Crypto Licensing & Virtual Currency Regulatory Filings

Comprehensive legal services for obtaining and maintaining financial services licenses, virtual currency licenses, and regulatory registrations for cryptocurrency businesses. McDermott's FinTech & Blockchain Practice, featuring the largest full-time crypto-exclusive legal team in the industry, provides end-to-end licensing support for cryptocurrency exchanges, custody providers, and digital asset service providers.

Virtual Currency Licensing

BitLicense (New York):

• BitLicense application preparation and filing
• NY DFS application strategy and submission
• License maintenance and ongoing compliance
• Deficiency response and regulator communication
• Amendment filings for business changes

Money Transmitter Licenses (MTL):

• State-by-state MTL application strategy (48+ state analysis)
• Multi-state licensing coordination and management
• Surety bond procurement and maintenance
• License renewal and compliance reporting
• Permissible investments compliance

Trust Company Licensing:

• State-chartered trust company applications
• Virtual currency trust authority applications
• Special counsel on first crypto company to acquire NY DFS-regulated trust company (Ripple/Standard Custody & Trust)
• Trust company capitalization and governance requirements
• Multi-state trust operations licensing

Federal Registration

FinCEN Registration:

• Money Services Business (MSB) registration
• FinCEN Form 107 filing and updates
• Bank Secrecy Act (BSA) registration requirements
• MSB compliance program establishment

CFTC Registration:

• Swap dealer registration analysis
• Designated Contract Market (DCM) applications
• Derivatives Clearing Organization (DCO) registration
• CFTC reporting and compliance

International VASP Licensing

EU MiCA Registration:

• Crypto-Asset Service Provider (CASP) licensing
• EU member state application strategy
• MiCA compliance roadmap and implementation
• Prudential safeguards and capital requirements

Other Jurisdictions:

• Singapore MAS Digital Payment Token (DPT) licensing
• UK FCA Crypto-Asset Registration
• Cayman VASP registration
• Switzerland FINMA licensing for crypto intermediaries

Exchange & Trading Platform Licensing

• Alternative Trading System (ATS) registration
• Broker-dealer applications for crypto securities
• National securities exchange applications
• State securities registration (Blue Sky compliance)

Stablecoin Regulatory Approval

• Ongoing counsel for Ripple USD (RLUSD) regulatory approval
• Stablecoin reserve compliance filings
• State-by-state stablecoin authorization
• Central bank engagement for stablecoin issuance

Ongoing Regulatory Filings

• License renewals and amendments
• Quarterly and annual regulatory reports
• Material change notifications
• Examination response and deficiency remediation
• Correspondence and negotiation with regulators

The team has successfully obtained virtual currency licenses for cryptocurrency exchanges custodying $3.8+ billion in digital and fiat assets, navigating complex state-by-state regulatory frameworks and federal oversight regimes.

Why Choose McDermott

With Partner Joseph B. Evans leading the largest full-time crypto-exclusive legal team in the industry (recognized as a "trailblazer" by The American Lawyer), McDermott combines deep regulatory expertise with proven success in groundbreaking crypto licensing matters. The firm's Band 1 ranking in Crypto-Asset Disputes by Chambers USA and experience advising on the first crypto company acquisition of a NY DFS-regulated trust company demonstrates unparalleled sophistication in navigating complex virtual currency regulatory frameworks across federal and state jurisdictions.