The Puerto Rico money transmitter licence guide (Faisal Khan LLC, July 2026) covers the regime issued by the Office of the Commissioner of Financial Institutions under Act No. 136 of 2010 and Regulation 9393 of 2022 — one of very few US jurisdictions whose licensing materials name cryptocurrency directly.
The guide's central correction is that Puerto Rico carries two separate $500,000 requirements routinely conflated: a $500,000 GAAP net worth test (capital that must exist on the balance sheet) and a separate $500,000 surety bond (a security instrument satisfied by an annual premium, typically 1–3%). The bond scales by $10,000 per additional office or agent, not by transaction volume — "if you see [a volume-tier table], it is invented." OCIF lists exchanging, managing or maintaining convertible virtual currency, and operating Bitcoin Teller Machines, among the licensed activities, and full federal BSA obligations apply since Puerto Rico is within the US for that purpose.
What the guide covers:
- Regulator and statute: OCIF, under Act 136 of 21 September 2010 and Regulation 9393 of 8 July 2022
- Fees: $2,500 application plus $1,250 registration plus $120 NMLS; renewal $2,500 plus $100 per agent
- Liquid assets requirement: at least $100,000 in cash, bank deposits, or securities maturing under three months
- Renewal deadline: due on or before 1 December regardless of when the licence issued, with missed deadlines treated as renunciation
- No published processing timeline and no deemed-approval provision
- The IFE regime under Act 273-2012 is a separate licence entirely and must not be conflated with the Act 136 money transmitter licence
Customer funds belong to the customer until delivered and must never appear as working capital — and a Puerto Rico licence authorises Puerto Rico business only.