New York decision tool

Timeline urgency

Need a path in under 12 months 12 to 24 months is acceptable Multi-year build is acceptable

Capital available

Under $1m regulatory / build capital $1m to $5m Over $5m

New York customer need

Must serve NY retail customers directly NY is important but not day-one critical NY only via B2B / no retail Can exclude NY residents for now

Score NY routes

Routes compared

• NY BitLicense (23 NYCRR Part 200): Covers virtual currency business activity but not the fiat leg, so this scenario also needs a money transmitter licence. NYDFS applies case-by-case capital and bond, with a long, DFS-paced review. Last verified 2026-07-16.
  Sources: dfs.ny.gov, law.cornell.edu
• Conditional BitLicense (2020 framework): Proposed by DFS in June 2020 for startups partnering with an existing licensee. Used once, by PayPal, later converted to a full licence in 2022; treated here as dormant rather than reliably available. Last verified 2026-07-16.
  Sources: dfs.ny.gov, dfs.ny.gov
• NY limited purpose trust charter (Banking Law): Used by Gemini, Paxos, Coinbase Custody and others. Avoids a separate money transmitter licence and allows fiduciary powers, trading a bond-based BitLicense model for bank-style chartering and case-by-case capital. Last verified 2026-07-16.
  Sources: dfs.ny.gov, dfs.ny.gov
• Serve NY through a licensed partner: Operating through an already-licensed BitLicensee, money transmitter or limited purpose trust company for the New York leg. NYDFS's supervisory relationship sits with the partner, not this business. Last verified 2026-07-16.
  Sources: dfs.ny.gov, dfs.ny.gov
• Geoblock New York residents: Excludes New York residents entirely rather than licensing. NYDFS applies a long-arm test to virtual currency business activity involving New York residents, so solicitation and geofencing accuracy both matter. Last verified 2026-07-16.
  Source: dfs.ny.gov

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