Money Services FAQs

The Money Services Division issues two different license types for money service businesses:

Money Transmitter License: This license is required for any company or person engaging in the business of money transmission or advertising, soliciting, or holding itself out as providing money transmission. Money transmission means selling or issuing payment instruments or stored value, or receiving money or monetary value for transmission. Money transmission does not include the provision solely of delivery, online, or telecommunications services or network access.

Currency Exchange License: This license is required for any company or person engaging in the business of currency exchange or advertising, soliciting, or holding itself out as providing currency exchange for which the person receives revenues equal to or greater than five percent of total revenues. Currency exchange means receipt of revenues from the exchange of money of one government for money of another government.

Check Casher Licenses are issued by the South Carolina Board of Financial Institutions/Consumer Finance Division. 

Money service businesses are required to complete a license application through the Nationwide Multi-State Licensing system (“NMLS”). Requirements for each specific license type are provided in the License & Registration section of the NMLS.

The Money Services Division views virtual currencies as lacking the characteristics necessary to be a medium of exchange.  Therefore, it is the view of the Division that virtual currencies alone do not qualify as monetary value.  However, to the extent that virtual currency transactions also involve the transfer of fiat currency, they may be subject to money transmission regulation under the Act.  For more information, see the Division’s December 5, 2018 interpretation.pdf

For situations in which an automated machine, or ATM, is involved with the transfer of virtual currency, please see Order MSD-19003 (pdf) to assist in determining if a license would be required in South Carolina.

No. You will be considered an authorized delegate (agent) of the license holder. As an authorized delegate of a license holder, such as Western Union, you do not need a license from the Division for the activities covered by the authorized delegate agreement. The license holder is responsible for reporting all of its active authorized delegates to the Money Services Division on a quarterly basis.

However, if you are also offering other Division-regulated money services business activities not covered in your authorized delegate agreement with the license holder, you would need a license from the Division. For example, if in addition to being a Western Union agent you also offer currency exchange services on your own, you may also need a Currency Exchange License from the Money Services Division.

The amount of the required security must be the greater of $100,000 or an amount equal to one hundred percent (100%) of the licensee's average daily money transmission liability in this state calculated for the most recently completed calendar quarter, up to a maximum of eight hundred thousand dollars ($800,000).  The security can be in the form of a surety bond, letter of credit or other similar security in a form acceptable to the Commissioner.

See Section 35-11-215 for additional information about the required security.

Security is not required for currency exchange licenses.

Applicants must demonstrate compliance with Title 31 CFR Chapter X link to:  https://www.fincen.gov/resources/statutes-regulations/chapter-x regarding anti-money laundering programs and the registration of money service businesses. See FINCEN. https://www.fincen.gov/

To verify a money service business license, please refer to the NMLS Consumer Access Portal. https://www.nmlsconsumeraccess.org/

The Money Services Division does not issue license certificates or license numbers for money service businesses. The NMLS ID number assigned to your business will be the South Carolina license identifying number.

Yes. Within 45 days after the quarter has ended, the Money Services Division requires that each money transmitter licensee file the Money Services Call Report through the NMLS.

The Money Services Division also requires the money transmitter and currency exchange license holders to report all authorized delegate adjustments (additions, deletions, and modifications) within 45 days after the end of each quarter. The reports must be submitted through the Uniform Authorized Agent Reporting (UAAR) functionality in the NMLS system.

Requests for written interpretations shall be in writing.  The request must state or contain:

       (1) the specific section or subsection of the particular statute, regulation, or order to which the request pertains;

       (2) the names of each person and entity involved in the underlying facts;

       (3) a description of the particular situation at hand. Requests must not attempt to include every possible type of situation that may arise in the future. The facts and representations must be specific, not general, and contain all relevant facts;

       (4) an indication as to why the requesting party thinks a problem exists, the requesting party’s opinion on the matter, and the basis of the opinion, to include any relevant legal analysis; and

       (5) if the requesting party seeks confidential treatment, a specific request for confidential treatment and the basis for confidential treatment must be submitted with the request.

The Commissioner, in his discretion, may decline to issue orders when the requests do not meet the requirements listed above, or when there is deemed to be sufficient guidance existing on the issue at hand.