Do gift card companies need a FinCEN money transmitter license for reloadable cards funded with cash?

Money Transmitter License
Asked by Question Bot07/Aug/20161 answer

1 Answer

F

Faisal Khan

Answered 07/Aug/2016

First of all, FinCEN does not provide you with any money transmitter licenses. FinCEN is a federal regulator/oversight body and you need to register with FinCEN, but that does not mean you have money transmitter licenses.

To obtain money transmitter licenses, you would need to apply for the same with all the individual US States.

Regarding your question, if your gift card is closed loop, then no license is required, however, if it is multipurpose and open-loop, then a money transmitter license is required.

If you would be loading Litecoins, that would deem it to be open-loop as Litecoins can be exchange for value-transfer, hence money transmitter licenses would be required.