1. US MTL license 2024-2026 New statutory regulatory regulations and trends in 2019
2024：Multistate Joint Application Agreement
MMLA popularization，The review is divided into "Phase 1 (General Information and Background Check)" and "Phase 2 (Specific State Requirements)"。After passing the first stage，Phase 2 applications can be submitted to multiple participating states。
2025：California DFA Act Takes Effect
California’s Digital Financial Assets Act (DFA) takes effect。Entities engaged in digital financial asset-related businesses shall 2025 Beginning in 2018, you must apply for a license from the California Department of Financial Protection and Innovation (DFPI)。
2026：Connect to the FedNow system
The FedNow real-time payment and settlement system launched by the Federal Reserve will only be accessible to MTL licensees。Allow licensed institutions to directly participate in national clearing networks，Realize instant arrival of funds 7×24 hours。
2026：Stablecoins are subject to strong supervision
All stablecoin issuers operating in the United States (such as USDC、USDT) must hold an MTL license，Added "Cross-border Stablecoin Payment" license category。MMLA upgrade，Up to 5 states can be submitted for simultaneous review at one time。
2. The two-tier structure of U.S. financial regulation：Statutory differences between federal MSB and state MTL
| review elements | MSB (Federal Money Services Business License) | MTL (State Money Transfer License) |
|---|---|---|
| Licensing and Regulatory Agencies | A federal basic license issued by the U.S. Department of the Treasury’s Financial Crimes Enforcement Agency (FinCEN)。 | Issued by state financial regulators，Belongs to state-level special authorization。 |
| Licensed business scope | Allow fund transfers、currency exchange、Prepaid card issuance, etc.，But only for currency transactions，Excluding legal currency business。 | Allow transactions involving fiat currency (such as fiat currency recharge、Fiat to cryptocurrency exchange and fund transfer)。 |
| Application threshold and approval time | Registration conditions are relatively simple：No margin required，generally 1-2 Zhou was approved，Low annual review cost。Must be done after the establishment of the enterprise 180 Complete registration within days。 | Strict approval：Financial audit required、Deposit pledge、Compliance interview。Assume MSB，Single state approval required 4-12 varies from month to month。 |
3. [Capital Funds for MTL Licenses in U.S. States、Margin and regulatory differences]
new york state (New York)：The most stringent supervision。Companies involved in cryptocurrency must apply for a BitLicense or establish a limited purpose trust company。Extremely high capital requirements (approximately $5 million in trust funds)，Anti-money laundering and information security standards are extremely high。
Texas (Texas)：The most lenient policy towards cryptocurrency。Capital requirements are approximately US$2.5 million，Accept Bitcoin as margin collateral。Short approval time (about 4-6 months)。
california (California)：Tech business friendly。Capital requirements are approximately US$3 million。When business volume is heavy，The bond requirement is $500,000。
Florida (Florida)：Unauthorized transfers of virtual currencies are strictly prohibited，Enforcing compliance with extremely high anti-money laundering (AML) and customer due diligence (KYC) standards。
Other special states：Montana is the only state without a specific MTL。Wyoming only regulates “individuals、"Household Purpose" Money Transfer，Bitcoin deposit accepted。Illinois only regulates the “sale” of prepaid cards, not the “issuance” of them。
4. [Statutory conditions and core compliance requirements] for applying for a US MTL license
1. Anti-money laundering (AML) Compliance Program：A written AML compliance program must be established，Designate a dedicated compliance officer to be responsible for daily supervision，Anti-money laundering training for employees，Regular independent third-party audit testing。
2. Financial and Capital Requirements：Minimum net worth required (e.g. over US$100,000)，And pay a performance bond (Surety Bond) according to the business scale，Amounts range from US$50,000 to US$2 million (up to US$7 million)。
3. Background checks and credit checks：company owner、Executives and controllers must have no criminal records and bankruptcy information。Must accept submission of credit report、Fingerprints for FBI criminal records check。
4. Non-U.S. entity requirements：MSBs located overseas also need to register with FinCEN，A resident of the United States must be appointed as the agent for service of process，and maintain business records within the United States。
