# New York BitLicense ## 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. 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. ## 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. ## 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. ## How to get licensed 1. **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. 2. **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. 3. **Application Preparation**, We prepare the full NYDFS submission, including business plans, financial statements, biographical and fingerprint materials, and supporting policies. 4. **NYDFS Coordination**, We manage communication with the department, respond to deficiency letters, and shepherd the application through its extended review. 5. **Ongoing Compliance**, After approval we manage reporting, capital and bond maintenance, change applications, and examination readiness. ## Frequently asked questions ### 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. ### How Much Does a BitLicense Cost? The nonrefundable application fee is 5,000 dollars. Beyond that, applicants should budget for the capital requirement set by NYDFS, a surety bond or trust account for customers, and the cost of building the cybersecurity and compliance programs the application requires. ### Is There an Alternative to the BitLicense in New York? A limited purpose trust company charter from NYDFS is an alternative path that also permits virtual currency activity and adds fiduciary powers. We help evaluate whether the BitLicense or a trust charter is the better fit for your model and growth plans. ### Do I Also Need a New York Money Transmitter License? Depending on your activity, a BitLicense holder may also need a New York money transmitter license. We analyze your specific flows and coordinate both filings where required so there are no compliance gaps. ### What Are the Ongoing Requirements? Licensees file regular reports and financial statements, maintain required capital and bonding, keep their cybersecurity and AML programs current, and obtain NYDFS approval before material changes or a change of control. We manage these ongoing obligations for you.