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NYDFS Virtual Currency

New York BitLicense

The BitLicense is the most demanding crypto regime in the country. We prepare the full NYDFS application, build the compliance and cybersecurity program behind it, and manage the year-plus review so you do not lose access to the New York market.

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  • Human review on every filing

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Reviewed by Cornerstone Staff28 years of financial services state licensing experienceLast verified August 6, 2026

NYDFS Virtual Currency

Who needs a New York BitLicense?

As of 2026, any business engaged in virtual currency business activity involving New York or a New York resident generally needs a BitLicense from the New York Department of Financial Services. The framework, set out in 23 NYCRR Part 200, covers capital requirements, custody and consumer protection, a written cybersecurity program, anti-money-laundering obligations, and detailed disclosure and reporting duties. The application is long and the review is rigorous, so a single BitLicense commonly takes more than a year to obtain, and a holder may also need a New York money transmitter license depending on its activity.

Who Needs a BitLicense?
Any business conducting virtual currency business activity involving New York or a New York resident generally needs a BitLicense. That includes receiving, transmitting, storing, buying, selling, exchanging, controlling, or issuing virtual currency. Merchants using crypto only for their own purchases and chartered banking organizations are excluded.
How Long Does a BitLicense Take?
The review commonly takes more than a year. NYDFS conducts a thorough review and typically issues one or more deficiency letters. A complete, well-documented initial application and fast responses to follow-up requests are the best way to keep the timeline as short as possible.

Money transmitter licensing by the numbers

US jurisdictions require a money transmitter license
51 of 52 US jurisdictions require a money transmitter license Source: state regulator statutes compiled in our state-law index, verified August 2026. Money transmitter license state laws
statutory surety bond range across licensing states
$10,000 to $1,000,000 statutory surety bond range across licensing states Source: state regulator statutes compiled in our state-law index, verified August 2026. Money transmitter license state laws

The Cornerstone Way

A repeatable method, from first filing to every renewal

Faster licenses, less effort on your side, fewer mistakes, and fewer headaches. It is the way we combine experienced specialists, intentional AI, and the Atlas platform across one sequenced process.

  1. Discover

    We connect you with independent attorneys to pin down which licenses you need.

  2. Prepare

    Your licensing specialist assembles each application; our software handles the repetitive work.

  3. Review

    That same specialist reviews every filing before it reaches a regulator.

  4. Approve

    We submit, track each application, and keep you posted until the license is granted.

  5. Renew

    We file every renewal ahead of its deadline in Atlas so licenses stay current.

Anyone can list five steps. Here is what makes ours hold up.

The shortcut

The common approach is to scrape the web for an answer and hope it is current. When the rules change, or the page was wrong to begin with, the mistake surfaces as a deficiency after the filing is in, when it costs the most time.

The Cornerstone Way

  • Specialists who know the answer

    Decades of licensing specialists, so the answer is right rather than guessed.

  • Trusted relationships with the regulator

    Direct, trusted relationships with regulators, so we ask the question instead of assuming the answer.

  • Living internal checklists

    Checklists that update the moment we learn something new, so deficiencies are caught before they happen.

99.995% On-time submissions in 2025. Filed correctly and on time, so you start operating sooner without avoidable back and forth.
See how it works

Licensing Virtual Currency Activity in New York

New York requires a BitLicense from the Department of Financial Services for any business engaged in virtual currency business activity involving New York or a New York resident. The framework, set out in 23 NYCRR Part 200, is comprehensive. It covers capital requirements, custody and consumer protection, a written cybersecurity program, AML and BSA obligations, and detailed disclosure and reporting duties. The application is long, the review is rigorous, and a single license commonly takes more than a year to obtain. Cornerstone has worked inside this regime since its early years, and we manage the full BitLicense process so a New York presence does not stall your roadmap.

What Triggers a BitLicense

Virtual currency business activity under Part 200 is broad. If you receive virtual currency for transmission, transmit it, store or hold it on behalf of others, buy and sell it as a customer business, exchange it, or control or issue a virtual currency, you generally need a BitLicense to serve New York. Banking organizations and merchants using crypto only to buy goods or services for their own account are outside the rule.

