Hawaii (HI)
Money transmission and virtual currency licensing planning data for Hawaii.
Population weight (planning): 0.41% · 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: 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.
Verified 2026-07-16. Source
Fiat treatment
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.
Verified 2026-07-16. Source
Virtual currency treatment
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.
Verified 2026-07-16. Source
Regulator
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.
Verified 2026-07-16. Source
NMLS / portal
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.
Verified 2026-07-16. Source
MTMA adoption
partial: S.B. 1325 / H.B. 1027 (2023); see also S.B. 973 (2022), effective July 1, 2023.
Verified 2026-07-16. Source
Launch posture
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.
Verified 2026-07-16. Source
Net worth / capital (locked)
Net worth / capital is included with access.Permissible investments (locked)
Permissible investments is included with access.Exam / audit timeline (locked)
Exam / audit timeline is included with access.Practitioner notes (locked)
Practitioner notes is included with 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.