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.
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| Jurisdiction | MTL required | Fiat treatment | Virtual currency treatment | Regulator | NMLS / portal | MTMA adoption | Launch posture | Application fees | Renewal fees | Net worth / capital | Surety bond | Bond formula | Permissible investments | Control persons | Local presence | Exam / audit timeline | Exemptions | Typical timeline | Practitioner notes |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 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. | Fiat money transmission, receiving money or monetary value for transmission, is the core licensed activity under the Act, subject to the exclusions and exemptions in sections 8-7A-3 and 8-7A-4. Ala. Code 8-7A-2(10). | 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. | Money Transmitter License, filed through the Nationwide Multistate Licensing System; ASC's own instructions also describe direct paper filing of Form MT by mail. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Fiat money transmission is licensed the same way as any other money-services activity under the Alaska Uniform Money Services Act. 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. | Money Transmitter License, filed through the Nationwide Multistate Licensing System; Alaska issues no paper licence for NMLS-administered licence types. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Receiving money for transmission from a person in Arizona is one of three licensed activities and is the leg that brings this scenario into scope. A.R.S. 6-1201(17), 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). | Money Transmitter License, filed through the Nationwide Multistate Licensing System. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Receiving money for transmission is one of the listed money transmission activities requiring licensure. Ark. Code 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). | Money Transmitter License, filed through the Nationwide Multistate Licensing System. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Standalone fiat transmission sits under the Money Transmission Act (Fin. Code 2003). For DFAL persons, transmitting payment for the purchase, exchange or sale proceeds of a digital financial asset is the subject of a proposed MTA exemption in PRO 02-23, not yet effective. | 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. | Money Transmitter License and Digital Financial Asset Business License, both filed through the Nationwide Multistate Licensing System. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Receiving money for transmission from a Colorado person is one of three licensed money transmission activities. C.R.S. 11-110-201(20)(a)(III). | 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). | Money Transmitter License, filed through the Nationwide Multistate Licensing System. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Receiving money or monetary value for transmission is the core licensed activity; virtual currency is treated similarly to fiat under the same statute rather than a separate scheme. Conn. Gen. Stat. 36a-596. | 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. | Money Transmission License, filed through the Nationwide Multistate Licensing System. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Yes. Section 2303 requires a licence for a person engaged in the business of receiving money for transmission or transmitting the same, and this applies regardless of whether virtual currency is also handled. The newly enacted replacement statute keeps the same 'receiving money for transmission' trigger. | 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. | NMLS licence type: Check Seller, Money Transmitter (Delaware). The Office of the State Bank Commissioner directs all Chapter 23 licensees to apply, renew and amend through the Nationwide Multistate Licensing System. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Yes, on its own. Money transmission is defined as the sale or issuance of payment instruments, or receiving money for transmission or transmitting money 'by any and all means', which commonly triggers licensing under the licence-required provision regardless of any virtual currency activity. | 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. | NMLS licence type: Money Transmitter (District of Columbia). DISB's own guidance directs applicants engaged in virtual currency money transmission to file the application and supporting documents through the Nationwide Multistate Licensing System. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Yes. 'Money transmitter' is defined to include receiving currency or monetary value to act as an intermediary in transmitting it, and the licence-required section separately confirms that compensation from exchanging currency alone commonly triggers the Part II licensing requirement. | 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. | Florida does not use NMLS for money services business licensing, unlike most other states. Applications, renewals and amendments go through OFR's own Online Services (REAL system) portal for the Part II Money Transmitter licence. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Yes. The fiat leg alone, receiving money for transmission, independently satisfies the money transmission definition at O.C.G.A. 7-1-680(14)(A) and commonly triggers review under the licensing requirement at O.C.G.A. 7-1-681, regardless of whether a virtual currency leg is also present. | 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. | NMLS licence type: Money Transmitter (Georgia). State-specific licensing requirements and the new-application checklist are published on the NMLS State Licensing Requirements page for Georgia. