FAQ

Crypto Exchange FAQ — 20 Questions Before Building a Crypto Exchange

Licensing, matching engines, market makers, KYC/AML, and infrastructure — answered for founders building crypto exchanges in the US and internationally.

US licensing guidanceTechnical architectureSecurity and complianceMarket maker dynamics

Detailed answer

US crypto exchanges need FinCEN MSB registration and state Money Transmitter Licenses (49 states). New York requires additional BitLicense. Timeline: 12–24 months for all state licenses. Cost: $200,000–$500,000+ in legal fees. Matching engines must be built in C++, Rust, or Java for low latency. Minimum liquidity: $5M+ in market maker commitments to have viable trading activity.

Q1: What licenses does a US crypto exchange need?

Minimum: FinCEN MSB registration (federal). State Money Transmitter Licenses (49 states require separate licenses). New York: BitLicense additionally. Timeline: 12–24 months for all state licenses. Cost: $200,000–$500,000+ in legal fees and license costs.

Q2: What is the difference between a spot exchange and derivatives exchange?

Spot exchange: users buy and sell actual crypto assets. Derivatives (futures/options) exchange: users trade contracts that derive value from crypto prices — no actual crypto changes hands. Derivatives face additional CFTC regulation as financial derivatives.

Q3: Can we launch a crypto exchange in a US state without an MTL?

Not legally for most business models. Some 'non-custodial' P2P models have avoided MTL requirements, but this interpretation is legally contested. Any model where you hold customer funds requires MTL in states where those customers reside.

Q4: How does a matching engine work?

The matching engine is the core of any exchange. It receives order submissions (limit orders, market orders) and matches buyers and sellers based on price-time priority: highest bid matched first with lowest ask, with ties broken by time of submission. All matching logic runs in-memory for microsecond performance.

Q5: What is a market maker and why do exchanges need them?

A market maker places continuous buy and sell orders to provide liquidity. Without market makers: users would face high spreads and poor execution. Exchanges typically offer: reduced fees (sometimes negative/rebate fees) to attract market makers who in turn attract traders.

Q6: What is order book depth?

The quantity of buy and sell orders at each price level. Deep order book: large volumes at each price level, low price impact for large trades. Shallow order book: small volumes, high price impact. Deep order books attract institutional traders.

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