US state licensing matrix
Money transmitter and virtual currency requirements across states and territories. Posture and identity columns are free; fees, bonds and timelines unlock with access.
56 of 56 shown
| Jurisdiction | MTL required | Virtual currency treatment | Regulator | MTMA adoption | Launch posture | Application fees | Surety bond | Typical timeline |
|---|---|---|---|---|---|---|---|---|
| Alabama AL | Yes. The Monetary Transmission Act licenses money transmission, defined as receiving money or monetary value for transmission; monetary value expressly includes virtual currency, so both the fiat ramp and the CVC leg sit inside one licence. Ala. Code 8-7A-5, 8-7A-2. | Inside the money transmission statute, not a separate regime: monetary value is defined to include virtual or fiat currencies, so transmitting virtual currency as a business typically falls under the same licence as fiat transmission. Ala. Code 8-7A-2(8). | Alabama Securities Commission (ASC), Registration Division, not a banking department, administers monetary transmission licensing. | none: no MTMA enactment as of 16 July 2026. | green: Conventional single-tier MTL with a modest $25,000 net worth floor and a scenario bond well under the $5,000,000 ceiling. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Alaska AK | Yes. Alaska's money transmission licence expressly authorises crypto currency dealing and exchanging, crypto ATMs or kiosks, and crypto custodial services, and the fiat ramp independently triggers licensure as receiving money for transmission. AS 06.55.101. | Folded into the same money transmission licence rather than a separate regime: the Division's current licence expressly authorises crypto dealing, exchanging, ATMs and custodial services, but imposes a heightened, currency-specific bond described under surety_bond. AS 06.55. | Alaska Division of Banking and Securities (DBS), Department of Commerce, Community and Economic Development. | full: SB 86 (2026), effective 1 July 2026. Enrolled 5 June 2026; final gubernatorial action not independently confirmed as of 16 July 2026. | amber: Ordinary fiat and crypto MTL in scope, but Alaska's flat $500,000 virtual-currency bond is a meaningfully higher fixed cost than the $150,000 cap non-crypto transmitters face. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Arizona AZ | Yes. The Money Transmitters Act licenses selling or issuing payment instruments, selling or issuing stored value, and receiving money for transmission; the scenario's fiat on and off ramp is receiving money for transmission and requires a licence. A.R.S. 6-1201, 6-1207. | Not defined as its own category: the core definitions of money, monetary value and money transmission do not mention virtual currency, so a pure crypto-to-crypto business sits in a grey area. Arizona instead created a separate cryptocurrency kiosk licence (A.R.S. 6-1236, from 1 January 2026) layered on the same article. | Arizona Department of Insurance and Financial Institutions (DIFI). | full: Ch. 236 (2022 Session Laws), effective 2022 (specific date not stated in CSBS tracker). | amber: Full 2023 MTMA adoption gives predictable, capped bond and net worth formulas, but the statute does not itself define virtual currency, leaving the non-fiat leg resting. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Arkansas AR | Yes. A Money Transmitter License is required for money transmission activity, defined to include receiving money, virtual currency, or monetary value for transmission, so both the fiat ramp and the CVC leg are captured directly. Ark. Code 23-55-201, 23-55-102. | Inside the same statute, not a separate regime: virtual currency is a defined term written directly into the definition of money transmission activity, receiving money, virtual currency, or monetary value for transmission, so no extra crypto licence sits alongside the Money Transmitter License. Ark. Code 23-55-102(23). | Arkansas Securities Department (Securities Commissioner). | partial: H.B. 1438 (2023), effective August 1, 2023. | green: Virtual currency is written directly into the core statute with no interpretive guesswork, fees and bond are capped and predictable, and the like-kind virtual currency reserve. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| California CA | Yes: a DFPI Digital Financial Assets Law licence is mandatory for covered crypto activity since 1 July 2026. Whether the fiat leg also needs a Money Transmission Act licence is transitional: DFPI proposed exempting DFAL persons (PRO 02-23, 10 CCR 80.3002), but the rule was not final as of 16 July 2026. | A separate licensing regime, not folded into the Money Transmission Act: the Digital Financial Assets Law requires its own licence for exchanging, transferring, storing or redeemably issuing digital financial assets for California residents, running alongside the fiat MTA licence here. Fin. Code 3103. | California Department of Financial Protection and Innovation (DFPI) administers both the Money Transmission Act and the Digital Financial Assets Law. | partial: A.B. 1116 (2023); see also A.B. 1498 (2022), effective January 1, 2025. | red: new mandatory DFAL regime with DFPI-determined security and capital, plus unresolved MTA overlap while the PRO 02-23 exemption remains a proposed rule. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Colorado CO | Yes, because of the fiat ramp. The Money Transmission Modernization Act (effective 6 August 2025) licenses receiving money for transmission from a Colorado person, and the Division of Banking's own December 2025 interim guidance confirms this fiat leg triggers licensure regardless of the crypto side of the business. | Guidance-clarified carve-out, not a separate licence: the Division's December 2025 interim guidance concludes pure virtual currency transmission, no fiat leg, not a payment stablecoin, is not itself licensable; payment stablecoins count as stored value and need a licence unless the issuer is federally qualified under the GENIUS Act, which preempts the state requirement. | Colorado Division of Banking, Department of Regulatory Agencies (DORA). | full: H.B. 25-1201, effective July 17, 2025. | amber: Brand-new MTMA regime with a helpful regulator carve-out for pure crypto-to-crypto activity, but this scenario's fiat ramp keeps it fully in scope, and payment-stablecoin handling adds. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Connecticut CT | Yes. Money transmission is defined to include receiving money or monetary value for transmission by any means, including virtual currency, and Department of Banking opinion letters confirm an exchange holding or transmitting fiat or virtual currency for Connecticut residents needs a licence. Conn. Gen. Stat. 36a-596, 36a-598. | Expressly written into the money transmission statute, not guidance-only or a separate regime: virtual currency is a defined term folded into money transmission and monetary value, and 2019 opinion letters confirm exchanges holding or transmitting fiat or virtual currency for residents need a licence, with no carve-out for broker-dealers or out-of-state trust companies. Conn. Gen. Stat. 36a-596, 36a-609. | Connecticut Department of Banking. | partial: H.B. 5211 (2024); see also S.B. 268 (2022), effective October 1, 2024. | amber: Virtual currency is squarely inside the statute with strong regulator opinion-letter support, but the currency-specific bond has no fixed ceiling, only a case-by-case Commissioner determination, which. