Do gift card companies need a FinCEN money transmitter license for reloadable cards funded with cash?

Asked Aug 7, 2016· 1 answer ·United States
Faisal KhanAnswered Aug 7, 2016
First of all, FinCEN does not provide you with any money transmitter licenses. FinCEN is a federal regulator/oversight body and you need to register with FinCEN, but that does not mean you have money transmitter licenses.

To obtain money transmitter licenses, you would need to apply for the same with all the individual US States.

Regarding your question, if your gift card is closed loop, then no license is required, however, if it is multipurpose and open-loop, then a money transmitter license is required.

If you would be loading Litecoins, that would deem it to be open-loop as Litecoins can be exchange for value-transfer, hence money transmitter licenses would be required.
Related in US Money Transmitter Licensing and MSB Registration