How to Fill Out the Washington DFI Money Transmitter License Application + FAQs

The Washington money transmitter license is the state approval that lets your company legally move money, virtual currency, or stored value on behalf of other people, and you apply for it through the Nationwide Multistate Licensing System (NMLS) with the Washington State Department of Financial Institutions (DFI) as your reviewer. If your fintech, payments app, remittance shop, or crypto platform touches customer funds in transit, even for a moment, you likely need this license before you serve a single Washington customer.

This guide walks you through the 2025 New Application Checklist (with agency requirements last updated 5/23/2023), field by field, the way a compliance pro with 30 years of filings would explain it over coffee. Washington DFI does not issue a paper license, and it does not hand out approvals to anyone who looks unprepared, so getting each box right the first time matters. State data and industry guides put the typical approval window at roughly three to seven months, and the single biggest cause of delay is a sloppy or incomplete file, not a flaw in your business.

Here is what you will walk away knowing:

• 📋 Exactly what each NMLS field, document, and box asks for, in plain English.
• 💰 How to calculate your net worth and surety bond so you do not under-file and trigger a hold.
• 🧾 Which items go through NMLS and which must be emailed straight to your DFI reviewer.
• 🏦 How to prepare your business plan, flow of funds, and AML policy so reviewers say yes faster.
• ❓ Answers to the field-level questions that stall most first-time filers.

What the License Is and Who Must File It

The Washington money transmitter license is a state authorization issued under RCW Chapter 19.230, the state’s version of the Uniform Money Services Act. It covers any company that receives money or its equivalent value, including virtual currency, to transmit, deliver, or instruct to be delivered to another location, inside or outside the United States, by any means. The license also covers selling or issuing payment instruments like money orders and traveler’s checks, and currency exchange falls under the same license.

The agency that receives and reviews your application is the Washington State Department of Financial Institutions, and the law that requires it is RCW 19.230.030, which makes it illegal to transmit money in Washington without a license. The deadline that governs you is simple: you must hold the license before you handle a Washington customer’s funds, not after. The penalty for skipping this step can include enforcement action, fines, and a forced shutdown of your business in the state.

You must file if your product takes custody of or control over money or crypto on behalf of someone else. That sweeps in digital wallets, P2P payment apps, remittance services, custodial crypto exchanges, and prepaid or stored-value programs. A few things are not money transmission under RCW 19.230.010(18): internet connection or telecom services, reward-program points that cannot be cashed out, and value used only inside an online game with no outside use. Non-custodial wallet software that never controls user assets is generally treated differently, but the line is thin, so review your flow of funds before you assume you are exempt.

Before You Start: Documents and Information You Need

Washington expects you to arrive prepared, not to figure things out during review. Gather every item below before you open the application, because a missing piece almost always turns into a follow-up request that adds weeks to your timeline.

• Legal entity formation papers. You need a formed corporation or LLC. Without a valid entity, DFI has no licensee to approve, and the file stalls at the door.
• Washington Secretary of State registration. If you are not a sole proprietor, you must register with the Secretary of State, and out-of-state firms need a certificate of authority as a foreign entity. Skip this and your entity is not legally allowed to operate in the state.
• Washington business license and UBI number. The Department of Revenue Business Licensing Service issues these, and your Unified Business Identifier (UBI) number appears on the license. DFI asks for the UBI directly in NMLS, so you cannot finish the form without it.
• FinCEN MSB registration. You must register as a Money Services Business with the U.S. Treasury through FinCEN. You will enter the confirmation number and filing date in NMLS, so register first.
• Audited financial statements. Washington requires GAAP financials, audited by a CPA, plus the past two years and two-year projections. Many filings are delayed because founders underestimate how long an audit takes.
• Dedicated bank account. You need a business bank account in the applicant’s name used for money transmission. Finding a bank willing to serve a fintech or crypto model is often the hardest pre-step.
• Responsible Individual details. Have the résumé and ten-year work history ready for the W-2 employee who will run Washington compliance.
• Control person information. Every direct owner, indirect owner of 10% or more, and executive officer needs identity, credit, and fingerprint data for their MU2 forms.
• AML/BSA policy and risk assessment. A written program with a company risk assessment must exist before you apply, not after approval.