The first step is a careful read of your activity against the statute. Some models that look like simple software fall inside the rule once they touch custody, and some that look regulated fall outside it. We do that analysis before you commit to the filing.

Core BitLicense Requirements

NYDFS expects a complete picture of your business, your finances, and your controls before it will approve a license.

Capital Requirements

NYDFS sets a minimum capital level for each applicant based on its assessment of the business, its assets, and its risk. Applicants must show they can hold the required capital on an ongoing basis.

Custody and Consumer Protection

Licensees must hold customer virtual currency in the same type and amount owed, maintain a surety bond or trust account for the benefit of customers, and provide clear consumer disclosures.

Cybersecurity Program

A written cybersecurity program is mandatory, covering audit trails, penetration testing, a chief information security officer function, and an incident response plan.

AML and BSA Program

Applicants must maintain an anti-money-laundering program with customer identification, transaction monitoring, and suspicious activity reporting consistent with federal expectations.

Fingerprinting and Background Checks

Principal officers, directors, and significant stakeholders must submit fingerprints and background information for NYDFS review.

Timeline and Cost

A BitLicense application is a major undertaking. The nonrefundable application fee alone is 5,000 dollars, and applicants should budget significant time and resources for the supporting program build. NYDFS review commonly runs well beyond a year as the department issues deficiency letters and requests follow-up information.

We shorten the path where we can by submitting a complete, well-documented application the first time, responding quickly to deficiency letters, and keeping a single point of contact who knows both your file and the NYDFS process. For businesses that also need broader coverage, we sequence the BitLicense alongside money transmitter filings in other states so the longest review is running in parallel rather than blocking everything else.

Ongoing Obligations After Approval

The BitLicense is a living obligation, not a one-time approval. Licensees file regular financial statements and reports, maintain their capital and bond levels, keep the cybersecurity and AML programs current, and seek NYDFS approval before material changes such as new products or a change of control.

Cornerstone stays with you after approval. We track every reporting deadline, prepare change applications, manage bond riders as requirements move, and keep your program documentation examination-ready. In Atlas you can see your New York status alongside every other license in your portfolio, with due dates and open tasks in one view.

Checklist

New York BitLicense checklist

01

Activity Assessment

We test your business against 23 NYCRR Part 200 to confirm whether a BitLicense is required and which activities fall inside the rule.

02

Program Build

We help assemble the capital plan, custody and consumer protection policies, cybersecurity program, and AML and BSA program that the application must document.

03

Application Preparation

We prepare the full NYDFS submission, including business plans, financial statements, biographical and fingerprint materials, and supporting policies.

04

NYDFS Coordination

We manage communication with the department, respond to deficiency letters, and shepherd the application through its extended review.

05

Ongoing Compliance

After approval we manage reporting, capital and bond maintenance, change applications, and examination readiness.

FAQ

Frequently Asked Questions

Related Pages

Cryptocurrency Licensing Money Transmitter License Crypto Exchange & Trading Platform Licensing

Ready for licensing the Cornerstone way?

Anyone can file paperwork and hand you a license. Licensing the Cornerstone way is the same outcome done right: fewer deficiencies, a faster path to approval, less work on your plate, and renewals that stay managed long after you go live.

  • Right the First Time

    We prepare and file it correctly the first time, so most applications are accepted on the first submission instead of bouncing back with correction notices.

  • 25 to 30x

    faster than doing it yourself

    Faster to Licensed

    Start applications for 12 to 15 states on your own and it crawls. Hand those same states to a Cornerstone Licensing Specialist and they get you licensed 25 to 30 times faster, pursuing every state at once and knowing what each examiner expects.

  • 97-98.5%

    of the work handled for you

    Less Work for You

    You answer questions once, then Cornerstone generates and files the license. Your part is the few minutes it takes to confirm the details.

  • 99.995%

    on-time submissions in 2025

    Renewals That Stay Managed

    Every license, bond, and renewal date lives in Atlas and is tracked for you, so nothing lapses once you are approved.

See what the Cornerstone way means

Ready to Apply?

Start Your Application Now

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Money transmitter regulations by state

Money transmitter regulations by state

We are refreshing our state-by-state summaries for money transmitter. Browse the states we have published below.

