Money Transmitter License (MTL) requirements are regulated at the state level, which means there is no single “U.S. money transmitter license.” If your company moves money, supports payments, holds customer funds, or facilitates wallet or stablecoin activity, you may need an MTL in one or more states depending on your business model. This guide provides a state-by-state overview of MTL requirements across all 50 states to help payments, fintech and digital asset companies understand where licensing may apply.
If you are unsure whether your business model triggers money transmission or which states apply, Ridgeway Financial Services can help you map your flow of funds, assess MTL exposure, and plan a compliant rollout. Contact our team to discuss next steps.
Below is a brief overview table of MTL requirements by state. Use the table to scan high-level requirements, then review the detailed state sections below for expanded notes and the official state regulator link.
| State | MTL Required | Regulator | Notable Notes |
|---|---|---|---|
| Alabama | Yes | Banking Dept | Standard MTL |
| Alaska | Depends | Banking & Securities | Crypto not regulated |
| Arizona | Yes | DIFI | Sandbox available |
| Arkansas | Yes | Securities Dept | Standard MTL |
| California | Yes | DFPI | Higher scrutiny |
| Colorado | Yes | Division of Banking | Standard MTL |
| Connecticut | Yes | Dept of Banking | Standard MTL |
| Delaware | Yes | Bank Commissioner | Standard MTL |
| Florida | Yes | OFR | Active enforcement |
| Georgia | Yes | Banking & Finance | Crypto addressed |
| Hawaii | Depends | DFI | Crypto exempt program |
| Idaho | Yes | Dept of Finance | Standard MTL |
| Illinois | Yes | IDFPR | Crypto included |
| Indiana | Yes | DFI | Standard MTL |
| Iowa | Yes | Division of Banking | Standard MTL |
| Kansas | Depends | Bank Commissioner | Crypto not regulated |
| Kentucky | Yes | DFI | Standard MTL |
| Louisiana | Yes | OFI | Standard MTL |
| Maine | Yes | Consumer Credit | Standard MTL |
| Maryland | Yes | OFR | Standard MTL |
| Massachusetts | Yes | Division of Banks | Standard MTL |
| Michigan | Yes | DIFS | Standard MTL |
| Minnesota | Yes | Dept of Commerce | Standard MTL |
| Mississippi | Yes | Banking Dept | Standard MTL |
| Missouri | Yes | Division of Finance | Standard MTL |
| Montana | No | N/A | No MTL law |
| Nebraska | Yes | Banking & Finance | Standard MTL |
| Nevada | Yes | FID | Standard MTL |
| New Hampshire | Depends | Banking Dept | Crypto exempt |
| New Jersey | Yes | DOBI | Standard MTL |
| New Mexico | Yes | FID | Standard MTL |
| New York | Yes | NYDFS | BitLicense regime |
| North Carolina | Yes | Commissioner of Banks | Standard MTL |
| North Dakota | Yes | DFI | Standard MTL |
| Ohio | Yes | DFI | Standard MTL |
| Oklahoma | Yes | Banking Dept | Standard MTL |
| Oregon | Yes | DFR | Standard MTL |
| Pennsylvania | Yes | Banking & Securities | Crypto included |
| Rhode Island | Yes | DBR | Standard MTL |
| South Carolina | Yes | AG Office | Crypto included |
| South Dakota | Yes | Division of Banking | Standard MTL |
| Tennessee | Depends | DFI | Crypto not regulated |
| Texas | Depends | Dept of Banking | Crypto guidance issued |
| Utah | Depends | DFI | Token exemptions |
| Vermont | Yes | DFR | Standard MTL |
| Virginia | Yes | BFI | Standard MTL |
| Washington | Yes | DFI | Higher scrutiny |
| West Virginia | Yes | DFI | Standard MTL |
| Wisconsin | Yes | DFI | Crypto included |
| Wyoming | Depends | Division of Banking | Crypto exempt |
Alabama
License Requirement
Alabama generally requires a license to engage in money transmission, including selling or issuing payment instruments, stored value, or receiving money or monetary value for transmission, under the Alabama Monetary Transmission Act.
Regulatory Authority
Alabama Securities Commission, Registration Division.
Key Considerations
- The definition of money transmission is broad. Handling stored value instruments or virtual currency exchange activity can fall under licensing, which founders often overlook when launching new payment models.
- Alabama requires a minimum net worth of $25,000 and a surety bond of at least $100,000. In practice, the bond must equal or exceed $100,000 or be calculated based on outstanding obligations, whichever is greater.
- The Securities Commission allows either direct paper application or NMLS filing. In all cases, extensive documentation is required upfront, including financial statements, background checks, and a business plan. Startups should expect a thorough vetting process.
Official Resource
This is the official resource: https://asc.alabama.gov
Alaska
License Requirement
A state license is required to conduct money transmission in Alaska under the Uniform Money Services Act. This includes selling or issuing payment instruments, stored value, or receiving money for transmission.
