Illinois (IL)
Money transmission and virtual currency licensing planning data for Illinois.
Population weight (planning): 3.68% · 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: 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.
Verified 2026-07-16. Source
Fiat treatment
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.
Verified 2026-07-16. Source
Virtual currency treatment
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.
Verified 2026-07-16. Source · under review
Regulator
Illinois Department of Financial and Professional Regulation (IDFPR), Division of Financial Institutions, Currency Exchange and Money Transmitter Section.
Verified 2026-07-16. Source
NMLS / portal
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.
Verified 2026-07-16. Source
MTMA adoption
full: S.B. 3412 (Public Act 103-0991), effective January 1, 2026.
Verified 2026-07-16. Source
Launch posture
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.
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.