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Delaware DE | Yes. Current law (5 Del. C. Chapter 23, the Sale of Checks Act) requires a Check Seller, Money Transmitter licence for receiving money for transmission, and the regulator's own licensee list already includes over 200 firms in this category, most major convertible virtual currency exchanges among them. A newly enacted rewrite, Senate Bill 18, confirms the same result under its replacement regime. | Not separately defined in the Chapter 23 text still shown on the official code site, but the Office of the State Bank Commissioner already licenses convertible virtual currency exchanges under the existing 'receiving money for transmission' language. Senate Bill 18, signed 6 to 7 July 2026, adds an express virtual currency business activity subchapter inside the same licence, phasing in over 6 to 12 months. | Delaware Office of the State Bank Commissioner. | full: SB 18, the Delaware Money Transmission and Virtual Currency Modernization Act, signed 7 July 2026; provisions phase in and the enactment post-dates the CSBS tracker update. | amber: Convertible virtual currency exchanges are routinely licensed today under the existing statute, but Delaware just repealed and replaced the entire chapter (Senate Bill 18, signed 6. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| District of Columbia DC | Yes. A convertible virtual currency exchange with a fiat ramp needs a District of Columbia money transmitter licence: the fiat leg falls within the broad 'money transmission' definition, and the Department of Insurance, Securities and Banking has repeatedly stated since 2022 that Bitcoin and other virtual currency transactions independently qualify as money transmission. | Guidance-only. D.C. Code Title 26, Chapter 10 has no statutory definition of virtual currency. DISB's updated notice of 9 August 2024 (superseding 2022 and 2023 bulletins) states that Bitcoin and virtual currency transfers, including via kiosks, are money transmission, citing United States v. Harmon, 474 F. Supp. 3d 76 (D.D.C. 2020). There is no separate crypto licence regime. | District of Columbia Department of Insurance, Securities and Banking (DISB), Banking Bureau. | none: no MTMA enactment as of 16 July 2026. | green: The fiat leg is unambiguously covered by the licence-required statute, and DISB has repeatedly and consistently confirmed since 2022 that virtual currency transmission is covered too,. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Florida FL | Yes. Florida's 'money transmitter' definition expressly includes receiving virtual currency for the purpose of transmitting it, and the licence-required section states that compensation includes profit or loss on the exchange of currency, monetary value or virtual currency, so a CVC exchange with a fiat ramp needs the Part II Money Transmitter licence. | Inside the statute. 'Virtual currency' is separately defined at 560.103(36), added by 2022 amendments, and 'money transmitter' at 560.103(24) expressly covers receiving or transmitting virtual currency; 'monetary value' at 560.103(22) expressly excludes virtual currency, so it is its own defined category brought within the same money transmitter licence rather than a separate regime. | Florida Office of Financial Regulation (OFR), Division of Consumer Finance. | none: no MTMA enactment as of 16 July 2026. | green: Florida has expressly defined and licensed virtual currency money transmission inside its money services business statute since 2022, with a mature, formula-based fee and bond structure. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Georgia GA | Yes. A convertible virtual currency exchange running a fiat on/off ramp falls within Georgia's money transmission definition (receiving money or monetary value for transmission) and commonly requires a money transmitter licence from the Department of Banking and Finance; no crypto-specific exchange carve-out exists. | Inside the money transmission statute. Virtual currency is a defined term at O.C.G.A. 7-1-680(30), added by 2024 Ga. Laws 701 effective 1 July 2024, and monetary value under 7-1-680(13) already captured non-cash mediums of exchange; there is no separate crypto-only licence regime. | Department of Banking and Finance (Georgia DBF), the state agency that licenses and supervises money transmitters under O.C.G.A. Title 7, Chapter 1, Article 4. | partial: H.B. 55 (2023); see also Act 748 (2022), effective July 1, 2023. | green: Georgia completed a multi-year statutory modernisation (2022-2024) that expressly defines virtual currency and average daily money transmission liability inside the money transmission statute, giving CVC exchanges. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Hawaii HI | Yes: the scenario's fiat on/off ramp (receiving and paying out US dollars) meets the HRS 489D-4 definition of money transmission, so a Hawaii money transmitter licence is typically required for the business as a whole. The Division of Financial Institutions' 2024 position removes only crypto-only activity from scope; it does not extend to fiat handling. | Guidance-based exclusion, not a statutory carve-out. The Division of Financial Institutions announced on 25 January 2024, effective with the Digital Currency Innovation Lab's 30 June 2024 conclusion, that digital-currency-only activity does not align with 'money transmission' under HRS chapter 489D, so no Hawaii licence applies to pure virtual currency activity; federal FinCEN, SEC and FINRA duties still apply. | Hawaii Department of Commerce and Consumer Affairs, Division of Financial Institutions (DFI): the state regulator administering HRS chapter 489D money transmitter licensing, examinations and enforcement, and the body behind the 2024 digital currency scope announcement. | partial: S.B. 1325 / H.B. 1027 (2023); see also S.B. 973 (2022), effective July 1, 2023. | amber: A standard, well-established Hawaii money transmitter licence is required for the fiat leg via NMLS, but a 2023 modernisation act raised net worth, bond and fee. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Idaho ID | Yes. The Department of Finance explicitly lists virtual currency exchangers that accept fiat for later delivery of virtual currency as needing a money transmitter licence, squarely covering a CVC exchange with a fiat on/off ramp; no exchange-specific statutory carve-out exists. | Guidance-only. The 1994 Idaho Money Transmitters Act (Idaho Code 26-2901 et seq.) has no statutory definition of virtual or digital currency; the Department instead brings virtual currency exchangers within the existing money transmission definition through its own published interpretive guidance. | Idaho Department of Finance, Securities Bureau, the state agency that administers and enforces the Idaho Money Transmitters Act, Idaho Code 26-2901 et seq. | none: no MTMA enactment as of 16 July 2026. | amber: Idaho licenses virtual currency exchangers only through Department guidance interpreting an unamended 1994 statute that never defines virtual currency, leaving the framework settled in practice but. