🇺🇸 United States
No single federal crypto licence, a fragmented state money-transmitter patchwork plus FinCEN MSB registration, now overlaid by the newly-signed GENIUS Act and the still-pending CLARITY Act.
Data verified: oldest cell 46 days ago (verified 2026-07-02). Individual cells show their own verification date below.
Licence type
No single federal crypto licence. Fragmented dual-layer regime: (a) State-level Money Transmitter Licence (MTL), required in 49 states (all except Montana) plus DC, applied for via NMLS (Nationwide Multistate Licensing System) under each state's money transmission statute (31 states have adopted the Money Transmission Modernization Act, MTMA, in full or part as of Feb 2026); (b) Federal FinCEN Money Services Business (MSB) registration under the Bank Secrecy Act, via FinCEN Form 107, required for any business acting as a money transmitter/administrator/exchanger of convertible virtual currency. Some states have specific regimes (e.g., NY BitLicense from NYDFS, 23 NYCRR Part 200) as an alternative/superseding requirement.
Regulator
No single federal crypto regulator. Federally, FinCEN (US Treasury) handles MSB registration and BSA/AML oversight. At the state level, each state's banking/financial-services department (e.g., NYDFS in New York, DFPI in California) issues and supervises money transmitter licences via NMLS. The SEC and CFTC separately assert jurisdiction over certain crypto activities (securities/commodities), the allocation of that jurisdiction is the subject of the pending CLARITY Act.
Capital requirement
United States capital requirement is included with access.Timeline to authorisation
United States timeline to authorisation is included with access.Local substance ⓘ
United States local substance is included with access.Application cost
United States application cost is included with access.Ongoing cost
United States ongoing cost is included with access.Passporting ⓘ
United States passporting is included with access.MiCA CASPs approved ⓘ
United States mica casps approved is included with access.Key restrictions
United States key restrictions is included with access.Recent changes
The GENIUS Act's 18 July 2026 deadline for federal implementing rules passed with no agency having finalised a rule: the OCC, FDIC, NCUA and Treasury (with FinCEN and OFAC) have issued proposed rules since December 2025, the Federal Reserve joined a five-agency customer identification proposal on 18 June 2026, and on 27 July 2026 the OCC sought approval for stablecoin issuer application forms (comments due 25 September 2026). The Act sets no penalty for the missed deadline; it takes effect on the earlier of 18 January 2027 or 120 days after final rules. The CLARITY Act remains stalled in the Senate: reported by the Banking Committee on 1 June 2026 with a substitute amendment, no cloture motion filed and no floor vote expected before the August recess; Senate Republicans circulated revised negotiating text on 22 July 2026. The SEC's three planned crypto rulemakings (token issuance safe harbour, broker-dealer capital and custody amendments, market structure) remained unpublished as of late July 2026.
Difficulty rating ⓘ
United States difficulty rating is included with access.Know when United States moves
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Not legal advice. Entries marked placeholder or awaiting verification shouldn't be relied on. Verify with United States's regulator and qualified local counsel before acting.