Where to Get the Form and How to Access It

There is no paper “form” to download and mail. The Washington money transmitter application lives entirely inside the Nationwide Multistate Licensing System, the online portal that Washington and most other states share. You create a company account, request the Washington Money Transmitter license authorization, and complete the electronic Company Form (MU1) plus an MU2 for each control person.

To start, set up your company record at the NMLS Resource Center, then add Washington and the Money Transmitter license type to your filing. The system walks you through company identity, ownership, control persons, and a long list of document uploads. Your roadmap for what to attach is the official Washington Money Transmitter New Application Checklist, which DFI maintains on the NMLS site and which you should keep open in a second tab the whole time.

You can reach Washington DFI’s non-mortgage licensing team at (360) 902-8703 or by email at CSLicensing@dfi.wa.gov if you get stuck on a Washington-specific item. Remember that DFI does not issue a paper license for this type; once approved, you receive a copy of your license by email, so keep that message in your permanent records.

Step-by-Step: How to Fill Out the Washington Money Transmitter Application Line by Line

The application is a set of NMLS fields plus required document uploads. Below, each major field or document gets its own walkthrough. Follow the order, and name each uploaded file exactly as the checklist tells you, because reviewers sort files by name and a misnamed document can look “missing.”

Company Identifying Information (MU1)

This is where you enter your company’s legal name, any DBA trade names, main address, entity type, and formation details. Enter your legal name exactly as it appears on your Secretary of State and Department of Revenue records, in the same capitalization and spelling, because DFI cross-checks these against state databases.

For example, BridgePay Holdings, LLC should be typed with the comma and “LLC” if that is how the state registered it, not as “BridgePay Holdings Inc.” A nuance many filers miss: if you use trade names, you must first register each DBA on your Washington business license, then list those same DBAs in NMLS. The most common mistake here is a name mismatch between NMLS, the Secretary of State, and the business license, which triggers a hold while DFI tries to confirm you are the same company. A frequent misconception is that NMLS “pulls” your legal name automatically; it does not, so you must verify every character yourself.

FinCEN Registration Number (Approvals and Designation)

This field asks for proof that you registered as a federal Money Services Business with FinCEN. You answer it by entering your MSB registration confirmation number and filing date on the FinCEN Registration line under Approvals and Designation in the MU1.

For example, Maria Lopez, founder of a remittance startup, enters her confirmation number and the date she filed, such as 31000012345678 filed 02/10/2026. The edge case to watch: if you registered but have not received a confirmation number yet, do not guess or leave it blank with a promise to update later, because DFI treats federal MSB status as a hard prerequisite. The common mistake is applying for the state license before completing the FinCEN registration, which means you cannot truthfully fill this field and your application is incomplete. A misconception is that state licensing replaces federal registration; in truth, you need both, and they run in parallel.

UBI Number (Other Approval/Designation)

This field captures your Washington Unified Business Identifier number, which proves you hold a state business license. You enter the UBI on the “Other Approval/Designation” line of the MU1.

For example, a fintech enters 601 234 567 exactly as printed on its Department of Revenue business license. The nuance: the UBI must belong to the same legal entity named in the application, not to a parent or affiliate, even if they share offices. The common mistake is entering a federal EIN here instead of the state UBI, which sends reviewers looking for a number that does not match Washington’s system. A widespread misconception is that the UBI and your IRS EIN are interchangeable; they are two separate numbers from two separate agencies, and DFI wants the state one.

Bank Account Information

This field identifies the bank account used for your money transmission activity. You enter the account details and confirm the account is in the name of the applicant, not a founder’s personal account or a related company.

