Regulatory Compliance Requirements by Jurisdiction
This table provides a comprehensive overview of regulatory requirements across different jurisdictions for money transmitter licensing and compliance.
| Jurisdiction | License Type | Capital Requirements | Application Timeline | Key Compliance Requirements | Ongoing Obligations |
|---|---|---|---|---|---|
| United States - Federal | MSB Registration (FinCEN) | No minimum capital requirement | 2-4 weeks | Registration with FinCEN, state-by-state licensing, BSA compliance program, customer identification procedures | Annual MSB renewal, suspicious activity reporting, currency transaction reporting, record keeping requirements |
| New York State | Money Transmitter License | $500,000 minimum net worth | 12-18 months | Comprehensive application, background checks, business plan review, compliance manual, anti-money laundering program | Annual reporting, surety bond maintenance, quarterly financial statements, regulatory examinations |
| California | Money Transmission License | $250,000 minimum tangible net worth | 9-12 months | Application with fingerprinting, surety bond, financial statements, compliance policies, consumer protection measures | Annual renewal, financial reporting, compliance monitoring, permissible investment maintenance |
| European Union | Electronic Money Institution (EMI) | €350,000 initial capital | 6-9 months | Authorization application, prudential requirements, safeguarding arrangements, operational resilience | Regulatory reporting, capital adequacy maintenance, operational resilience testing, consumer protection compliance |
| United Kingdom | Authorised Payment Institution | £125,000 initial capital | 9-12 months | FCA authorization, safeguarding requirements, operational resilience, conduct requirements | Regulatory reporting, capital requirement calculations, operational resilience testing, conduct monitoring |
| Singapore | Major Payment Institution | S$1 million base capital | 6-9 months | MAS licensing, technology risk management, anti-money laundering compliance, customer due diligence | Annual compliance reporting, technology risk assessments, AML transaction monitoring, regulatory submissions |
| Canada - Federal | Money Services Business | No minimum capital (varies by province) | 4-6 weeks | FINTRAC registration, compliance program, record keeping, client identification | Annual compliance reporting, suspicious transaction reporting, large cash transaction reporting |
| Australia | Remittance Service Provider | AUD $1 million financial requirement | 6-8 months | AUSTRAC registration, compliance program, risk assessment, customer identification procedures | Annual compliance reporting, transaction monitoring, ongoing customer due diligence, regulatory liaison |
| Switzerland | FinTech License | CHF 300,000 minimum capital | 6-9 months | FINMA authorization, prudential requirements, risk management, organizational requirements | Regulatory reporting, risk management updates, compliance monitoring, capital adequacy maintenance |
| Japan | Funds Transfer Service Provider | ¥10 million minimum capital | 3-6 months | FSA registration, internal control systems, segregation of customer funds, operational procedures | Annual reporting, internal audit requirements, customer fund segregation monitoring, regulatory compliance |
| Hong Kong | Money Service Operator | HK$100,000 minimum paid-up capital | 2-4 months | Customs licensing, anti-money laundering compliance, customer due diligence, record keeping | Annual renewal, suspicious transaction reporting, customer identification verification, compliance monitoring |
| UAE | Stored Value Facility License | AED 3 million minimum capital | 6-12 months | Central Bank licensing, governance framework, risk management, consumer protection measures | Regulatory reporting, risk assessment updates, compliance monitoring, operational resilience testing |
| Brazil | Payment Institution | R$ 2 million minimum capital | 9-12 months | Central Bank authorization, corporate governance, risk management, operational requirements | Regular reporting, capital adequacy monitoring, compliance assessments, operational resilience maintenance |
| Mexico | Electronic Payment Fund Institution | MXN 3 million minimum capital | 6-9 months | CNBV authorization, operational requirements, risk management, consumer protection | Financial reporting, compliance monitoring, risk assessment updates, regulatory examination participation |
| South Africa | Designated Non-Bank Financial Institution | ZAR 1 million minimum capital | 6-8 months | SARB authorization, compliance program, fit and proper requirements, risk management | Quarterly reporting, compliance monitoring, risk management updates, regulatory examination compliance |
Key Considerations for Multi-Jurisdiction Licensing
When planning expansion across multiple jurisdictions, consider:
Strategic Planning
Start with jurisdictions that align with your target markets and have established regulatory frameworks. Consider passporting opportunities within economic regions like the EU.
Warning
Capital requirements can accumulate quickly across jurisdictions. Plan for adequate funding to meet multiple licensing requirements simultaneously.
For detailed guidance on specific jurisdictions and licensing strategies, contact our regulatory specialists.