Money Transmitter Licensing
Our team takes care of everything you need about cryptocurrency and fiat currencies, including helping clients who want to accept, hold, or transmit those currencies without getting a money transmitter license.
If you’re acting as a money services business, you generally would need to do this with the state and federal government.
Each and every state in the country has their own money transmitter license requirements, and our team is able to help you get the advice and support you need as a fintech and digital currency business so you can employ the best strategy and get through all of the different applications with ease.
Each and every state in the country has their own money transmitter license requirements, and our team is able to help you get the advice and support you need as a fintech and digital currency business so you can employ the best strategy and get through all of the different applications with ease.
Attorney Experience
We’ve advised digital exchanges and more to launch exchanges in Europe and the Middle East using US Alternative Trading System registration, FINRA registration, money transmitter licensing, and broker-dealer registration, plus we obtained a New York BitLicense.
We advised a digital accounting and management provider about getting their money transmitter license and a New York BitLicense so that they could incorporate crypto/fiat payment systems and conversion, as well as a digital wallet for their platform.
We advised a decentralized e-commerce platform about getting a money transmitter license and a New York BitLicense so they could offer crypto/fiat exchange services and escrow services with a smart wallet.
We advised a decentralized e-commerce platform about getting a money transmitter license and a New York BitLicense so they could offer crypto/fiat exchange services and escrow services with a smart wallet.
Helping Our Clients Through the Process
Just about any business that is going to accept and transmit funds is considered an MSB or money services business. And that means they’re going to need an MTL for each state where they are conducting business. That can be a lot of work, which is why you may want to get a bit of help along the way.
Registering for the federal license is relatively simple, but when you’re registering for the state systems you’re looking at something else entirely. This legislation is entirely different between the states, and each offers a different set of requirements and regulations. Plus, New York has a BitLicense that’s required for anyone involved in virtual currency business activity.
The MTL requirements vary but generally you’ll be required to
- Register with the Financial Crimes Enforcement Network (FinCEN)
- Conduct background checks
- Pay application fees and surety bonds
- Maintain permissible investments
- Calculate minimum net worth
- Create a business plan and compliance program
- Pay MTL-related costs
Even worse, the processing time takes different amounts from one state to another, lasting up to 2 years, and can cost upwards of $1 million just to get started. And that doesn’t include things like legal fees.
Since there is no consistent system in place most companies need to have some type of strategy to get through the process. For some, this means prioritizing certain states first even though it means that they will be prohibited from doing business in areas where they haven’t completed the process.
Since there is no consistent system in place most companies need to have some type of strategy to get through the process. For some, this means prioritizing certain states first even though it means that they will be prohibited from doing business in areas where they haven’t completed the process.
Getting Through Every State
Our team of lawyers can help clients get through the entire MTL application process for each state. This includes:
- Developing a nationwide strategy for cryptocurrency trading platforms and exchanges and traditional businesses
- Submitting all required applications for each state
- Preparing the business plan, summary of operations, financial statements, affidavits, and any other required paperwork
- Taking care of all surety bonds
- Executing FinCEN registration
- Filling out any necessary corporate actions including qualification for out-of-state companies, provision of registered agents, drafting and amending corporate governance documents
- Developing compliance programs, including anti-money laundering
- Representing clients for any and all communication with both state and federal agencies
- Maintaining and completing renewal for MTLs