New York (NY)
Money transmission and virtual currency licensing planning data for New York.
Population weight (planning): 5.79% · 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
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.
Verified 2026-07-16. Source
Fiat treatment
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.
Verified 2026-07-16. Source
Virtual currency treatment
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.
Verified 2026-07-16. Source
Regulator
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.
Verified 2026-07-16. Source
NMLS / portal
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.
Verified 2026-07-16. Source
Launch posture
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.
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.