Regulatory Authority
Alaska Department of Commerce, Community, and Economic Development, Division of Banking and Securities.
Key Considerations
- Alaska mandates a surety bond of $25,000 plus $5,000 per location, capped at $150,000. New entrants often underestimate location based bond scaling and relatively high application fees.
- Licensees must maintain compliance for five years even after ceasing operations, with bonds remaining in effect. Applicants must also obtain an Alaska business license and submit a state specific affidavit. These nuances can trip up founders expanding into Alaska.
Official Resource
This is the official resource: https://www.commerce.alaska.gov/web/dbs
Arizona
License Requirement
Arizona law requires all money transmitters to be licensed. Covered activity includes selling or issuing payment instruments, receiving money for transmission, or exchanging money on behalf of others.
Regulatory Authority
Arizona Department of Insurance and Financial Institutions, Financial Institutions Division.
Key Considerations
- Arizona uses a tiered bond schedule based on in state agents or locations, ranging from $25,000 up to a $500,000 maximum. A minimum tangible net worth of $100,000 is also expected, which surprises many startups.
- Arizona’s definition of money transmission includes receiving money for obligors to pay bills. Bill pay aggregators and fintechs handling bill payments must be licensed. While the law does not separately address virtual currency, the broad definition of monetary value has been applied to crypto activity in practice.
Official Resource
This is the official resource: https://difi.az.gov
Arkansas
License Requirement
Arkansas requires a license under its Uniform Money Services Act to engage in money transmission, including selling or issuing payment instruments or receiving money for transmission.
Regulatory Authority
Arkansas Securities Department.
Key Considerations
- Arkansas imposes a bond of $50,000 plus $10,000 per location, capped at $300,000. Multi location businesses must budget for materially higher bonding.
- The license applies equally to traditional money orders and electronic transfers. Companies using authorized delegates must report each location, and each contributes to bond requirements. This administrative detail often creates friction if overlooked during expansion.
Official Resource
This is the official resource: https://securities.arkansas.gov
California
License Requirement
California law generally requires a license to receive money for transmission or issue payment instruments under the Money Transmission Act.
Regulatory Authority
California Department of Financial Protection and Innovation.
Key Considerations
- California historically imposed high financial thresholds, including minimum tangible net worth of $500,000 and significant bonding or securities on deposit, often around $250,000 or more at the Commissioner’s discretion.
- California adopted portions of the Model Money Transmission Modernization Act in 2023, replacing the flat net worth requirement with a sliding scale tied to transaction volume.
- California does not have a separate crypto license, but regulators have pursued unlicensed crypto transmitters under the Money Transmission Act. Crypto companies must carefully assess whether licensing applies unless operating under a specific exemption or sandbox.
Official Resource
This is the official resource: https://dfpi.ca.gov
Colorado
License Requirement
Colorado requires a Money Transmitter license for anyone receiving money for transmission or selling payment instruments.
Regulatory Authority
Colorado Division of Banking, Department of Regulatory Agencies.
Key Considerations
- Colorado mandates a $1,000,000 surety bond, one of the highest fixed bond requirements in the country. This presents a meaningful barrier for smaller fintechs.
- The application process is detailed and includes personal financial disclosures, background checks, fingerprinting, an extensive business plan, and proof of FinCEN MSB registration. Founders often underestimate the documentation burden and review timeline.
Official Resource
This is the official resource: https://banking.colorado.gov
Connecticut
License Requirement
Connecticut requires a Money Transmitter license for engaging in the business of receiving money for transmission or transmitting money by any means.
Regulatory Authority
Connecticut Department of Banking, Office of the Banking Commissioner.
Key Considerations
- Bonding is volume based, starting at $300,000 and scaling up to $1,000,000 for larger transmitters. Applicants anticipating higher transaction volumes must plan accordingly.
- Connecticut explicitly includes virtual currency in its regulatory framework. Crypto transmission is treated as money transmission, and licensees must meet the same net worth, bonding, and permissible investment standards as traditional MSBs.
- Annual renewals require audited financials and updated permissible investment schedules equal to outstanding obligations.
Official Resource
This is the official resource: https://portal.ct.gov/dob
Delaware
License Requirement
Delaware requires a license under its Sale of Checks and Transmission of Money Act for any business receiving money for transmission.
Regulatory Authority
Delaware Office of the State Bank Commissioner.
Key Considerations
- Bonding starts at $25,000 plus $5,000 per additional location, capped at $250,000. This makes Delaware relatively accessible from a bonding standpoint.
- Application fees are modest, but the state still requires a detailed business plan and background checks for all officers, directors, and owners. Failure to disclose issues upfront commonly delays approval.
Official Resource
This is the official resource: https://banking.delaware.gov
Florida
License Requirement
Florida requires a Money Transmitter license for anyone receiving currency or monetary value for transmission by any means, including electronic transfer or the internet.
Regulatory Authority
Florida Office of Financial Regulation.
