Authorisations in United States, as at 21 September 2026
Authorisations
141
across 8 licence families
Licensed
110
of 141 authorisations
In the pipeline
27
Applications and in-principle approvals
Ended
4
Refused, withdrawn or lapsed
Authorisations by licence
Money services business registration
24%
34
OCC national trust bank charter
20%
28
NYDFS BitLicense
19%
27
State money transmitter licence
16%
22
NYDFS limited purpose trust charter
9%
13
Other authorisations
7%
10
OCC national bank charter
4%
5
Trust company charter
1%
2
These 141 authorisations belong to 85 companies. The company-level records are in Atlas Pro.
What those authorisations permit
Holding assets for clients71
Moving value for clients92
Scope not stated in the licence10
One authorisation can cover several activities, so these figures overlap.
What each activity needs
Six common activities, and the authorisation each one requires. Almost every US business doing one of these needs more than one licence, because the federal and state layers apply at the same time.
This is the one activity with a bespoke federal regime. The GENIUS Act bars anyone but a Permitted Payment Stablecoin Issuer from issuing a payment stablecoin, and offers three routes to becoming one: an OCC-approved federal nonbank issuer, an approved subsidiary of an insured bank or credit union, or a state-qualified issuer under a state regime the Stablecoin Certification Review Committee has certified. The state route closes to an issuer once consolidated outstanding issuance passes 10 billion dollars.
Enacted 18 July 2025. Not yet in effect: it takes effect on the earlier of 18 January 2027 or 120 days after final rules.
Holding it for someone else
No federal crypto custody licence exists. Holding customer assets or keys is regulated under the Bank Secrecy Act if you also transmit, under state money transmission law in most states, and most distinctly through New York, where custody is virtual currency business activity requiring a BitLicense or a limited purpose trust charter. Large custodians have used an OCC national trust bank charter instead, which reaches every state at once.
The Bank Secrecy Act and the New York regime are in force now. GENIUS does not change custody.
Exchange and on/off-ramps
Spot exchanges and fiat on and off-ramps have no bespoke federal licence. They register with FinCEN as money services businesses, hold state money transmitter licences, take a BitLicense for New York, and operate inside an unsettled SEC and CFTC perimeter. The CLARITY Act would create CFTC-registered digital commodity exchanges and close the spot-market gap; it is not enacted.
The current framework applies now. The market-structure bill is still in the Senate.
Payments and money transmission
Receiving and transmitting value is the classic money transmission activity: FinCEN registration federally, plus a money transmitter licence in each state of operation, plus a BitLicense where virtual currency is involved and the customer is in New York. There is no federal payments charter. The GENIUS Act governs the stablecoin instrument, not the act of transmitting it.
In force now, and unchanged by GENIUS.
There is no dedicated US licence for a stablecoin card programme. Programmes reach the Visa and Mastercard rails through a sponsor bank that holds network principal membership and the BIN and is the issuer of record, so the programme manager avoids a banking charter. Where the programme holds or transmits customer funds or stablecoins itself, FinCEN registration and state money transmitter licences still apply.
In force now. Network accreditation of BIN sponsors has tightened, which is the practical constraint.
Cross-border transfer and remittance
Cross-border transfer and consumer remittance using stablecoins are regulated as money transmission rather than under a separate remittance licence: FinCEN registration plus state money transmitter licences, with a BitLicense for New York. Consumer remittance transfers also trigger the CFPB's Remittance Rule, which is a conduct rule and not a licence: disclosures before payment and on receipt, a thirty-minute cancellation window, and error-resolution procedures.
In force now. The Remittance Rule applies above 100 consumer transfers a year.
The licences: who grants them, how long, what they cost
The statutory clock is the formal decision period, where the regulator publishes one. “Observed” is the real-world timeline reported by applicants, not a figure the regulator sets. Capital is the regulatory minimum, not legal or advisory fees. Where a figure is not yet available, we show “Unavailable”; where one exists but Anvesan has not verified it, we show “Not sourced”.
State money transmitter figures vary by state and by volume, and the fifty-state footprint most businesses need is fifty separate applications. Anvesan publishes the ranges its sources state and no single figure it cannot cite.
Permitted Payment Stablecoin Issuer, federal route
- Who grants it
- The Office of the Comptroller of the Currency, as the primary federal payment stablecoin regulator for a nonbank issuer.
- What triggers it
- Issuing and redeeming a US dollar payment stablecoin to the public as a nonbank.