5. Compliance Officer Localization Requirements：The compliance officer must have relevant local experience in the United States (new regulations in 2026 allow compliance officers to perform their duties remotely，However, it is mandatory to have at least one U.S. citizen or green card holder holding this position)。
5. [Official application fee details] for US MTL and MSB licenses
| Charge item category | Official fees and amounts (USD) |
|---|---|
| Federal FinCEN Registration Fee | There is no flat filing fee for federal FinCEN registration itself。Renewal is required every two years before December 31st。 |
| State Application and Licensing Fees (NMLS system charges and will not refund) |
Texas $10,000；California/Pennsylvania/Ohio $5,000；minnesota $4,000；michigan $3,650；new york state $3,000；Florida $2,250；connecticut $1,975；washington state $1,100；illinois $200。 |
| Unified system and review fees | Controller Credit Report Fee：per person $15；Federal Criminal Background Check (Fingerprint) Fee：per person $36.25。 |
| Authorized agent annual processing fee (UAAR) | forward 100 Free for each site。If the number of agent outlets exceeds 100 indivual，$0.25 per active agent location per year (maximum $25,000 per year)。 |
6. Difficulties in applying and operating MTL in the United States、Compliance Costs and [Heavy Penalties Minefield]
“De-risking” and the difficulty of opening a bank account：Traditional banks generally believe that businesses involving cross-border remittances or digital assets have extremely high money laundering risks.，Will directly refuse to open an account or close existing accounts without warning。This is the biggest existential challenge currently facing MSB/MTL。
State regulation is severely fragmented：The United States does not have a unified federal money transfer license。Must apply for a separate license in each state in which you intend to do business，Leading to extremely high redundant compliance costs。
Extremely high capital and compliance costs：The total upfront licensing cost to apply for a license across the United States is approximately 18 million dollars，Annual maintenance cost is approx. 14 million dollars。The five most populous states alone require at least 120 US$10,000 performance bond。
High-pressure supervision and reporting obligations：Must submit more than 10,000 Currency Transaction Report (CTR) for USD and for 2,000 Suspicious Activity Report (SAR) for suspicious activity above USD。Failure to perform will result in license revocation，Facing the highest every time 10 $10,000 fine，Even up to 50 Motokazu Mami 10 criminal penalty of 1 year in prison。
7. [Panorama Process of Legal Review] for Obtaining US MSB and State MTL Licenses
step 1：Setting up a U.S. company and applying for an IRS tax ID
Register a local company in the United States (tax-friendly states such as Delaware are recommended)，Apply to the IRS to obtain a federal Employer Identification Number (EIN)。
step 2：Bank account opening and financial audit
Open a business bank account to deposit funds，And arrange for a professional accounting firm to conduct a financial audit，Provide necessary financial statements for MTL applications。
step 3：Apply for a Federal MSB License (1-2 week)
After the company's operations begin 180 within days，Submit a Form to FinCEN through the BSA E-Filing system 107 Register MSB，This is a prerequisite for applying for MTL。
step 4：Submit an MTL application through the NMLS system
Submit MU1 and MU2 forms to the target state。Upload audited financial statements、business plan、AML policy、Security Privacy Policy，and be fingerprinted for an FBI background check.。
step 5：Pay deposit、System interview and approval (4-18 months)
Purchase a surety bond or pay a deposit。Reply to NMLS report，Some states may require an interview with the compliance officer。Approval cycle：Texas 4-6 months，california 6-8 months，new york state 9-12 months。
8. Hong Kong Huitong's one-stop US MSB and MTL license agency service
US corporate registration and tax registration
Register your corporate entity in US states such as Delaware，Apply for an EIN Federal Tax ID Number，and provide a valid local business address that meets the requirements of each state's financial regulatory authority.。
Full set of financial legal and AML writing
An AML compliance manual prepared by professional legal personnel that complies with US FinCEN and state standards、business plan、Fund flow diagram、User Agreement and Privacy Policy。
NMLS system agency and bank account opening
Fully authorized to submit an interstate application (MMLA) in the NMLS system on your behalf。Assist you to successfully open an account at American Commercial Bank、Purchase a performance bond (Surety Bond)，and provide local compliance officer personnel matching。