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Illinois IL | Yes: money transmission licensing under the Uniform Money Transmission Modernization Act commonly applies, since a fiat on/off ramp fits the receiving-money-for-transmission limb of money transmission. A companion Digital Assets and Consumer Protection Act registration duty exists but is not yet operative until 2027. | Currently inside the general money transmission statute (205 ILCS 658) through IDFPR's fiat-intermediary interpretation, not a named category; pure crypto-to-crypto activity typically sits outside it. The Digital Assets and Consumer Protection Act (205 ILCS 731, enacted August 2025) layers a separate registration regime, not yet operative until 2027; overlap with money transmission awaits Department rulemaking. | Illinois Department of Financial and Professional Regulation (IDFPR), Division of Financial Institutions, Currency Exchange and Money Transmitter Section. | full: S.B. 3412 (Public Act 103-0991), effective January 1, 2026. | amber: Money transmission law fully switched from the Transmitters of Money Act to the Uniform Money Transmission Modernization Act on 1 January 2026, and a separate Digital. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Indiana IN | Yes: the fiat on/off ramp is licensable money transmission under Indiana's Money Transmission Modernization Act (IC 28-8-4.1-201(19)), effective 1 January 2024. Indiana's adoption expressly excludes virtual currency transmission itself from the licensing perimeter, so only the fiat leg of this scenario triggers the requirement. | Excluded by choice. Indiana adopted the CSBS Model Act (SEA 458, 2023) but expressly declined its virtual currency module. DFI guidance confirms transmission of virtual currency alone is not licensable, though a business also transmitting fiat still needs a licence for that fiat activity. | Indiana Department of Financial Institutions (DFI), Division of Consumer Credit. | full: S.B. 458, effective January 1, 2024. | amber: Modern Model Act framework, but virtual currency itself sits outside Indiana's licensing perimeter, creating classification questions for a combined fiat/crypto exchange model. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Iowa IA | Yes. Iowa Code ch. 533C treats virtual currency as monetary value, so both the fiat ramp and the crypto exchange leg of this scenario fall within one money transmission licence, confirmed by Iowa Division of Banking guidance. | Included within the statute. The Iowa Division of Banking treats virtual currency as monetary value under section 533C.102, so receiving virtual currency for transmission requires a licence. Kiosk operators face added wallet-verification duties under section 533C.1004, effective 1 July 2025. | Iowa Division of Banking (IDOB), within the Department of Insurance and Financial Services. | full: H.F. 675 (2023), effective July 1, 2023. | green: Modern Model Act chapter with virtual currency expressly folded into the statutory definition, fixed statutory fees, and a stated 121-day decision clock. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Kansas KS | Yes. The Kansas Money Transmission Act covers receiving money for transmission and selling or issuing payment instruments or stored value, and OSBC guidance applies this to virtual currency, so both legs of the scenario need a licence. | Covered by regulator guidance rather than an explicit statutory definition. OSBC guidance, reissued 2 January 2025 to confirm it still applies under the new Act, treats virtual currency transmission as licensable. A separate virtual currency kiosk licensing duty phases in from 1 July 2026. | Kansas Office of the State Bank Commissioner (OSBC), Consumer and Mortgage Lending Division. | full: H.B. 2560, effective January 1, 2025. | green: Newly modernised Act, explicit OSBC guidance applying it to virtual currency, and the clearest regulator-published fee schedule of the seven states. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Kentucky KY | Yes. KRS 286.11 defines money transmission broadly enough to cover a fiat/virtual currency exchange, confirmed by the department's own 2022 guidance. A narrow 2025 exemption for blockchain-protocol software and crypto-to-crypto activity does not reach a custodial fiat on/off ramp like this scenario. | Included within the statute via the monetary value or medium of exchange definition (KRS 286.11-003), confirmed by KDFI's 2022 guidance applying the Act to cryptocurrency. A June 2025 amendment (2025 Ky. Acts ch. 50) exempts blockchain-protocol software, node operation and crypto-to-crypto exchange only, under KRS 286.11-007(8). | Kentucky Department of Financial Institutions (KDFI). | none: no MTMA enactment as of 16 July 2026. | amber: Virtual currency is clearly covered by statute and guidance, but Kentucky kept its pre-Model-Act 2006 framework, with a flat, commissioner-discretionary bond up to $5m and an. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Louisiana LA | Yes, and likely twice over. The new Louisiana Money Transmission Act (effective 1 July 2026) covers the fiat leg, while the separate Virtual Currency Businesses Act covers exchanging, transferring or storing virtual currency, so this scenario commonly triggers review under both regimes. | Separate licence regime. The new LMTA (R.S. 6:1031-1072) contains no virtual currency provisions at all. Exchanging, transferring or storing virtual currency is licensed separately under the Virtual Currency Businesses Act, R.S. 6:1381 et seq., extended to virtual currency kiosks by 2025 Act 369, effective 1 August 2025. | Louisiana Office of Financial Institutions (OFI). | full: H.B. 1230, effective July 1, 2026. | red: Two parallel licensing regimes are commonly triggered for this scenario, one of them only weeks old with no track record, the other carrying a bond that. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Maine ME | Yes, under a single unified licence. Maine's Money Transmission Modernization Act folds virtual currency business activity into the same business of money transmission as the fiat leg, so one NMLS record and one licence commonly cover this whole scenario. | Included in the same licence. Subchapter 13 of ch. 79-A makes a person licensed for virtual currency business activity, being the exchange, transfer or storage of virtual currency, subject to the whole Act as money transmission, under 32 M.R.S. section 6100-QQ, with added disclosure and unhosted-wallet requirements. | Maine Bureau of Consumer Credit Protection, Department of Professional and Financial Regulation. | full: L.D. 2112 / S.P. 905, effective August 9, 2024. | green: Single unified licence explicitly covers both the fiat and virtual currency legs, with the lowest and simplest bond of the seven states. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Maryland MD | Yes. Maryland's own definition of money transmission reaches other value that substitutes for currency, and the Commissioner's advisory applies this to virtual currency, so both the fiat ramp and the crypto exchange leg of this scenario are covered by one licence. | Included in the statute. The money transmission definition itself captures other value that substitutes for currency (FI section 12-401(p)), which the Commissioner's industry advisory applies to virtual currency. A separate COMAR 09.03.16 kiosk regime, finalised effective 30 March 2026, adds registration duties for kiosk operators specifically. | Office of the Commissioner of Financial Regulation (OCFR), Maryland Department of Labor. | full per the CSBS tracker, adopted through COMAR 09.03.14 regulations effective 11 December 2023; the underlying statute is not Model Act text, so practitioner analyses vary. | amber: Virtual currency is squarely inside the statutory definition and the bond formula is transparent, but Maryland has not adopted the CSBS Model Act text and carries. