Payment and remittance businesses serving US residents hold a licence in each state that licenses money transmission, filed through NMLS and coordinated across 32 states under the multistate programme.
Selected engagements from more than 250 licences obtained since 2013, for payment, e-money, cryptoasset and consumer credit firms.
Volkswagen
Payment InstitutionObtained Nexpay’s FCA Authorised Payment Institution licence.
Electronic Money InstitutionObtained Dzing Finance’s FCA Authorised Electronic Money Institution licence.
Obtained Orbital’s FCA Authorised Payment Institution licence.
Our realistic timeline from submission, set against the regulator’s own published figures.
Safeguarding, operating and settlement accounts opened alongside the application, so you trade on authorisation.
Candidates introduced for a compliance officer and senior officers, each assessed against the regulator’s standard.
A reply within three business hours and a written proposal the same day: the licence, the requirements, the cost and the timing.
You will need a compliance officer and senior officers who pass each state’s fingerprint, credit and criminal checks, with extra personal questionnaires in New York.
One engagement and one timetable, from scoping to launch. Speak to an expert about the people, the banking and the technology for this licence.
The regulator’s requirements, capital, timing, fees and the questions firms ask, from the regulator’s own publications.
A business that receives money for transmission or transmits it, issues payment instruments or stored value, or exchanges currency for residents of a state needs that state’s licence. New York Banking Law section 641 provides that no person shall engage in the business of receiving money for transmission or transmitting the same without a licence; Texas Finance Code Chapter 152 licenses money transmission and currency exchange; California licenses money transmitters, including issuers of payment instruments and stored value, under the Money Transmission Act, with exemptions in Financial Code sections 2010 to 2011. Agents of a licensee, called authorised delegates in Texas, are exempt. New York has a separate BitLicense for virtual currency business. Every money services business also registers with FinCEN, a federal registration that confers no right to operate in any state. Applications are filed through NMLS, the Nationwide Multistate Licensing System, in New York, California and most other states, so a national programme means a licence in every state that requires one.
| State | Regulator and law | Tangible net worth | Surety bond or security | Application fee |
|---|---|---|---|---|
| New York | Department of Financial Services; Banking Law Article 13-B | Not published; assessed by the Superintendent | Not less than US$500,000, set by the Superintendent; US$750,000 for traveler’s checks | US$3,000 |
| California | Department of Financial Protection and Innovation; Money Transmission Act, Financial Code from section 2000 | Greater of US$100,000 or 3% of total assets to US$100 million; 2% to US$1 billion; 0.5% above | US$250,000–US$7,000,000 for money received for transmission; US$500,000–US$2,000,000 for payment instruments and stored value; cumulative | US$5,000 |
| Texas | Department of Banking; Finance Code Chapter 152 | Greater of US$100,000 or 3% of assets to US$100 million; US$3 million plus 2% to US$1 billion; US$21 million plus 0.5% above | US$100,000 minimum; up to US$500,000 where net worth is 10% or less of total assets | Set by commission rule |
| Requirement | Amount |
|---|---|
| Tangible net worth, California and Texas (MTMA formula) | Greater of US$100,000 or 3% of total assets up to US$100 million; 2% from US$100 million to US$1 billion; 0.5% above |
| Tangible net worth, New York | Not published; assessed by the Superintendent |
| Surety bond, New York | Not less than US$500,000; US$750,000 for traveler’s checks |
| Surety bond, California | US$250,000–US$7,000,000 for transmission; US$500,000–US$2,000,000 for payment instruments and stored value; cumulative |
| Security, Texas | US$100,000 minimum; up to US$500,000 where net worth is 10% or less of total assets |
Bond amounts in each state scale with volume and financial condition; the aggregate for a national programme is the sum of the amounts each state sets.
| Figure | Value | Source |
|---|---|---|
| Statutory decision period | Texas: 120 days, about 4 months, from a complete application, deemed approved if no decision; New York and California: no statutory period | Texas Finance Code 152.106; NY DFS and California DFPI application pages |
| Application preparation | 6 to 8 weeks | From instruction to submission, including banking in parallel |
| Our realistic timeline | 6 to 8 months after submission for a multistate programme | The firm’s own figure, from the regulator’s published data and its own applications |
Figures published by the regulator are quoted as published and converted to months. The realistic timeline is the firm’s own, for a complete, well-prepared application.
