Cryptocurrency & Fintech Licensing Services

Sullivan & Cromwell provides comprehensive legal services for obtaining and maintaining financial services licenses and regulatory registrations for cryptocurrency, blockchain, and fintech companies. Drawing on more than 140 years of experience advising the world's leading financial institutions, S&C assists clients in structuring their businesses to comply with federal and state regulations while maintaining operational flexibility.

Federal Regulatory Licensing

S&C's regulatory team advises on the full spectrum of federal licensing requirements for digital asset businesses, including Money Services Business (MSB) registration with FinCEN, federal banking charter applications for fintech and digital asset companies, broker-dealer registrations for investment platforms, and engagement with the Federal Reserve and FDIC on digital asset banking activities. The firm has pioneered regulatory pathways for innovative financial institutions seeking to integrate digital asset capabilities into their operations.

State Licensing & Registrations

The practice provides comprehensive counsel on state-level regulatory requirements, including money transmitter licenses across all 50 jurisdictions, state virtual currency and BitLicense requirements (including New York's stringent licensing regime), state securities registrations for token offerings and digital asset platforms, and state lending licenses for digital lending platforms. S&C's deep experience with state regulators enables efficient navigation of complex multi-state licensing processes.

Payment & Exchange Licenses

The firm advises on specialized licensing for digital payment platforms and e-wallet services, cryptocurrency exchange licenses and registrations, payment institution licenses in the UK and Europe under e-money and payment services regulations, Virtual Asset Service Provider (VASP) registrations globally, and real-time payment system participation including FedNow and RTP networks.

Stablecoin Regulatory Framework

S&C provides cutting-edge advice on emerging payment stablecoin regulations, including navigating the FDIC's proposed application requirements under the GENIUS Act for state nonmember bank subsidiaries issuing payment stablecoins, Federal Reserve policy statements on bank engagement with stablecoins, and state stablecoin licensing frameworks. The firm actively advises industry participants on shaping these evolving regulatory frameworks through engagement with policymakers and supervisory authorities.

License Applications & Renewals

The team manages the full lifecycle of regulatory licensing, including initial license application preparation and submission, regulatory filings and correspondence with supervisory authorities, license renewals and ongoing compliance reporting, regulatory examinations and responses to examiner inquiries, and remediation of licensing deficiencies. S&C's meticulous approach ensures applications meet the highest standards expected by financial regulators.

Global Licensing Coordination

Leveraging S&C's truly global platform with 13 offices across four continents, the practice coordinates multi-jurisdictional licensing strategies across the United States, United Kingdom, European Union, and Asia-Pacific markets to support worldwide digital asset and fintech operations. The firm's unified partnership structure enables seamless coordination across jurisdictions, ensuring consistent service quality globally.

Industry Leadership

Recognized by Law360 as 'Practice Group of the Year' for Fintech in both 2025 and 2026, Sullivan & Cromwell's digital assets and financial services regulatory practice is at the forefront of licensing and regulatory compliance for the next generation of financial services companies.