

As an example, writing software that allows customers to self-custody Virtual Currency in a wallet would not, in and of itself, require a BitLicense. However, building a wallet service in which you kept custody of other people’s funds on their behalf likely would require a BitLicense.
If you are unable to find the answer to your questions on this website, call the Research and Innovation unit at (212) 709-3812 or contact DFS or NMLS as follows: