You Move Money for Other Businesses. Someone Just Said Money Transmitter.
Your own licenses cost $250,000 and take up to two years. There is a second legal route: operate as an authorized delegate under licensed money transmitters, on a platform adapted to your flow of funds, with compliance running underneath. Live in weeks.
Who This Is For
Businesses that collect, hold or forward money for others, and discovered that this has a legal name.
Receivables & billing outsourcers
You invoice and collect on behalf of client businesses, hold the funds for a few days, and forward them net of your fee.
Payout & disbursement platforms
You pay contractors, vendors, sellers or claimants on a client's behalf from funds the client sends you first.
Vertical software that added payments
Rent, tuition, dues, bookings or marketplace sales flow through your platform before they reach the business that earned them.
Stablecoin payment companies
You move value for third parties across borders and settle on stablecoins. The rail does not change the licensing answer.
Payroll, escrow and holdback services
Funds sit with you between the payer and the person entitled to them, which is the definition regulators use.
Accounting practices that run collections
Bookkeeping and AR firms that moved from reconciling client money to actually receiving and remitting it.
Why the Question Came Up
The definition is broader than most founders expect, and the exemptions are narrower.
Under the Bank Secrecy Act, a money transmitter is any person that accepts currency, funds or value from one person and transmits it to another. It does not matter that both parties are businesses, that you charge a flat fee, that the funds only sit with you for three days, or that they move by ACH rather than across a border.
Most states offer an exemption for an agent of the payee: a business that collects on a payee's behalf under a written agreement, so that payment to the agent counts as payment to the payee. It is a real exemption and many models fit inside it. Many do not. Taking assignment of a receivable, collecting into an entity you own, netting your own fee from the funds, or holding money for your own account are the usual ways a model steps outside it, and the moment a bank's compliance team or a state examiner notices, the question becomes a letter.
The answer in that letter is binary: get licensed, or operate under someone who is. Federal law anticipates the second path. Under 31 CFR § 1022.380(a)(3), a business that is a money services business solely because it acts as the agent of another money services business is not required to register separately. That is the authorized delegate model, and it is the structure most money movement in the United States already runs on.
Operating as an unlicensed money transmitting business is a federal offence under 18 U.S.C. § 1960 and a state offence almost everywhere. If you are already moving funds for others, the exposure is current, not future. This page is general information, not legal advice; the right answer for your model comes from a review of your actual flow of funds.
Your Own Licenses vs. Operating Under Ours
Same business, same customers, same brand. A different route to being allowed to run it.
| Feature | Your own MTLs | Authorized delegate on Platly |
|---|---|---|
| Upfront licensing cost | $250,000+ | None |
| Time before you can operate compliantly | 12-24 months | Weeks |
| Surety bonds and net worth minimums | ||
| Write and audit your own AML program | ||
| State examinations and reporting | ||
| KYB, KYC and sanctions screening tooling | Build or buy | Included |
| ACH, card and wire collection | Build or buy | Included |
| Stablecoin settlement where it fits | Separate stack | Included |
| Platform adapted to your flow of funds | Your engineering | Ours, with you |
| Your brand, your pricing, your customers |
How It Works
Four steps from the first call to operating compliantly.
Step 1
Scope the flow
A 30-minute call to map who pays, who is paid, where funds rest, for how long, and in which states. Most flows are clear within the hour.
Step 2
Compliance review
Our compliance team and the licensing principal confirm whether your flow fits under the licenses and what the controls look like for your model.
Step 3
Adapt the platform
Collection methods, payout rails, settlement timing, FBO structure, reporting. We configure the platform around your flow rather than asking you to fit ours.
Step 4
Go live as an authorized delegate
You operate under the licenses with the compliance program running underneath. Weeks from the first call, not years.
What Runs Underneath
The licensing is the visible part. This is what makes a flow of funds operable.
The compliance program is described on our compliance page. If your model is consumer remittance at a counter rather than business payments, start with the money transmitter license page instead.
Questions Founders Ask
We just collect payments for our clients. Is that really money transmission?
What does operating as an authorized delegate mean?
Can any flow of funds be covered?
We settle on stablecoins. Does that change anything?
What stays our responsibility?
We already applied for our own licenses. Is this still relevant?
Scope Your Flow of Funds
A 30-minute call: who pays, who is paid, where the money rests, and whether the authorized delegate route fits your model. A straight answer either way.