State-by-State Crypto Licensing Map: 2026 Requirements Guide

By Chanté Eliaszadeh | Updated June 2026

Navigating money transmitter licensing across the United States remains one of the most significant compliance challenges for cryptocurrency businesses. Most states require a license for crypto money transmission, but the picture is more nuanced than the common “every state but Montana” shorthand: a handful of states exempt standalone virtual currency outright, a large group reach it only on custody or a fiat-currency leg, and the rest license it---each with its own bond amounts, net-worth requirements, and application fees. The complexity can overwhelm crypto companies planning multi-state expansion.

This reference guide provides crypto businesses with a state-by-state orientation to licensing, a strategic prioritization framework, and cost-planning guidance. It also places the 2025 federal development that most often gets misread---the GENIUS Act---precisely: that statute narrows state licensing for one specific activity, payment-stablecoin issuance, and only once it becomes effective. The state-by-state map below otherwise remains intact.

The GENIUS Act: A Narrow, Not-Yet-Effective Stablecoin Carve-Out

Any 2026 state-licensing map has to account for the GENIUS Act, but it has to do so carefully, because the statute is far narrower than the headlines suggest.

The GENIUS Act (S. 1582, Pub. L. 119-27, codified at 12 U.S.C. § 5901 et seq.) was enacted July 18, 2025, but is not yet effective. It becomes operative on the earlier of January 18, 2027, or 120 days after final implementing rules are issued. As of mid-2026 those rules are still in proposed form---the OCC published its notice of proposed rulemaking in the Federal Register on or about March 2, 2026---so no part of the statute’s operative regime is in force yet.¹

What it preempts---and what it does not:

• The Act’s preemption provision, Section 5(h) (codified at 12 U.S.C. § 5904(h)), preempts state charter and license requirements only for permitted payment-stablecoin issuers.
• It does not preempt state consumer-protection law.
• Critically, it does not eliminate state money-transmitter or BitLicense requirements for non-stablecoin crypto activity. Crypto exchanges, custodians, and trading or broker services still need state money transmitter licenses.

The practical takeaway is that the GENIUS Act carves out payment-stablecoin issuance, and only once effective. For every other crypto activity---and for stablecoin issuers until the statute’s operative date arrives---the state-by-state map below remains the governing framework.

Overview: The Multi-State Licensing Landscape

As of 2026, cryptocurrency businesses that transmit, exchange, or store digital assets on behalf of customers must obtain money transmitter licenses in nearly every state where they have customers. The regulatory landscape has continued to evolve:

• 31 states had adopted all or part of the Money Transmission Modernization Act (MTMA) as of February 2026, creating some harmonization (the count moves frequently; confirm against the live CSBS tracker).²
• Pennsylvania moved from a policy statement treating virtual currency as “money” (effective Oct. 15, 2024) to statutory codification: Act 7 of 2025 (SB 202, signed June 27, 2025, effective Aug. 26, 2025) renames the governing statute the “Money Transmission and Virtual Currency Transmission Business Licensing Law.”³
• California’s Digital Financial Assets Law (DFAL) takes effect July 1, 2026; the DFPI began accepting applications via NMLS on March 9, 2026.⁴
• Illinois signed the Digital Assets and Consumer Protection Act (DACPA) and the Digital Asset Kiosk Act on Aug. 18, 2025, but DACPA licensing is deferred---covered entities must register with IDFPR by July 1, 2027.⁵
• Virginia enacted MTMA legislation in 2025 (H.B. 1942), moving it from the pending list to enacted.

Despite modernization, significant variation persists across states, requiring careful planning for multi-state operations.

Where a License Is---and Isn’t---Required: A Four-Status Framework

A common shorthand says a money-transmitter license is required “in every state but Montana.” That is not accurate, and the nuance matters: it determines where a business can operate today, where it must hold off, and where the rules are still moving. Rather than a binary “licensed / not licensed,” it is more precise to sort the fifty states and the District of Columbia into four categories.