  • Alabama
    Regulator: Alabama Securities Commission
    License: yes
    Bond: Not less than $100,000, or the average daily outstanding money-received-for-transmission obligations in Alabama plus 50% of average daily outstanding payment-instrument and stored-value obligations in Alabama, whichever is greater; commission may raise to a maximum of $5,000,000
    Open Alabama guide Official regulator site
  • Alaska
    Regulator: Alaska Department of Commerce, Community, and Economic Development, Division of Banking and Securities
    License: yes
    Bond: $25,000 plus $5,000 for each location, not exceeding a total addition of $125,000 (base + additions); department may raise to a maximum of $500,000 based on financial condition
    Open Alaska guide Official regulator site
  • Arizona
    Regulator: Arizona Department of Insurance and Financial Institutions
    License: yes
    Bond: Greater of $25,000 or 100% of the licensee's average daily money transmission liability in Arizona (most recent three-month period), up to a maximum of $500,000; $25,000 if tangible net worth exceeds 10% of total assets
    Open Arizona guide Official regulator site
  • Arkansas
    Regulator: Arkansas Securities Department
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in Arkansas (most recent three-month period), up to a maximum of $500,000; $100,000 if tangible net worth exceeds 10% of total assets
    Open Arkansas guide Official regulator site
  • California
    Regulator: California Department of Financial Protection and Innovation (DFPI)
    License: yes
    Bond: $250,000 to $7,000,000 for receiving money for transmission; selling or issuing payment instruments or stored value carries a separate $500,000 to $2,000,000 bond, and the two are cumulative
    Open California guide Official regulator site
  • Colorado
    Regulator: Colorado Department of Regulatory Agencies, Division of Banking
    License: yes
    Bond: Greater of $250,000 or 100% of the licensee's average daily money transmission liability in Colorado (most recent three-month period), up to a maximum of $1,000,000
    Open Colorado guide Official regulator site
  • Connecticut
    Regulator: Connecticut Department of Banking
    License: yes
    Bond: Non-virtual-currency transmitters: not less than $300,000 (avg weekly transmissions < $300,000), $500,000 ($300,000-$500,000), or $1,000,000 (> $500,000); virtual-currency transmitters: amount set by the commissioner
    Open Connecticut guide Official regulator site
  • Delaware
    Regulator: Delaware Office of the State Bank Commissioner
    License: yes
    Bond: $25,000, plus $5,000 for each location in excess of one, not to exceed $250,000 total
    Open Delaware guide Official regulator site
  • District of Columbia
    Regulator: District of Columbia Department of Insurance, Securities and Banking
    License: yes
    Bond: $50,000, increased by $10,000 per additional location, not to exceed $250,000 total
    Open District of Columbia guide Official regulator site
  • Florida
    Regulator: Florida Office of Financial Regulation
    License: yes
    Bond: Amount specified by rule, but not less than $50,000 and not exceeding $2,000,000 (rule allows for financial condition, number of locations, and anticipated volume)
    Open Florida guide Official regulator site
  • Georgia
    Regulator: Georgia Department of Banking and Finance
    License: yes
    Bond: $250,000 minimum; the Department may require additional coverage, capped at $2,000,000
    Open Georgia guide Official regulator site
  • Hawaii
    Regulator: Department of Commerce and Consumer Affairs, Division of Financial Institutions
    License: yes
    Bond: $100,000 for the initial 12 months of licensure; commissioner may increase up to a maximum of $500,000 based on impaired financial condition
    Open Hawaii guide Official regulator site
  • Idaho
    Regulator: Idaho Department of Finance
    License: yes
    Bond: $10,000, increased by $5,000 per additional location/authorized representative, up to a maximum of $500,000
    Open Idaho guide Official regulator site
  • Illinois
    Regulator: Illinois Department of Financial and Professional Regulation, Division of Financial Institutions
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in Illinois for the most recently completed quarter, capped at $2,000,000
    Open Illinois guide Official regulator site
  • Indiana
    Regulator: Indiana Department of Financial Institutions
    License: yes
    Bond: Greater of $300,000 or the licensee's average daily money transmission liability in Indiana for the most recent calendar quarter, capped at $500,000
    Open Indiana guide Official regulator site
  • Iowa
    Regulator: Iowa Division of Banking
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in Iowa for the most recent 3-month period, capped at $500,000
    Open Iowa guide Official regulator site