| Item | Amount | Notes |
|---|---|---|
| New York application fee | US$3,000 | Banking Law 641.3; change of control US$3,000; annual assessment charged separately by DFS |
| California application fee | US$5,000 | Financial Code 2032(a); non-refundable |
| Texas application and annual fees | Set by commission rule | Finance Code 152.107; late fees accrue per business day |
| NMLS processing fees | US$120 company, US$25 branch, US$35 individual | At set-up and each annual renewal; credit report and FBI background check fees per individual on top |
| New York BitLicense application | US$5,000 | Separate licence for virtual currency business |
| Professional fees | Fixed, in writing | Quoted after scoping |
The Money Transmission Modernization Act is the Conference of State Bank Supervisors’ model law. It sets tangible net worth at the greater of US$100,000 or 3% of total assets up to US$100 million, 2% of assets from US$100 million to US$1 billion and 0.5% above, and requires permissible investments at least equal to outstanding money transmission obligations. CSBS lists 31 states that enacted its provisions in full or in part between 2022 and 2025: Arizona, Arkansas, California, Colorado, Connecticut, Georgia, Hawaii, Illinois, Indiana, Iowa, Kansas, Maine, Maryland (by regulation), Massachusetts, Minnesota, Mississippi, Missouri, Nebraska, Nevada, New Hampshire, North Dakota, Rhode Island, South Carolina, South Dakota, Tennessee, Texas, Utah (partial), Vermont, Virginia, West Virginia and Wisconsin. Bills were introduced in 2026 in Alaska, Delaware, Louisiana, Maryland, Michigan, Nebraska and Oklahoma and had not been enacted at the August 2026 update.
The Multistate MSB Licensing Agreement coordinates the review of a money transmitter application across 32 states. One Phase One state reviews the elements common to every state, the business plan, the owners with their background checks, the financial statements and the Bank Secrecy Act anti-money laundering programme, and issues a certification valid for 90 calendar days. Each Phase Two state then reviews its own requirements and issues its own licence. Intake runs through the lead state, the Washington Department of Financial Institutions; the applicant applies to its Phase One state within 30 days of the welcome email and files a complete Phase One application within 60 days.
| Phase | States |
|---|---|
| Phase One (12) | Connecticut, Georgia, Kansas, Maryland, North Carolina, North Dakota, Rhode Island, Tennessee, Texas, Vermont, Washington, Wyoming |
| Phase Two (20) | California, Idaho, Illinois, Indiana, Iowa, Kentucky, Louisiana, Maine, Massachusetts, Michigan, Minnesota, Mississippi, Nebraska, Ohio, Oregon, Pennsylvania, South Carolina, South Dakota, Utah, Wisconsin |
The programme began with 7 states in February 2018 and reached 23 by June 2019. NMLS states that applying for fewer than five states may not give a significant benefit, that the programme is open to companies based in the United States, and that it is closed to applicants serving the marijuana industry, with prior unlicensed activity, or with control persons holding felony convictions. The certification is not a licence and no state is bound by it.
Each state licence covers that state only. There is no federal money transmitter licence and no passporting between states; the multistate agreement coordinates review but, in NMLS’s words, certification is not a licence and no state is bound to approve the applicant. FinCEN registration covers the whole country and confers no right to operate. Groups serving the United States alongside the United Kingdom and the EU hold the state licences with a UK EMI licence or an EU authorisation; the firm obtains each.
The states publish their grounds.
A money transmitter needs operating and settlement accounts with US banks that accept money services businesses, together with the permissible investments each state requires against outstanding obligations. The firm arranges these through institutions that serve the sector, with the FinCEN registration and the AML programme the banks review first. See banking and payment processing.
One in each state that licenses money transmission, with each licence covering that state only; agents of a licensee are exempt in states such as New York and Texas. The multistate agreement coordinates review across 32 states and issues no multistate licence.
Under the model law formula, tangible net worth of the greater of US$100,000 or 3% of total assets up to US$100 million, with lower percentages above. Bonds start at US$500,000 in New York, US$250,000 in California and US$100,000 in Texas and scale with volume.
Texas must decide within 120 days of a complete application, with the licence deemed approved if no decision is made; New York and California publish no period. The firm plans for six to eight months after submission for a multistate programme.
No. FinCEN registration is a federal filing required whether or not a state licence is held; the state licence is what permits the business in each state.
Yes, through a US entity, applying state by state; the multistate agreement is open only to companies based in the United States.
A regulatory advisory firm to payment, e-money and cryptoasset companies since 2013, with more than 250 licences obtained in more than 60 countries. The firm advises on authorisation, compliance, safeguarding, banking and transactions, and builds the white-label payment and card technology its clients launch on.
A written proposal on cost, timing and requirements, the same day: speak to an expert.
This guide is general information for firms considering authorisation and is reviewed against the regulator’s published requirements. It is not legal advice; requirements and fees change, and the regulator’s current publications take precedence.
The requirements, the cost and the timing for your business, in a written proposal the same day.