Key Considerations
- The surety bond amount is set by regulators based on volume and risk, up to $250,000. Applicants do not know the final bond amount until review.
- Florida amended its statutes to explicitly include virtual currency as monetary value. Businesses selling or transmitting cryptocurrency now clearly fall under licensing unless a specific exemption applies.
- Florida imposes rigorous background checks and expects an AML program to be in place at application time.
Official Resource
This is the official resource: https://flofr.gov
Georgia
License Requirement
Georgia requires a money transmitter license to engage in money transmission for a fee or commission, including selling payment instruments or transmitting money electronically.
Regulatory Authority
Georgia Department of Banking and Finance.
Key Considerations
- The surety bond starts at $100,000 and may be increased up to $2,000,000 based on volume or risk profile. Bond requirements can scale as the business grows.
- Authorized agents must be registered, and agent activity can trigger higher bonding. Missing agent registration is a common post licensure compliance issue.
Official Resource
This is the official resource: https://dbf.georgia.gov
Hawaii
License Requirement
Hawaii requires a money transmitter license for transmitting money or equivalent monetary value within, from, or to the state under its Money Transmitters Act.
Regulatory Authority
Hawaii Division of Financial Institutions, Department of Commerce and Consumer Affairs.
Key Considerations
- Hawaii historically imposed a double reserve requirement for digital currency businesses, requiring fiat reserves equal to digital assets held. This made compliance difficult for crypto companies.
- The state introduced a Digital Currency Innovation Lab and later modernized its laws, exempting certain virtual currency only transmissions from licensing. Founders must confirm whether their activity still falls under licensing.
- Bonding is generally $10,000 per location. Licensees must still maintain permissible investments equal to outstanding transmission obligations, which is separate from the bond and actively reviewed by regulators.
Official Resource
This is the official resource: https://cca.hawaii.gov/dfi
Idaho
License Requirement
Idaho requires a license under the Idaho Money Transmitters Act for selling or issuing payment instruments or receiving money for transmission.
Regulatory Authority
Idaho Department of Finance.
Key Considerations
- Bonding is $10,000 plus $5,000 per additional location, capped at $500,000. Single location startups often overlook how quickly bonding increases as they add agents.
- Idaho does not explicitly reference cryptocurrency in statute, but regulators interpret monetary value broadly. Crypto businesses should assume licensing applies.
- Idaho requires a minimum net worth of $50,000, with higher expectations for multi location operations. Audited financials may be required for newer applicants.
Official Resource
This is the official resource: https://www.finance.idaho.gov
Illinois
License Requirement
Illinois requires a Transmitter of Money license for businesses transmitting money or monetary value, including electronic transfers, for Illinois customers.
Regulatory Authority
Illinois Department of Financial and Professional Regulation, Division of Financial Institutions.
Key Considerations
- Bonding is the greater of $50,000 or 1 percent of Illinois transmission volume, capped at $2,000,000. Bond obligations increase as transaction volume grows.
- Illinois generally expects a minimum net worth around $500,000 and requires permissible investments equal to outstanding obligations.
- Illinois charges annual examination and audit fees. These ongoing regulatory costs are often underestimated by startups.
Official Resource
This is the official resource: https://idfpr.illinois.gov
Indiana
License Requirement
Indiana requires a license to engage in money transmission, including selling or issuing payment instruments or receiving money for transmission.
Regulatory Authority
Indiana Department of Financial Institutions.
Key Considerations
- Indiana imposes a flat $300,000 surety bond requirement for all money transmitters, regardless of volume or number of locations.
- Applicants must disclose all other state licenses and any prior regulatory actions. Transparency is critical to avoid delays.
- Indiana requires FBI background checks for principals. While no statutory minimum net worth exists, regulators still review financial condition for safety and soundness.
Official Resource
This is the official resource: https://www.in.gov/dfi
Iowa
License Requirement
Iowa requires a license under Iowa Code Chapter 533C for money transmission, including selling payment instruments or receiving money for transmission.
Regulatory Authority
Iowa Division of Banking.
Key Considerations
- Bonding is $50,000 plus $10,000 per location. Out of state companies with no physical Iowa location must post a flat $300,000 bond.
- Iowa requires a minimum net worth of $100,000 and permissible investments equal to outstanding transmission liabilities.
- Quarterly reporting of authorized delegates and annual updates of permissible investments are strictly enforced.
Official Resource
This is the official resource: https://banking.iowa.gov
Kansas
License Requirement
Kansas requires a money transmitter license for engaging in money transmission by any means, including wire and ACH transfers.
Regulatory Authority
Kansas Office of the State Bank Commissioner.
Key Considerations
- Kansas requires a minimum $200,000 surety bond, with authority to increase it up to $1,000,000 based on financial condition and projected volume.
- Kansas follows a risk based modernization framework for net worth and permissible investments.
- Agent of bank exemptions are narrow and must be carefully documented. Most fintechs still require full licensure.