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Yes, on its own. HRS 489D-4 defines money transmission to include receiving money (fiat currency authorised or adopted by a government) for transmission from a person in the State. A fiat deposit or withdrawal rail commonly triggers HRS 489D licensing regardless of what the funds are later converted into. | 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. | Licence type: Money Transmitter Licence (HRS chapter 489D). DFI directs applicants to file through the NMLS Resource Center, and Hawaii publishes an NMLS company new-application checklist; the checklist's own fee line items could not be rendered directly, so figures here rely on the codified statute instead. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Yes. Money transmission is defined to include the business of receiving money for transmission at Idaho Code 26-2902(11), so the fiat leg alone commonly triggers the licensing requirement at Idaho Code 26-2903, independent of any virtual currency leg. | 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. | NMLS licence type: Money Transmitter (Idaho). Applications and the state-specific new-application checklist are filed through the Nationwide Multistate Licensing System. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Yes: receiving a customer's US dollars as an escrow-like intermediary before delivering value independently satisfies the receiving-money-for-transmission limb of money transmission (205 ILCS 658/2-1), regardless of the digital asset side of the transaction, mirroring IDFPR's longstanding interpretive guidance on digital currency exchangers. | 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. | NMLS licence type: Money Transmitter License. Illinois participates in NMLS for licensing and reporting, and requires the electronic surety bond through NMLS from calendar year 2026; the state resource page is hosted on NMLS's Illinois state licensing portal. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Money transmission covers selling or issuing payment instruments or stored value, and receiving money for transmission, from a person located in Indiana, under IC 28-8-4.1-201(19). The definition excludes solely online or telecommunications services or network access. | 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. | Money Transmitter Licence (MT), Indiana DFI Division of Consumer Credit, applied for and renewed through NMLS. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Money transmission covers selling or issuing payment instruments or stored value, and receiving money or monetary value for transmission, under Iowa Code section 533C.301 and the definitions in section 533C.102. | 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. | Money Transmitter Licence, Iowa Division of Banking, applied for and renewed through NMLS. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Money transmission covers selling or issuing payment instruments or stored value to, and receiving money for transmission from, a person located in Kansas, plus payroll processing services, under the Kansas Money Transmission Act, K.S.A. 9-555 et seq., replacing the repealed 9-508 et seq. from 1 January 2025. | 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. | Money Transmitter (MT) Licence, Kansas OSBC, applied for and renewed through NMLS. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Money transmission means receiving money or monetary value, redefined by a 2025 amendment to reference a medium of exchange, to transmit, deliver or instruct delivery of money or monetary value to another location by any means, including issuing stored value, under KRS 286.11-003. | 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). | Money Transmitter Licence, Kentucky Department of Financial Institutions, applied for and renewed through NMLS. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Money transmission covers selling or issuing payment instruments or stored value, and receiving money for transmission, from a person in Louisiana, under the Louisiana Money Transmission Act, R.S. 6:1031 et seq. (Act 888/HB 1230 of 2026, effective 1 July 2026, replacing the 1966 Sale of Checks and Money Transmission Act). | 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). | Money Transmitter Licence (LMTA) plus a separate Virtual Currency Business Activity licence, both administered by Louisiana OFI through NMLS. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Money transmission covers selling or issuing payment instruments or stored value, and receiving money for transmission, under 32 M.R.S. ch. 79-A, the Maine Money Transmission Modernization Act, enacted 22 April 2024 and effective 16 July 2024. | 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. | Money Transmitter and Virtual Currency Business Activity Licence, Maine Bureau of Consumer Credit Protection, applied for through NMLS. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Money transmission means selling or issuing payment instruments or prepaid access, or receiving currency, funds or other value that substitutes for currency and transferring it to another person or location, under Md. Code Ann., Financial Institutions section 12-401(p). | 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. | Money Transmitter Licence, Maryland Office of the Commissioner of Financial Regulation, applied for and renewed through NMLS. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Domestic fiat transmission is regulated for the first time. Section 1 defines money transmission as selling payment instruments, selling stored value, or receiving money for transmission from a person in the Commonwealth for personal, family or household purposes; business-to-business flows are outside scope. | 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. | NMLS Money Transmitter licence (Massachusetts). The Division began accepting applications through NMLS around 1 July 2025, with no licences issued before 1 January 2026. