance
| Surety bond | Greater of $100,000 or 100% of average daily money transmission liability in Wisconsin (most recent 3 months), capped at $500,000 |
|---|---|
| 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
To obtain a money transmitter license in Wisconsin, applicants generally need to submit a completed application to the Wisconsin Department of Financial Institutions, 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 Wisconsin 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 Wisconsin 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). Wisconsin may have specific requirements for cryptocurrency and virtual currency businesses.
Key statutes
- Money transmission tangible net worth (Wis. Stat. § 217.10) . Requires tangible net worth of the greater of $100,000 or a percentage of total assets: 3% of the first $100 million, 2% of assets from $100 million to $1 billion, and 0.5% of assets above $1 billion.
- Model Money Transmission Modernization Law (Wisconsin Money Transmitters chapter) (Wis. Stat. § 217.10(2)) . Sets the minimum required security as the greater of $100,000 or 100% of average daily money transmission liability in the state, capped at $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