- Legal basis
- GENIUS Act, Pub. L. 119-27, enacted 18 July 2025; OCC proposed rules published 2 March 2026.
This is the only bespoke federal licence for a stablecoin. Everything else on this page is the pre-existing money transmission framework, which GENIUS does not replace.
Statutory clock
120 days
The regulator must approve or deny a substantially complete application within 120 days. An application it fails to decide in that window is deemed approved, which is unusual in US bank licensing and was written in deliberately.
What it takes in practice
Not yet available
No issuer has been approved, because the Act is not yet in effect. It takes effect on the earlier of 18 January 2027 or 120 days after final rules, and the statutory rulemaking deadline of 18 July 2026 passed with every major rule still at proposal stage.
| ReservesUS currency, insured demand deposits, short-dated Treasuries, overnight Treasury repos, government money-market funds |
1:1 in high-quality liquid assets |
|---|
| Capitalthe OCC's proposal adds money-market-fund-style conditions; no flat figure in the statute |
Set by the regulator |
|---|
Reserves are segregated, cannot be rehypothecated, and no yield may be paid to holders. A monthly attestation by a registered public accounting firm with officer certification is required.
Application fee Not yet set. The application process does not exist until the Act takes effect.
Permitted Payment Stablecoin Issuer, bank subsidiary route
- Who grants it
- The insured institution's primary federal regulator: the OCC, the FDIC or the NCUA.
- What triggers it
- An insured depository institution or insured credit union issuing a payment stablecoin through an approved subsidiary.
- Legal basis
- GENIUS Act, Pub. L. 119-27; FDIC standards proposed 10 April 2026; NCUA standards proposed 18 May 2026.
Statutory clock
120 days
The same 120-day decision period and the same deemed-approval rule as the federal nonbank route.
What it takes in practice
Not yet available
The standards are at proposal stage at both the FDIC and the NCUA, so no subsidiary has been approved under them.
| Reservesthe same GENIUS issuer standards as the federal route |
1:1 in high-quality liquid assets |
|---|
| Capitalplus whatever the primary federal regulator sets for the subsidiary |
The parent's own requirements |
|---|
Segregation, no rehypothecation, no yield, monthly attestation, and a BSA/AML and sanctions programme, as on the federal route.
Application fee Not yet set.
Permitted Payment Stablecoin Issuer, state-qualified route
- Who grants it
- A state banking or financial services regulator, under a state regime certified by the Stablecoin Certification Review Committee, which the Treasury chairs.
- What triggers it
- Issuing a payment stablecoin under state approval while consolidated outstanding issuance stays at or below 10 billion dollars.
- Legal basis
- GENIUS Act, Pub. L. 119-27, state-qualified issuer path; Treasury proposed rules on acceptable state regimes.
Statutory clock
Not published
The Act sets the certification process for the state regime, not a decision clock for the issuer's own application. That will come from each certified state.
What it takes in practice
Not yet available
No state regime has been certified, so the route is not yet open anywhere.
| Reservesthe state regime must be certified as substantially similar to the federal standard |
1:1 in high-quality liquid assets |
|---|
The route closes to an issuer once consolidated outstanding issuance passes 10 billion dollars: at that point it must transition to a federal regulator.
Application fee Set by each certified state.
OCC national trust bank charter
28 in the Atlas
- Who grants it
- The Office of the Comptroller of the Currency.
- What triggers it
- Providing custody and fiduciary services nationally under a federal charter, without taking deposits.
- Legal basis
- National Bank Act; 12 CFR Part 5; the OCC Licensing Manual.
This is the route several large custodians took to serve every state without fifty money transmitter licences.
Statutory clock
Not published
Anvesan has not found a decision deadline in statute. The OCC works to internal target timeframes in its Licensing Manual and treats them as targets rather than limits.
What it takes in practice
18 months and up
The longest route on this page by the timelines applicants report. Preliminary conditional approval is a stage rather than the end.
| Minimum capitalthe OCC sets it in the charter approval against the applicant's business plan |
Set case by case |
|---|
A charter carries continuing supervision, examination and an operating agreement, which is the real cost rather than the opening figure.
Application fee OCC filing fees plus assessment once chartered.
FinCEN money services business registration
34 in the Atlas
- Who grants it
- The Financial Crimes Enforcement Network. It is a registration, not a licence, and nobody approves it.
- What triggers it
- Acting as a money transmitter or exchanger of convertible virtual currency as a business.
