A money transmitter license (MTL) is a state licence: in the United States each state's financial regulator issues its own, and there is no federal MTL. A business that accepts money or crypto from customers and transmits it usually needs two layers of authorisation: registration with FinCEN as a money services business (MSB) and a money transmitter licence in each state where it serves customers, with state applications filed through NMLS. Montana is the only state that does not regulate money transmitters, so a company serving customers nationwide works state by state.
In short:

Money transmission means accepting money or value from one person and transmitting it to another person or location. For crypto, FinCEN's 2019 guidance (FIN-2019-G001) restates that exchangers and administrators of convertible virtual currency generally qualify as money transmitters under the Bank Secrecy Act, while users do not.
Each state defines money transmission and its exemptions in its own law, so the same business model can need a licence in one state and fall under an exemption in another. New York regulates virtual currency business separately through the BitLicense: see crypto licence in New York (BitLicense).

Every state except Montana regulates money transmitters. The Montana Division of Banking and Financial Institutions states that it does not regulate money transmitters and that money transmission is not defined under Montana law. The District of Columbia and Puerto Rico also manage MSB licences in NMLS. Customers in other states still trigger those states' licensing rules, FinCEN registration applies regardless of the state, and the Montana Division notes that a money transmitter may still need other Montana licences depending on what else it does.
The MTMA is a model law released by the Conference of State Bank Supervisors (CSBS) for state adoption on 9 September 2021. It gives states a single set of standards for definitions, exemptions, control, the licensing process, net worth, bonding and permissible investments, which makes multistate licensing and joint examinations easier.
According to the CSBS enactment table dated 8 October 2026, 35 states have enacted the MTMA: 31 in full and 4 in part (California, Connecticut, Rhode Island and Utah). In three of them the act takes effect later: Oklahoma on 1 November 2026, Alaska on 1 July 2027, and Delaware on 6 July 2027 or earlier if implementing regulations are published. The CSBS overview page, dated 3 September 2026, gives the earlier count of thirty-one states. CSBS reports that money transmitters licensed in at least one MTMA state account for 99% of reported money transmission activity.
Where a state follows the MTMA, the regulator must approve or deny the application within 120 days after the date it determines the file complete, and may extend this for good cause; under the model law an application left undecided after that period is treated as approved. For a BitLicense, the New York regulation sets 90 days from the date the application is deemed complete, also extendable. In both cases the clock starts only when the file is complete; NYDFS names missing documents as the most common reason for delays.
| Requirement | Rule in the MTMA model law |
|---|---|
| Tangible net worth | The greater of $100,000 or 3% of total assets up to $100 million, 2% of additional assets from $100 million to $1 billion and 0.5% above $1 billion (Section 10.01) |
| Surety bond | The greater of $100,000 or 100% of average daily money transmission liability in the state, up to $500,000 (Section 10.02) |
| Permissible investments | Assets that cover outstanding money transmission obligations (Section 10.03) |
States outside the MTMA set their own amounts. New York sets BitLicense capital individually for each licensee (23 NYCRR 200.8).
Under 18 U.S.C. §1960, whoever knowingly conducts, controls, manages or owns an unlicensed money transmitting business faces a fine, up to 5 years in prison, or both. A business counts as unlicensed if it operates without a required state licence where that is a misdemeanor or felony under state law (whether or not the defendant knew a licence was required), fails to register with FinCEN, or transmits funds known to come from crime or intended to support unlawful activity.
Failure to register with FinCEN also carries a civil penalty of $5,000 per violation under 31 U.S.C. 5330(e), adjusted for inflation to $10,556 for penalties assessed on or after 17 January 2025 (31 CFR 1010.821); each day the violation continues is a separate violation. States add their own administrative and criminal penalties.
A licensing mistake here is a criminal-law risk under §1960, and state definitions differ in details, so the work is done by a team under a written contract that maps every state. Our fee is quoted in writing after the review. Request a free MTL review.
Other markets: crypto licences by country, MSB registration in Canada.
Map the states where you serve customers, register with FinCEN as an MSB, file a state application in NMLS for each state that requires a licence, post the surety bond and show the required net worth, then answer each regulator's questions until approval.
All states except Montana regulate money transmitters; the District of Columbia and Puerto Rico also manage MSB licences in NMLS. Whether your model needs a licence in a given state depends on that state's definition of money transmission and its exemptions.
Under the MTMA model law the regulator decides within 120 days after the application is complete; New York decides on a BitLicense within 90 days after the application is deemed complete. Both periods can be extended, and preparing a complete file is part of the timeline.
Federal law (18 U.S.C. §1960) provides for a fine, up to 5 years in prison, or both. Failure to register with FinCEN adds a civil penalty of up to $10,556 per violation per day for penalties assessed from 17 January 2025.
Separate licences and bonds per state, net worth and permissible investments, MSB Call Reports, renewals, approval of changes in control, and state examinations, which the MTMA encourages states to coordinate through multistate supervision (Section 4.04).
FinCEN guidance says exchangers and administrators of convertible virtual currency generally qualify as money transmitters, and whether a state licence is needed depends on each state's definition of money transmission. New York requires a BitLicense for virtual currency business activity.
FinCEN registration is federal and covers the Bank Secrecy Act obligations. An MTL is a state licence. A money transmitter usually needs both.
Facts checked against the sources above on 11 October 2026. This page is general information about the regulatory framework; requirements for a specific business depend on its model and states.