  • Kansas
    Regulator: Office of the State Bank Commissioner
    License: yes
    Bond: Greater of $200,000 or 100% of the licensee's average daily money transmission liability in Kansas for the most recent 3-month period, capped at $1,000,000 (or $200,000 if tangible net worth exceeds 10% of total assets)
    Open Kansas guide Official regulator site
  • Kentucky
    Regulator: Kentucky Department of Financial Institutions
    License: yes
    Bond: At least $500,000; commissioner may increase up to a maximum of $5,000,000 based on financial condition, net worth, or transaction volume
    Open Kentucky guide Official regulator site
  • Louisiana
    Regulator: Louisiana Office of Financial Institutions
    License: yes
    Bond: Minimum $100,000, up to a maximum of $500,000, or a higher amount deemed appropriate by the Commissioner up to a maximum of $1,000,000
    Open Louisiana guide Official regulator site
  • Maine
    Regulator: Bureau of Consumer Credit Protection
    License: yes
    Bond: $100,000
    Open Maine guide Official regulator site
  • Maryland
    Regulator: Office of the Commissioner of Financial Regulation
    License: yes
    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
    Open Maryland guide Official regulator site
  • Massachusetts
    Regulator: Massachusetts Division of Banks
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in Massachusetts over the most recently completed three months, capped at $500,000
    Open Massachusetts guide Official regulator site
  • Michigan
    Regulator: Department of Insurance and Financial Services (DIFS)
    License: yes
    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
    Open Michigan guide Official regulator site
  • Minnesota
    Regulator: Minnesota Department of Commerce
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in Minnesota (most recent 3-month period), capped at $500,000
    Open Minnesota guide Official regulator site
  • Mississippi
    Regulator: Mississippi Department of Banking and Consumer Finance
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in Mississippi (most recent 3-month period), capped at $500,000 (commissioner may raise up to $1,000,000)
    Open Mississippi guide Official regulator site
  • Missouri
    Regulator: Missouri Division of Finance
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in Missouri (most recent 3-month period), capped at $500,000
    Open Missouri guide Official regulator site
  • Montana
    Regulator: Montana Division of Banking
    License: no
    Bond: Not required (no state license needed)
    Open Montana guide Official regulator site
  • Nebraska
    Regulator: Nebraska Department of Banking and Finance
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in Nebraska (most recent 3-month period), capped at $500,000
    Open Nebraska guide Official regulator site
  • Nevada
    Regulator: State of Nevada Department of Business and Industry, Financial Institutions Division
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in Nevada (most recently completed quarter), capped at $500,000
    Open Nevada guide Official regulator site
  • New Hampshire
    Regulator: New Hampshire Banking Department
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in New Hampshire (most recent 3-month period), capped at $500,000
    Open New Hampshire guide Official regulator site
  • New Jersey
    Regulator: New Jersey Department of Banking and Insurance
    License: yes
    Bond: Amount set by the Commissioner by regulation, not less than $100,000 and not more than $1,000,000 (money transmitter). Foreign money transmitters use a volume-based schedule starting at $25,000.
    Open New Jersey guide Official regulator site
  • New Mexico
    Regulator: New Mexico Regulation and Licensing Department, Financial Institutions Division
    License: yes
    Bond: Greater of $300,000 or 1% of the licensee's total yearly dollar volume of money transmission business in New Mexico (or projected first-year volume), up to a maximum of $2,000,000
    Open New Mexico guide Official regulator site
  • New York
    Regulator: New York State Department of Financial Services
    License: yes
    Bond: Set by the Superintendent of Financial Services for each licensee; New York Banking Law Article 13-B fixes no dollar amount, so confirm the required bond with DFS before relying on a figure
    Open New York guide Official regulator site
  • North Carolina
    Regulator: North Carolina Office of the Commissioner of Banks
    License: yes
    Bond: $150,000 base (transmission volume in NC up to $1,000,000); increases with NC transmission volume (e.g., $175,000, $200,000, and higher tiers)
    Open North Carolina guide Official regulator site
  • North Dakota
    Regulator: North Dakota Department of Financial Institutions
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in North Dakota (most recent 3-month period), capped at $500,000