1. Required---the state’s money-transmission regime, by statute or binding regulator guidance, reaches the business of transmitting or exchanging virtual currency on behalf of others.
2. Conditional---licensing depends on the facts: typically whether the business takes custody or control of customer assets, or whether a transaction involves a fiat-currency leg. Genuinely non-custodial, crypto-only activity often falls outside the regime.
3. Not required / exempt---virtual-currency activity standing alone is outside the money-transmitter regime, by express exemption or because no statute reaches it.
4. Unsettled---there is no clear primary-source position.

Not required for standalone crypto (seven jurisdictions): Montana (no money-transmitter statute at all), New Hampshire (express statutory exemption, RSA 399-G:3), Wyoming (express exemption, Wyo. Stat. § 40-22-104), Utah (blockchain tokens excluded, Utah Code § 7-25-102(9)(b)), Hawaii (since the state’s Digital Currency Innovation Lab closed in mid-2024---note this rests on the regulator’s interpretation, not a statutory amendment, so it is less durable than the express exemptions), Texas (non-stablecoin cryptocurrency is not “money” under Supervisory Memorandum 1037, revised January 2025), and South Carolina (standalone virtual currency is outside “monetary value”). In each, a fiat-currency leg, custody of customer assets, or a virtual-currency kiosk can change the analysis, and federal FinCEN registration still applies. The thesis is cleanest for Montana (no statute at all) and New Hampshire (a clean solely-virtual-currency statutory exemption).

Conditional (custody- or fiat-dependent): Alaska (the Division of Banking has said it lacks authority over virtual currency itself; only the fiat leg is reached), Arkansas, California, Colorado, Florida, Idaho, Illinois, Indiana, Kansas, Massachusetts (newly codified under c. 169B, effective January 1, 2026---the Division of Banks treats transactional virtual currency as monetary value), Tennessee (the Department of Financial Institutions licenses only where a sovereign-currency leg is involved), Virginia, Wisconsin, and the District of Columbia (custody and transmission are licensed; mere buying and selling of crypto for cash is not).

Unsettled: Delaware (the money-transmitter statute is silent on virtual currency, and the agency’s broad reading of undefined “money” leans toward license-required---do not read the silence as safe-to-operate-unlicensed) and Oklahoma (virtual-currency kiosks are licensed; treatment of other crypto activity is unsettled).

Required in the remaining states, several of which add a crypto-specific regime or a virtual-currency-kiosk overlay.

The table below states, for each jurisdiction, whether a money-transmitter license is required to transmit or exchange virtual currency on behalf of others, any crypto-specific regime, and the controlling authority. Status reflects activity conducted for customers; a business transacting only in its own account is analyzed differently. Statutes and regulator positions change frequently---confirm the controlling authority for any target state before relying on a single cell.

In the conditional states, the same business can be licensed or exempt depending on how it is structured. Two tests recur: a custody/control test (states such as Florida---which reaches only an intermediary that can “unilaterally execute or indefinitely prevent” a transaction---Arkansas, Idaho, California, and the District of Columbia) and a fiat-leg test (states such as Colorado, Illinois, Indiana, Kansas, Tennessee, Virginia, and Wisconsin, which generally do not license crypto-only activity but do reach transactions that exchange crypto for, or transmit, fiat currency). This is where careful entity and product design matters most.

Beyond New York, California, and Wyoming (discussed below), two states regulate virtual currency through a dedicated framework: Louisiana, whose Virtual Currency Businesses Act (La. R.S. 6:1381 et seq.) is a stand-alone licensing regime administered by the Office of Financial Institutions, and Minnesota, which added a dedicated virtual-currency module (Minn. Stat. §§ 53B.69—53B.75) within its money-transmission statute.

Strategic State Prioritization: A Tier System

Not all states are equal for crypto licensing purposes. Prioritizing by market size, regulatory environment, and customer concentration can optimize licensing timelines and costs.

Tier 1 States: Essential Markets

These states represent the largest crypto markets, strictest enforcement, or unique regulatory requirements that demand early attention:

New York---The BitLicense state, with the most stringent requirements and highest costs. Often essential for institutional credibility despite the complexity.

California---Largest state economy, with DFAL requirements taking effect July 1, 2026. Both a money transmitter license and DFAL compliance may be required.

