MSB, FinTech and CryptocurrencyMoney Transmitter Licensing

Multinational financial institution seeks to enter the US

The Challenge:

A leading multi-asset trading organization focusing on payment capabilities in the US. The catch: this multinational organization had little experience in the US, and needed guidance on how to operate with the US regulatory landscape with fiat and cryptocurrency services.

The Solution:

Bates Group was chosen to navigate the complex process of acquiring and maintaining state money transmitter licenses based on our wealth of experience in the space. Bates formulated a phased approach for licensing and bank account onboarding to layer into the US market in line with the client's business plan. The licensing team utilized its knowledge of the regulatory landscape to build up the program from FinCEN registration to policy and procedure development.

• Reviewing all state applications for license requirements
• Providing a detailed overview and explanation of each state’s requirements with appropriate Client personnel
• Coordinating with appropriate Client personnel on any information that is needed from Client to complete the applications
• Providing best practice recommendations related to the acquisition of licenses
• Coordinating with Client’s Registered Agent to obtain all necessary state Business Registrations (and any other items/information needed from them)
• Coordinating with Client’s Surety Bond provider to obtain all necessary bonds
• Obtaining and filling out all application forms (Client and officer forms)
• Coordinating with Client officers and setting up any required fingerprint appointments
• Submitting all required documents in the National Multi-State Licensing System (NMLS)
• Submitting state applications in NMLS
• Completing all paper applications & mailing to the state regulator(s)
• Creating accounts for any state(s) that have licensing systems outside of NMLS
• Coordinating directly with all state regulators on any follow up questions or documentation needed once the initial applications are submitted

The Result:

Bates built the US regulatory program from the ground up, acquiring over 40 state money transmitter licenses and bringing the client into compliance with all federal and state laws. At Bates, we strive to help strengthen our client’s compliance program by providing value with our insight from industry experts.