The Connecticut money transmitter license guide (Faisal Khan LLC, July 2026) covers a state whose capital rule most other guides get wrong: Connecticut sets no flat minimum net worth. Instead, § 36a-603 imposes a dynamic test — permissible investments, valued at GAAP, must at all times equal the aggregate outstanding Connecticut money transmissions, drawn from a narrow class of assets that expanded after Public Act 24-146 to include international wires in transit and card-funded receivables.
The bond has no small-operator tier: it is set off average weekly Connecticut transmissions for the twelve months ending 30 June, and even a brand-new applicant with zero volume posts $300,000. Virtual currency is ring-fenced separately — a licensee must hold virtual currency of the same type and amount owed, with fractional reserving unavailable, and both permissible investments and held crypto are deemed held in trust by operation of law.
What the guide covers:
- License fee $1,875 ($1,250 license + $625 investigation), non-refundable; renewal $1,125
- Only three exemptions under § 36a-609 — federally insured banks/credit unions, USPS and its contractors, and government-benefit transfer agents — with no broker-dealer, insurer or trust-company exemption
- The new kiosk rule effective 1 October 2024: anyone who owns, operates, solicits, markets or facilitates a virtual currency kiosk needs a license, even without owning the hardware
- Two clocks that matter: a 60-day deemed-abandonment rule for unanswered information requests, and a 15-day window to report application changes
- A documented wind-down plan, a Public Act 24-146 obligation absent from most other states' guidance
- Beneficial owner disclosure triggered at 10%, not the more common 20%
Connecticut is only a partial MTMA adopter, so full-harmonization arguments across states will not necessarily hold up here.