- Legal basis
- Bank Secrecy Act; 31 CFR Part 1022; FinCEN guidance of 2013 and 2019 on convertible virtual currency.
Commonly mistaken for a licence. A company describing itself as FinCEN registered has met a federal reporting obligation, not obtained permission to operate.
Statutory clock
180 days to register
Form 107 is filed on the BSA E-Filing System within 180 days of starting operations, and renewed every two years. There is no approval to wait for.
What it takes in practice
Effective on filing
The registration itself is immediate. The work is the anti-money-laundering programme behind it, which examiners will test.
No capital or bond requirement. Registration authorises nothing: it does not replace a state money transmitter licence.
Application fee No fee.
State money transmitter licence
22 in the Atlas
- Who grants it
- Each state's banking or financial services regulator, applied for through NMLS. There is no national licence.
- What triggers it
- Receiving money or monetary value, which in most states now includes stablecoins, for transmission.
- Legal basis
- State money transmission statutes; the Money Transmission Modernization Act model law, adopted in part by most states.
Whether custody alone counts as money transmission varies by state, which is why the same business can need a licence in one state and be exempt next door.
Statutory clock
Varies by state
The model act sets a decision period that adopting states have implemented differently, and states outside it set their own. There is no single national clock.
What it takes in practice
12 to 24 months
For the fifty-state footprint most businesses need, this is fifty applications, fifty sets of financials, fifty background checks and fifty surety bonds, run in parallel through NMLS.
| Minimum net worthtiered by transmission volume in states following the model act |
Set per state |
|---|
| Surety bondhigher in some states and for higher-volume or crypto activity |
Commonly 10,000 to 500,000 dollars |
|---|
| Permissible investmentsthe value transmitted but not yet delivered must be held in prescribed assets |
Backing of outstanding obligations |
|---|
The figures vary widely by state and by volume. A national footprint costs the sum of fifty of them rather than the largest single one.
Application fee Set per state, plus NMLS system fees and annual renewals.
NYDFS BitLicense
27 in the Atlas
- Who grants it
- The New York State Department of Financial Services.
- What triggers it
- Any virtual currency business activity involving a New York person: custody, exchange, transmission, issuance or control of virtual currency.
- Legal basis
- New York virtual currency business activity regulation, 23 NYCRR Part 200.
A BitLicense does not cover money transmission of fiat. A business doing both in New York needs a money transmitter licence as well.
Statutory clock
90 days, extendable
23 NYCRR 200.6 requires the superintendent to approve or deny within 90 days of an application deemed complete. The same provision lets the superintendent extend that period at their discretion for as long as compliance requires, which is why the written deadline and the observed wait are so far apart.
What it takes in practice
12 to 24 months and up
The written 90 days run from an application NYDFS deems complete, and the extension is discretionary and open-ended. NYDFS has since published a phased application process, and applicants still plan in years rather than months.
| Application feepayable on filing, non-refundable |
5,000 dollars |
|---|
| Capitaldetermined case by case against the applicant's activity and volume |
Set by NYDFS |
|---|
| Surety bond or trust account500,000 dollars is a common floor in practice rather than a stated minimum |
Set by NYDFS |
|---|
Customer assets must be protected in insolvency, titled for the benefit of the customer, segregated and not commingled, with prior NYDFS approval of sub-custodians.
Application fee 5,000 dollars on application, plus supervisory costs once licensed.
NYDFS limited purpose trust charter
13 in the Atlas
- Who grants it
- The New York State Department of Financial Services, under the New York Banking Law.
- What triggers it
- Custody and fiduciary activity in New York, as an alternative to the BitLicense.
- Legal basis
- New York Banking Law; 23 NYCRR Part 200 applies to the virtual currency activity itself.
The two New York routes are alternatives, not a sequence. Firms hold one or the other, occasionally both across group entities.
Statutory clock
Not published
NYDFS does not publish a decision period for a limited purpose trust charter. The BitLicense carries one in 23 NYCRR 200.6; the Banking Law charter route does not.
What it takes in practice
12 to 24 months and up
Chosen over a BitLicense by firms that want fiduciary powers and a charter rather than a licence, and it takes at least as long.
| Capitaldetermined case by case; higher than a BitLicense in practice |
Set by NYDFS |
|---|
A charter carries continuing supervision and examination, and prior approval for new virtual currency activity.
Application fee Set by NYDFS.