For example, Marcus Lee of a digital wallet startup lists his company’s operating account at an insured bank held under the exact entity name on the application. The edge case applies to Third Party Account Administrators, who must use a dedicated account at an insured institution for creditor payments. The common mistake is listing a personal or pre-incorporation account, which signals weak fund segregation and invites extra questions. The misconception that trips people up is that any business account works; DFI wants the account that actually handles transmitted funds, in the licensee’s legal name.

Qualifying Individual / Responsible Individual

This field names the person with principal managerial authority over money services in Washington, entered in the Qualifying Individual section of the MU1. You enter the Responsible Individual (RI), who must be a U.S. citizen or have legal work status, hold W-2 employee status with the licensee, know the laws and rules, and be accountable for compliance.

For example, a startup names Janet Okafor, its Chief Compliance Officer, as the RI and uploads her résumé and ten-year work history. The edge case: if the RI is not a U.S. citizen, you must upload proof of the right to work, such as an Employment Authorization Document, Permanent Resident Card, or an H-1B, L-1B, or P visa, under Legal Name/Status Documentation. The common mistake is naming a contractor or an outside consultant who is not a W-2 employee, which fails the statute and forces you to re-designate. The misconception is that this can be a figurehead; DFI will actually contact this person for exams and compliance matters, so name someone who truly runs your program.

Credit Report Authorization

This field, completed inside each MU2, authorizes NMLS to pull a credit report on control persons. Washington requires credit reports for direct owners, indirect owners, and the Qualifying Individual, so each of those people authorizes the pull within their own MU2.

For example, David Chen, who owns 30% of a payments company, logs into his MU2 and completes the credit report authorization with his identity details. The edge case: if a control person has thin or no U.S. credit history because they recently moved to the country, expect to also provide the third-party investigative report described later. The common mistake is forgetting that an indirect owner of 10% or more also needs an MU2 with a credit pull, which leaves a control person undocumented. The misconception is that the company credit history covers individuals; Washington reviews each person separately.

Criminal Background Check (Fingerprints)

This field, also handled in the MU2, schedules and authorizes fingerprint-based criminal background checks for control persons. Each direct owner or executive officer, each indirect owner of 10% or more, and the Washington Responsible Individual must submit fingerprints through the NMLS process.

For example, Marcus Lee schedules a fingerprint appointment through the NMLS link and pays the processing cost as part of his MU2. The edge case: prior fingerprints on file from another state filing may be reused if still valid, which saves a step, but confirm before assuming. The common mistake is having only some owners complete fingerprints, leaving a 12% indirect owner unscreened, which stalls the whole file. The misconception is that a minor old offense automatically disqualifies you; DFI reviews context, but hiding it on the MU2 disclosure is what truly sinks an application.

AML/BSA Policy Upload

This upload is your written Anti-Money Laundering and Bank Secrecy Act program. You upload it under the AML/BSA Policy document type in the MU1, named in the format [Company Name] – AML Policy Internally Approved Date mm-dd-yyyy, and it must include a company risk assessment, either inside the policy or as a stand-alone document.

For example, a crypto exchange uploads CoinBridge Inc – AML Policy Internally Approved Date 01-15-2026 with a risk assessment that rates each risk area and lists mitigating steps. The edge case: include your independent review if you have one, which strengthens the file even though it is optional for new applicants. The common mistake is uploading a generic template with no real risk assessment, which signals you do not understand your own exposure and draws hard questions. The misconception is that AML is a post-license task; Washington wants a working program documented before approval.

Business Plan Upload

This upload is a full business plan, attached under the Business Plan document type and named [Company Legal Name] Business Plan. It must cover an executive summary, the products and services under the license, target markets and marketing strategy with a fee schedule, management and organization, an operational plan with a typical-transaction flowchart, and your method for tracking Washington business separately from other states.

For example, Maria Lopez writes a plan explaining her Mexico remittance corridors, her per-transfer fee schedule, and how her ledger tags Washington transactions for assessment and bond math. The edge case: if you already uploaded one plan that contains everything, do not upload a second; add Washington-specific detail to the single existing plan instead. The common mistake is leaving out the assessment-tracking method, which DFI needs to verify your surety and annual reporting numbers. The misconception is that a pitch deck counts; reviewers want an operational document, not investor marketing.

