What a crypto exchange needs to operate
Regulators look at what you actually do: exchanging crypto for fiat, transferring value between customers, or holding assets on their behalf. Each activity can trigger registration, AML, and reporting obligations.
- A legal entity in a suitable jurisdiction
- FinCEN MSB registration for US money transmission activity
- An AML/KYC compliance program and a designated compliance officer
- Banking and payment partners willing to support crypto flows
- A secure customer platform for accounts, balances, and transfers
US MSB as a starting point
A FinCEN-registered MSB is a recognised foundation for crypto-to-fiat services. Montana is notable as a US state without a state money transmitter licensing statute, so a Montana MSB can be a practical base. State requirements still apply where you serve customers.
Montana MSB offers newly formed and existing MSB companies, including structures designed for crypto businesses.
European fiduciary custody
A Swedish trust company can hold digital assets as trustee under a trust deed governed by foreign law, while acting as an AML/CFT-registered trustee. That is a fiduciary custody arrangement, not an exchange or transfer service, and it sits alongside your US registration rather than replacing it.
Software for your exchange
EBANQ provides a white-label banking platform with multi-currency accounts, transfers, customer messaging, administration, and branded iOS and Android apps. Additional currencies and units of value can be configured, and the REST API supports integrations with liquidity and custody providers.
Common questions
Do I need a license to run a crypto exchange in the US?
Businesses exchanging or transmitting virtual currency are generally money services businesses and must register with FinCEN. Some states also require money transmitter licenses depending on where customers are located.
Is an MSB registration the same as a license?
No. FinCEN registration is a federal registration, not a license. State licensing is separate and depends on your activities and customer locations.
Can I buy an existing crypto-ready MSB?
Existing MSB companies are sometimes available for acquisition. Montana MSB lists current options and new formations.
Can client crypto assets be held in trust in Europe?
A Swedish trust company can act as trustee and hold digital assets under a trust deed. It is an AML/CFT-registered fiduciary arrangement, not an exchange or a licensed custody service.
General information only, not legal advice. Requirements depend on your activities and the jurisdictions where you serve customers.