What to watch
Regulatory changes only: what is being decided, by whom, and when. Company-level licence changes are tracked in Atlas Pro. Reviewed 10 September 2026.
Ahead
18 January 2027
Deadline
The GENIUS Act takes effect, rules or no rules
The Act takes effect on the earlier of 18 January 2027 or 120 days after final implementing rules. The statutory deadline for those rules, 18 July 2026, passed with every major rulemaking still at proposal stage: the OCC published its proposal on 2 March 2026, the FDIC on 10 April 2026 and the NCUA on 18 May 2026. Absent final rules the default date decides it.
What changes From that date, issuing dollar stablecoins in the US without Permitted Payment Stablecoin Issuer status is prohibited. No firm holds that status yet.
GENIUS Act, Pub. L. 119-27
Pending
Open question
Whether any state regime is certified in time
The state-qualified issuer route needs a state regime certified by the Stablecoin Certification Review Committee, which the Treasury chairs. The Treasury has proposed principles for acceptable state regimes. No state has been certified.
What changes If no state is certified before the Act takes effect, issuance would have to use the federal route, making the $10 billion state ceiling irrelevant.
GENIUS Act, Pub. L. 119-27, state-qualified issuer path
Vote indicated for 2026
In the Senate
The CLARITY Act and the spot-market gap
The market-structure bill passed the House in July 2025 and was reported out of the Senate Banking Committee on 1 June 2026. The Senate adjourned for its August 2026 recess without a floor vote, with one indicated for later in the year. The Act is not enacted.
What changes It would create CFTC-registered digital commodity exchanges and clarify which regulator oversees spot trading. Until then, exchanges operate inside an SEC and CFTC perimeter that has never been clearly drawn.
CLARITY Act, H.R. 3633
Recently landed
18 July 2025
In force
The GENIUS Act became law
The first federal payment stablecoin statute. It bars issuance by anyone other than a Permitted Payment Stablecoin Issuer, sets 1:1 high-quality liquid reserves, prohibits paying yield to holders, and requires a monthly attestation by a registered public accounting firm with officer certification.
What changes Enactment is not effectiveness. The prohibition and the licence both wait for the effective date above.
GENIUS Act, Pub. L. 119-27
Questions this page answers
How many companies hold a stablecoin-related licence in the United States?
Atlas tracks 141 authorisations across 85 companies in the US federal, state and New York regimes, read from the OCC and NYDFS registers and checked on 21 September 2026. Of those, 110 are licensed, 27 are in the pipeline, and 4 have ended.
What licence does a stablecoin issuer need in the US?
Permitted Payment Stablecoin Issuer status under the GENIUS Act, by one of three routes: OCC approval as a federal qualified nonbank issuer, approval of a subsidiary by an insured institution's federal regulator, or a state-qualified route under a certified state regime. None of the three is available yet, because the Act is not in effect.
Is FinCEN registration a licence?
No. Registering as a money services business with FinCEN is a federal reporting obligation under the Bank Secrecy Act. Nobody approves it, it carries no capital requirement, and it authorises nothing. A business transmitting value still needs a money transmitter licence in each state where it operates.
How long does a US money transmitter licence take?
There is no single national licence and no single clock. Applications go through NMLS state by state, and businesses building the fifty-state footprint most of them need report 12 to 24 months for the full set. New York is separate again and takes longer.
What does a BitLicense cost?
The application fee is 5,000 dollars. Capital and the surety bond or trust account are set by NYDFS case by case rather than by a published minimum, with 500,000 dollars a common floor in practice. The larger cost is time: NYDFS sets no decision deadline and applicants plan in years.
Does a licence from one state work in another?
No. Money transmission is licensed state by state, and there is no passporting between them. That is why several large custodians pursued an OCC national trust bank charter instead, which reaches every state under one federal charter.
How these numbers are made
- Registers read
- The OCC's list of chartered institutions and applications, and the NYDFS registers of virtual currency licensees and limited purpose trust companies.
- Cadence
- Checked daily. Changes are recorded when they appear in the register, together with the date they were seen. Last checked 21 September 2026.
- Licence detail reviewed
- 10 September 2026. Counts are refreshed daily. Licence terms, timelines and capital thresholds are reviewed separately because they come from the underlying rules rather than the register.
- Known gap
- NMLS, which holds state money transmitter licences, is not read into this dataset: the state money transmitter records here come from company reporting and are marked as such. Where a figure is unavailable, we mark it as missing rather than estimate it.
- Corrections
- research@anvesan.org