Exchanges, Custody & Licensing
Exchange, custody and licensing counsel.
Legal counsel for platforms that hold, move or trade digital assets for customers.
What We Do
For platforms that hold customer assets.
- Licensing roadmaps — FinCEN money services business registration, state money-transmitter licenses and New York’s BitLicense.
- Custody model review — self-custody and third-party custody models, key management, asset segregation and customer terms.
- Compliance programs — BSA/AML, customer identification, sanctions screening and Travel Rule processes.
- EU and UK tax reporting — DAC8 and CARF scope analysis, registration and customer due diligence for platforms with European customers. See our DAC8 and CARF compliance counsel.
- Customer terms and disclosures — account terms, risk disclosures and complaint handling.
- Counterparty agreements — banks, liquidity providers, custodians and technology vendors.
- Regulator inquiries and examinations — responding to information requests and preparing for examinations.
The Landscape
Licensing follows the activity.
Platforms that hold or move customer assets often need registration and licenses at more than one level before they serve customers.
- Federal — money transmitters that handle convertible virtual currency generally must register with FinCEN as money services businesses.
- State — state money-transmitter laws can apply, and New York regulates virtual-currency business activity under its BitLicense regime (23 NYCRR Part 200).
- International — in the European Union, crypto-asset service providers are authorized under MiCA, and transfers are subject to the EU’s Transfer of Funds Regulation.
Who It’s For
Built for platforms in the flow of funds.
- Exchanges and brokers — centralized trading platforms and brokerage services.
- Wallets and custodians — custody providers and wallet services that control customer assets.
- On- and off-ramps — payment and conversion platforms between fiat and digital assets.
- Fintechs adding crypto — existing financial products introducing digital-asset features.
When to Call
- Before you hold customer assets — custody choices drive licensing and compliance obligations.
- Before you serve New York residents — where state licensing can apply.
- Before entering new states or the EU — to map registrations and authorizations.
- When a regulator or bank partner asks — for licensing analysis or compliance documentation.
Next Step
Two ways to start.
Want a written assessment first?
The Launch Readiness Assessment is a fixed-scope review with a written Launch Risk Map, a preliminary view on the questions that decide your launch, and a 30-Day Legal Action Plan, offered after your consultation.
See the Assessment →This page is general information, not legal advice, and does not create an attorney–client relationship.