The Montana Money Transmitter License guide (Faisal Khan LLC, July 2026) covers the outlier case: Montana is the only US state with no money transmitter licence at all, a position the state's own Division of Banking and Financial Institutions states directly on its website.
The most useful point is the warning against misreading that gap. "Montana is not a regulatory void" — federal obligations remain unchanged and non-negotiable, and the SAR filing threshold is the federal MSB figure of $2,000, not the $5,000 bank threshold that most guides get backwards. Montana's legislature also meets only in odd-numbered years, so with no bill emerging in 2025, the next chance for a licensing statute is 2027.
What the guide covers:
- What still applies: FinCEN MSB registration (Form 107, renewed every 24 months), full BSA/AML program, CIP, CDD/EDD, and OFAC screening
- State-level exposure: Secretary of State business registration and the Montana Unfair Trade Practices and Consumer Protection Act
- Adjacent licensing traps: the Division does license consumer finance companies, escrow businesses, and mortgage originators — no MTL does not mean no licence needed
- Costs: federal compliance infrastructure runs roughly $19,500 to $175,500 one-time, and $87,000 to $365,000+ annually
- Strategic value: a staging ground to build clean transaction history before applying in California, New York or Illinois
- Digital asset legislation: SB 178, SB 426 and SB 265 cover property status, UCC treatment and CBDC bans, all separate from money transmission