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The Multi-Year US Licensing Roadmap — Crypto Exchange Regulatory Strategy — The Multi-Year US Licensing Roadmap
Operating a US crypto exchange without proper licensing is a federal crime. Here is the realistic multi-year licensing roadmap that takes exchanges from bare minimum compliance to full 50-state coverage.
Free, online, immediate confirmation. Required before any operations. Non-negotiable. URL: fincen.gov/msb-registrant-search
Written AML policy, appointing a compliance officer, KYC procedures, transaction monitoring, and SAR filing capability. We can provide a template AML program framework ($5,000–$10,000) that your compliance officer adapts and owns.
Map every state's MTL requirement. Some states exempt certain activities or have no MTL requirement: - States with no MTL requirement (as of 2025): Montana, South Carolina, a few others - States with MTL but crypto-exempted: varies — check current status with legal counsel - States requiring MTL: majority of US states...
First priority states (largest populations, most active crypto markets):
Crypto Exchange Regulatory Strategy — The Multi-Year US Licensing Roadmap
Common integrations: The Graph, Alchemy/Infura, OpenZeppelin Defender, and popular wallet providers.
Clarify requirements, compliance needs, architecture risks, and launch goals.
Implement core contracts, integrations, product flows, tests, and deployment automation.
Run QA, prepare audit handoff, deploy infrastructure, and support production rollout.
In most states: no — operating without a required MTL is illegal, and pending status does not grant permission to operate. In a few states: temporary licenses or provisional status may be available. Your licensing attorney must verify the specific rules for each state where you want to operate before you begin serving residents of that state.
Schedule a discovery call and receive a tailored scope and estimate. No commitment required.