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.
- All 50 states
- Specialist support
- Human review on every filing
Talk to an expert
Tell us about your situation and we will follow up within one business day.
NYDFS Virtual Currency
Who needs a New York BitLicense?
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.
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.
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Discover
We connect you with independent attorneys to pin down which licenses you need.
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Prepare
Your licensing specialist assembles each application; our software handles the repetitive work.
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Review
That same specialist reviews every filing before it reaches a regulator.
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Approve
We submit, track each application, and keep you posted until the license is granted.
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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
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Specialists who know the answer
Decades of licensing specialists, so the answer is right rather than guessed.
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Trusted relationships with the regulator
Direct, trusted relationships with regulators, so we ask the question instead of assuming the answer.
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Living internal checklists
Checklists that update the moment we learn something new, so deficiencies are caught before they happen.
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
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.
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.
Application Preparation
We prepare the full NYDFS submission, including business plans, financial statements, biographical and fingerprint materials, and supporting policies.
NYDFS Coordination
We manage communication with the department, respond to deficiency letters, and shepherd the application through its extended review.
Ongoing Compliance
After approval we manage reporting, capital and bond maintenance, change applications, and examination readiness.
FAQ
Frequently Asked Questions
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.
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100%
accepted by the second submission
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. The few that need a second pass are accepted then, with no avoidable back and forth.
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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.
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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.
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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.
Ready to Apply?
Start Your Application Now
Save and resume from any step. An expert reviews every submission within one business day.
Money transmitter regulations by state
Money transmitter regulations by state
Where you operate shapes what you file
52 of 52 jurisdictions documented. Pick a state to see the regulator, the license rule, and the bond.
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Stay Ahead of the Rules
Recent rule changes, deadline announcements, and state agency updates we are tracking for you.
No regulatory updates to report right now. Our team is monitoring the agencies and will surface changes here as soon as they land.
Start Your BitLicense Application
Contact us for a BitLicense readiness assessment. We will tell you what the NYDFS application requires for your model and how to sequence it with the rest of your licensing.