Money transmitter license

In the United States, money transmission is regulated mainly by the states. A business that receives money or value from one person to transmit it to another generally needs a licence in each state where it serves customers, and most states consider exchanging or transferring crypto on behalf of customers to fall within that definition. Requirements include surety bonds, minimum net worth, audited financial statements, AML programmes and regular examinations.

At the federal level, FinCEN guidance, notably from 2013 and 2019, treats crypto exchangers and administrators as money services businesses under the Bank Secrecy Act. They must register with FinCEN, run AML and KYC programmes, keep records and file suspicious activity reports. Federal registration does not replace state licences.

Getting licensed in nearly every state is slow and expensive, which is why large US crypto firms often announce their licence counts as a competitive milestone. Some states have adopted a model law to harmonise rules, and New York keeps its separate BitLicense regime.