Document Samples Upload

This upload provides the customer-facing documents you use in the regular course of business. At minimum, upload sample money transmission receipts, and if you use independent authorized delegates, include a sample delegate contract plus a full description of how you screen delegates, including any forms and how you check criminal history.

For example, a wallet app uploads a sample receipt showing the amount sent, fees, exchange rate, and delivery details. The edge case: if you do not use delegates, you skip the delegate contract, but you still must provide receipts. The common mistake is uploading mock-ups that do not match how your product actually works, which reviewers will catch and push back on. The misconception is that receipts are trivial; Washington reads them to confirm you disclose fees, delays, and limits clearly to consumers.

Flow of Funds Structure Upload

This upload describes each transaction type step by step, from the customer’s first encounter to the moment money reaches the beneficiary, named simply Flow of Funds Structure. If you offer multiple transaction types, combine them into one document.

For example, Marcus Lee diagrams how a user loads funds, how the bank and processor hold them, and how a recipient withdraws, labeling each counterparty and the timing of each transfer. The edge case is crypto: if your platform initiates or directs money movement, even through an API, that changes how DFI treats your control over funds, so map it precisely. The common mistake is a vague one-line description, which makes DFI suspect you are hiding custody risk. The misconception is that reviewers know your infrastructure; assume they do not, and label every box in plain language.

Management Chart and Organizational Chart Uploads

These two uploads show who runs and who owns the company. The Management Chart, named [Company Legal Name] Management Chart, displays your divisions, directors, officers, and managers by individual name and title. The Organizational Chart/Description, named [Company Legal Name] Organizational Chart – Description, shows direct owners totaling 100%, indirect owners, and any subsidiaries and affiliates.

For example, a startup’s org chart shows David Chen at 30%, two co-founders at 35% each, and a parent holding company as an indirect owner. The edge case: if a single existing chart already includes everything, upload just one rather than duplicates. The common mistake is direct ownership that does not add up to exactly 100%, which is an instant red flag for reviewers. The misconception is that these charts are decorative; DFI uses them to decide who needs an MU2 and a background check.

Surety Bond (Submitted Through NMLS)

This item is your surety bond, calculated on your Washington money transmission and payment instrument dollar volume and submitted electronically through NMLS. The bond is $10,000 for every $1 million of Washington volume, with a minimum of $10,000 and a maximum of $550,000, per WAC 208-690-040.

For example, a new company with under $1 million in projected Washington volume posts the $10,000 minimum bond, while a firm doing $5 million posts $50,000. The edge case: brand-new firms with no prior-year volume still post the $10,000 minimum, then adjust later as real volume comes in. The common mistake is bonding on nationwide volume instead of Washington-only volume, which leads to the wrong number and a correction request. The misconception is that the bond is insurance for the company; it actually protects your customers and the state if you fail to meet obligations.

List of Countries and 12-Month Volume Statements

These two uploads, filed under the Additional Requirements section, give DFI your geographic and volume footprint. The List of Countries names every country you will transmit money to and from. The 12-Month Money Transmissions statement is a one-line dollar figure of total Washington money transmitted over the prior 12 months.

For example, Maria Lopez lists Mexico, Guatemala, and El Salvador and writes a single line such as Washington money transmission volume, prior 12 months: $0 (new entrant). The edge case: a brand-new business with no history writes $0 honestly rather than padding a projection into this field. The common mistake is confusing this prior-year actual figure with your two-year projection, which belongs in the business plan instead. The misconception is that “countries” means only destinations; Washington wants both where money goes and where it comes from.

Washington Licensing Declaration Form (Cybersecurity)

This upload is the Washington Licensing Declaration Form for money transmitters, where you attest you maintain a cybersecurity program under WAC 208-690-240 and 208-690-250. The program must protect your electronic systems and any sensitive data from unauthorized access, use, or tampering, and a parent or affiliate may run it as long as you adopt it and it is available for DFI review.

