Licensing
Digital Asset Licensing
Assess federal and state licensing, registration, and compliance requirements for crypto platforms, custodians, virtual currency businesses, and related financial products.
Schedule a CallHow we work through it
- ClassifyDescribe what the business does with customer assets: exchange, custody, transfer, issuance. Token classification is coordinated with counsel.
- MapIdentify which state licenses apply, where money transmission law reaches you, and what can launch first.
- PreparationBusiness plan, financials, AML and sanctions program, custody and cybersecurity documentation, and disclosures.
- SubmissionState applications and FinCEN registration, then regulator questions until a decision.
- MaintenanceRenewals, reporting, new-product and material-change notices, and exam preparation.
Potential regulatory pathways
Exact requirements depend on your activity, your customers, and the states you serve. The state regimes below are examples, not requirements for every business.
New York BitLicense
New York's license for virtual currency business activity involving New York or its residents, subject to its exemptions.
California DFAL license
California's license for digital financial asset business activity with California residents, under the Digital Financial Assets Law and current DFPI rules.
State virtual currency licenses
A small number of states have a dedicated virtual currency regime of their own.
State money transmitter licenses
Some states apply money transmission law to exchanging or transmitting virtual currency; others exclude it. Treatment varies by state and activity.
FinCEN MSB registration
Certain virtual currency businesses, such as some exchangers and administrators, must register as MSBs. Registration is not a federal crypto license or authorization.
State trust company charter
An alternative institutional structure some custody businesses use instead of state licenses, rather than a standard license. Covered under Bank and Trust Charters.
Kiosk operator requirements
A growing number of states set registration, disclosure, or transaction-limit rules for crypto kiosks.
What the license expects of you
Regulators review the program behind a license application, and examine it afterward. We help build it through our compliance service.
- AML program built for on-chain activity
- Sanctions and wallet screening
- Travel Rule compliance
- Custody and safeguarding of customer assets
- Customer disclosures and complaint handling
- Stablecoin issuer scope analysis, coordinated with counsel
Who regulates what
Who it's for
Exchanges, brokers, custodians, wallet providers, kiosk operators, and stablecoin and tokenization businesses serving U.S. customers.
Let's discuss your regulatory needs.
Tell us about your business, product, or licensing challenge. We'll review your inquiry and discuss the appropriate next steps.
Schedule a Call