Stablecoins After the GENIUS Act, Part 3: Do You Still Need Money Transmitter Licenses?

The GENIUS Act’s stablecoin framework is prompting businesses to reassess whether state money transmitter licenses (MTLs) remain necessary, with Part 3 of Kelman Law’s guide examining the overlap between federal stablecoin rules and existing state licensing regimes. The analysis, written by Michael Handelsman, focuses on how the new federal regime may reduce or reshape MTL obligations for stablecoin issuers and intermediaries, though it stops short of declaring state licenses obsolete. It matters because MTLs are among the most costly and time-consuming compliance burdens for crypto firms operating across U.S. states, and clarity on their continued role could lower barriers to entry and change compliance budgets. The key question for firms is how state regulators will interpret the federal framework alongside their own statutes, and whether dual licensing persists in practice. Watch for state regulator guidance and any legislative adjustments as stablecoin issuers map federal permissions against state-by-state requirements.