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MTL State Guides

New York BitLicense

Money Transmitter License Guide

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The New York BitLicense guide (Faisal Khan LLC, July 2026) covers what it calls the most rigorous crypto licence in America — created by Superintendent Benjamin Lawsky after the Mt. Gox collapse (roughly $500M in customer losses) and effective 24 June 2015 under 23 NYCRR Part 200.

The single most common mistake applicants make: a BitLicense does not replace any other New York licence. The moment a firm transmits fiat — which nearly every exchange, on-ramp and payment processor does — it needs a separate money transmitter licence under Banking Law Article 13-B, meaning many firms end up holding both and budgeting for two applications. Capital is set case-by-case by the Superintendent with no published figure or sliding scale, and the application fee is $5,000, non-refundable even on denial. NYDFS publishes no service standard; the realistic timeline runs 12–30+ months, averaging 18–24.

What the guide covers:

  • Bond or trust account acceptable to the Superintendent, with a stated general minimum of $500,000, rising with the business model
  • The five licensable activities under § 200.2(q) — receiving, transmitting, custody, buying/selling and exchange services — with only two narrow exemptions
  • Cybersecurity duties under 23 NYCRR Part 500: a designated CISO, an April 15 dual-signed certification, MFA since November 2025, and 72-hour incident notification
  • The June 2022 stablecoin guidance requiring 100% reserves, monthly CPA attestations and T+2 redemption
  • Coin listing paths — DFS approval, self-certification, or the short Greenlist (BTC, ETH, GUSD, GYEN, ZUSD, RLUSD, USDW, GOLD)
  • Corrections to the market's roster: Kraken has no BitLicense, Paxos converted to an OCC trust charter in December 2025

Year-one costs range from roughly $790,000 to $4,930,000+, with an annual assessment that carries no published dollar figure.

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Page Last Updated: 22/SEPT/2026 (1300072)