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MONEY TRANSMITTER LICENSING

For Digital Payment Systems & Crypto-Related Businesses in the U.S.

Summary
Money Transmitter Licensing
Service Type
Money Transmitter Licensing
Provider Name
Dilendorf Law Firm,
60 Broad Street, 24th Floor,New York,New York-10004,
Telephone No.212.457.9797
Area
Alabama Alaska Arizona Arkansas California Colorado Connecticut Delaware Florida Georgia Hawaii Idaho Illinois Indiana Iowa Kansas Kentucky Louisiana Maine Maryland Massachusetts Michigan Minnesota Mississippi Missouri Montana Nebraska Nevada New Hampshire New Jersey New Mexico New York North Carolina North Dakota Ohio Oklahoma Oregon Pennsylvania Rhode Island South Carolina South Dakota Tennessee Texas Utah Vermont Virginia Washington West Virginia Wisconsin Wyoming
Description
Money Transmitter Licensing - the state and federal licenses required to operate as a Money Services Business (MSB)

Dilendorf law Firm assists clients that accept, hold and/or transmit fiat and cryptocurrencies with obtaining and maintaining Money Transmitter Licenses (MTLs) – the state and federal licenses required to operate as a Money Services Business (MSB).

As each U.S. state has separate MTL requirements, our lawyers advise fintech and digital currency businesses on the best MTL strategy and represent the clients throughout the concurrent MTL application procedures.

Summary
Money Transmitter Licensing
Service Type
Money Transmitter Licensing
Provider Name
Dilendorf Law Firm,
60 Broad Street, 24th Floor,New York,New York-10004,
Telephone No.212.457.9797
Area
Alabama Alaska Arizona Arkansas California Colorado Connecticut Delaware Florida Georgia Hawaii Idaho Illinois Indiana Iowa Kansas Kentucky Louisiana Maine Maryland Massachusetts Michigan Minnesota Mississippi Missouri Montana Nebraska Nevada New Hampshire New Jersey New Mexico New York North Carolina North Dakota Ohio Oklahoma Oregon Pennsylvania Rhode Island South Carolina South Dakota Tennessee Texas Utah Vermont Virginia Washington West Virginia Wisconsin Wyoming
Description
Money Transmitter Licensing - the state and federal licenses required to operate as a Money Services Business (MSB)

ATTORNEYS' EXPERIENCE

Advised a digital exchange sponsor and developer that launched several digital exchanges in Europe and the Middle East on U.S. alternative trading system (ATS) registration, broker-dealer registration, FINRA registration, money transmitter licensing and obtaining New York BitLicense

Advised a digital accounting and data management provider on obtaining money transmitter licenses and New York BitLicense in relation to incorporating crypto/fiat payment system, crypto/fiat conversion and digital wallet services into their platform.

Advised a decentralized e-commerce platform on obtaining money transmitter and New York BitLicense in relation to their crypto/fiat exchange services and escrow services via integrated smart wallet.

Helping Clients Navigate Through MTL Requirements and Challenges

With limited exceptions, any business that accepts and transmits funds, including cryptocurrencies, such as bitcoin, will be considered an MSB and require an MTL in each U.S. state where the business operates. Money transmitters are a part of a broader category of MSBs. So, the terms MTL and MSB are related and often used together.

While registration on the federal level is relatively straightforward, the MSB legislation is not harmonized and almost all 53 states and territories have their own regulations, requirements and exceptions for money transmitter licensure. In addition, New York established a separate license for digital currency businesses, the so-called “BitLicense” – a license required to engage in any “virtual currency business activity”.

MTL requirements vary state-by-state but usually include registration with the Financial Crimes Enforcement Network (FinCEN), background checks, application fees, security (surety bond), maintenance of permissible investments, minimum net worth, business plan and a compliance program. MTL-related costs and processing times may differ significantly from state to state, especially compared to New York and California. The costs may exceed a $1 million, excluding legal fees, and the processing times may take from several months to 1-2 years.

Because of the lack of consistent regulation, companies tackling the U.S. MSB market must develop a comprehensive strategy to get MTLs. When obtaining MTLs, a business may choose to prioritize some states and apply first there but will be prohibited from operating in the states where it does not maintain an MTL.

Guiding Clients Through MTL Application Procedures in Every State

Our lawyers advise and assist clients throughout the MTL application process, including the following steps:

  • Developing an MTL strategy nation-wide for traditional businesses and cryptocurrency trading platforms and exchanges;
  • Submitting applications in individual states;
  • Preparing a business plan, summary of historical and current operations, financial statements, affidavits and other required documentation;
  • Acquiring mandatory surety bonds;
  • Completing FinCEN registration;
  • Accomplishing necessary corporate actions, including local qualification of out-of-state companies, provision of registered agents, drafting/amending corporate governance documents;
  • Developing anti-money-laundering (AML) and other compliance programs;
  • Representing clients in communications with the federal and state agencies;
  • Maintaining and renewing MTLs.

