Is a license required to operate crypto-related services in the US?

Disclaimer: I am not a lawyer. I'm going to give you my opinion of what I think is correct.

So if you are doing a crypto to crypto play in the US, no license is required, provided you do not touch the US dollar or you do not touch any other fiat or other asset that is issued by a government or an entity like that. I cannot comment regarding anything to do with SEC or FINRA etc. So I'm only going to talk about money transmission law, but specifically from what my understanding is, if you're doing crypto to crypto if you want to launch a wallet service, for example, and you're not touching any fiat and it's pure crypto play, no license is required.

There is a caveat to the statement though, you would be required to have compliance in place. You would be required to have something like the FATF travel rule in place, you would be required to have you know the policies and procedures because it is invariably something that would be licensed down the line or if your system is somehow compromised or involved in an illegal transaction, law enforcement agencies will come and ask you to show you know certain transaction etc. and you would have to comply going forward.

Right now, the US states are not requiring licenses, but I think going forward it is in variable inevitable rather that you know wallets would be licensed in some manner whatsoever. They would have some sort of a regulatory oversight to them, and you would have to abide by them.

It is widely expected that by fall 2022, the United States would be releasing its crypto guidelines that would most likely include licensing.