Official Resource
This is the official resource: https://www.osbckansas.org
Kentucky
License Requirement
Kentucky requires a license to operate a money transmission business, covering transmission of money or monetary value by any means.
Regulatory Authority
Kentucky Department of Financial Institutions.
Key Considerations
- Kentucky mandates a minimum surety bond of $500,000, with authority to increase it up to $5,000,000. This significantly limits entry to well capitalized firms.
- Licensees must maintain permissible investments equal to all outstanding transmission obligations and submit detailed annual reporting.
- Existing licenses in other states can help streamline review, but background checks remain comprehensive.
Official Resource
This is the official resource: https://kfi.ky.gov
Louisiana
License Requirement
Louisiana requires a Money Transmitter license for selling or issuing payment instruments or receiving money for transmission.
Regulatory Authority
Louisiana Office of Financial Institutions.
Key Considerations
- Bonding starts at $25,000 and increases by $5,000 per additional location, typically capped at $250,000.
- Louisiana recognizes certain agent of payee exemptions, particularly for bill payment activity. Applicability depends on exact fund flow.
- A minimum net worth of $100,000 is required, and standard audits and background checks apply.
Official Resource
This is the official resource: https://ofi.la.gov
Maine
License Requirement
Maine requires a money transmitter license under the Maine Sale of Checks and Money Transmission Act.
Regulatory Authority
Maine Bureau of Consumer Credit Protection.
Key Considerations
- Maine requires a flat $100,000 surety bond with no scaling by volume or location.
- Licensees must maintain permissible investments equal to 100 percent of outstanding transmission liabilities.
- Historically, crypto businesses faced effective double reserve requirements. Founders should confirm whether modernization has altered reserve treatment.
Official Resource
This is the official resource: https://www.maine.gov/pfr/consumercredit
Maryland
License Requirement
Maryland requires a license for money transmission, broadly defined as receiving money for transmission domestically or internationally.
Regulatory Authority
Maryland Commissioner of Financial Regulation, Maryland Department of Labor.
Key Considerations
- Maryland requires a $150,000 surety bond and a minimum net worth of $150,000. Audited financials are commonly requested.
- Maryland adopted a modernized framework allowing limited recognition of digital assets as permissible investments.
- The application includes a detailed cybersecurity and IT risk review that often surprises new applicants.
Official Resource
This is the official resource: https://labor.maryland.gov/finance
Massachusetts
License Requirement
Massachusetts requires a license only for transmitting money to foreign countries. A Foreign Transmittal Agency license is needed to receive money for the purpose of transmitting it abroad. Purely domestic money transmission within Massachusetts is not licensed at the state level.
Regulatory Authority
Massachusetts Division of Banks, Office of the Commissioner of Banks.
Key Considerations
- Because the law targets international transmissions, startups offering remittances or cross border payments must be licensed, while purely domestic peer to peer payment apps often operate without a state license. This distinction is commonly missed.
- The surety bond requirement is $50,000. Massachusetts is known for strict scrutiny of applicants’ background and financial soundness, including expectations around AML controls due to the international focus. Crypto activity involving international fiat movement can be treated as foreign transmittal activity.
Official Resource
This is the official resource: https://www.mass.gov/orgs/division-of-banks
Michigan
License Requirement
Michigan requires a license under the Money Transmission Services Act for any person in the business of money transmission, including issuing payment instruments, stored value, or receiving money for transmission.
Regulatory Authority
Michigan Department of Insurance and Financial Services.
Key Considerations
- Michigan requires substantial bonding, generally between $500,000 and $1,500,000 at the regulator’s discretion. Minimum net worth expectations include $100,000 plus $25,000 per branch location.
- Michigan closely reviews multi state operators. Prior regulatory actions must be disclosed, and consent orders or enforcement history from other states can delay approval if not provided up front.
- NMLS reciprocity elements can reduce duplicative submissions, but regulators still expect complete, organized supporting documentation.
Official Resource
This is the official resource: https://www.michigan.gov/difs
Minnesota
License Requirement
Minnesota requires a money transmitter license for businesses selling or issuing payment instruments or receiving money for transmission by wire or electronic transfer.
Regulatory Authority
Minnesota Department of Commerce.
Key Considerations
- Bonding varies by number of business locations, starting at $25,000 and increasing through defined tiers up to a $250,000 cap. Scaling agent or branch footprints can increase bonding materially.
- Minnesota does not explicitly address virtual currency in statute, but regulators have treated transmission of virtual value convertible to money as licensable activity.
- Annual renewal involves ongoing compliance expectations, including policies and documentation supporting transaction monitoring and permissible investment practices.
Official Resource
This is the official resource: https://commerce.state.mn.us
Mississippi
License Requirement
Mississippi requires a license under the Money Transmitters Act to sell or issue payment instruments or receive money for transmission by any means.
Regulatory Authority
Mississippi Department of Banking and Consumer Finance.