    Open North Dakota guide Official regulator site
  • Ohio
    Regulator: Ohio Department of Commerce, Division of Financial Institutions
    License: yes
    Bond: Security device (surety bond or permitted alternative) of not less than $300,000, up to a maximum of $2,000,000 as the Superintendent finds appropriate
    Open Ohio guide Official regulator site
  • Oklahoma
    Regulator: Oklahoma State Banking Department
    License: yes
    Bond: $50,000 plus $10,000 per authorized-delegate location, not exceeding a total of $500,000
    Open Oklahoma guide Official regulator site
  • Oregon
    Regulator: Oregon Department of Consumer and Business Services, Division of Financial Regulation
    License: yes
    Bond: $25,000, increased by $5,000 per additional location/authorized delegate (amount otherwise set by rule/Director)
    Open Oregon guide Official regulator site
  • Pennsylvania
    Regulator: Pennsylvania Department of Banking and Securities
    License: yes
    Bond: Bond in the penal sum of $1,000,000 (department may require additional bond based on average daily outstanding transmission balance)
    Open Pennsylvania guide Official regulator site
  • Puerto Rico
    Regulator: Puerto Rico Office of the Commissioner of Financial Institutions (OCIF)
    License: yes
    Bond: $500,000 for a single office, increased by $10,000 per additional office or authorized agent (Commissioner may require a higher bond based on business volume/financial condition)
    Open Puerto Rico guide Official regulator site
  • Rhode Island
    Regulator: Rhode Island Department of Business Regulation, Division of Banking
    License: yes
    Bond: $50,000 (currency transmission licensees); department may accept an alternative security form if a surety bond is not commercially available at reasonable cost
    Open Rhode Island guide Official regulator site
  • South Carolina
    Regulator: South Carolina Attorney General (Commissioner under the South Carolina Uniform Money Services Act)
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in South Carolina (most recent 3 months), capped at $500,000; alternatively $100,000 if tangible net worth exceeds 10% of total assets
    Open South Carolina guide Official regulator site
  • South Dakota
    Regulator: South Dakota Division of Banking
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in South Dakota (most recent 3 months), capped at $500,000; alternatively $100,000 if tangible net worth exceeds 10% of total assets
    Open South Dakota guide Official regulator site
  • Tennessee
    Regulator: Tennessee Department of Financial Institutions
    License: yes
    Bond: Greater of $50,000 or 100% of average daily money transmission liability in Tennessee (most recent calendar quarter), capped at $800,000
    Open Tennessee guide Official regulator site
  • Texas
    Regulator: Texas Department of Banking
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in Texas (most recent 3 months), capped at $500,000; alternatively $100,000 if tangible net worth exceeds 10% of total assets
    Open Texas guide Official regulator site
  • Utah
    Regulator: Utah Department of Financial Institutions
    License: yes
    Bond: Flat minimum surety bond of $50,000
    Open Utah guide Official regulator site
  • Vermont
    Regulator: Vermont Department of Financial Regulation
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in Vermont (most recent 3 months), capped at $2,000,000
    Open Vermont guide Official regulator site
  • Virginia
    Regulator: Virginia State Corporation Commission, Bureau of Financial Institutions
    License: yes
    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
    Open Virginia guide Official regulator site
  • Washington
    Regulator: Washington State Department of Financial Institutions
    License: yes
    Bond: Surety bond based on prior year's money transmission and payment instrument dollar volume; minimum $10,000, not to exceed $550,000
    Open Washington guide Official regulator site
  • West Virginia
    Regulator: West Virginia Division of Financial Institutions
    License: yes
    Bond: $300,000 for money transmission; $100,000 for check or money-order sale or currency exchange; increased by 1% of annual West Virginia volume over $10 million, capped at $1,000,000
    Open West Virginia guide Official regulator site
  • Wisconsin
    Regulator: Wisconsin Department of Financial Institutions
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in Wisconsin (most recent 3 months), capped at $500,000
    Open Wisconsin guide Official regulator site
  • Wyoming
    Regulator: Wyoming Division of Banking
    License: yes
    Bond: $10,000 or 2.5 times outstanding payment instruments, whichever is greater, not to exceed $500,000
    Open Wyoming guide Official regulator site

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