Resources:

Federal

State Money Transmitter Licensing Authorities:

State State Money Transmitter Licensing Authority
Alabama Alabama Securities Commission
Alaska Alaska Division of Banking and Securities
Arizona Arizona Department of Financial Institutions
Arkansas Arkansas Securities Department
California California Department of Business Oversight
Colorado Colorado Division of Banking
Connecticut Connecticut Department of Banking
Delaware Delaware Office of the State Bank Commissioner
District of Columbia District of Columbia Department of Insurance, Securities and Banking
Florida Florida Office of Financial Regulation
Georgia Georgia Department of Banking and Finance
Hawaii Hawaii Department of Commerce and Consumer Affairs
Idaho Idaho Department of Finance
Illinois Illinois Department of Financial & Professional Regulation
Indiana Indiana Department of Financial Institutions
Iowa Iowa Division of Banking
Kansas Kansas Office of the State Bank Commissioner
Kentucky Kentucky Department of Financial Institutions
Louisiana Louisiana Office of Financial Institutions
Maine Maine Office of Consumer Credit Protection
Maryland Maryland Department of Labor, Licensing & Regulation
Massachusetts Massachusetts Office of Consumer Affairs and Business Regulation
Michigan Michigan Department of Insurance and Financial Services
Minnesota Minnesota Department of Commerce
Mississippi Mississippi Department of Banking and Consumer Finance
MIssouri MIssouri Division of Finance
Montana Montana Division of Banking & Financial Institutions
Nebraska Nebraska Department of Banking and Finance
Nevada Nevada Department of Business & Industry
New Hampshire New Hampshire Banking Department
New Jersey New Jersey Department of Banking & Finance
New Mexico New Mexico Regulation and Licensing Department
New York New York Department of Financial Services
North Carolina North Carolina Commissioner of Banks
North Dakota North Dakota Department of Financial Institutions
Ohio Ohio Department of Commerce
Oklahoma Oklahoma Banking Department
Oregon Oregon Division of Financial Regulation
Pennsylvania Pennsyvlania Department of Banking and Securities
Rhode Island Rhode Island Department of Business Regulation
South Carolina South Carolina Attorney General
South Dakota South Dakota Division of Banking
Tennessee Tennessee Department of Financial Institutions
Texas Texas Department of Banking
Utah Utah Department of Financial Institutions
Vermont Vermont Department of Financial Regulation
Virginia Virginia State Corporation Commission
Washington Washington State Department of Financial Institutions
West Virgnia West Virginia Division of Financial Institutions
Wisconsin Wisconsin Department of Financial Institutions
Wyoming Wyoming Division of Banking

New York

California

Florida

  • OFR-560-01 – Application to Register as a Money Services Business
  • OFR-560-02 – Location Notification Form
  • OFR-560-03 – Declaration of Intent to Engage in Deferred Presentment Transactions
  • OFR-560-04 – Money Services Business Quarterly Report Form
  • OFR-560-05 – Pledge Agreement
  • OFR-560-06 – Money Services Business Surety Bond Form
  • OFR-560-07 – Security Device Calculation Form
  • Chapter 560, Florida Statutes – Money Services Businesses
  • Rule 69V-560, Florida Administrative Code – Money Transmitters
  • Form OFR-560-09 – Disciplinary Guidelines for Money Services Businesses
  • Security Device Calculation Form

 

Summary
Money Transmitter Licensing
Service Type
Money Transmitter Licensing
Provider Name
Dilendorf Law Firm,
60 Broad Street, 24th Floor,New York,New York-10004,
Telephone No.212.457.9797
Area
Alabama Alaska Arizona Arkansas California Colorado Connecticut Delaware Florida Georgia Hawaii Idaho Illinois Indiana Iowa Kansas Kentucky Louisiana Maine Maryland Massachusetts Michigan Minnesota Mississippi Missouri Montana Nebraska Nevada New Hampshire New Jersey New Mexico New York North Carolina North Dakota Ohio Oklahoma Oregon Pennsylvania Rhode Island South Carolina South Dakota Tennessee Texas Utah Vermont Virginia Washington West Virginia Wisconsin Wyoming
Description
Money Transmitter Licensing - the state and federal licenses required to operate as a Money Services Business (MSB)

For more information about our money transmitter licensing services,

please contact Dilendorf Law Firm by sending an email or calling us at 212.457.9797.

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