Key Considerations
- The surety bond must be at least $25,000 and can be increased up to $500,000 at the regulator’s discretion. Founders should plan for higher bonding if volume or risk profile is significant.
- Mississippi does not explicitly include digital currency in its definitions, but licensing has been applied where virtual currency activity is tied to fiat conversion or custodial fiat handling.
- Mississippi requires an in state agent for service of process, which must remain current to maintain license standing.
Official Resource
This is the official resource: https://www.dbcf.ms.gov
Missouri
License Requirement
Missouri requires a license to engage in money transmission. No person may transmit money or sell payment instruments without a Missouri license.
Regulatory Authority
Missouri Division of Finance, Office of the Director of Finance.
Key Considerations
- Missouri has a flat $100,000 bond requirement.
- Missouri requires a CPA certified audit of the applicant’s most recent financial statements, which founders often fail to budget for in time and cost.
- Missouri expects evidence of FinCEN MSB registration or a clear explanation for why federal registration is not required.
Official Resource
This is the official resource: http://finance.mo.gov
Montana
License Requirement
None. Montana does not require a money transmitter license to offer money transmission services to residents.
Regulatory Authority
Montana Division of Banking and Financial Institutions, which does not regulate money transmitters.
Key Considerations
- Even without state licensing, businesses may still be subject to federal MSB registration and AML obligations.
- The absence of a state license can complicate banking and investor conversations because there is no state approval framework to reference. Some companies adopt strong compliance and consumer protection practices voluntarily to support de risked partnerships.
Official Resource
This is the official resource: https://banking.mt.gov
Nebraska
License Requirement
Nebraska requires a license under the Nebraska Money Transmitters Act for issuing payment instruments, stored value, or receiving money for transmission.
Regulatory Authority
Nebraska Department of Banking and Finance.
Key Considerations
- Bonding starts at $100,000 and increases by $5,000 per additional Nebraska location beyond one, capped at $250,000. Authorized delegate locations can affect the calculation.
- Nebraska enforces permissible investment requirements aligned to outstanding obligations and may require periodic reporting.
- Nebraska has allowed limited recognition of digital assets as permissible investments, but firms must maintain tight treasury management to avoid falling below required coverage.
Official Resource
This is the official resource: https://ndbf.nebraska.gov
Nevada
License Requirement
Nevada requires a license to engage in money transmission pursuant to Nevada Revised Statutes Chapter 671.
Regulatory Authority
Nevada Financial Institutions Division, Nevada Department of Business and Industry.
Key Considerations
- Bonding starts at $10,000 and increases by $5,000 per additional business location, capped at $250,000. Nevada also expects minimum net worth of $100,000, supported by certified financial statements.
- Nevada’s process may involve direct state follow up even when using NMLS.
- Out of state companies often must complete Nevada foreign qualification and obtain a Nevada state business license before the regulator will approve the money transmitter license.
Official Resource
This is the official resource: http://fid.nv.gov
New Hampshire
License Requirement
New Hampshire requires a money transmitter license for businesses selling or issuing payment instruments, stored value, or receiving currency or monetary value for transmission.
Regulatory Authority
New Hampshire Banking Department.
Key Considerations
- New Hampshire requires a flat $100,000 surety bond, plus moderate fees.
- New Hampshire provides a narrow exemption for certain crypto only activity that does not touch fiat. If the business buys or sells crypto for dollars, licensing is still required.
- Applicants should confirm whether their model qualifies for any exemption, because the boundary is specific and often misunderstood.
Official Resource
This is the official resource: https://www.nh.gov/banking
New Jersey
License Requirement
New Jersey requires a license under its Money Transmitter Act for transmitting money, including selling or issuing payment instruments or receiving money for transmission by any means.
Regulatory Authority
New Jersey Department of Banking and Insurance.
Key Considerations
- New Jersey has two bond tiers, including $100,000 for a money transmitter license and a lower tier commonly described as a foreign money transmitter category. Most fintechs serving New Jersey consumers should expect the $100,000 bond requirement.
- New Jersey has been moving toward clearer treatment of digital assets within money transmission concepts, and regulators may scrutinize crypto balance sheet volatility and risk management.
- Net worth expectations are commonly at least around $100,000 or higher depending on activity and risk profile.
Official Resource
This is the official resource: https://www.nj.gov/dobi
New Mexico
License Requirement
New Mexico requires a license under its Uniform Money Services Act for money transmission, including selling or issuing payment instruments, stored value, or receiving money or monetary value for transmission.
Regulatory Authority
New Mexico Regulation and Licensing Department, Financial Institutions Division.
Key Considerations
- New Mexico has a high bond requirement. The bond must be $300,000 or 1 percent of total yearly transmission volume, whichever is greater, capped at $2,000,000. This creates a $300,000 minimum even for new entrants and can scale quickly with volume.
- New Mexico’s application process is thorough and expensive, including significant application and license fees, and the state is known for post licensure examination expectations.