9. Questions and Answers on Core Legal Affairs and Practical Practices of MSB and MTL Licenses in the United States (FAQ)
MTL licenses are issued by states，Applicable business scope includes：Pay bill service、money transport services、Electronic money transfer services、Foreign exchange trading or exchange services、Virtual currency services (select states)、Issue or sell money orders/travelers' checks，and issuing/selling prepaid access and stored value services。
MSB is a federal-level basic registration license，Issued by FinCEN，No margin required，Only fund transfers and currency transactions are allowed，Excluding legal currency business。MTL is a state-level special operating license，Must be MSB prerequisite，Allow transactions involving fiat currency (such as fiat currency recharge、Fiat and cryptocurrency exchange)，Extremely strict approval，Financial audit and high deposit required。
since 2026 Since，The Federal Reserve’s FedNow real-time clearing system will only be accessible to MTL licensees。at the same time，according to 2026 new regulations，All stablecoin issuers operating in the United States must hold an MTL license，Added new license category of "Cross-border Stablecoin Payment"。
Requirements vary greatly from state to state。Usually the minimum net worth required is 10 More than Wanmiyuan。Based on business size and location，A performance bond must be paid (Surety Bond)，Amount from 5 Thousands of dollars arrived 200 Ranging from ten thousand U.S. dollars (up to 700 million U.S. dollars)。New York State requires approx. 500 US$10,000 in trust funds；Texas Requirements 250 10,000 USD (Bitcoin collateral accepted)；California requirements 300 million dollars。
Applicants and key management personnel must have no criminal records and bankruptcy information。Owner、Executives and controllers must undergo fingerprint FBI criminal checks and credit report checks。The compliance officer must have local experience in the United States；2026New regulations require that at least one U.S. citizen or green card holder must hold this position。
Submit company MU1 and individual MU2 forms through the NMLS system。Need to upload：Financial statements audited by a professional accounting firm、business plan、Company organizational chart、Fund flow diagram、Anti-Money Laundering (AML/BSA) Compliance Policy、Security and Privacy Policy，And authorized agency contract template。
Federal MSB registration is submitted electronically，1-2 Can be completed in weeks。While MTL individual state approval requires 4 arrive 18 varies from month to month。Fastest in Texas (4-6 months)，California Intermediate (6-8 months)，New York State Extremely Strict (9-12 months)。If a company wants to do business in all states in the United States，Obtaining a full set of licenses may take up to 6 Year。
There is no fixed application fee for MSB registration。MTL state fees are high and non-refundable：Texas $10,000；California/Pennsylvania/Ohio $5,000；New York $3,000。Fingerprint fee per person $36.25，credit report $15。It is estimated，The total cost of licensing applications across the United States is approximately 18 million dollars，Annual maintenance cost is approx. 14 million dollars。
MSBs must establish a written AML plan and conduct third-party audits。Must submit a super 10,000 Currency Transaction Report (CTR) for USD，and 2,000 Suspicious Activity Report (SAR) for suspicious activity above USD。Violations will result in license revocation，Face maximum per violation 10 $10,000 civil penalty，Even up to 50 Motokazu Mami 10 criminal penalty of 1 year in prison。
Upon completion of MSB registration at the federal level，Must be present every two years 12 moon 31 A renewal was recently issued to FinCEN.。State MTL licenses require regular annual processing fees according to the regulations of the state.，If the number of active agent outlets exceeds 100 indivual，Payable annually for each outlet $0.25 Unified authorized agent filing fee。
The biggest survival challenge is the “De-risking” of traditional banks。Banks generally believe that MSB business involving cross-border remittances or high-risk areas carries extremely high money laundering risks，Therefore, many banks will directly refuse to open an account.，or close existing accounts without warning。also，Severe fragmentation of state regulation leads to extremely high redundant compliance costs。
Hong Kong Huitong provides services from setting up a US company、Apply for an IRS tax ID number，to initial services for registering an MSB license with FinCEN。Entering the MTL application stage，We assist in submitting MU1/MU2 forms in the NMLS system，Write a complete business plan and AML policy，And assist in opening commercial bank accounts and paying deposits。
