Money transmitters in New York

Who needs this in New York

A business that transmits money for New York customers generally needs a DFS money-transmitter license. Firms that engage in virtual-currency business activity defined in 23 NYCRR 200 generally also need a BitLicense (or a limited-purpose trust charter). Those are different authorities.

Where to file

Request the New York money-transmitter license on NMLS. If the model includes virtual-currency business activity, plan the BitLicense or charter path with DFS as a separate workstream. FinCEN MSB registration is still required.

Federal overlay

FinCEN MSB registration and the Bank Secrecy Act are federal duties. They never substitute for a required state money-transmitter license. Unlicensed money transmission can also be a federal crime under 18 U.S.C. § 1960.

Sources

• NMLS / CSBS state agency contacts
• FinCEN MSB registration
• NYDFS virtual currency