The Delaware Money Transmitter License guide (Faisal Khan LLC, July 2026) covers a license issued by the Office of the State Bank Commissioner under the Sale of Checks Act, 5 Del. C. §§ 2301–2319 — a statute Delaware has never modernized.
Delaware has not adopted the Money Transmission Modernization Act. It still runs nineteen sections drafted for sellers of checks and money orders, with no permissible investments framework, no tiered net worth, and no deemed-approval clock. The guide's central warning: because Delaware's numbers look nothing like MTMA states, most published guidance quotes figures that belong elsewhere.
The most useful correction is on net worth: Delaware requires flat $100,000 net worth, GAAP-computed, with no "tangible" qualifier — nothing excluded for goodwill or intangibles. Guides claiming a tangible test have imported another state's rule. The bond is driven entirely by location count — $25,000 plus $5,000 per additional location, capped at $250,000 — with no volume escalator, so a single-location licensee moving very large volumes still posts just $25,000.
State fees are near-nominal: a $172.50 investigation fee and $230 annual renewal, set decades ago and never revised. Approval is two-step — a written conditional approval under § 2308, with the license issuing only once the bond is filed.
Chapter 23 doesn't mention virtual currency at all, and there is no Delaware crypto license. Senate Bill 18, introduced 16 April 2026 and not yet enacted, would repeal Chapter 23 entirely and replace it with tiered net worth, scaled bonds and a dedicated virtual currency framework.
What the guide covers:
- The supervisory assessment under § 127, with a $500/$1,000 floor for in-state versus out-of-state exams
- The two-year claims window the Commissioner keeps open after bond cancellation
- Why renewal, not examination, functions as Delaware's real enforcement mechanism
- The federal $2,000 SAR threshold versus the $5,000 bank threshold
- Why a Delaware license covers Delaware only, with no passporting