Texas---A large economy with a comparatively crypto-receptive posture. Ordinary cryptocurrency exchange is generally not money transmission in Texas, but stablecoin and third-party-exchanger activity can require licensing depending on the facts (see the Texas discussion below).

Florida---A major crypto market. Florida eased its virtual-currency licensing treatment effective Jan. 1, 2023 (discussed below).

Illinois---A large state economy with new digital-asset legislation signed in 2025, though its comprehensive licensing regime is deferred to 2027.

Pennsylvania---A major northeastern market that now codifies virtual-currency-transmission licensing under Act 7 of 2025 (effective Aug. 26, 2025).

Washington---Significant crypto activity with specific virtual-currency-storage requirements.

Georgia---A major southeastern market with explicit virtual-currency licensing requirements.

Tier 2 States: Important Regional Markets

Mid-sized markets with established licensing frameworks and moderate costs---important for regional coverage and growth:

Ohio, Michigan, Massachusetts, New Jersey, North Carolina, Virginia, Arizona, Colorado, Maryland, Minnesota, Wisconsin, Tennessee, Indiana, Missouri.

Tier 3 States: Expansion Markets

Smaller markets typically addressed in later expansion phases:

Alabama, Alaska, Arkansas, Connecticut, Delaware, Hawaii, Idaho, Iowa, Kansas, Kentucky, Louisiana, Maine, Mississippi, Nebraska, Nevada, New Hampshire, New Mexico, North Dakota, Oklahoma, Oregon, Rhode Island, South Carolina, South Dakota, Utah, Vermont, West Virginia, Wyoming.

State Requirements: Verified Anchors and Illustrative Ranges

Specific fee, bond, and net-worth figures move frequently and scale with transaction volume. The ranges below are illustrative, intended as a starting point for budgeting, not a substitute for current data.

These are illustrative ranges; confirm current figures directly with each state regulator and through the Nationwide Multistate Licensing System (NMLS) before relying on them. Application fees typically run from roughly $250 to $10,000 per state; surety bonds commonly range from roughly $25,000 to $2,000,000 or more, scaled to transaction volume; minimum net worth commonly ranges from roughly $25,000 in the smallest states to roughly $500,000 in the largest. Processing times vary widely---often a few months in faster states and well over a year in the slowest. Figures current as of June 2026.

A handful of figures are stable or specifically confirmed enough to anchor planning:

• New York---BitLicense application fee $5,000; limited-purpose trust company charter application fee $12,500; both under the NYDFS framework (23 NYCRR Part 200).
• Florida---Application fee $375; minimum net worth $100,000; surety bond $50,000 to $2,000,000 (volume-based).
• California---The DFAL surety-bond floor is $500,000. This is distinct from the volume-based money transmitter bond (which can range higher with volume); do not conflate the two.
• The licensing-count nuance---the common “49 states require a license, Montana excepted” shorthand overstates it: roughly seven jurisdictions do not require a license for standalone virtual currency, and about a dozen more are conditional (see the four-status table above). Federal FinCEN registration can apply regardless.

The point is directional: build a current, regulator-confirmed budget for each target state rather than relying on a fixed per-state figure. The numbers move; the method does not.

Key State Treatments

New York: BitLicense Plus a Money Transmitter License

New York imposes the most demanding crypto licensing regime in the country. A firm serving New York residents generally needs both a BitLicense under 23 NYCRR Part 200 (a $5,000 application fee) and a New York money transmitter license. A limited-purpose trust company charter (a $12,500 application fee) is an alternative that provides custody and fiduciary authority.⁶

California: DFAL Plus the Existing MTL Framework

California’s DFAL (Cal. Fin. Code Division 1.25) takes effect July 1, 2026, adding a dedicated digital-asset licensing regime on top of the existing money transmitter framework. The DFPI began accepting DFAL license applications through the NMLS on March 9, 2026.⁴

The DFAL surety-bond floor is $500,000. This should not be confused with the separate, volume-based money transmitter bond. DFAL covers exchanging, transferring, or storing digital financial assets; exemptions include banks and entities with under $50,000 in annual covered activity.

