Money Transmitter License (MTL) Readiness Assessment
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Page 1 – Company basics and model
Company Basics
Q1. What stage is your business currently in?
Select...
Idea or pre launch
Product built, not live
Live with first few customers
Live with steady customers and revenue
Q2. Have you registered with FinCEN as a Money Services Business (MSB)?
Select...
Yes, and we have our MSB registration number
We have submitted the registration and are waiting
No, but we plan to register soon
No, and we are not sure if we need to
Q3. What type of legal entity are you using for this business?
Select...
LLC
C Corporation
S Corporation
Sole proprietorship
Partnership
Other
Q4. Does your business deal with fiat money, crypto or digital assets, or both?
Select...
Only fiat money
Only crypto or digital assets
Both fiat and crypto
Q5. At any point, do you hold or control customer funds or assets, even for a short time?
Yes
No
Not sure
Page 2 – Product, flow of funds and banking
Product & Flow
Q6. Which activities best describe what your business does? (Select all that apply)
Sending money between customers, remittances or P2P
Accepting funds for bill pay or payouts
Digital wallet that holds balances
Buying or selling crypto for customers
Payment processing for merchants
Other
Q7. Do you have a written description or diagram of how money or assets move from sender to recipient in your product?
Yes
No
In progress
Q8. Where are customer funds held while in transit?
Select...
In a dedicated client or trust account
In the company’s general operating account
With a third party bank or payment partner
We never hold or control customer funds
Q9. Are customer funds kept in bank accounts that are separate from your company’s operating funds?
Yes
No
Not applicable
Q10. Do you already have a business bank account or banking partner that is aware of your business model?
Select...
Yes, with a bank that supports MSBs or fintechs
Yes, but the bank is not aware of our model
We have a bank but are not sure if they allow MSBs
No, we do not have a business bank yet
Page 3 – Compliance core: AML, KYC and BSA Officer
Compliance
Q11. Do you have a written Anti-Money Laundering and Bank Secrecy Act (AML/BSA) policy for your business?
Select...
Yes, written and tailored to our business
Drafted but not finalized
No, we do not have one yet
Q12. Do you have a defined Know Your Customer (KYC) process to verify customer identity?
Select...
Yes, using an external KYC provider
Yes, using our own internal checks
We have a rough plan but nothing formal
No, we do not have a KYC process yet
Q13. Have you formally appointed a BSA / AML Compliance Officer for your business?
Select...
Yes, an experienced compliance professional
Yes, an internal team member who is learning the role
We plan to appoint one but have not yet
No, we do not have a compliance officer
Q14. Do you monitor transactions for unusual or suspicious activity and have a process to handle that?
Select...
Yes, with automated tools
Yes, with manual review
We plan to set this up soon
No, we do not monitor transactions yet
Q15. Have you provided or planned AML / KYC training for relevant staff or founders?
Select...
Yes, initial and ongoing training
Yes, one time training only
Training is planned but not done yet
No, we have not planned training
Page 4 – Financial readiness, capital and bonding
Financials & Capital
Q16. Approximately how much total equity or net worth does the company currently have, assets minus liabilities? (USD)
Q17. Approximately how much cash or cash equivalent does the company have available right now? (USD)
Q18. Which best describes your current financial statements?
Select...
Audited financial statements by a CPA
Reviewed or compiled statements by a CPA
Internal management financials only
We do not have financial statements yet
Q19. Have you estimated the minimum net worth or capital required for the states you plan to apply in?
Select...
Yes, for all target states
Yes, for some states only
We have a rough idea but no detailed numbers
No, we have not looked into this yet
Q20. Have you obtained or requested quotes for the surety bond required by the states you are targeting?
Select...
Yes, bond already in place
Yes, we have one or more quotes
We have spoken with a bond provider but no quote yet
No, we have not started the bond process
Page 5 – Business plan, licensing scope and background
Plan & Background
Q21. Do you have a written business plan that explains your product, target customers, revenue model, and how you will handle compliance and risk?
Select...
Yes, we have a detailed written business plan
We have a short deck or summary but not a full plan
We have ideas but nothing written yet
No, we do not have a business plan
Q22. How many U.S. states do you expect to serve in the next 12 months?
Select...
1 state
2 to 5 states
6 to 10 states
11 to 20 states
More than 20 states
Q23. Have you reviewed at least one target state’s money transmitter license checklist or application requirements?
Select...
Yes, in detail for one or more states
Yes, but only skimmed the requirements
No, not yet
Q24. Are all owners and key executives willing to undergo background checks and fingerprinting as part of licensing?
Yes
No
Not sure
Q25. To the best of your knowledge, does any owner or key executive have a history of felony conviction or regulatory action related to fraud, money laundering or financial crime?
Select...
No
Yes, but it was minor and long ago
Yes, and it may be significant
Not sure or prefer not to say
Page 6 – Crypto specific
Crypto
Q26. What best describes your role with crypto or digital assets?
Select...
Custodial wallet provider holding crypto for customers
Crypto exchange or brokerage for customers
Payments or remittances using crypto or stablecoins
Issuing our own token or stablecoin
DeFi or Web3 protocol front end
Other
We do not handle crypto
Q27. How are customer crypto assets held and secured?
Select...
With a regulated third party custodian
Our own custody using multi-signature and cold storage
Our own custody using mainly hot wallets
We do not custody customer crypto
Q28. Do you use any blockchain analytics or on-chain monitoring tools for AML and risk checks?
Select...
Yes, for all relevant crypto activity
Yes, for some activity only
Not yet, but we plan to
No, we do not use any tools
Q29. Are you compliant or planning to be compliant with the Travel Rule for applicable crypto transfers?
Select...
Yes, we are already compliant
We have a plan and are working on it
No, we are not compliant yet
Not sure what the Travel Rule is
Q30. Have you obtained legal or regulatory advice specific to your crypto business and licensing obligations, for example MTL, virtual currency license or BitLicense?
Select...
Yes, we have a formal written legal opinion
Yes, we had an informal consultation
No, we have not obtained advice yet
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MTL Readiness Summary