FAQ: Licensing & Regulations

• Are there any restrictions on MSB licenses that we should know about?
• Are they (the principal license holder) going to hold some money? For example, if they got 100% from the customer, do they hold to the funds or will they release it all?
• Are you the owner of the license to be rented?
• Can I pick and choose a few US states for which we require money transmitter license coverage? If so, how does the pricing work?
• Can a marketplace rely on the Agent-of-the-Payee exemption instead of obtaining money transmitter licenses?
• Can we also market in the African corridors we are licensed in and send/receive payments between the African corridors?
• Can we apply for a Lithuanian license if we are already incorporated in Ireland? That would be our preferred option given that we’ll need to staff operations in whatever country we do get our license.
• Can we get the US multi-currency accounts without being licensed in the US yet?
• Can we selectively get license coverage for some states in The United States?
• Can we work under a Trust’s Money Transmitter License?
• Can we, in due time, transfer to another license in the future (if one day we decide to obtain our own license in the USA)?
• Can you give some examples of additional services not offered by the Principal License Holder?
• Common Misconceptions regarding MTL
• Do I need a license for a private USDT transaction in Florida?
• Do OTC services require a license?
• Do Trust Companies provide money transmitter license coverage?
• Do we have to hire an accounting firm in the license holder’s country?
• Do we need to be licensed in any capacity, such as a money transmitter?
• Do you have any list price for regulatory coverage for each US state to help us pick our “Must-have States”?
• Do you have any typical sponsorship agreements drafts that you could share so I can get a better understanding of the potential terms we can expect?
• Does MSB in Montana has the same value as MSB in Canada?
• Does the solution provider only allow us to conduct business in the US (as we only seek to conduct business in the US based on domestic clients and domestic transfers)?
• Does using Stripe Connect mean my marketplace does not need money transmitter licenses?
• For the Bitcoin ATM business, are the financial institutions prescreened and verified?
• How can I gain access to regulatory coverage for Canada?
• How do BIN Partnerships differ from what MSB will provide us?
• How do fines or penalties typically work?
• How do you get a Forex trading license in the UK, and what does it involve?
• How long does it take to sign the contract with the Principal License Holder providing us with regulatory coverage?
• How long does the leasing period last?
• How long will the money transmitter license coverage be provided for?
• How many days will the owner of the license take to make a deposit (liquidation of the money) in my clients bank account?
• How much does a US Money Transmitter License Cost?
• How to Buy or Sell a Licensed Payments Company
• How to Verify a Payments License or Regulated Company
• If my marketplace receives customer funds and then pays the seller through Payoneer or Hyperwallet, does that make my marketplace a money transmitter?
• If you're a billing aggregator and you're simply providing billing information but not handling the payments, are you considered a money services business?
• Is Faisal Khan the principal license holder or a sublicensee and solution provider (in the case of US as well as the UK/EU rollout)?
• Is a money transmitter license required for the operation of closed-loop cards in the United States?
• Is a payout partner provided only in the case of a white-labeled offering?
• Is nationwide coverage guaranteed?
• Is there a monthly fee charged by the Principal License Holder?
• Is there a non-compete clause for the customers that we bring in?
• Is there an advantage of getting the EMI license in Lithuania vs Ireland?
• Isn’t the idea of ‘renting’ a license considered wrong? Could it have legal ramifications if we rented a license?
• Montana does not require a money transmitter license, so if I register a company there am I exempt from money transmitter licenses?
• Our understanding was that the UK/EU integrations could be possible in Q4 2021, kindly confirm if this understanding is correct.
• Regarding the US: which states are included? Are TX, CA and NY included as part of the initial package?
• Since our company is about to obtain a Labuan Money Brokering license, may I know whether it is sufficient to use this license to apply to be a Registered Agent (RA) under an EMI holder?
• There is no crypto-license sponsorship option in the EU, am I right?
• What License Does Our Payments Business Actually Need?
• What are MTL Bonding and Financial Requirements?
• What are the restrictions on the MSB License that my company will acquire?
• What are the state requirements for authorized delegates in terms of managing funds?
• What does it mean to acquire a Money Transmitter License (sponsorship)?
• What does it mean to list the MUST HAVE STATES?
• What does it mean to sponsor under their license?
• What does it mean to “lease” a license and what services does your company (Faisal Khan & Co) provide for the fee you charge?
• What if the license holder has some problem with the government? Will our funds be frozen?
• What is Europe's Electronic Money Directive or EMD?
• What is FATF?
• What is Money Transmitter Licensing (MTL)?
• What is Regulatory Arbitrage?
• What is the Best Route to Market for a Regulated Payments Business
• What is the Model Money Transmitter Law?
• What is the difference between an agent and non-agent of an EMI in Europe/UK?
• Why are payroll processors suddenly concerned about MTL?
• Would the financials be in line with the expectations we have set in the term sheet?
• Would we be sub-licensed under the Principle License Holder (PLH)?