Texas: Conditional Treatment Under Supervisory Memorandum 1037

Texas treats virtual currency conditionally under Supervisory Memorandum 1037, not as a blanket licensing trigger. Ordinary cryptocurrency (bitcoin, ether) is not “money” or “monetary value” under SM 1037, so its exchange is generally not money transmission in Texas. Money-transmission status for a stablecoin turns on whether the stablecoin is backed by sovereign currency with a redemption right; sovereign-backed, redeemable stablecoins can fall within money transmission, while ordinary cryptocurrency generally does not.

SM 1037 was revised and re-issued in approximately January 2025 under the Texas Money Services Modernization Act (effective Sept. 1, 2023). The earlier “Jan. 2, 2019” version is superseded. Because the current memorandum could not be independently fetched for this guide, treat this summary as corroborated by secondary practitioner analysis and confirm the operative analysis against the current SM 1037 before relying on it.⁷

Florida: Eased Virtual-Currency Treatment

Florida eased virtual-currency licensing effective Jan. 1, 2023. Certain two-party sales and certain Bitcoin-ATM operators are not money transmitters under the amended framework. Florida’s minimum net worth is $100,000, its application fee is $375, and its surety bond ranges from $50,000 to $2,000,000 (volume-based). The earlier characterization of Florida as having “explicit virtual currency coverage” with “active enforcement” overstated the posture; Florida’s 2023 amendments narrowed, rather than expanded, virtual-currency licensing.⁸

Illinois: New Laws, Deferred Licensing

Illinois signed the Digital Assets and Consumer Protection Act (DACPA) and the Digital Asset Kiosk Act on Aug. 18, 2025. DACPA is not a live comprehensive regime today: its licensing and registration obligations are deferred, with covered entities required to register with IDFPR by July 1, 2027. Only the Kiosk Act imposes immediate obligations.⁵

(Note on scale: Illinois is roughly fifth or sixth among the states by GDP---Texas and New York both exceed it---so the prior “third-largest economy” framing is corrected here.)

Pennsylvania: From Policy Statement to Statute

Pennsylvania first treated virtual currency as “money” by a Statement of Policy effective Oct. 15, 2024. That policy was then codified by Act 7 of 2025 (SB 202, signed June 27, 2025, effective Aug. 26, 2025), which renames the governing statute the “Money Transmission and Virtual Currency Transmission Business Licensing Law.” Cite Act 7 with its Aug. 26, 2025, effective date, not the earlier policy date.³

Wyoming: SPDI Charters

Wyoming exempts certain virtual-currency activity from money transmission licensing and offers an alternative banking framework through its Special Purpose Depository Institution (SPDI) charter:

• Structure: A state-chartered bank specifically for digital assets.
• Requirements: 100% reserves for customer deposits; cannot make fiat-currency loans.
• Powers: Custody, asset servicing, and fiduciary asset management, without an FDIC-insurance requirement.
• Charters issued (four to date): Kraken (Sept. 2020), Avanti, Wyoming Deposit & Transfer, and Commercium Financial (charter granted August 2021).⁹

Separately, Wyoming’s Decentralized Unincorporated Nonprofit Association (DUNA) Act took effect July 1, 2024. It is a DAO legal-entity statute, not a money-transmitter licensing regime, and is noted here only as a notable development.

Montana: No Money-Transmitter Statute

Montana is the cleanest “no license” state: it has no money-transmitter licensing statute at all, so there is no license to obtain (the “Montana crypto exemption” sometimes cited online is really just the absence of a regime). It is not the only state where standalone crypto falls outside licensing---see the four-status framework above---but it is the most absolute. Federal FinCEN registration still applies.

State Licensing Exemptions and Special Provisions

Understanding which states offer exemptions for specific cryptocurrency activities can materially affect licensing strategy and cost.

Alaska---The Division of Banking has stated it is not authorized under state law to regulate virtual currencies; only fiat-currency transactions are subject to money transmitter laws.

New Hampshire---Businesses dealing solely in “convertible virtual currency” are exempt from money transmitter licensing, though still subject to the state’s unfair-trade-practices law.

Texas---As discussed above, ordinary cryptocurrency exchange is generally not money transmission under SM 1037; sovereign-backed redeemable stablecoins and third-party exchangers can require licensing depending on the facts. Confirm against the current memorandum.