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Fiat money transmission has been licensed since the Act took effect on 1 January 2007. It covers selling or issuing payment instruments or stored value, or receiving money or monetary value for transmission; pure currency exchange alone is excluded. | 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. | NMLS Money Transmission Services licence (Michigan). | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Standard MTMA definition: selling or issuing payment instruments or stored value, or receiving money for transmission, triggers licensing. Enacted via 2023 Session Law Chapter 57 (Senate File 2744), signed 24 May 2023, replacing the prior Chapter 53B regime. | 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. | NMLS Money Transmitter licence (Minnesota); state landing page also links the NMLS licence description directly. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Money transmission is defined as engaging in the business of selling or issuing checks, or receiving money or monetary value for transmission; this fiat-transmission core has applied since the original 1966 Act and continues under the 2025 modernization. | 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. | NMLS Money Transmitter licence (Mississippi). | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Money transmission covers selling or issuing payment instruments, selling or issuing stored value, or receiving money for transmission from a person in Missouri; this replaced the former Sale of Checks Law effective 28 August 2024. | 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. | NMLS Money Transmission licence (Missouri). | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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 at the state level. Fiat money transmission activity is unregulated by Montana; only federal FinCEN money services business registration and Bank Secrecy Act obligations apply. | 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. | No NMLS money transmitter licence type exists for Montana. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Money transmission means selling or issuing payment instruments or stored value to a person in Nebraska, or receiving money for transmission from a person in Nebraska; it also expressly includes payroll processing and informal value transfer system services. | 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. | NMLS Money Transmitter licence (Nebraska). | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Fiat money transmission is the core, unmodified activity the chapter regulates: selling or issuing payment instruments or stored value, or receiving money or credits for transmission, from a person located in Nevada, all trigger licensing under NRS 671.013. | 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. | Money Transmitter licence (NMLS); initial and renewal applications run through NMLS using the Company Form (MU-1) for the principal office. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Selling or issuing payment instruments or stored value, or receiving money for transmission, from a person located in New Hampshire triggers licensing under RSA 399-G:2(XVIII); money means a medium of exchange authorised or adopted by a government, so a fiat leg is squarely covered. | 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. | Money Transmitter licence (NMLS); all new New Hampshire money transmitter licensing runs through NMLS. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Fiat money transmission is the Act's core, unmodified trigger: the sale or issuance of payment instruments, or the receipt of money for transmission within the United States or abroad, for a fee, commission or other benefit. | 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. | Money Transmitter licence (NMLS); DOBI also maintains its own paper application package alongside NMLS submission. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Fiat money transmission is the statute's core trigger: selling or issuing payment instruments or stored value, or receiving money or monetary value for transmission, to persons located in New Mexico, requires a money transmitter licence. | 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. | Money Transmitter licence (NMLS); verify licensees through NMLS Consumer Access. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Fiat deposits, withdrawals and the on/off ramp are money transmission under Banking Law Article 13-B, licensed separately from virtual currency activity, and administered through NMLS alongside the BitLicense application. | 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. | NMLS State Licensing Resource Center page for New York, listing both the virtual currency business activity licence and money transmitter licence checklists and transition guides. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Fiat money transmission is the Act's baseline activity: receiving money or monetary value for transmission within the United States or abroad by payment instrument, stored value, wire, facsimile or electronic transfer, for personal, family or household purposes. | 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). | Money Transmitter licence (NMLS); NCCOB requires all applications through NMLS. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Fiat money transmission is the base activity the chapter regulates: selling or issuing payment instruments to, selling or issuing stored value to, or receiving money or credits for transmission from, a person located in North Dakota. | 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). | Money Transmitter licence (NMLS); the chapter refers throughout to filings through the nationwide system. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Fiat money transmission is the statute's unmodified base case: receiving money or its equivalent from a person and delivering, paying or making it accessible to the same or another person, at the same or another time or place, requires a licence under R.C. 1315.02. | 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. | Money Transmitter licence (NMLS); the Division accepts all applications through NMLS. