General information only. CryptoRegHub provides summaries for informational purposes and does not constitute legal or compliance advice. Always verify with official sources and consult qualified legal counsel before making compliance decisions.
United States — New YorkExchange / tradingCustodyBroker / dealerTransfer / paymentsLive
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General information only — not legal advice
CryptoRegHub provides plain-English summaries of crypto regulations for informational purposes only. This does not constitute legal, compliance, or financial advice. Regulations change frequently — always verify information with official sources and consult qualified legal counsel before making any compliance decisions.
The marquee US state crypto licence, in force since 2015 and among the most rigorous in the country. The application fee is $5,000, but capital is set case-by-case by NYDFS under 23 NYCRR 200.8 — there is no fixed number — and preparation costs run to many multiples of the fee. A firm transmitting both fiat and crypto needs the BitLicense and the separate NY money transmitter licence; New York has not adopted the MTMA, so its standards cannot be assumed from other states. The limited-purpose trust charter is the established alternative route, historically favoured by custodians.
Application process
1
Choose licence vs trust charter
The BitLicense covers virtual currency business activity; the limited-purpose trust charter is the alternative route, historically used by custodians, and carries fiduciary powers.
2
Prepare the full file
Business plan, organisational chart, biographical and financial documentation for all directors, officers and 10%+ shareholders, policy drafts, fingerprints and background checks.
3
File via NMLS and pay the $5,000 fee
The fee covers review only — preparation cost is the real number.
4
RFI rounds
Multiple rounds of requests for information are standard; NYDFS sets capital case-by-case during review.
5
Stack the MTL if you touch fiat
Transmitting fiat as well as crypto requires the separate NY money transmitter licence alongside.
Ongoing obligations
Capital — as determined by NYDFS under 23 NYCRR 200.8, reviewed against your risk profile; NY Banking Law adds 100% permissible-investment coverage where the MTL applies.
Cybersecurity — 23 NYCRR 500 applies in full.
Supervisory assessments — billed five times a year on custody holdings and volume.
Conduct and consumer protection — AML/BSA, coin-listing policies, BCDR, complaint handling and extensive reporting.
Common rejection & delay reasons
Documentation depth underestimated
The file is the product: incomplete biographical, financial or policy documentation drives the multi-round RFI cycle that stretches timelines toward 24 months.
Fee anchoring
Budgeting around the $5,000 fee rather than the preparation cost — public examples run to seven figures.
Fiat scope missed
Discovering mid-review that the NY MTL is also required.
What's changing
CLARITY Act federal preemption debates would reshape state regimes if enacted — no operative effect until rulemaking
· proposed
Frequently asked questions
At a glance
JurisdictionUnited States — New York
RegulatorNew York State Department of Financial Services (NYDFS)
TypeLicence
CapitalCase-by-case (NYDFS-set)
Application feeUSD 5,000
Ongoing feesNYDFS supervisory assessments billed five times a year, tiered on custody holdings and transaction volume — roughly $15,000–$80,000+ per year for startups (industry estimate) — plus examinations.
Realistic timelineTypically 6–24 months (industry estimate); one public example ran around 18 months with roughly $2.1M in direct costs.
PassportingNone — New York only
Last verified28 Jul 2026
Local presence
Background checks and fingerprints for principals; New York presence expectations through the application; full documentation of directors, officers and 10% shareholders.
This guide is for general informational purposes only and does not constitute legal advice. Figures change — always verify with the regulator and consult qualified counsel before applying.