Utah---The Blockchain Technology Act (2019) exempts persons who facilitate the creation, exchange, or sale of blockchain tokens from the Utah Money Transmitter Act.

Wyoming---Buying, selling, issuing, or taking custody of payment instruments in virtual currency is exempt from money transmission licensing; the SPDI charter offers an alternative banking framework.

Montana---Complete exemption: no money transmitter licensing requirement exists.

The MTMA: The Standardization Trend

The single most important structural development in multi-state money transmission is the Money Transmission Modernization Act (MTMA)---a model law developed through the Conference of State Bank Supervisors (CSBS) to harmonize money transmitter requirements across states. As of February 2026, 31 states had adopted the MTMA in whole or in part, with more considering adoption. The count moves frequently, so confirm the current status against the live CSBS tracker.²

For a crypto business pursuing a national footprint, the MTMA standardizes things that used to differ state by state:

• Common definitions of money transmission, including the treatment of virtual currency.
• Uniform net-worth requirements scaled to transaction volume rather than set ad hoc per state.
• Harmonized permissible-investment rules governing how customer funds may be held.
• Streamlined multistate coordination through NMLS and shared examination standards.

The practical effect is that the patchwork is slowly becoming a grid: a single, well-built application package travels further, and the cost of each marginal state falls. States with MTMA-related activity still in progress include Alaska and Idaho; Virginia has now enacted MTMA legislation (H.B. 1942, 2025).

Cost Planning: An Honest Framing

There is no honest single number for multi-state licensing, because the real figure depends on how many states you enter, your transaction volume, your credit profile (which drives surety-bond premiums), and how much compliance work you build in-house versus outsource.

The illustrative cost ranges and aggregate totals that often circulate in licensing guides are practitioner estimates, not quotes; actual costs and timelines vary. Treat any all-state total or processing-time figure as directional modeling, not an authoritative quote.

The useful framing is directional: licensing a meaningful footprint is a six- to seven-figure undertaking, and full coverage across all 49 states runs well into seven figures in year one once application fees, surety bonds, net-worth funding, legal and consulting work, and compliance build-out are all counted. Ongoing compliance is a substantial annual cost on top of that.

Rather than anchoring on a fixed estimate, build a current, regulator-confirmed budget: pull the present fee and bond schedule for each target state from its regulator and NMLS, obtain a surety-bond quote against your actual credit and projected volume, and price the legal and compliance work for your specific business model.

Strategic Sequencing

Strategic sequencing of applications can optimize time-to-market while maintaining compliance.

Phase 1: Foundation. Complete federal FinCEN MSB registration, establish core compliance infrastructure, and apply to the faster, crypto-receptive Tier 1 states (for example, Texas, Georgia, Florida) while initiating the New York application given its long timeline.

Phase 2: Major Markets. Complete California and Illinois applications and begin Pennsylvania and Washington.

Phase 3: Regional Expansion. Submit applications to remaining Tier 2 states and high-priority Tier 3 states; respond promptly to deficiency notices.

Phase 4: Comprehensive Coverage. Complete remaining Tier 3 states, finalize New York if applicable, and implement state-specific compliance variations.

Timeline reality check. Even with aggressive sequencing and adequate resources, achieving broad multi-state licensing typically takes well over a year because applications are filed and reviewed state by state. Plan launches accordingly, and consider partner-bank models or limited geographic rollouts during the licensing process.

Federal Enforcement Backdrop

Operating without required licenses carries real exposure.

The OKX resolution (February 2025). On Feb. 24, 2025, OKX (through the entity Aux Cayes FinTech) pleaded guilty to operating an unlicensed money transmitting business under 18 U.S.C. § 1960---a federal offense---and resolved the matter for approximately $504 million in total. Section 1960 reaches the absence of a required state license as one of its statutory predicates (§ 1960(b)(1)(A)), so this was a federal § 1960 conviction, not a guilty plea “under state law.” The case is a reminder that unlicensed activity can be charged federally when a state license was required and absent.¹⁰

Multi-state coordination. State regulators have increasingly coordinated enforcement, including multi-state actions in the digital-asset space, demonstrating growing sophistication in state-level supervision.