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Fiat money transmission is licensed under the Oklahoma Financial Transaction Reporting Act, 6 O.S. section 1511 et seq., administered by the Oklahoma State Banking Department. | 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. | Money Transmitter licence, filed through NMLS; checklist on the NMLS State Licensing Resource Center (StateID OK). | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Fiat money transmission (wiring, bill payment, payment instruments) is licensed under ORS 717.205, administered by the Division of Financial Regulation within the Department of Consumer and Business Services. | 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. | Money Transmitter licence via NMLS; Oregon's checklist sits on the NMLS State Licensing Resource Center (StateID OR). | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Fiat money transmission has been licensed since the original Money Transmitter Act (Act 249 of 1965), now the Money Transmission and Virtual Currency Transmission Business Licensing Law, 7 P.S. section 6101 et seq., administered by the Department of Banking and Securities. | 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. | Money Transmitter licence via NMLS; Pennsylvania's Money Transmitter Application Checklist is on the NMLS Checklist Compiler under New Application, PA, Company, Money Transmitter Licence. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Fiat currency transmission is licensed under R.I. Gen. Laws chapter 19-14.3 (Currency Transmissions), together with the bonding and licensed-activities provisions of chapter 19-14, administered by the Department of Business Regulation's Division of Banking. | 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. | Currency Transmitter licence via NMLS; Rhode Island's Phase Two requirements checklist is published on the NMLS State Resource Center. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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)). | Fiat money transmission (payment instruments, stored value, receiving money for transmission) is licensed under the Money Transmitter Licence, S.C. Code Ann. section 35-11-200(A) and 35-11-105(12), administered by the Attorney General's Money Services Division. | 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. | Money Transmitter licence via NMLS; South Carolina's licence and registration requirements are listed on the NMLS State Licensing Resource page (StateID sc-ag). | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Fiat money transmission (sale of payment instruments or stored value, or receiving money for transmission) is licensed under SDCL chapter 51A-17, administered by the Division of Banking within the Department of Labor and Regulation. | 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. | Money Transmitter licence via NMLS; South Dakota's requirements are published on the Division of Banking's site alongside the NMLS State Licensing Resource page (StateID SD). | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Fiat money transmission is licensed under the Money Transmission Modernization Act, Tenn. Code Ann. section 45-7-101 et seq. (effective 1 January 2024), administered by the Department of Financial Institutions. | 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). | Money Transmitter licence via NMLS; the Tennessee Money Transmitter License Requirements Checklist is published within NMLS. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Money transmission is defined as selling or issuing payment instruments or stored value, or receiving money for money transmission services, from a person located in Texas (Finance Code section 152.003(22)). Handling the fiat funding or cash-out leg of the exchange falls directly within this definition, triggering licensing 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. | Money Transmission License (a separate, narrower Currency Exchange License covers currency-conversion-only businesses and would not fit this scenario). New applications, financials, background forms and bonds are filed through NMLS per the TX-DOB Money Transmission Company New Application Checklist. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Money transmission is defined at 7-25-102(9)(a) as selling or issuing a payment instrument, or engaging in the business of receiving money for transmission or transmitting money within the United States or abroad by any means including wire, facsimile, or electronic transfer. A fiat on/off ramp meets this definition directly. | 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. | NMLS licence type: Money Transmitter. Applications, renewals, and authorised-delegate reporting (UAAR) all run through NMLS; Utah DFI's own regulator-authored new-application checklist is published on the NMLS Resource Center. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Money transmission is defined at 8 V.S.A. section 2503(17) as selling or issuing payment instruments, selling or issuing stored value, or receiving money for transmission, in each case to or from a person located in Vermont. A fiat on/off ramp falls within this definition, requiring a licence under section 2505. | 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. | NMLS licence type: Money Transmitter. Applications, authorised-delegate reporting (UAAR), and renewals are all submitted through NMLS; DFR's own Money Services page sets out fees and prerequisites and links through to the NMLS portal. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | The fiat side is squarely money transmission: section 6.2-1922 defines money transmission as selling or issuing payment instruments, selling or issuing stored value, or receiving money for transmission from a person in the Commonwealth. Section 6.2-1929 requires a licence before engaging in that business or advertising it. | 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.). | Licence type name found on an NMLS-hosted Virginia checklist filename: Money Order Seller and Money Transmitter License. The Virginia NMLS state resource page redirected to a generic system homepage rather than rendering state-specific text, so this name could not be independently confirmed from live page content. