The Vermont Money Transmitter License guide (Faisal Khan LLC, July 2026) covers Vermont's 2024 statutory rewrite — Act 110 (H.659), amended again by Act 23 of 2025 and Act 142 of 2026 — which replaced the old money transmission chapter with an MTMA-based statute and bolted on a virtual currency subchapter Vermont wrote its own way.
The most useful correction in the guide: Vermont's Department of Financial Regulation still shows the repealed per-location bond ladder on its own website, but the statute now sets a single bond of the greater of $100,000 or 100% of average daily Vermont liability, capped at $2,000,000. Get that wrong and the bond calculation is wrong before the application is even filed. There's also an annual expiration trap: renewal is due with $1,000 by 1 December, and the license automatically expires 31 December with no published grace period.
On crypto, Vermont treats virtual currency business activity as money transmission under the same license, not a separate one. Custody rules at §2575 were written directly in response to FTX, Celsius, Voyager, BlockFi and Genesis, barring pledging, hypothecation or lending of customer coin. A kiosk moratorium runs until 1 July 2027 for anyone not already licensed and operating by 30 June 2024.
What the guide covers:
- Total fees of $2,100 (license, investigation and NMLS) — not the $500 figure often quoted, which is the check-casher fee
- Tangible net worth under §2540, with the Commissioner able to exempt for good cause
- The 60-day statutory decision clock under §2103(c)(1) and the 120-day abandonment rule
- Kiosk daily limits, fee caps and mandatory phone screening for high-risk customers
- Criminal penalties up to $100,000 and three years for unlicensed activity
- Delegate sheltering under the licensee's own license and bond, not an exemption
Montana remains the only state with no money transmitter license requirement at all.