Practical Strategic Guidance

Direct Licensing vs. Partner-Bank Models

Direct licensing offers operational control, direct customer relationships, and long-run cost efficiency at scale, but carries high upfront capital requirements, a long implementation timeline, and an ongoing compliance burden across many states.

Partner-bank models offer faster time to market, lower upfront capital, and a simplified regulatory burden (the bank handles state licensing), but reduce margins through revenue sharing and reduce operational flexibility.

A common pattern is to use a partner bank for speed to market while pursuing parallel direct-licensing applications, then transition to direct licensing once transaction volume justifies the investment.

Common Licensing Pitfalls

• Underestimating timelines. Comprehensive coverage typically takes well over a year; New York can take longer still. Begin the process well before a planned multi-state launch.
• Inadequate capitalization. Budget for legal, consulting, compliance technology, and ongoing operational costs---not just application fees and bonds.
• Treating licensing as a purely legal exercise. It requires coordinated effort across legal, compliance, finance, technology, and operations.
• Launching before licensing is complete. Operating without a required license carries federal exposure under 18 U.S.C. § 1960, and failure to register a money transmitting business carries a civil penalty under 31 U.S.C. § 5330, as the OKX resolution illustrates.¹¹ Use robust geofencing and customer verification.
• Ignoring state-specific requirements. Each state has its own examination expectations and reporting requirements beyond the initial application.
• Weak AML/BSA programs. Build robust AML/KYC programs---policies, training, transaction monitoring, and SAR procedures---before applying.

When to Seek Legal Counsel

Consult experienced money transmitter and cryptocurrency regulatory counsel when:

• Determining whether your business model requires money transmitter licensing.
• Developing a multi-state licensing strategy and prioritization.
• Preparing initial applications and supporting documentation.
• Evaluating exemptions and alternative frameworks (SPDI, partner-bank models).
• Responding to state examination findings or enforcement actions.
• Assessing how the GENIUS Act will affect a payment-stablecoin issuance business once it becomes effective.

The combination of multi-state money transmitter licensing and rapidly evolving crypto-specific requirements makes specialized legal guidance essential for most crypto businesses navigating this landscape.

---

Need Multi-State Licensing Guidance?

Astraea Counsel advises crypto and fintech companies on money transmitter licensing strategy, multi-state compliance, and regulatory matters. We develop licensing roadmaps, prepare applications, and build sustainable compliance programs. Explore our Fintech & Payments services.

Related Resources

• Crypto Enforcement Tracker (2024-2026)---Federal SEC and CFTC enforcement actions, penalties, and the Atkins reversal that complement the state-licensing picture.
• How to Get a Crypto Exchange License: State-by-State Requirements---The exchange-specific licensing path, including the NY BitLicense and CA DFAL detail for trading platforms.
• Money Transmitter Licensing: A State-by-State Strategy for Crypto Startups---The startup decision process: strategic state selection, the partner-bank alternative, the NMLS application process, and a license-vs-partner-vs-exclude framework.
• Do Crypto Companies Need a Money Transmitter License?---The threshold question, answered by business model (custodial exchange, wallet, DEX, miner, payment processor).
• What Multi-State Crypto Money Transmitter Licensing Actually Costs---The dedicated cost deep-dive: application fees, surety bonds, net-worth thresholds, and the hidden line items.
• Federal vs. State Stablecoin Regulation: Choosing Your Registration Path---For payment-stablecoin issuers: the GENIUS Act dual-track framework and the federal-vs-state registration decision.
• FinCEN’s CVC Kiosk Crackdown: What Crypto ATM Operators Need to Know---Federal MSB compliance.
• Regulatory Compliance Practice---Navigate state and federal requirements.
• Contact Us---Discuss your licensing strategy.

---

Disclaimer: This article provides general information only and does not constitute legal advice. Money transmitter licensing requirements change frequently, and state-specific figures and rules should be verified with state regulators, the NMLS, and qualified legal counsel before being relied upon.