- New Mexico explicitly treats virtual currency activity as covered money services. The state allows limited recognition of virtual currency as permissible investments when aligned to outstanding obligations in that same virtual currency.
Official Resource
This is the official resource: https://www.rld.nm.gov/financial-institutions/
New York
License Requirement
New York requires a license for transmitting money under New York Banking Law Article 13 B. Any entity receiving money for transmission or selling payment instruments to New York residents must be licensed by the regulator.
Regulatory Authority
New York State Department of Financial Services.
Key Considerations
- New York is one of the most stringent states, with high bonding expectations, substantial application costs, and net worth requirements that can range from hundreds of thousands to several million depending on the business model and projected volume.
- New York regulates cryptocurrency under a separate BitLicense framework. Companies engaging in virtual currency business activity with New York residents must evaluate BitLicense or alternative charter requirements, which can be in addition to, or instead of, traditional money transmission licensing depending on activity.
- Approval timelines are often long, with extensive background investigations, frequent regulator engagement, and intensive ongoing reporting and examination expectations after licensure.
Official Resource
This is the official resource: https://www.dfs.ny.gov
North Carolina
License Requirement
North Carolina requires a license for money transmission, but it limits the scope largely to transmissions primarily for personal, family, or household purposes. Pure business to business payment flows are exempt.
Regulatory Authority
North Carolina Office of the Commissioner of Banks.
Key Considerations
- North Carolina’s consumer focus exemption is a major nuance. Enterprise only payment platforms may not require a license, but any consumer functionality can trigger licensing. Mixed use platforms often misjudge this.
- Bonding is volume based, ranging from $150,000 up to $250,000 maximum, tied to annual transaction volume thresholds.
- North Carolina expressly integrated virtual currency concepts into its money transmission framework and provides clearer exemptions for certain payment processing models. For some crypto transmitters, additional cybersecurity related expectations can apply.
Official Resource
This is the official resource: https://www.nccob.org
North Dakota
License Requirement
North Dakota requires a license to engage in money transmission, including selling or issuing payment instruments, stored value, or receiving money for transmission.
Regulatory Authority
North Dakota Department of Financial Institutions.
Key Considerations
- North Dakota requires a $150,000 surety bond, with discretion to increase up to $500,000 based on financial condition and the business model.
- North Dakota participates in multi state licensing coordination, which can streamline review for companies pursuing broad state coverage, but complete NMLS documentation is still required.
- A common delay is incomplete background check processing for control persons. Each individual must complete required filings and checks before approval.
Official Resource
This is the official resource: https://www.nd.gov/dfi
Ohio
License Requirement
Ohio requires a money transmitter license for any person receiving money or its equivalent for transmission to another location or person.
Regulatory Authority
Ohio Division of Financial Institutions, Ohio Department of Commerce.
Key Considerations
- Ohio requires a $300,000 surety bond for all money transmitters and charges a high, nonrefundable application fee that can surprise startups.
- Ohio has required clear disclosure of virtual currency related activities in licensing, and crypto transmitters can be required to be licensed when activity involves fiat or custodial arrangements.
- Ohio expects a designated responsible individual with relevant experience. Insufficient experience or unclear accountability can delay or derail applications.
Official Resource
This is the official resource: https://www.com.ohio.gov/financial
Oklahoma
License Requirement
Oklahoma requires a license for receiving money for transmission by any means, including electronic networks and payment instruments.
Regulatory Authority
Oklahoma State Banking Department.
Key Considerations
- Oklahoma uses a tiered bonding structure depending on activity type. Bonding can vary significantly based on whether the business is categorized as electronic only transmission, check selling, or other covered activity. Misclassification is a common mistake.
- Oklahoma expects proof of federal FinCEN registration and an AML program at application time, not as a later stage deliverable.
- Net worth expectations can be higher for certain activity profiles, and the regulator may require direct engagement with principals during review.
Official Resource
This is the official resource: https://oklahoma.gov/banking
Oregon
License Requirement
Oregon requires a license under its Money Transmitters Act for selling or issuing payment instruments or receiving money for transmission, including electronic transfers.
Regulatory Authority
Oregon Department of Consumer and Business Services, Division of Financial Regulation.
Key Considerations
- Oregon’s bond is $25,000 plus $5,000 per location, capped at $150,000. Oregon may treat authorized delegate locations as locations for bonding purposes, which can push companies to the cap.
- Oregon excludes certain closed loop stored value products from regulation, but open loop prepaid and wallet like products are regulated.
- Oregon expects applicants to address security and consumer protection practices, including how customer data and funds will be safeguarded.
Official Resource
This is the official resource: https://dfr.oregon.gov
Pennsylvania
License Requirement
Pennsylvania requires a Money Transmitter license to engage in the business of transmitting money by any means, for any amount.
Regulatory Authority
Pennsylvania Department of Banking and Securities.
