Money transmitter license
Money transmitter license means a state-issued license a US non-bank needs before transmitting money for people in that state. It also covers selling payment instruments and issuing stored value.
This page explains the rules in general terms and is not legal or regulatory advice. Check the primary source and take advice on how the rules apply to your firm.
United States: licenses are issued by individual states, with licensing data from NMLS as of 31 December 2024. Federal registration with FinCEN is a separate requirement.
How it works
Licensing happens state by state. At the end of 2024, 49 states, the District of Columbia and Puerto Rico managed money services licenses on NMLS. That year, 599 companies held 8,858 money transmitter licenses between them. Remitly, for example, reports licenses in the 49 states that require one, plus the District of Columbia and various US territories (Form 10-K for fiscal year 2025).
State licensing is separate from federal registration. FinCEN requires money services businesses to register with it. FinCEN has also said it cannot decide whether a state license is needed. Firms must take that question to each state regulator.
Licenses carry ongoing duties. These typically include minimum net worth, surety bonds, reporting and limits on how customer funds are invested. Intermex lists reserves to cover outstanding payment obligations among them. The CSBS model law aims to align these rules across states.
Example
Illustrative example: Under the CSBS model law, a licensee with $250,000,000 of total assets needs tangible net worth of at least $6,000,000. That is 3% of the first $100,000,000 ($3,000,000) plus 2% of the next $150,000,000 ($3,000,000). Each state's enacted version may differ.
Frequently asked questions
Do we need a license in every state?
You need one in each state where your activity is licensable and no exemption applies. Requirements differ by state, even among states that adopted the model law. FinCEN registration does not settle the state question.
What does a license require day to day?
Expect net worth minimums, a surety bond, periodic reports and permissible investments covering outstanding obligations. Treasury must be able to show that coverage at all times, not just at period end.
Related terms
Sources
- 2024 NMLS Money Services Businesses Report · Nationwide Multistate Licensing System (NMLS)
- Definition of Money Services Business (Money Transmitter/Currency Dealer or Exchanger), FinCEN Ruling 2003-9 · Financial Crimes Enforcement Network (FinCEN)
- Remitly Global, Inc. Form 10-K for fiscal year 2025 · U.S. Securities and Exchange Commission (EDGAR)
- CSBS Money Transmission Modernization Act (model law text) · Conference of State Bank Supervisors (hosted by NMLS)
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