For non-U.S. businesses, obtaining an MTL is essential for operating legally and compliantly within the U.S. market. The MTL ensures that businesses meet U.S. regulatory requirements, enabling them to offer a range of services, including money transmission, cross-border transactions, and payments. It’s a key to accessing the well-regulated U.S. market, where customers and business partners prioritize security and compliance. Holding an MTL demonstrates a commitment to following U.S. financial regulations, enhancing business credibility and trust.

In addition to compliance, obtaining an MTL provides businesses with the ability to scale operations across multiple U.S. states, each with its own money transmission laws. This regulatory clarity and access are invaluable for international companies seeking to expand their reach in the U.S. The MTL allows businesses to operate smoothly across jurisdictions, ensuring legal consistency while offering services to U.S. consumers.

For non-U.S. companies, the MTL not only offers the competitive advantage of trust and credibility in the U.S. market but also facilitates easier partnerships with U.S. financial institutions and other crypto businesses. This access to established partnerships is crucial for long-term growth, as it positions businesses as reliable players in the evolving U.S. crypto space.

Our Recommendation:

Montana: LLC Formation with MSB Registration FinCEN

Montana is the only state in the US that does not have a specific Money Transmitter License. However, depending on the company’s activities, MT’s in Montana may need to secure other forms of licensing (such as escrow license, consumer finance company license, etc).

Registration with the Financial Crimes Enforcement Network (FinCEN) as a Money Services Business (MSB) is a requirement.

Company Formation (LLC)

Bank Account Opening

FinCEN Registration as MSB

Our professional fees for these activities amount to: 26,500 USD

Estimated Timeframe: 1-2 weeks

Money Transmitter License Strategy Options

Option 1: New License: Own State MTLs (Depending on the state, can take up to 24 Months and 2.2M USD due to surety bond and minimum net worth requirements).

Best For: Established companies with significant capital and long-term regulatory commitment

• Full regulatory autonomy and brand control
• Direct banking relationships and correspondent agreements
• High barrier to entry creates competitive moat

Option 2: Authorized Delegate/Agent (3-8 Weeks) 37,500 - 64,500 USD

Best For: Most fintech startups and payment companies seeking rapid market entry

• Flow-of-funds control through sub-accounts
• Own KYC/KYB programs with branded customer relationships
• Direct correspondent agreements (co-signed with principal)
• Regulatory track record building for future license applications
• Cost-effective scaling with 12-60 bps revenue sharing