Informational only — not legal advice. Verify with qualified counsel before acting. Full disclaimer

District of Columbia (DC)

Money transmission and virtual currency licensing planning data for District of Columbia.

Population weight (planning): 0.20% · Back to matrix · Launch map

How to read this page: confirmed cells are checked against a primary regulatory source and dated. Under review marks a cell where primary sources conflict or a figure awaits confirmation.

MTL required

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.

Verified 2026-07-16. Source

Fiat treatment

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.

Verified 2026-07-16. Source

Virtual currency treatment

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.

Verified 2026-07-16. Source

Regulator

District of Columbia Department of Insurance, Securities and Banking (DISB), Banking Bureau.

Verified 2026-07-16. Source

MTMA adoption

none: no MTMA enactment as of 16 July 2026.

Verified 2026-07-16. Source

Launch posture

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,.

Verified 2026-07-16. Source

Application fees (locked)

Application fees is included with access.

Unlock with LicenceMap access

Renewal fees (locked)

Renewal fees is included with access.

Unlock with LicenceMap access

Net worth / capital (locked)

Net worth / capital is included with access.

Unlock with LicenceMap access

Surety bond (locked)

Surety bond is included with access.

Unlock with LicenceMap access

Bond formula (locked)

Bond formula is included with access.

Unlock with LicenceMap access

Permissible investments (locked)

Permissible investments is included with access.

Unlock with LicenceMap access

Control persons (locked)

Control persons is included with access.

Unlock with LicenceMap access

Local presence (locked)

Local presence is included with access.

Unlock with LicenceMap access

Exam / audit timeline (locked)

Exam / audit timeline is included with access.

Unlock with LicenceMap access

Exemptions (locked)

Exemptions is included with access.

Unlock with LicenceMap access

Typical timeline (locked)

Typical timeline is included with access.

Unlock with LicenceMap access

Practitioner notes (locked)

Practitioner notes is included with access.

Unlock with LicenceMap access

Under the planning scenario

LicenceMap's bond and net worth figures use one scenario throughout: a virtual currency exchange with a fiat on and off ramp, $50m in annual US transmission volume, $2m in average daily outstanding liability, and a single principal office.

Surety bond: Surety bond is included with access.

Net worth / capital: Net worth / capital is included with access.

Unlock with LicenceMap access