Northeast · Last reviewed 2026-07
Massachusetts money transmitter license
Requirements, bond, timeline, and crypto notes for the Money Transmitter License under M.G.L. c. 169B — for companies preparing an application or diligence questionnaire.
Key requirements
- Regulator
- Massachusetts Division of Banks
- License
- Money Transmitter License under M.G.L. c. 169B
- Statute
- M.G.L. c. 169B (Acts 2024, ch. 312); historically G.L. c. 169 (foreign transmittal agencies)
- Surety bond
- MTMA-style tiers, commonly $100,000–$500,000 — verify the schedule under c. 169B
- Net worth
- Tiered to transmission volume under the modernized framework; verify with the Division
- NMLS
- Required
- Application fee
- Verify the current schedule — the new regime's fees were still settling as of our last review
- Typical timeline
- 5–9 months (expect variability as the new regime matures)
Crypto & virtual currency
Massachusetts was, for decades, a famous outlier: it licensed only "foreign transmittal agencies" (G.L. c. 169). That changed with M.G.L. c. 169B (Acts 2024, ch. 312), under which the Division of Banks began licensing money transmitters from January 1, 2026. The Division's FAQ indicates that transactional virtual currency (e.g., bitcoin, USDC) is generally treated as monetary value for purposes of the new act. Companies that lawfully operated unlicensed in Massachusetts under the old regime should have already assessed transition deadlines; if you have not, make this a priority. Requirements change frequently — always verify current figures and interpretations directly with the state regulator before filing.
Frequently asked questions
Did Massachusetts really not license money transmitters?
For domestic transmission, historically no — only "foreign transmittal agencies" sending money abroad needed a license under G.L. c. 169. That ended with M.G.L. c. 169B (Acts 2024, ch. 312), under which Division licensing began January 1, 2026.
Does the new Massachusetts law cover crypto?
Generally yes for transactional virtual currency. The Division of Banks' FAQ indicates that transactional VC such as bitcoin and USDC is generally treated as monetary value under c. 169B. Fiat-touching activity is clearly covered. Obtain a current legal read for your specific flows.
I operated lawfully in Massachusetts before c. 169B. Am I grandfathered?
Do not assume so. New licensing regimes typically include transition windows with hard deadlines rather than grandfathering. Verify the transition provisions and your filing deadline with the Division of Banks immediately if you have Massachusetts customers.
This page is educational and does not constitute legal advice. Requirements change frequently — always verify current figures and interpretations directly with Massachusetts Division of Banks before filing.