For example, a crypto firm signs the declaration confirming its information security plan is part of its books and records. The edge case: if a parent company runs your security program, state that clearly and confirm you adopted it. The common mistake is signing the attestation without an actual written plan behind it, which becomes a serious problem at exam time. The misconception is that cybersecurity is optional for small firms; the declaration is mandatory regardless of size.

Third Party Investigatory Background Checks (Emailed Directly to DFI)

This item applies only when a control person has not lived in the U.S. for at least five years before you apply. In that case, an acceptable search firm must prepare an investigative background report, and you email it directly to your DFI application reviewer, not through NMLS.

For example, if David Chen lived abroad until two years ago, you commission a report covering a comprehensive credit history, civil and bankruptcy court records for five years, and criminal records for five years across the countries and towns where he lived and worked. The edge case: this is in addition to the standard NMLS credit and fingerprint checks, not instead of them. The common mistake is uploading this report into NMLS, where it gets lost, instead of emailing it to your named reviewer. The misconception is that recent U.S. arrivals are exempt from scrutiny; in reality, they face more documentation, not less.

Application and Processing Fees

This is where you pay to file. The Washington application fee is $1,000.00, the NMLS processing fee is $120.00, and there is no separate license registration fee. If you report authorized agents at licensing, a $100.00 fee applies for each additional money-services location, capped at $5,000 per quarter.

For example, a single-location wallet startup pays $1,000 plus $120 and nothing more. The edge case: companies reporting more than 100 active agents later face a Uniform Authorized Agent Reporting fee of $0.25 per agent location, invoiced each November and capped at $25,000 a year. The common mistake is assuming the $1,000 fee is refundable if you withdraw; it is generally not. The misconception is that paying the fee guarantees approval; it only opens the review.

Three Filled-Out Examples Using Real Scenarios

Below are three common filers walked through the application. Each shows what that person enters in the key sections.

Scenario 1: Maria Lopez, a cross-border remittance startup sending to Latin America.

Form Section	What Maria Enters
Company legal name	RemesaYa, LLC, matched to her Secretary of State filing
FinCEN registration	Confirmation number plus filing date 02/10/2026
UBI number	601 234 567 from her Department of Revenue license
Qualifying Individual	Herself, as W-2 owner-operator with managerial authority
AML/BSA Policy	RemesaYa LLC – AML Policy Internally Approved Date 01-20-2026
Business Plan	Mexico, Guatemala, El Salvador corridors with fee schedule
List of Countries	Mexico, Guatemala, El Salvador (to and from)
Surety Bond	$10,000 minimum, new entrant with under $1M volume
Application Fee	$1,000 plus $120 NMLS processing

Scenario 2: Marcus Lee, a digital wallet and P2P payments app.

Form Section	What Marcus Enters
Company legal name	PayLoop Inc., exact match across all state records
Entity registration	Foreign entity certificate, since PayLoop is Delaware-based
Bank account	Company operating account in PayLoop Inc. name
Responsible Individual	Janet Okafor, CCO, W-2 employee, with résumé uploaded
Flow of Funds	Step-by-step load, hold, transfer, and withdraw diagram
Org chart	Direct owners totaling 100%, parent holding co. as indirect
Financial statements	CPA-audited GAAP statements plus two-year projections
Surety Bond	$50,000 on $5M projected Washington volume
Cybersecurity declaration	Signed, with information security plan on file

Scenario 3: CoinBridge, a custodial crypto exchange holding user wallets.

