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Money Transmitter License Solutions from US to Africa

 

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Dilendorf Law Firm assists clients with obtainining Money Transmitter Licenses (MTLs) to facilitate remittances flows between the U.S. and African Countries. We provide turn-key MTL solutions for launching cross-border remittance platforms and payment systems for fiat and cryptocurrencies.

Our experienced FinTech lawyers regularly represent and consult companies in connection with obtaining MTL licenses for fiat and crypto to provide remittance services to Sudan, Senegal, Cameroon, Nigeria, Kenya, Zimbabwe, Sudan, and other regions in Sub-Saharan Africa.

Since 2010, sub-Saharan African countries accounted for eight of the 10 fastest growing immigrant populations in the United States.  Approximately 2.1 million sub-Saharan African immigrants resided in the United States in 2019, representing 5 percent of the total foreign-born population of 44.9 million. For example, Kenya alone receives over $1 billion annually in remittances from the United States.

We are familiar with the federal and state regulatory nuts and bolts of successfully launching remittance flows from the United States to sub-Saharan Africa regions. Reliable payments rails play an essential role in many sub-Saharan African economies.

ATTORNEYS' EXPERIENCE

ATTORNEYS' EXPERIENCE

Advising a cross-border startup facilitating payments between US and select African countries (Tanzania, Kenya, Uganda, Rwanda and Ghana) on obtaining money transmitter licenses in US

ATTORNEYS' EXPERIENCE

Representing a payment platform from Texas with obtaining money transmitter licenses to facilitate remittances between the US and Sub-Saharan Africa

Helping Clients Navigate Through MTL Requirements and Challenges

With limited exceptions, any business that accepts and transmits fiat or digital assets will be considered an MSB and require an MTL in each U.S. state where the company operates.

Money transmitters are a part of a broader category of MSBs. So, the terms MTL and MSB are related and often used together.

While registration on the federal level is relatively straightforward, the MSB legislation is not harmonized, and almost all 53 states and territories have their own regulations, requirements, and exceptions for money transmitter licensure.

MTL requirements vary state-by-state but usually include registration with the Financial Crimes Enforcement Network (FinCEN), background checks, application fees, security (the surety bond), maintenance of permissible investments, minimum net worth, and business plan and a compliance program.

When obtaining MTLs, a business may choose to prioritize some states and apply first there but will be prohibited from operating in the states where it does not maintain an MTL.

We strive to understand our client’s background, goals and other critical factors when advising clients on the best BSA/AML & MTL strategies for setting up remittance services between the U.S. and African Countries.

Guiding Clients Through MTL Application Procedures in Every State

Our lawyers advise and assist clients throughout the MTL application process, including the following steps:

  • Developing an MTL strategy nationwide for companies engaging in remittance activities (fiat + crypto) between U.S. and Africa;
  • Selecting and establishing optimal corporate and tax business structures supporting U.S. and cross-border payments and remittances;
  • Assisting clients with opening bank accounts to power remittance platforms;
  • Preparing a business plan, a summary of historical and current operations, financial statements, affidavits, and other required documentation;
  • Submitting applications in individual states;
  • Acquiring mandatory surety bonds;
  • Completing FinCEN registration;
  • Accomplishing necessary corporate actions, including local qualification of out-of-state companies, provision of registered agents, drafting/amending corporate governance documents;
  • Developing anti-money-laundering (AML) and other compliance programs;
  • Representing clients in communications with the federal and state agencies; and
  • Maintaining and renewing MTLs.

Resources:

 

Federal

State Money Transmitter Licensing Authorities:

State State Money Transmitter Licensing Authority
Alabama Alabama Securities Commission
Alaska Alaska Division of Banking and Securities
Arizona Arizona Department of Financial Institutions
Arkansas Arkansas Securities Department
California California Department of Business Oversight
Colorado Colorado Division of Banking
Connecticut Connecticut Department of Banking
Delaware Delaware Office of the State Bank Commissioner
District of Columbia District of Columbia Department of Insurance, Securities and Banking
Florida Florida Office of Financial Regulation
Georgia Georgia Department of Banking and Finance
Hawaii Hawaii Department of Commerce and Consumer Affairs
Idaho Idaho Department of Finance
Illinois Illinois Department of Financial & Professional Regulation
Indiana Indiana Department of Financial Institutions
Iowa Iowa Division of Banking
Kansas Kansas Office of the State Bank Commissioner
Kentucky Kentucky Department of Financial Institutions
Louisiana Louisiana Office of Financial Institutions
Maine Maine Office of Consumer Credit Protection
Maryland Maryland Department of Labor, Licensing & Regulation
Massachusetts Massachusetts Office of Consumer Affairs and Business Regulation
Michigan Michigan Department of Insurance and Financial Services
Minnesota Minnesota Department of Commerce
Mississippi Mississippi Department of Banking and Consumer Finance
MIssouri MIssouri Division of Finance
Montana Montana Division of Banking & Financial Institutions
Nebraska Nebraska Department of Banking and Finance
Nevada Nevada Department of Business & Industry
New Hampshire New Hampshire Banking Department
New Jersey New Jersey Department of Banking & Finance
New Mexico New Mexico Regulation and Licensing Department
New York New York Department of Financial Services
North Carolina North Carolina Commissioner of Banks
North Dakota North Dakota Department of Financial Institutions
Ohio Ohio Department of Commerce
Oklahoma Oklahoma Banking Department
Oregon Oregon Division of Financial Regulation
Pennsylvania Pennsyvlania Department of Banking and Securities
Rhode Island Rhode Island Department of Business Regulation
South Carolina South Carolina Attorney General
South Dakota South Dakota Division of Banking
Tennessee Tennessee Department of Financial Institutions
Texas Texas Department of Banking
Utah Utah Department of Financial Institutions
Vermont Vermont Department of Financial Regulation
Virginia Virginia State Corporation Commission
Washington Washington State Department of Financial Institutions
West Virgnia West Virginia Division of Financial Institutions
Wisconsin Wisconsin Department of Financial Institutions
Wyoming Wyoming Division of Banking

 

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