United States · State-Level
State-by-state stablecoin licensing
The bottom line: US stablecoin issuers face a patchwork of 50+ state licensing regimes. Most states require a money transmitter license (MTL) through NMLS. Three states offer special crypto charters — New York's BitLicense, Wyoming's SPDI, and Nebraska's DADI. At the federal level, the OCC has granted a handful of national trust bank charters to digital asset firms. Toggle between the MTL and OCC views to see the full picture.
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License Types
US stablecoin licensing pathways
State MTL
What it is: State-level money transmitter license, required in 48 states + DC for money transmission activities including stablecoin issuance and distribution. Why it matters: The de facto compliance pathway. Requirements vary: surety bonds from $25K (Alabama) to $7M (California), net worth minimums, and BSA/AML programs. Applied for through NMLS. Full 50-state coverage takes 12–24 months.
NY BitLicense
What it is: New York DFS virtual currency business license (23 NYCRR Part 200, effective 2015). Why it matters: The most stringent US crypto license. Requires DFS approval for any virtual currency business activity in New York. Compliance costs exceed $1M, approval takes 12–18 months, and DFS has rejected the majority of applications. Alternative: NY Trust Company charter (used by Paxos, Gemini).
Wyoming SPDI
What it is: Special Purpose Depository Institution charter under Wyoming HB 74 (2019). Why it matters: The most crypto-friendly state charter in the US. SPDIs can custody digital assets, hold reserves, and conduct crypto-banking activities without FDIC insurance. Kraken Financial and Custodia Bank hold SPDI charters. Wyoming also exempts crypto from state property tax.
Nebraska DADI
What it is: Digital Asset Depository Act institution charter (LB 649, 2021). Why it matters: Modeled on Wyoming's SPDI, Nebraska's charter allows digital asset custody and stablecoin services under state banking supervision. Second state to create a bank-like charter specifically for digital assets.
OCC National Trust
What it is: Federally chartered national trust bank supervised by the OCC. Why it matters: Grants federal banking powers — custody, settlement, and reserve management — preempting state-by-state licensing. OCC Interpretive Letters 1170/1174/1176 (2021) confirmed authority for crypto custody and stablecoin reserves. Three conditional charters granted: Anchorage Digital, Paxos, Protego (returned).
GENIUS Act (Federal)
What it is: The Guiding and Establishing National Innovation for US Stablecoins Act (2025). Why it matters: Establishes a dual-track federal framework. Issuers can choose federal supervision (OCC/Fed) or state supervision. 1:1 reserve mandate, monthly attestation, redemption at par. Read the GENIUS Act deep dive →
OCC Charter Tracker
National trust bank charter applications
| Entity | Status | State | Date |
|---|---|---|---|
| Anchorage Digital Bank | Granted | SD | Jan 2021 |
| Paxos National Trust | Conditional | NY | Apr 2021 |
| Protego Trust | Returned | WA | Feb 2021 |
| Figure Technologies | Pending | NV | — |
The OCC fintech charter pathway remains legally contested. The CSBS (Conference of State Bank Supervisors) challenged OCC's authority in Lacewell v. OCC (2020). The GENIUS Act partially resolves this by codifying a federal pathway alongside state supervision.
Methodology
How state data is maintained
MTL coverage is tracked per issuer using NMLS public records, state licensing databases, and company disclosures. Status reflects the latest available data: Licensed (active MTL or equivalent), BitLicense (NY DFS authorization), Exempt (state does not require MTL), Pending (application filed).
OCC charter data is sourced from OCC conditional charter grant announcements and Interpretive Letters. Charter status: Granted (full or conditional charter active), Conditional (charter with operating conditions), Pending (application under review), Returned (charter granted but returned by applicant).
Sources: NMLS, OCC Interpretive Letters 1170/1174/1176, NY DFS BitLicense registry, Wyoming Division of Banking SPDI records, Nebraska DBF DADI records, CSBS state licensing databases, issuer public filings. Updated quarterly.