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MTL State Guides

South Dakota Money Transmitter License

Money Transmitter License Guide

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The South Dakota Money Transmitter License guide (Faisal Khan LLC, July 2026) corrects several errors the guide calls "everywhere" in published material, plus a crypto rule most guides omit entirely.

South Dakota rebuilt Chapter 51A-17 across three sessions, culminating in S.B. 58 (2024, effective 1 July 2024), which repealed §§ 51A-17-1 to 51A-17-51 and replaced them with §§ 51A-17-52 to 51A-17-122. Any citation below section 52 — including the NMLS state checklist, still dated March 2020 — is repealed law.

The most useful correction: the true cost at the counter is $1,500 (a $500 application fee plus $1,000 license fee), not the $500 many sources quote, and the bond floor is $100,000, not $50,000. South Dakota does not require credit reports, a genuine saving other states don't offer.

On crypto, South Dakota adopted the MTMA without its optional virtual currency article, and its narrow "money" definition makes crypto look excluded — it isn't. A three-link statutory chain, confirmed by a 2019 Division memorandum and 2026 enacted text, brings virtual currency transmission inside the license. The guide flags a like-kind holding rule (§ 51A-17-109) as commercially decisive and missing from most competitors' guides: a licensee must hold like-kind virtual currency equal to what it owes consumers, foreclosing rehypothecation and yield on customer coin.

What the guide covers:

  • The bond formula, capped at $500,000, with a $100,000 flat alternative for well-capitalized applicants
  • The 120-day deemed-approval timeline under § 51A-17-64
  • New kiosk rules under Chapter 51A-18, capping charges at 25% of value (not the 3% still widely circulated)
  • Why a South Dakota trust charter is an alternative to the MTL, not a stack with it — and why South Dakota has no SPDI charter of its own
  • The Class 6 felony penalty for unlicensed transmission earning over $500 in 30 days

A corrective read before relying on older South Dakota guidance.

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Page Last Updated: 22/SEPT/2026 (1300061)