The Guam Money Transmitter License guide (Faisal Khan LLC, July 2026) covers what Guam actually calls a Foreign Exchange License, issued under 11 GCA chapter 109 by the Department of Revenue and Taxation's Insurance, Securities, Banking and Real Estate Branch — with no NMLS; applications are filed on paper directly with the regulator.
The guide's central correction is that Guam's security requirement does not scale at all. Operators post a fixed $50,000, either a surety bond or a cash/securities deposit with the Treasurer of Guam — alternatives, not cumulative requirements — regardless of projected volume, and the published "tier tables" showing $50,000/$75,000/$100,000 by volume band do not exist in Guam law. There is also no net worth requirement of any kind; the "$50,000 market value" language people cite is simply the valuation standard for securities posted in lieu of a bond. Fees are a flat $500 per year plus $50 per registered agent, among the lowest headline figures in any US jurisdiction, but engaging in the business without complying — or merely representing that you are authorized — is a felony under § 109122.
What the guide covers:
- The exemption list under § 109102, which covers exactly two categories: Guam-licensed banks and trust companies, and agents of an incorporated telegraph company
- The § 109111 ten-day forwarding clock and the § 109110 requirement that receipt forms be filed with the Commissioner before use
- The § 109115 statutory fee cap on cashing checks and money orders: one-half of one percent of face amount or $0.50, whichever is greater
- Why customer funds are trust funds under § 109116 until payment directions are given
- Why crypto is genuinely uncharted — no statute, no guidance, and an untested definition reaching money "or its equivalent"
- Examination costs (per-hour, per-examiner, plus travel) and the annual 1 July license term with renewal due 15 June