The Illinois Money Transmitter License guide (Faisal Khan LLC, July 2026) covers a state that replaced its money transmission law and, separately, built one of the most structured digital asset regimes in the country in under a year.
The sharpest point in the guide is that a money transmitter licence and Illinois's new crypto law do not substitute for each other: "An MTL does not cover you for DACPA, and DACPA does not cover you for the MTL." The Digital Assets and Consumer Protection Act (205 ILCS 731) requires separate registration for digital asset business activity, with civil penalties running to $100,000 per day for operating unregistered — and an unregistered person cannot even sue to collect compensation earned while unregistered.
What the guide covers:
- The statutory reset — 205 ILCS 658, the Uniform Money Transmission Modernization Act (P.A. 103-991), replaced the old Transmitters of Money Act, repealed 1 January 2026
- Fees — a $2,500 application fee, a $0 licence fee, and examination costs billed at $400 per examiner day
- Bond — the greater of $100,000 or 100% of average daily Illinois liability, capped at $2,000,000, with electronic surety bonds now mandatory
- A genuine 120-day deemed-approval clock on new applications, plus 60 days on change-of-control
- Two additional 2025 crypto statutes — DACPA's registration and custody rules, and the Digital Assets Kiosk Act's daily transaction caps and mandatory scam-victim refunds
- Authorized delegate rules — subdelegation is prohibited outright, and a delegate who fails to remit more than $1,000 held in trust commits a felony
Insurance companies are not exempt, and the burden of proving any exemption falls on the claimant. Unlicensed money transmission is a Class 3 felony carrying 2–5 years and up to $25,000 in fines.