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Massachusetts MA | Yes. Chapter 169B (licensing effective 1 January 2026) requires a money transmitter licence for anyone selling payment instruments, issuing stored value, or receiving money for transmission from a Massachusetts consumer, replacing the old foreign transmittal agency and check seller regime. | No express virtual currency definition. The Division of Banks FAQ states common transactional virtual currencies such as Bitcoin or USDC count as monetary value under section 1, so a CVC exchange with a fiat ramp typically needs a licence; closed loop game currency does not. | Massachusetts Division of Banks, within the Office of Consumer Affairs and Business Regulation. | full: H.B. 4840, effective January 1, 2026. | amber: Brand new domestic regime only fully operative from January 2026, with administratively set fees and no published processing timeline yet. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Michigan MI | Yes. The Money Transmission Services Act (2006 PA 250, MCL 487.1001 et seq.) requires a licence from DIFS for selling payment instruments, issuing stored value, or receiving money or monetary value for transmission, which covers a CVC exchange holding customer fiat pending conversion. | No express virtual currency definition exists. DIFS guidance treats an exchanger holding customer funds in an e-wallet as money transmission, tying licensing to whether FinCEN would treat the business as an administrator or exchanger. Major exchanges hold Michigan money transmitter licences on this basis. | Michigan Department of Insurance and Financial Services (DIFS), Consumer Finance Licensing. | pending: HB 5544 and SB 835 introduced in 2026; neither had passed a chamber as of 16 July 2026. | green: Long-established regime with a fixed, predictable $500,000 bond and $100,000 net worth for a single office, despite two DIFS pages disagreeing on the net worth ceiling. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Minnesota MN | Yes. Minnesota Statutes Chapter 53B, the state's Money Transmission Modernization Act enacted in 2023, requires a licence from the Department of Commerce for money transmission, which the Department states explicitly includes virtual currency business activity. | Chapter 53B contains dedicated virtual currency business activity sections (53B.69 to 53B.75), plus 2024 kiosk-specific amendments (Session Law 2024 Chapter 114, effective 1 August 2024) for physical kiosks. An online CVC exchange with a fiat ramp sits under the general virtual currency business activity provisions rather than the kiosk rules. | Minnesota Department of Commerce, Financial Institutions Division. | full: S.F. 2744 / H.F. 2680 (2023), effective August 1, 2023. | green: Explicit statutory virtual currency chapter, standard MTMA bond and net worth figures, and a clearly published application fee make this one of the most transparent regimes. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Mississippi MS | Yes. Money transmission requires a licence from the Department of Banking and Consumer Finance. The 2025 Money Transmission Modernization Act (House Bill 1428, effective 1 July 2025) replaced the prior Mississippi Money Transmitters Act, and a CVC exchange receiving customer fiat for transmission or exchange typically falls within scope. | Treated within the money transmission umbrella. A 2026 act (House Bill 1625, the Virtual Currency Kiosk Consumer Protection Act, effective 1 July 2026) expressly requires kiosk operators to hold a money transmitter licence; a non-kiosk online CVC exchange is understood to need the same general licence, though the exact current core definition text could not be independently retrieved. | Mississippi Department of Banking and Consumer Finance (DBCF), Nonbank Division. | full: H.B. 1428 / S.B. 2507, effective July 1, 2025. | amber: Genuine modernization is underway (HB 1428, HB 1625) but the regulator's own published requirements list has not caught up in places, so fee, bond and net. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Missouri MO | Yes. The Money Transmission Modernization Act of 2024 (sections 361.900 to 361.1035 RSMo) requires a licence from the Division of Finance for money transmission, and a CVC exchange receiving customer fiat for transmission falls within the receiving-money-for-transmission definition. | No express virtual currency definition; coverage rests on the broad monetary value and receiving-money-for-transmission definitions. A specific virtual currency kiosk provision effective 28 August 2025 separately deems kiosk operators to be engaged in money transmission requiring licensure. | Missouri Division of Finance, within the Department of Commerce and Insurance. | full: S.B. 1359, effective August 28, 2024. | green: Clean statutory MTMA adoption with confirmed net worth and bond formulas. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Montana MT | No. Montana remains the only US state with no money transmitter licensing regime. The Division of Banking and Financial Institutions states plainly that it does not regulate money transmitters, so a CVC exchange needs no state licence to serve Montana residents. | Not licensed or separately defined for money transmission purposes. The 2025 Financial Freedom and Innovation Act (Senate Bill 265, effective October 2025) protects rights to use digital assets and creates securities-style certification for network token issuers, but creates no money transmitter or exchange licence. | Montana Division of Banking and Financial Institutions has no money transmission jurisdiction; the State Auditor's office separately administers Senate Bill 265 network token certification. | none: no MTMA enactment as of 16 July 2026. | green: No state money transmitter licence, fee, bond or net worth requirement applies to this scenario. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Nebraska NE | Yes. The Nebraska Money Transmitters Act (Neb. Rev. Stat. Chapter 8, Article 27) requires a licence for money transmission, defined broadly enough to capture a CVC exchange with a fiat on/off ramp. Nebraska also offers a separate digital asset depository charter under the Financial Innovation Act, not required for this scenario. | No express virtual currency definition. Monetary value is defined only as a medium of exchange whether or not redeemable in money, broad enough that the Department has not needed a separate virtual currency clause. Nebraska runs a distinct Crypto ATMs regulatory page and a Financial Innovation Act depository charter alongside the ordinary MTL path. | Nebraska Department of Banking and Finance (NDBF), Financial Institutions Division. | full: L.B. 474 (2025), effective October 1, 2025. | green: Comprehensive, recently modernized statute with every core figure confirmed directly from the legislature's own statute pages. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Nevada NV | Yes, NRS Chapter 671 requires a money transmitter licence for any entity receiving or transmitting money or credits, and the Financial Institutions Division applies this to fiat-touching virtual currency exchange activity. A pure custody-only digital asset model may instead sit under the NRS 669 trust company regime. | Not a defined term in the rewritten Chapter 671 (the 2023 MTMA-style rewrite added no virtual currency definition). FID instead makes a case-by-case licensure determination under the general money transmission definition, treating fiat-touching crypto exchange as money transmission and routing pure custody toward the trust company chapter. | Nevada Financial Institutions Division (FID), Department of Business and Industry. | full: A.B. 21 (2023), effective July 1, 2023. | amber: Solid MTMA-style regime with moderate cost, but no virtual currency definition means FID requires a case-by-case licence-route determination before a crypto exchange can proceed. