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West · Last reviewed 2026-07

Montana money transmitter license

Requirements, bond, timeline, and crypto notes for the None — no state money transmitter license exists — for companies preparing an application or diligence questionnaire.

Key requirements

License
None — no state money transmitter license exists
Statute
No money transmitter licensing statute (Montana is the only state without one)
Surety bond
Not applicable
Net worth
Not applicable
NMLS
Not required (verify with regulator)
Application fee
Not applicable
Typical timeline
Not applicable

Crypto & virtual currency

Montana is the only US state with no money transmitter licensing statute at all — for fiat or crypto. There is nothing to apply for and no state bond or net worth requirement. Three critical caveats. First, federal law applies in full: a money services business serving Montana customers must still register with FinCEN under 31 CFR 1022.380, maintain a BSA/AML program, and comply with OFAC sanctions. Second, Montana's consumer protection and securities laws still apply to crypto activity. Third, serving customers in any other state still triggers that state's licensing law — Montana's gap does not travel with you. Bills to enact a transmitter statute surface periodically; monitor the legislature. Requirements change frequently — always verify current figures and interpretations directly with the state regulator before filing.

Frequently asked questions

Is it true Montana has no money transmitter license?

Yes — Montana is the only state with no money transmitter licensing statute. No state license, bond, or net worth requirement applies to transmission. Federal FinCEN MSB registration and BSA/AML obligations still apply in full, as do Montana consumer protection and securities laws.

Can I base my crypto company in Montana and skip licensing?

Only for Montana customers. Licensing follows where your customers are, not where you sit. A Montana-headquartered exchange serving customers in Washington, New York, or Texas needs those states' licenses. Montana eliminates exactly one state from the map.

What obligations remain for a Montana MSB?

FinCEN registration (31 CFR 1022.380), a written BSA/AML program with a designated compliance officer, SAR and CTR filing, OFAC screening, and Travel Rule compliance. State licensure is the only layer missing — the federal stack is unchanged.

Will Montana adopt a money transmitter law?

Bills have been introduced over the years without enactment as of our last review. Treat the gap as current law, not permanent law — include Montana in your regulatory change monitoring.

This page is educational and does not constitute legal advice. Requirements change frequently — always verify current figures and interpretations directly with Montana Division of Banking and Financial Institutions before filing.

How does your program read to a Montana licensing analyst?

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