Form Section	What CoinBridge Enters
Company legal name	CoinBridge Inc., matched to state registration
Net worth	$100,000 minimum, triggered by holding customer wallets
Flow of Funds	Custody flow showing control of private keys and user funds
AML/BSA Policy	CoinBridge Inc – AML Policy Internally Approved Date 01-15-2026 with risk assessment
Control persons	MU2s with credit and fingerprints for each 10%+ owner
Third-party background	Investigative report emailed to reviewer for an overseas owner
List of Countries	All jurisdictions where users send and receive crypto value
Document samples	Sample receipts and risk disclosures for digital assets
Surety Bond	Volume-based, submitted electronically through NMLS

How to File the Completed Form

Washington runs this license almost entirely through one channel, with a few items going straight to DFI. Know which is which before you submit.

• NMLS portal (primary channel). Submit the MU1, every MU2, all document uploads, the surety bond, and your fees through the NMLS Resource Center. Pay the $1,000 application fee and $120 processing fee by the accepted electronic payment methods inside NMLS. Expect a review window of roughly three to seven months. Your proof of filing is the NMLS submission confirmation and your filing record, which you should download and save.
• Direct email to DFI. The third-party investigative background report (for control persons with under five years of U.S. residency) goes by email to your assigned application reviewer, not through NMLS. Keep the sent email and any reviewer reply as your proof.
• Outside-NMLS reports after licensing. The Money Transmitter Annual Assessment is filed outside NMLS per the checklist, so calendar it separately once you are licensed.

For Washington-specific questions during filing, contact DFI’s non-mortgage licensing team at (360) 902-8703 or CSLicensing@dfi.wa.gov, and keep a written record of any guidance they give you.

What Happens After You File

Once your application is in, DFI reviews every form, document, and disclosure, and the agency often sends follow-up requests for anything that looks incomplete or unclear. Respond fast and completely, because each open item pauses the clock and most of the total timeline is spent waiting on applicant replies, not on DFI.

When DFI is satisfied, the license is issued under RCW 19.230.070, and because Washington issues no paper license for this type, you receive your license copy by email. Save that email permanently, since it is your official record of authority. From that point you may legally transmit money for Washington customers within the scope you described.

Approval is the start of an ongoing relationship, not the finish line. You must renew each year through the NMLS renewal cycle (typically November through December), file annual reports including transmission volume data, keep your AML and cybersecurity programs running, retain records for at least five years, and report material changes in ownership or business model. DFI also conducts periodic exams, which may be document-based or onsite.

Mistakes to Avoid When Filling Out the Form

• Name mismatch across records. A legal name that differs between NMLS, the Secretary of State, and the business license triggers a hold while DFI confirms your identity.
• Skipping FinCEN registration first. Without an MSB confirmation number, you cannot truthfully complete the Approvals field, and your application is incomplete.
• Entering an EIN instead of a UBI. This sends reviewers searching for a number that does not exist in Washington’s system.
• Naming a non-employee as Responsible Individual. A contractor fails the W-2 requirement and forces you to re-designate, costing weeks.
• Bonding on nationwide volume. Using total U.S. volume instead of Washington-only volume produces the wrong bond amount and a correction request.
• Uploading a generic AML template. A policy with no real risk assessment signals you do not understand your exposure and invites deep scrutiny.
• Ownership that does not total 100%. Direct ownership percentages that miss 100% are an instant red flag on your org chart.
• Forgetting an indirect owner’s MU2. Leaving a 10%-plus owner unscreened stalls the entire file until they complete background checks.
• Vague flow of funds. A one-line description makes DFI suspect hidden custody risk and almost guarantees follow-up questions.
• Misnaming uploaded files. A document that does not follow the required naming format can look “missing” to a reviewer sorting by file name.
• Mailing the background report into NMLS. The third-party investigative report must be emailed to your reviewer, or it gets lost.
• Underestimating the audit. Booking a CPA audit late is one of the most common reasons applications sit unfinished for months.

Do’s and Don’ts

Do:

• Do open the official checklist in a second tab and check off every item as you go, because reviewers expect each one.
• Do register with FinCEN and the Department of Revenue before you start NMLS, since you need those numbers to finish.
• Do name a real, qualified W-2 Responsible Individual, because DFI will actually contact this person.
• Do calculate your bond and net worth on Washington-only volume, since that is the figure the statute uses.
• Do label every uploaded file in the exact format the checklist requires, so nothing reads as missing.
• Do respond to DFI follow-up requests within days, because open items freeze your timeline.

