The District of Columbia money transmitter licence guide (Faisal Khan LLC, July 2026) covers the DC regime administered by the Department of Insurance, Securities & Banking under the Money Transmitters Act of 2000 — and the two features that set it apart: a real statutory decision clock and financial requirements that are capped rather than tied to volume.
Both the bond and net worth requirements are pure footprint formulas: a licensee moving $500,000 a year and one moving $500 million from the same single DC location face the identical $50,000 bond. On crypto, DISB Notice 24-BB-001 (9 August 2024) confirmed virtual currency transmission is money transmission, relying on United States v. Harmon, and removed the earlier carve-out for simple cash-for-crypto sale — retaining crypto even briefly, direct cash-to-crypto exchange, kiosks, and OTC services that may hold user funds all trigger the licence requirement.
What the guide covers:
- Regulator and statute: DISB, under DC Official Code Title 26, Chapter 10
- Fees: $500 plus $25 per DC location, capped at $2,500 — also the first-year licence fee
- Security device: $50,000 plus $10,000 per additional location or delegate, capped at $250,000
- Net worth: $100,000 GAAP plus $50,000 per location, capped at $500,000
- Decision clock (§ 26-1009(b)): 120 days from completeness, deemed approved if DISB misses it
- No agent-of-payee or payroll-processor exemption, since DC has not adopted the national Money Transmission Modernization Act
Unlicensed transmission is a felony under § 26-1023(c), up to $25,000 and five years. Year-one costs range from roughly $5,800 for a lean single-location filing to $131,000 for a complex crypto operation, excluding the $100,000 capital requirement.
