United States
No single licence. A federal AML registration plus a state-by-state money-transmitter map, over contested securities jurisdiction.
Who regulates this
Financial Crimes Enforcement NetworkFinCEN
Money Services Business registration and Bank Secrecy Act obligations at federal level.
State banking departmentsState MTLs
Money transmitter licensing in each state where you serve customers. New York operates a separate BitLicense regime.
SEC and CFTCSEC / CFTC
Securities and derivatives jurisdiction over some assets.
Licences and permissions
FinCEN MSB registration
A federal filing, required before operating.
Cheap and fast — and on its own, nowhere near sufficient to operate.
State money transmitter licences
Each state you touch.
Realistically forty-plus licences for national coverage, each with its own bond, net-worth test and examination cycle.
NYDFS BitLicense
Virtual currency business activity involving New York or New Yorkers.
A separate, notoriously demanding application.
What it takes
Capital
Set state by state through surety bonds and minimum net worth. Aggregate bonding across a full national footprint runs into the millions.
Timeline
Two to three years for broad state coverage is normal, and the work never really stops.
Substance
A US entity, US compliance staff, and a bank willing to serve a crypto business — often the real constraint.
Where a software vendor sits
FinCEN's guidance turns on control of value. A provider of the communications or networking infrastructure supporting money transmission is treated differently from one that accepts and transmits it. Non-custodial architecture is directly relevant to that analysis, but the analysis is fact-specific and this is exactly where US counsel earns their fee.
What catches people out
The unresolved securities question sits over everything. Listing decisions carry legal risk that no amount of exchange technology addresses, and enforcement has repeatedly arrived years after the listing.
Verify this yourself
We would rather you checked. These are the primary and authoritative secondary sources behind the summary above.