Key Considerations
- Pennsylvania requires a $1,000,000 surety bond for all money transmitters and charges a large licensing fee, creating a significant upfront barrier.
- Pennsylvania expects strong ongoing compliance, including periodic reporting and pre approval of certain control changes. Internet only businesses may face additional practical scrutiny around presence and consumer protection readiness.
- Pennsylvania has treated pure virtual currency only transmissions differently from fiat touching models. Companies that touch fiat generally must be licensed, while pure crypto only activity may fall outside the statute depending on the facts.
Official Resource
This is the official resource: https://www.dobs.pa.gov
Rhode Island
License Requirement
Rhode Island requires money transmitters to be licensed under its Sale of Checks and Electronic Money Transfers Act, covering receiving money for transmission by traditional instruments or electronic means.
Regulatory Authority
Rhode Island Department of Business Regulation, Banking Division.
Key Considerations
- Rhode Island uses a flat $50,000 surety bond requirement. Net worth expectations apply, and in practice healthy capitalization is expected.
- Rhode Island updated its law to explicitly include virtual currency under money transmission concepts, reducing ambiguity for crypto businesses.
- Annual renewal and reporting obligations are straightforward but must be managed carefully to avoid administrative lapses that can jeopardize license standing.
Official Resource
This is the official resource: https://dbr.ri.gov
South Carolina
License Requirement
South Carolina requires a money transmitter license under its Anti Money Laundering Act for money transmission businesses, including selling or issuing payment instruments, stored value, or receiving money for transmission.
Regulatory Authority
South Carolina Attorney General’s Office, Money Services Division.
Key Considerations
- Bonding starts at $50,000 and increases by $10,000 per location, capped at $250,000. Oversight by the Attorney General’s Office is a notable structural difference from many states and can feel more enforcement oriented.
- While the statute does not expressly focus on virtual currency, licensing can apply where the business has custodial control and transmits monetary value broadly defined.
- A unique operational friction is the requirement for additional third party background screening beyond standard fingerprint and criminal checks, which can extend lead times.
Official Resource
This is the official resource: http://www.scag.gov
South Dakota
License Requirement
South Dakota requires a license for money transmission businesses under South Dakota Codified Laws Chapter 51A 17, covering selling or issuing payment instruments, stored value, or receiving money for transmission.
Regulatory Authority
South Dakota Division of Banking, South Dakota Department of Labor and Regulation.
Key Considerations
- South Dakota requires a flat $100,000 surety bond. There is no volume or location scaling, which makes planning straightforward.
- South Dakota does not impose a separate net worth requirement by statute, but regulators expect adequate capital and commonly look for meaningful equity support.
- South Dakota participates in multi state licensing coordination and can be relatively efficient when filings are complete. A frequent administrative issue is ensuring an in state registered agent is properly listed.
Official Resource
This is the official resource: https://dlr.sd.gov/banking
Tennessee
License Requirement
Tennessee requires a license to engage in money transmission, including selling or issuing payment instruments or receiving money for transmission by any means.
Regulatory Authority
Tennessee Department of Financial Institutions.
Key Considerations
- Tennessee’s bond is $50,000 plus $10,000 for each additional location, capped at $800,000. Authorized agent locations can be included in the location count, which can materially increase bonding as the network grows.
- Tennessee adopted modernization changes that affected net worth and permissible investment expectations, but the state continues to expect an experienced qualifying individual as part of the application.
- Renewal is comparatively straightforward, but material business model changes should be reported proactively to avoid licensing issues.
Official Resource
This is the official resource: https://www.tn.gov/tdfi
Texas
License Requirement
Texas requires a license for money transmission under the Texas Money Services Act. Covered activity includes issuing stored value or payment instruments, receiving money or monetary value for transmission, and related services such as bill payment or currency exchange.
Regulatory Authority
Texas Department of Banking.
Key Considerations
- Texas uses a bond formula for money transmission that is the greater of $300,000 or 1 percent of total yearly transmission volume in Texas, capped at $2,000,000. This creates a $300,000 minimum and scales with volume.
- Texas has a high application fee, which makes it one of the more expensive states to pursue early.
- Texas has issued guidance that some crypto activity may fall outside money transmission, particularly crypto to crypto exchange without fiat. Models involving fiat or stablecoin redemption can trigger licensing. Businesses often need a clear rationale if claiming an exemption, and ongoing reporting and examinations are expected once licensed.
Official Resource
This is the official resource: https://www.dob.texas.gov
Utah
License Requirement
Utah requires a Money Transmitter license for businesses selling or issuing payment instruments or receiving money for transmission within the United States or abroad.
Regulatory Authority
Utah Department of Financial Institutions.
Key Considerations
- Utah’s bond is at least $50,000. While the statute does not emphasize a strict cap, regulators can require higher bonding based on risk and safety considerations.
- Utah is viewed as comparatively accessible from a fee and bonding perspective, but applicants still must provide standard documentation, background checks, and AML readiness.