Don’t:

• Don’t transmit money for Washington customers before approval, because operating unlicensed invites fines and shutdown.
• Don’t pad your prior-year volume figure, since DFI verifies it against your financials.
• Don’t upload a pitch deck in place of a real business plan, because reviewers want operational detail.
• Don’t assume crypto is a gray area, since Washington regulates digital value like any other money.
• Don’t hide a control person’s old offense on the MU2, because the nondisclosure is worse than the offense.
• Don’t treat AML and cybersecurity as post-license tasks, since both must exist before approval.

Pros and Cons of Filing on Your Own vs. With Help

Filing on Your Own	Filing With a Compliance Pro or Attorney
Saves consultant fees, which matters for a bootstrapped startup	Costs more upfront, but often pays back in a faster, cleaner approval
You learn your own compliance program deeply, useful at exam time	An expert spots custody and flow-of-funds risks you might miss
Full control over timing and document choices	Templates and prior filings speed up your AML policy and business plan
No risk of a consultant misreading your unique model	Reduced risk of the small naming and math errors that cause holds
Direct relationship with your DFI reviewer from day one	Help managing multi-state filings if you expand beyond Washington

The right choice depends on your model’s complexity. A simple single-state remittance shop can often self-file with care, while a custodial crypto platform with overseas owners usually benefits from expert help, because the custody analysis and investigative background reports are where solo filers most often stumble.

FAQs

Do I need a Washington money transmitter license to handle crypto?

Yes. Washington treats virtual currency like any other monetary value, so custodial wallets, crypto-to-fiat conversion, and digital asset custody all require the license under RCW 19.230.

Is there a separate license for currency exchange?

No. Currency exchange is included within the Washington money transmitter license, so a single application under this license type covers both activities.

Do I enter my EIN or my UBI in the “Other Approval/Designation” field?

No to the EIN. You enter your Washington Unified Business Identifier (UBI) number from your Department of Revenue business license, not your federal IRS EIN.

Can my Responsible Individual be an outside consultant?

No. The Responsible Individual must hold W-2 employee status with the licensee and have principal managerial authority over money services in Washington.

Should the surety bond be based on my nationwide volume?

No. The bond is calculated on your Washington-only money transmission and payment instrument volume, at $10,000 per $1 million, with a $10,000 minimum and $550,000 maximum.

Do I write my prior-year volume or my projection in the 12-Month statement?

No projection here. The 12-Month Money Transmissions statement is your actual prior-year Washington figure; projections go in the business plan instead.

Is the AML policy required before I get the license?

Yes. You must upload a written AML/BSA policy with a company risk assessment as part of the application, not after approval.

Does every owner need a background check?

Yes. Direct owners, executive officers, indirect owners of 10% or more, and the Washington Responsible Individual all need credit and fingerprint checks via their MU2.

Do I upload the third-party investigative background report into NMLS?

No. That report is emailed directly to your DFI application reviewer, separate from the standard NMLS credit and fingerprint checks.

Is the higher net worth requirement only for crypto custody?

Yes. Virtual currency companies holding wallets for clients must maintain a $100,000 minimum tangible net worth, versus the $10,000 minimum for others.

Will I receive a paper license once approved?

No. Washington DFI does not issue paper licenses for this type; you receive a copy of your license by email after approval.

Is the $1,000 application fee refundable if I withdraw?

No. The application fee is generally not refundable, so make sure your file is complete and your model truly needs the license before you submit.

Do I have to register with FinCEN even if I have the state license?

Yes. Federal MSB registration with FinCEN runs in parallel with state licensing, and you must enter your FinCEN confirmation number in the application.

Does a non-custodial crypto wallet need this license?

No in most cases. Non-custodial software that never controls user assets is generally treated differently, but review your flow of funds carefully before assuming you are exempt.