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| New Hampshire NH | Yes for the fiat-touching side. A convertible virtual currency only business is exempted from RSA 399-G by section 399-G:3(VII), but a CVC exchange with a fiat on or off ramp receives money for transmission, which sits inside the general money transmission definition and triggers licensing for that fiat leg. | Convertible virtual currency is a defined term (RSA 399-G:2(VII)), and persons dealing solely in CVC, selling or issuing CVC-only stored value, or receiving CVC for transmission, are exempted from licensing by 399-G:3(VII), remaining subject only to the state's consumer protection act, RSA 358-A. The exemption does not extend once fiat money is also received for transmission. | New Hampshire Banking Department. | full: H.B. 1241 (2024), effective October 24, 2024. | green: A modernised, low-cost MTMA-style regime with a clearly worded, decades-old convertible virtual currency exemption that does not disturb licensing for the fiat leg of an exchange. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| New Jersey NJ | Yes. The Money Transmitters Act definition (receipt of money for transmission, or sale or issuance of payment instruments, for a fee) is applied by the Department of Banking and Insurance to virtual currency exchanges operating a fiat on or off ramp; there is no virtual currency specific carve-out or separate licence. | No express virtual currency provision exists. The Act's general definition of money transmitter, receiving money for transmission or selling payment instruments for a fee, is the sole trigger, and the Department licenses virtual currency exchanges with a fiat leg as ordinary money transmitters under that definition. | New Jersey Department of Banking and Insurance (DOBI), Division of Banking. | none: no MTMA enactment as of 16 July 2026. | amber: No in-state office and a flat, modest bond keep entry costs low, but the pending Digital Asset and Blockchain Technology Act and reports of long real-world. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| New Mexico NM | Yes. The Regulation and Licensing Department's own money services business page lists virtual currency exchanging and trading services as a covered activity, and a fiat-ramped CVC exchange falls within the money transmission definition of selling payment instruments or stored value, or receiving money or monetary value for transmission. | Not named in the statute's text, but confirmed by regulatory practice. The Uniform Money Services Act defines monetary value broadly as a medium of exchange whether or not redeemable in money, without mentioning virtual currency; the Financial Institutions Division's own website lists virtual currency exchanging and trading as a money services business activity requiring the licence. | New Mexico Regulation and Licensing Department (RLD), Financial Institutions Division. | none: no MTMA enactment as of 16 July 2026. | amber: Regulator practice explicitly covers virtual currency exchange, but the higher internet-business net worth tier and a live fee-schedule discrepancy argue for care before budgeting. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| New York NY | Required in addition to the BitLicense. NYDFS confirms many BitLicensees also hold a money transmitter licence for fiat legs; the BitLicense does not substitute for Banking Law Article 13-B licensure. | Exchange, custody and fiat-free virtual currency activity is Virtual Currency Business Activity under 23 NYCRR 200.2(q), requiring a BitLicense or an approved Banking Law charter such as a limited purpose trust company. | New York State Department of Financial Services (NYDFS): its Virtual Currency Unit administers the BitLicense, its Banking Division administers money transmitters, both reporting to one Superintendent of Financial Services. | none: no MTMA enactment as of 16 July 2026. | red: Dual licensing (BitLicense plus money transmitter licence), case-by-case capital and bond, and a track record of multi-year timelines and DFS enforcement make New York the heaviest. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| North Carolina NC | Yes. The Money Transmitters Act defines money transmission to include receiving money or monetary value for transmission, and NCCOB's own guidance lists virtual currency exchange or holding as an authorised activity under the same money transmitter licence, with no separate crypto licence. | Express and inline. Virtual currency is defined at G.S. 53-208.42 as a digital medium of exchange, unit of account or store of value falling within the Article's stored value definition, and NCCOB confirms the same Money Transmitters Act applies equally with no separate licensing track for virtual currency businesses. | North Carolina Office of the Commissioner of Banks (NCCOB). | none: no MTMA enactment as of 16 July 2026. | green: Virtual currency is named directly in the statute, the licence is perpetual, and NCCOB publishes an unusually detailed public FAQ and assessment calculator, making this one. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| North Dakota ND | Yes. A person engaging in virtual currency business activity is, by statute, engaged in the business of money transmission and needs the same licence as any other money transmitter. North Dakota fully adopted the CSBS Money Transmission Modernization Act in 2023, including its optional virtual currency business activity chapter. | Folded into the money transmission licence with an added layer. Sections 13-09.1-44 to 13-09.1-54 (enacted by SB 2119, 2023) cover virtual currency business activity specifically: required disclosures, property-interest protections for customer holdings, and, for licensees doing virtual currency business, permission to count proprietary virtual currency toward tangible net worth. | North Dakota Department of Financial Institutions (DFI). | full: S.B. 2119 (2023), effective August 1, 2023. | amber: Costs sit at the low end of the batch, but the full virtual currency business activity chapter adds disclosure, property-segregation and record-keeping duties a fiat-only money. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Ohio OH | Yes. Ohio Revised Code 1315.01(G) defines transmit money broadly, to receive money or its equivalent and deliver, pay or make it accessible, and the Division of Financial Institutions' own guidance states virtual currencies such as bitcoin are treated as money or its equivalent, so a fiat-ramped CVC exchange is money transmission. | Guidance-based rather than a separate statutory definition. Chapter 1315 nowhere defines virtual currency; the Division's Interpretive Guidance 2022-01 and its money transmitter guidance page instead confirm that holding, controlling, exchanging or intermediating virtual currency fits the existing transmit money definition and is licensed exactly like fiat money transmission. | Ohio Division of Financial Institutions, Department of Commerce. | none: no MTMA enactment as of 16 July 2026. | amber: Crypto is clearly in scope through regulator guidance and the bond and net worth figures are moderate, but both the application fee and the ongoing annual. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Oklahoma OK | Yes. The money transmitter definition (6 O.S. section 1512(7)) covers accepting and transmitting currency or funds; a CVC exchange's fiat on/off ramp falls within this regardless of how virtual currency itself is treated. Digital asset kiosk operators face an explicit duty under 2025's Senate Bill 1083. | Virtual currency is not itself 'money' under 6 O.S. section 1512(3), which limits currency to government-issued legal tender. Senate Bill 1083 (2025, effective 1 November 2025) separately requires digital asset kiosk operators to hold a money transmitter licence; a fiat-handling exchange is caught by the base statute instead. | Oklahoma State Banking Department. | full: H.B. 3521, effective November 1, 2026. | amber: A licence is required through the fiat leg with well-defined, moderate costs, but virtual currency's exclusion from 'money' plus a brand-new 2025 kiosk law leave the. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Oregon OR | Yes. Oregon's money transmitter licence (ORS chapter 717) has applied to virtual currency businesses since the 'money' definition was broadened to include value that substitutes for currency; the Division of Financial Regulation states plainly that virtual currency exchanges need a licence. | Virtual currency sits inside the 'money' definition itself (ORS 717.200(10)(b): value that substitutes for currency without government-backed legal-tender status), so exchanging or issuing virtual currency is money transmission requiring a licence, confirmed directly in DFR's consumer guidance. | Division of Financial Regulation (DFR), Oregon Department of Consumer and Business Services. | none: no MTMA enactment as of 16 July 2026. | green: Low fixed capital thresholds for a single office ($25,000 bond, $100,000 net worth) and an explicit, regulator-confirmed statutory inclusion of virtual currency leave little interpretive risk. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Pennsylvania PA | Yes. Act 7 of 2025 (effective 26 August 2025) amended the Money Transmission and Virtual Currency Transmission Business Licensing Law to require a licence for transmitting virtual currency by transmittal instrument for a fee, with no grace period; the fiat leg of a CVC exchange independently triggers the historic money transmission licence too. | Included in the statute itself since Act 7 of 2025 (section 2(a)(2)), requiring a licence to transmit virtual currency by transmittal instrument for a fee. This replaced an April 2024 policy statement that had reinterpreted 'money' to include virtual currency, rescinded when Act 7 took effect on 26 August 2025. | Pennsylvania Department of Banking and Securities. | none: no MTMA enactment as of 16 July 2026. | amber: Virtual currency is now explicitly in scope with no transition period, and capital thresholds are the highest of the batch. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Rhode Island RI | Yes. Chapter 19-14.3 licenses 'virtual currency business activity' (exchanging, transferring or storing virtual currency) as currency transmission in its own right, so a CVC exchange with a fiat ramp is squarely covered regardless of the ramp itself. | Included directly: 'virtual currency business activity' is defined at section 19-14.3-1.1(23) and licensed as currency transmission. Sections 3.5 to 3.13 add virtual-currency-specific disclosure, custody, fraud-prevention and kiosk rules onto the same licence. | Rhode Island Department of Business Regulation (DBR), Division of Banking. | partial: H.B. 7282 (2024); see also Banking Bulletins 2022-1 and 2022-2, effective June 25, 2024. | green: Lowest fixed bond in the batch, no numeric net-worth floor, and the clearest, most comprehensive statutory inclusion of virtual currency of the seven jurisdictions. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| South Carolina SC | Yes, via the fiat leg. The Money Services Division treats virtual currency alone as outside 'monetary value,' but transactions that also transfer fiat currency are treated as money transmission subject to licensing (S.C. Code Ann. section 35-11-200, 35-11-105(12)). | Guidance-only exclusion when virtual currency stands alone (viewed as lacking 'monetary value'), but the Division's FAQ and a 5 December 2018 interpretation treat virtual currency transactions that also transfer fiat currency as within the Act. A kiosk-specific order (MSD-19003) addresses ATM-based exchange. | South Carolina Attorney General's Office, Money Services Division. | full: H.B. 5068 / S.B. 1031, effective January 1, 2025. | amber: A recently modernised regime with a meaningful bond ceiling. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| South Dakota SD | Yes. The Division of Banking's own memorandum (11-002) treats virtual currency as 'monetary value' under SDCL 51A-17-1(13), so an entity receiving virtual currency for transmission needs a licence; the fiat leg of a CVC exchange is separately and squarely money transmission. | Included by regulatory interpretation: Memorandum 11-002 (25 May 2019) states it is the Division's position that virtual currencies, including Bitcoin, are 'monetary value' under SDCL 51A-17-1(13). Licensees must list virtual currency transmission as an NMLS business activity and complete the virtual currency sections of the quarterly Call Report. | South Dakota Division of Banking, Department of Labor and Regulation. | full: S.B. 58 (2024), effective July 1, 2024. | green: Clear, longstanding regulatory confirmation that virtual currency is in scope, paired with the lowest flat capital thresholds among the Money Transmission Modernization Act-adjacent states in this. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Tennessee TN | Limited. The Money Transmitter Licence itself, and its surety bond, do not cover virtual currency transmission. The Department's own guidance says a company that exchanges, administers or maintains virtual currencies for sovereign currency 'may be subject to' state licensing and federal regulation, without confirming this licence is the vehicle. | Expressly excluded from the core licence: the Department states 'cryptocurrency is not money under the Tennessee Money Transmitter Act' and receiving it for later delivery is not money transmission. Tennessee did not adopt the Act's optional virtual currency provisions, unlike North Dakota and Minnesota. | Tennessee Department of Financial Institutions (TDFI). | full: S.B. 268, effective January 1, 2024. | amber: The Department's own hedge over whether fiat-for-crypto exchange needs this specific licence creates real interpretive uncertainty, and several dollar figures remain unverified against a primary fee. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Texas TX | Yes, Finance Code Chapter 152 (Money Services Modernization Act) requires a money transmission licence for receiving money for money transmission from a person located in Texas. The scenario's fiat on/off ramp falls squarely inside that definition, so the CVC exchange as a whole needs a Money Transmission License under section 152.101. | Hybrid treatment: section 152.003(19) writes qualifying stablecoin (sovereign pegged, fully reserved, redeemable for sovereign currency) directly into the statutory definition of money. Non-stablecoin virtual currency is expressly excluded from that definition by Supervisory Memorandum 1037 guidance; custodial digital asset trading platforms can separately trigger Chapter 160 (Digital Asset Service Providers). | Texas Department of Banking, the state agency that licenses and supervises money services businesses under Finance Code Chapter 152; licensing runs through its Corporate Activities Division and ongoing supervision through its Non-Depository Supervision Division. | full: S.B. 895 / H.B. 3573, effective September 1, 2023. | amber: NMLS-integrated process with a clear statutory 120-day decision clock and crypto-considered statutory definitions, but a $500,000 bond, sizeable background-check burden, and an additional Chapter 160 digital-asset-custody. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Utah UT | Yes, the fiat on/off ramp function meets the Money Transmitter Act's definition of money transmission (receiving money for transmission, currency conversion) under 7-25-102(9)(a), triggering licensure under 7-25-201. The 2020 exclusion of blockchain tokens from that definition (7-25-102(9)(b)) does not exempt the fiat leg of a hybrid CVC exchange of this scale. | Excluded from the money transmission definition itself. Section 7-25-102(9)(b), added in 2020, states money transmission does not include a blockchain token, defined at 7-25-102(4) as an electronic record recorded on a blockchain and tradeable between persons without an intermediary. Utah has no separate virtual currency licensing regime; the exclusion narrows scope rather than creating parallel oversight. | Utah Department of Financial Institutions (DFI), the state agency responsible for licensing and supervising money transmitters under Title 7, Chapter 25. | partial: S.B. 183 (2022), effective 2022 (specific date not stated in CSBS tracker). | green: Flat, low fixed costs (net worth $1,000,000, bond $50,000, about $500 total to originally licence) with a narrow, predictable three-category exemption list and no separate virtual-currency. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Vermont VT | Yes, both the fiat and virtual-currency sides of this scenario trigger licensure. Money transmission is defined broadly at 8 V.S.A. section 2503(17), and section 2573(b) states that a person engaging in virtual-currency business activity is engaged in the business of money transmission, so a single licence must be authorised for virtual-currency business activity. | Defined within the same money transmission statute rather than a separate charter. Section 2503(27) and (29) define virtual currency and virtual-currency business activity, and a dedicated Subchapter 010 (sections 2571 to 2577), added by 2024's Act 110, layers custody, disclosure, and net-worth conditions onto money transmission licensees authorised for that activity. | Vermont Department of Financial Regulation (DFR), Banking Division, which licenses and supervises money transmitters and money services businesses under Title 8, Chapter 79. | full per the CSBS tracker: H. 659 (2024), effective 1 July 2024. Some practitioner analyses class Vermont as a modified adoption. | amber: The 2024 MTMA-style bond formula scales to the full $2,000,000 statutory cap for this scenario's outstanding liability, and a dedicated virtual-currency subchapter adds custody, disclosure, and. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Virginia VA | Yes, a fiat on/off ramp is money transmission under Code of Virginia section 6.2-1929, because receiving customer funds for transmission (defined in section 6.2-1922) captures the fiat deposit and withdrawal legs. Virtual currency itself is defined but excluded from money, so licensure for this scenario is anchored on the fiat side of the business. | Defined but excluded: section 6.2-1922 defines virtual currency as a digital representation of value used as a medium of exchange, then expressly states money does not include virtual currency. There is no separate virtual currency licence regime; a standalone crypto only business sits outside the core money transmission definition, unlike the fiat legs of this scenario. | Virginia State Corporation Commission, Bureau of Financial Institutions, which licenses and supervises money transmitters under Code of Virginia Chapter 19.1 (section 6.2-1922 et seq.). | full: H.B. 1942, effective July 1, 2026. | amber: Modern MTMA-style regime with capped, predictable requirements and NMLS-based multistate processing, but implementing regulations are mid-transition and the still-published bond rule has not yet been conformed. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Washington WA | Yes, our scenario is money transmission because the licence definition expressly includes virtual currency as equivalent value (RCW 19.230.010(18)). A convertible virtual currency exchange with a fiat on/off ramp falls squarely within Washington's money transmitter licence requirement, per DFI's own virtual currency guidance describing exchange platforms as money transmitters. | Virtual currency is brought directly inside the money transmission definition, not handled through a separate licence or mere guidance. RCW 19.230.010(18) states equivalent value includes virtual currency, and RCW 19.230.010(30) defines virtual currency. The same money transmitter licence covers both fiat and virtual currency activity, with added virtual-currency-specific rules layered on. | Washington State Department of Financial Institutions (DFI), Division of Consumer Services, licenses and supervises money transmitters under the Uniform Money Services Act. DFI maintains dedicated FinTech guidance, a licensing decision tree, and a glossary for virtual currency businesses, reflecting an active, hands-on approach to crypto supervision. | none: no MTMA enactment as of 16 July 2026. | amber: A money transmitter licence is mandatory with moderate net worth and bond figures (about $500,000 each for this scenario) plus added virtual-currency-specific reserve, security-audit, and disclosure. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| West Virginia WV | Yes, a convertible virtual currency exchange with a fiat on/off ramp falls within the currency transmission/money transmission definition at W. Va. Code 32A-2-1(j), covering receipt of currency for transmission and payment through a digital wallet, so licensure is required under 32A-2-2. | West Virginia Code 32A-2-1 defines virtual currency, virtual currency business activity, virtual currency kiosk, and digital wallet directly, and 32A-2-1(j)(3) folds operating a virtual currency kiosk into the money transmission definition itself. Detailed kiosk disclosure, transaction-limit, and compliance-officer rules sit at 32A-2-8c, added by 2026 House Bill 5353. | The West Virginia Division of Financial Institutions, headed by the Commissioner of Financial Institutions, licenses and supervises money transmitters under Chapter 32A, Article 2. | partial: Ch. 181 (2022); see also S.B. 345 (2023), effective March 10, 2023 (S.B. 345 letters-of-credit rule); Ch. 181 enacted 2022. | amber: Licensure is clearly required and the volume-scaled bond reaches $700,000 for this scenario, but a 120-day statutory decision clock and MTMA-aligned net worth and investment rules. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Wisconsin WI | Yes, a convertible virtual currency exchange with a fiat on/off ramp meets the money transmission definition in Wis. Stat. 217.02(17) (receiving money for transmission, selling stored value), and the Division of Banking's own guidance confirms licensure is required whenever fiat is exchanged for delivery of virtual currency to a customer or third party wallet. | Virtual currency itself is not defined in 217.02. Division of Banking guidance treats fiat received for delivery of virtual currency to a customer or third party wallet as money transmission under 217.02(17)(c). Kiosks have separate rules under 2025 Wisconsin Act 226 (cited by the Division as Wis. Stat. 217.12), not independently verified from the statute site this session. | The Wisconsin Department of Financial Institutions, Division of Banking, licenses and supervises money transmitters under chapter 217. | full: S.B. 668, effective January 1, 2025. | amber: Licensure is clearly required with a full MTMA-style compliance load (tiered net worth, a $500,000 bond ceiling, quarterly and annual reporting), but the process is standardised. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Wyoming WY | Limited. W.S. 40-22-104(a)(vi) exempts buying, selling, issuing, taking custody of, or transmitting virtual currency from the Wyoming Money Transmitters Act. The fiat on/off ramp is not exempt: receiving money for transmission still meets the definition at 40-22-102(a)(xiii), so a money transmitter licence typically applies to that leg. | Virtual currency is expressly carved out of the Act by W.S. 40-22-104(a)(vi), following 2018 House Bill 19: buying, selling, issuing, custody of, or transmitting virtual currency is not licensed activity. Firms such as Coinbase have nonetheless retained a Wyoming money transmitter licence for their fiat operations. | Wyoming Division of Banking, Office of the State Banking Commissioner, Money Transmitters programme. | none: no MTMA enactment as of 16 July 2026. | amber: Virtual currency itself is exempt by statute, but the fiat on/off ramp still needs a standard NMLS money transmitter licence with a capped bond and modest. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Puerto Rico PR · territory | Yes. Act 136-2010 requires an OCIF money transmitter licence for the fiat leg, 10 L.P.R.A. section 2601. Virtual currency is not exempted: OCIF Circular Letter CIF-CC-2021-03 states that an administrator or exchanger that accepts, transmits, buys or sells convertible virtual currency for any reason is a money transmission business requiring a licence. | Act 136-2010 does not itself define virtual currency, but OCIF Circular Letter CIF-CC-2021-03 (22 April 2021) confirms that businesses accepting, transmitting, buying or selling convertible virtual currency, including Bitcoin, Ethereum, Tether and similar assets, are money services businesses requiring an OCIF licence. OCIF later issued a cease and desist against an unlicensed crypto ATM operator. | Office of the Commissioner of Financial Institutions (OCIF), Financial Regulation Division. | none: not tracked by CSBS; this jurisdiction operates its own regime. | amber: OCIF licenses convertible virtual currency exchange and transmission but requires substantial capital, liquid assets and bond, and has actively shut down unlicensed crypto kiosk operators. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| U.S. Virgin Islands VI · territory | Limited, and in practice no viable route for a CVC exchange. Title 9 V.I.C. section 511 requires a money transmission licence for traditional fiat transmission, but Bulletin 2022-01 states the Banking Board will not approve or consider a money transmission application from an entity performing cryptocurrency services. | The Banking Board has formally determined cryptocurrency is a non-licensed product in the territory: not specifically authorised under Title 9, and not regulated by the Division. Money transmitter licensure 'extends only to persons performing traditional money transmission services,' per Bulletin 2022-01 (11 April 2022), which bars approval of applications from entities performing cryptocurrency services. | Office of the Lieutenant Governor, Division of Banking, Insurance and Financial Regulation; policy is set by the Virgin Islands Banking Board, chaired by the Lieutenant Governor. | none: not tracked by CSBS; this jurisdiction operates its own regime. | red: The Banking Board has formally stated it will not approve or consider a money transmission licence for an entity performing cryptocurrency services, so no lawful route. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Guam GU · territory | Limited. 11 GCA section 109102 requires a Foreign Exchange License for receiving money for transmission, expressly including transmission within the United States, so the fiat leg is covered. The chapter is silent on virtual currency, so the exchange leg's status is unaddressed rather than clearly resolved either way. | Not located in primary sources. Chapter 109 (Foreign Exchange) does not define or mention virtual currency, cryptocurrency or digital assets, and no Commissioner guidance comparable to Puerto Rico's or the Virgin Islands' crypto circulars was found. | Guam Department of Revenue and Taxation, Regulatory Division, Insurance, Securities, Banking and Real Estate Branch (ISBRE), under the Commissioner of Banking and Insurance. | none: not tracked by CSBS; this jurisdiction operates its own regime. | amber: The fiat leg clearly needs a Foreign Exchange License with a modest fixed bond, but the statute and public guidance are silent on virtual currency, leaving. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| American Samoa AS · territory | Yes, on the best evidence available, though primary statute text could not be directly retrieved. A Money Services Business Regulatory Act (reported effective around October 2019) requires an Office of Financial Institutions licence for money transfer businesses, and reporting indicates OFI has renewed certification for the entity that operates Binance.US. | No dedicated virtual currency statute or OFI guidance was located. Reporting states OFI has continued renewing money services business certification for the entity operating Binance.US, suggesting virtual currency exchange activity is being licensed as an ordinary money services business rather than addressed separately. | American Samoa Government Office of Financial Institutions (OFI), headed by a Commissioner; a Commissioner appointment was confirmed by official government memorandum in March 2025, indicating the office is currently active. | none: not tracked by CSBS; this jurisdiction operates its own regime. | amber: News reporting indicates a real, actively administered money services business regime that has licensed a Binance.US-linked entity, but the statute text and fee schedule could not. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
| Northern Mariana Islands MP · territory | Limited, and probably no for a purely domestic scenario. NMI Administrative Code 20-20.1 licenses 'remittance,' defined as receiving money to transmit to a country outside the Commonwealth. A domestic US CVC exchange with a US fiat ramp sits outside that definition on its face, and no separate general money transmitter or virtual currency statute was found. | Not located in primary sources. No provision of the Commonwealth Banking Code (4 CMC sections 6101 to 6814) or its implementing regulations reviewed addresses virtual currency, cryptocurrency or digital assets. | CNMI Department of Commerce, Division of Banking, under the Director of Banking within the Office of the Secretary of Commerce. | none: not tracked by CSBS; this jurisdiction operates its own regime. | amber: The existing licence is narrowly scoped to outbound foreign remittance and foreign currency exchange, so it is unclear whether or how it would reach a domestic. | Application fees is included with access. | Surety bond is included with access. | Typical timeline is included with access. |
Data version 2026-07-16.1-verified. Every cell cites its source; under review marks cells where primary sources conflict or a figure awaits confirmation.