You run an exchange serving the United States. Registration, staking treatment and transfer-information rules set the shape of your compliance year.
Information, not advice
This page is information, not legal advice about your matter. A retainer begins only when a lawyer confirms it.
Start here
Know which rules already apply to you, before you add anything new
Adding a service can change which state licences and federal registrations you need. Checking where you stand first is cheaper than unwinding it later.
What to work through, in order
Registration and licensing
Federal registration with FinCEN as a money services business, plus state-by-state money transmitter licensing, and a BitLicense for New York. Listing certain assets can additionally raise SEC or CFTC registration questions.
Staking, lending and yield
The SEC has treated retail lending and staking-as-a-service programmes as securities offerings in enforcement actions. Structure, custody arrangement and marketing all feed the analysis.
Transfer information and record keeping
The Bank Secrecy Act imposes the funds travel rule, recordkeeping and suspicious activity reporting on money services businesses, with OFAC sanctions screening running alongside.
Next steps
What happens if you go ahead
Scoping call
Written scope and fixed-fee quote
Engagement, once a lawyer confirms
Who would handle it
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San Francisco
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