What type of license is required if acting as an intermediary in an FX transaction between two parties?
1 Answer
Faisal Khan
Answered 18/Dec/2025
Yes, you would need a money transmitter license. This requirement arises because you are acting as a financial intermediary between Party A and Party B. Under federal law—and likely state laws as well—this classifies you as a money services business (MSB).
Furthermore, you would need a money transmitter license (MTL) in every state where Party A and Party B are located or where the transaction is facilitated. There is no separate "escrow license" in the traditional sense. Instead, escrow is simply one of the functions that a licensed money transmitter can perform.
By holding a money transmitter license, you are legally permitted to insert yourself into the flow of funds, take custody of those funds, and facilitate transactions between parties. This intermediary role is precisely why regulatory compliance, including proper licensing, is required.