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Any virtual currency business serving New York residents needs this licence wherever it is based, and we weigh it against the limited purpose trust company charter, the other route DFS offers.
Selected engagements from more than 250 licences obtained since 2013, for payment, e-money and cryptoasset firms.
Volkswagen
Payment InstitutionObtained Nexpay’s FCA Authorised Payment Institution licence.
Electronic Money InstitutionObtained Dzing Finance’s FCA Authorised Electronic Money Institution licence.
Obtained Orbital’s FCA Authorised Payment Institution licence.
Our realistic timeline from submission to decision.
Safeguarding, operating and settlement accounts opened alongside the application, so you trade on authorisation.
We assemble your team: a compliance officer, directors and senior officers.
The licence, the requirements, the cost and the timing for your business.
You will need a compliance officer, directors and senior officers, each assessed by DFS for character and fitness under its January 2024 guidance.
One programme, from scoping to launch. Speak to an expert about this licence.
Requirements, capital, timing, fees and common questions, drawn from the regulator’s own publications.
A business that receives virtual currency for transmission or transmits it, stores, holds or controls it for others, buys and sells it as a customer business, provides exchange services as a customer business, or controls, administers or issues a virtual currency, where the activity involves New York or a New York resident, needs a BitLicense. A firm located in another state or country that serves New Yorkers needs it; FinCEN registration does not substitute. Personal investment, merchants accepting virtual currency, mining alone, purely technical software development and advice alone do not require it. A BitLicense is often held together with a New York money transmitter licence.
| Route | Authority | Scope | Points |
|---|---|---|---|
| BitLicense | 23 NYCRR Part 200 | Virtual currency business activity involving New York or New York residents | US$5,000 fee; 90-day decision period; often paired with a money transmitter licence |
| Limited purpose trust company | New York Banking Law, with the superintendent’s approval | Fiduciary powers; money transmission without a separate money transmitter licence; virtual currency custody and exchange | Certificate of merit, investigation fee, capital affidavit, directors’ oaths, supervisory agreement and surety bond; at least one-third of total capital as capital stock; fidelity insurance of at least US$1,000,000 primary cover |
DFS’s list at 17 October 2026 shows 39 entities, of which 14 hold limited purpose trust charters, from Gemini in 2015 to Circle Internet Trust in July 2026.
| Requirement | Amount |
|---|---|
| Capital | The amount the superintendent deems sufficient on a risk assessment weighing asset mix and liquidity, liabilities, business volume, existing New York regulation, leverage, liquidity, customer protection through trust or bond, the entity types served and the products offered |
| Form of capital | Cash, virtual currency or high-quality, highly liquid, investment-grade assets |
| Surety bond or trust account | Generally at least US$500,000; higher by business model |
| Trust company | Capital sufficient as the superintendent determines, with at least one-third of total capital as capital stock; fidelity insurance of at least US$1,000,000 primary cover |
Part 200 sets no fixed dollar minimum for capital. The figure for a given business model is set by DFS during the application.
| Figure | Value | Source |
|---|---|---|
| Statutory decision period | 90 days, about 3 months, from the filing of a complete application, extendable for a reasonable period | 23 NYCRR 200.6(b) |
| Regulator’s published figure | Five BitLicenses issued from January 2022 to August 2023 and one in the prior 18 months; three licensees approved more than 12 months after their BSA/AML assessment and one nearly 4 years after; DFS attributes earlier backlogs to a hiring freeze and resources, with the virtual currency unit grown from 18 staff in December 2021 to over 60 in August 2023 | New York State Comptroller audit 2022-S-18, issued 2 January 2024 |
| Application preparation | 8 to 12 weeks | From instruction to submission, including banking in parallel |
| Our realistic timeline | 12 to 18 months after submission; the 90-day period runs only from a complete application after DFS’s completeness review | Our own figure, from the regulator’s published data and our applications |
Regulator figures are quoted as published and converted to months. Our realistic timeline assumes a complete, well-prepared application.
| Item | Amount | Notes |
|---|---|---|
| Application fee | US$5,000 | Non-refundable (23 NYCRR 200.5) |
| Annual assessment | Supervisory and regulatory components | Under Financial Services Law section 206 and 23 NYCRR Part 102: custody-basis and transaction-volume-basis hours by tier times the DFS hourly rate, plus a regulatory component shared equally; fiscal year 1 April to 31 March, billed quarterly |
| Surety bond or trust account | From US$500,000 | Set by business model |
| Trust company investigation fee | Per the DFS fee schedule | Part of the limited purpose trust company procedure |
| NMLS | Per NMLS | Company account and filings |
| Professional fees | Fixed | Quoted after scoping |
The BitLicense covers virtual currency business activity involving New York State or New York residents, wherever the business is located. Other states regulate under their own money transmission and virtual currency laws, and federal registration with FinCEN as a money services business applies alongside; we obtain each. A firm serving the United Kingdom holds the FCA cryptoasset authorisation and one serving the European Union a MiCA authorisation.
DFS states that most delays result from missing application elements, and that an application that is not informationally complete does not enter substantive review and may be delayed indefinitely or denied.
A virtual asset firm needs accounts for client fiat funds, separated from its own, and operating accounts in the markets it serves. Banks review the financial crime framework first: customer due diligence, transaction monitoring, travel rule arrangements and the wallet screening tools. We open the accounts alongside the application, with the financial crime framework the banks review. See banking and payment processing.
By regulation, 90 days from a complete application, extendable. The Comptroller’s audit found approvals more than twelve months after the BSA/AML assessment in several cases; we plan for twelve to eighteen months after submission.
US$5,000 on application, an annual assessment made up of supervisory and regulatory components billed quarterly, and a surety bond or trust account generally from US$500,000.
The amount the superintendent deems sufficient on a nine-factor risk assessment, held in cash, virtual currency or high-quality liquid assets. There is no fixed minimum; DFS sets the figure during the application.
A limited purpose trust company carries fiduciary powers and money transmission without a separate money transmitter licence, at the cost of a bank-style chartering process. Fourteen of the 39 listed entities hold one; we advise which route fits your model.
No. FinCEN registration as a money services business is a federal requirement that applies alongside the BitLicense; an out-of-state firm serving New Yorkers needs the licence.
A regulatory advisory firm to payment, e-money and cryptoasset companies since 2013, with more than 250 licences obtained in more than 60 countries. The firm builds licensed payment, e-money, crypto and stablecoin businesses: the licence, the team, the technology, the bank accounts and card issuing.
This guide is general information, not legal advice. Requirements and fees change, and the regulator’s own publications take precedence.
The licence, your team, banking and technology, delivered as one programme.