- Utah has used sandbox style innovation programs. Some fintechs may qualify for limited relief depending on program scope, but most operating models will still require the standard license.
Official Resource
This is the official resource: https://dfi.utah.gov
Vermont
License Requirement
Vermont requires a money transmitter license for selling or issuing payment instruments or stored value, or receiving money or monetary value for transmission, whether inside or outside the United States.
Regulatory Authority
Vermont Department of Financial Regulation.
Key Considerations
- Vermont’s bond starts at $100,000 and increases by $10,000 per additional location, capped at $500,000.
- Vermont requires minimum net worth of $100,000, with discretion for regulators to require higher net worth for larger operators.
- Vermont explicitly treats virtual currency activity as within the scope of licensing and allows limited use of virtual currency as permissible investments aligned to same currency obligations, but expects robust AML and cybersecurity practices.
Official Resource
This is the official resource: https://dfr.vermont.gov
Virginia
License Requirement
Virginia requires a license for money transmitters, defined as receiving money or monetary value for transmission or selling stored value by wire, electronic, or other means.
Regulatory Authority
Virginia Bureau of Financial Institutions, State Corporation Commission.
Key Considerations
- Virginia sets the bond amount based on financial condition and volume, generally between $25,000 and $500,000. Virginia also applies tangible net worth expectations tied to activity level with a minimum floor.
- Virginia requires state specific forms and personal financial disclosures for principals, which are easy to miss and can delay approvals.
- Virginia has treated virtual currency activity as licensable through the standard money transmitter license, and regulators may ask detailed questions on custody and cybersecurity.
Official Resource
This is the official resource: https://scc.virginia.gov
Washington
License Requirement
Washington requires a money transmitter license for businesses receiving money or equivalent value, including virtual currency, for transmission to another location or person.
Regulatory Authority
Washington State Department of Financial Institutions.
Key Considerations
- Washington uses a variable bond tied to transmission volume, with a minimum and maximum range. The bond amount can increase as volume grows.
- Washington applies a scaling tangible net worth requirement tied to volume, which can become significant for larger transmitters.
- Washington explicitly includes virtual currency in its scope without a separate crypto specific license, but may require enhanced cybersecurity practices. Operationally, some models must address local responsible individual requirements.
Official Resource
This is the official resource: https://dfi.wa.gov
West Virginia
License Requirement
West Virginia requires a license for money transmission, including selling or issuing payment instruments or receiving currency for transmission by wire, facsimile, or electronic means, including stored value card issuance.
Regulatory Authority
West Virginia Division of Financial Institutions.
Key Considerations
- West Virginia has a high bonding structure for electronic or wire transmission, plus additional bonding per authorized delegate location, capped at $1,000,000. Agent networks can drive bonding materially upward.
- West Virginia may require additional state specific background checks even where federal checks were completed through NMLS, which can lengthen the process.
- West Virginia may allow certain deposits of securities as an alternative to part of the surety bond, subject to approval.
Official Resource
This is the official resource: https://dfi.wv.gov
Wisconsin
License Requirement
Wisconsin requires a license under its Seller of Checks law for businesses transmitting money or monetary value, including issuing payment instruments and sending money domestically or abroad.
Regulatory Authority
Wisconsin Department of Financial Institutions.
Key Considerations
- Wisconsin’s bond is $10,000 for the first location plus $5,000 for each additional location, capped at $300,000.
- Wisconsin uses older terminology but applies it to modern electronic transmitters and crypto related activity where applicable.
- Wisconsin requires fees and complete documentation before processing. Incomplete submissions are commonly treated as incomplete and can be deprioritized, so packaging must be tight.
Official Resource
This is the official resource: https://www.wdfi.org
Wyoming
License Requirement
Wyoming requires a Money Transmitter license under the Wyoming Money Transmitters Act for selling or issuing payment instruments, stored value, or receiving money or monetary value for transmission.
Regulatory Authority
Wyoming Division of Banking.
Key Considerations
- Wyoming’s bond is the greater of $10,000 or a multiple of outstanding payment instruments or unremitted obligations. This can increase as outstanding obligations grow, so monitoring is important.
- Wyoming has enacted crypto friendly statutes and has provided exemptions for certain crypto only activity that does not involve fiat. If fiat rails are involved, licensing may still apply.
- Wyoming is generally open to innovation, including sandbox concepts, but licensees should still expect standard examinations and compliance expectations once within the regime.
Official Resource
This is the official resource: https://wyomingbankingdivision.wyo.gov
This guide is intended to provide a high-level, educational overview of Money Transmitter License requirements by state. Licensing rules, interpretations, and enforcement practices can change over time, and whether an MTL is required often depends on the specific facts of a company’s business model, flow of funds, and custody structure. If you need help assessing MTL requirements, evaluating state-by-state exposure, or planning a compliant rollout, you can reach out to Ridgeway Financial Services for guidance.
Reviewed By RFS Team