---

Sources and Citations

Footnotes

1. GENIUS Act, S. 1582, Pub. L. No. 119-27, 139 Stat. 419 (2025) (codified at 12 U.S.C. § 5901 et seq.), enacted July 18, 2025; preemption provision at Section 5(h), 12 U.S.C. § 5904(h). The Act is not yet effective (operative the earlier of January 18, 2027, or 120 days after final implementing rules). Implementing rules remained in proposed form as of mid-2026; the OCC notice of proposed rulemaking was published in the Federal Register on or about March 2, 2026. Confirm current rulemaking status with the OCC and FinCEN. ↩

2. Conference of State Bank Supervisors, “Money Transmission Modernization Act (MTMA),” https://www.csbs.org/csbs-money-transmission-modernization-act-mtma. Thirty-one states had adopted the MTMA in whole or in part as of February 26, 2026 (per the CSBS MTMA page); the count moves frequently. Confirm against the live CSBS tracker. ↩ ↩²

3. Pennsylvania Act 7 of 2025 (SB 202), signed June 27, 2025, effective Aug. 26, 2025, renaming the governing statute the “Money Transmission and Virtual Currency Transmission Business Licensing Law”; succeeds the Department of Banking and Securities Statement of Policy effective Oct. 15, 2024. Pennsylvania Department of Banking and Securities, https://www.pa.gov/agencies/dobs/. ↩ ↩²

4. California Digital Financial Assets Law (DFAL), Cal. Fin. Code Division 1.25, effective July 1, 2026; DFAL surety-bond floor of $500,000. The DFPI began accepting DFAL license applications via NMLS on March 9, 2026. California Department of Financial Protection and Innovation, https://dfpi.ca.gov/regulated-industries/digital-financial-assets/. ↩ ↩²

5. Illinois Digital Assets and Consumer Protection Act (DACPA) and Digital Asset Kiosk Act, signed Aug. 18, 2025. DACPA licensing/registration is deferred---covered entities must register with IDFPR by July 1, 2027; the Kiosk Act imposes immediate obligations. Illinois Department of Financial and Professional Regulation, https://idfpr.illinois.gov/. ↩ ↩²

6. New York Department of Financial Services, virtual-currency business licensing under 23 NYCRR Part 200; BitLicense application fee $5,000; limited-purpose trust company charter application fee $12,500; separate New York money transmitter license generally required. https://www.dfs.ny.gov/virtual_currency_businesses. ↩

7. Texas Department of Banking, Supervisory Memorandum 1037, revised and re-issued approximately January 2025 under the Texas Money Services Modernization Act (effective Sept. 1, 2023). Under SM 1037, ordinary cryptocurrency (bitcoin, ether) is not money or monetary value; money-transmission treatment of a stablecoin turns on sovereign-currency backing and a redemption right. The current memorandum could not be independently fetched for this guide; this summary is corroborated by secondary practitioner analysis (e.g., Hunton, Lowenstein, National Law Review). Confirm against the current SM 1037 at https://www.dob.texas.gov/. ↩

8. Florida Office of Financial Regulation. Florida eased virtual-currency licensing effective Jan. 1, 2023 (certain two-party sales and certain Bitcoin-ATM operators are not money transmitters); minimum net worth $100,000; application fee $375; surety bond $50,000 to $2,000,000 (volume-based). https://flofr.gov/. ↩

9. Wyoming Division of Banking, Special Purpose Depository Institutions; four SPDI charters issued to date: Kraken (Sept. 2020), Avanti, Wyoming Deposit & Transfer, and Commercium Financial (charter granted August 2021). Wyoming’s DUNA Act (effective July 1, 2024) is a DAO legal-entity statute, not a money-transmitter regime. https://wyomingbankingdivision.wyo.gov/banks-and-trust-companies/special-purpose-depository-institutions. ↩

10. U.S. Department of Justice, United States v. Aux Cayes FinTech Co. Ltd. (OKX), guilty plea Feb. 24, 2025, to operating an unlicensed money transmitting business under 18 U.S.C. § 1960 (a federal offense; § 1960(b)(1)(A) incorporates the absence of a required state license as a statutory predicate); approximately $504 million total resolution. ↩

11. Federal money-transmission framework: 18 U.S.C. § 1960 (operating an unlicensed money transmitting business) and 31 U.S.C. § 5330 (registration of money transmitting businesses; civil penalty of $5,000 per day for failure to register). ↩