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Fiat money transmission is captured by the core definition at RCW 19.230.010(18): receiving money or its equivalent value to transmit, deliver, or instruct delivery elsewhere, by any means. A money transmitter licence is required under RCW 19.230.030 before engaging in, advertising, or holding out as providing money transmission in the state. | 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. | Washington uses the NMLS licence type Money Transmitter License (MT), covering both fiat and virtual currency transmission activity; there is no separate virtual currency licence type or endorsement. Applications, the electronic surety bond, and annual assessments are filed through NMLS. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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(j) defines currency transmission or money transmission as selling or issuing cheques, receiving currency for transmission, or paying money or a money substitute by wire, electronic means, or digital wallet. A licence is required under 32A-2-2 unless 32A-2-3 exempts the activity. | 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. | NMLS licence type: Money Transmitter License. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Wisconsin Statutes 217.02(17) defines money transmission as selling or issuing payment instruments or stored value, or receiving money for transmission from a person in Wisconsin. A licence is required under 217.05(1) unless 217.03 exempts the activity. The 217.02 definitions page did not load directly this session; verified via the Justia mirror instead. | 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. | NMLS licence type: Money Transmitter (replaced the Seller of Checks licence effective 1 January 2025). | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Selling or issuing payment instruments, or receiving money or monetary value for transmission by wire, facsimile, electronic transfer or similar means, is money transmission requiring a licence under W.S. 40-22-103. This covers the fiat side of a convertible virtual currency exchange regardless of the virtual currency exemption. | 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. | Money Transmitter License via NMLS, confirmed on the Division's own application-forms page. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Receiving any payment order or other means of money transfer, including electronic transfers, for a service charge is a licensed 'Negocio de Transferencias Monetarias' under 10 L.P.R.A. section 2581(p). The fiat on/off ramp of a CVC exchange fits this definition directly. | 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. | Money Transmitter licence via NMLS; Puerto Rico has used NMLS for money services business licensing since at least 2019. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Selling or issuing payment instruments or stored value, or receiving money or monetary value for transmission, is licensed money transmission under Title 9 V.I.C. section 511, Uniform Money Services Act, Subchapter II. | 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. | Not on NMLS for money transmission. Applications go directly to the Division of Banking, Insurance and Financial Regulation; no Virgin Islands money transmitter checklist could be located on NMLS's state resource pages. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Receiving money for transmission, whether to a foreign country or within the United States by an instrument or order drawn on the recipient, is licensed activity requiring a Foreign Exchange License from the Commissioner of Banking and Insurance, 11 GCA section 109102. | 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. | Not on NMLS for this licence. Applications are made directly to the Department of Revenue and Taxation using paper forms (FX series); NMLS's ESB adoption listing for Guam covers only its mortgage licence types. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | Money transfer businesses (money transmitters) are licensed by the Office of Financial Institutions under the Money Services Business Regulatory Act, understood to sit within American Samoa Code Annotated Title 28 (Finance and Financial Institutions). Exact section numbers were not located in a directly retrieved primary text. | 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. | Not on NMLS. Applications are understood to be made directly to the Office of Financial Institutions; no application portal URL was confirmed in primary sources. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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. | The Commonwealth licenses 'remittance' (receiving money to transmit to a country outside the Commonwealth) and 'foreign exchange currency transactions' (buying or selling foreign currency notes), NMIAC section 20-20.1-005. Purely domestic US money transmission is not clearly within this definition. | 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. | Not on NMLS. Applications are made directly to the Department of Commerce, Division of Banking, using paper forms in the FX series. | 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. | Renewal fees is included with access. | Net worth / capital is included with access. | Surety bond is included with access. | Bond formula is included with access. | Permissible investments is included with access. | Control persons is included with access. | Local presence is included with access. | Exam / audit timeline is included with access. | Exemptions is included with access. | Typical timeline is included with access. | Practitioner notes 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.