Money transmitter license

A money transmitter license is a state authorization required for businesses that transmit or exchange money on behalf of others, and depending on the state and business model it can apply to crypto exchanges, custodians, and payment services.

Requirements vary by state and are separate from federal FinCEN registration as a money services business. Operating without a required license can be a crime.

Why it matters: a crypto business that touches customer funds needs a state-by-state analysis before launch.

Where this comes up in our work

Token and Web3 opinion letters

Howey analysis and written opinions for token projects and exchanges.

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Definitions are general information, not legal advice, and may not reflect the most recent changes in law.