Krowne Law
FinTech compliance, money services and VASP/crypto-asset licensing, and AML advisory — built for founders who are scaling into a regulated business.
FinTech & AML Advisory ServicesThe Challenge
Regulatory expectations are rising — your headcount isn’t.
Not every FinTech requires a full-time Chief Compliance Officer — but nearly every growing FinTech needs effective compliance leadership, the right government licenses, and a defensible AML program. There is a real gap between “someone should own this” and “we’re ready for a $250K+ executive hire.”
In the meantime, regulators remain active, audits continue, and risk does not decrease.
Krowne Law was built to close that gap. We combine hands-on FinTech compliance leadership, multi-jurisdictional licensing expertise, and business-oriented legal counsel — all under the protection of attorney-client privilege. Our clients include FinTechs, payment companies, cryptocurrency exchanges, custody providers, MSBs, and blockchain platforms navigating U.S. federal and state and foreign regulatory regimes.
Senior compliance leadership, state-by-state licensing, and ad hoc AML counsel — scaled to match where your business actually is today.
Our Three Core Service Areas
Whether you need embedded compliance leadership, a path to state or federal licensure, or a seasoned advisor on a specific AML question, our offerings fall into three major areas—and scale as your business grows:
1) FinTech Compliance‑as‑a‑Service
Subscription-based, fractional compliance leadership for FinTechs that need senior oversight without a full-time executive hire. Fractional CCO, board reporting, exam preparation, policy suites, TPRM, and specialized program build-outs.
2) License Acquisition Services
End-to-end support obtaining state Money Transmitter Licenses (MTLs), virtual currency / BitLicense-type authorizations, MSB registration, and other state and federal FinTech license regimes — across all 50 states, D.C., and U.S. territories.
3) AML Advisory
Ad hoc AML and FinTech regulatory counsel on the issues that land on your desk — BSA/AML questions, KYC and sanctions calls, SAR reviews, remediation planning, regulator responses, and strategic analysis on new products and jurisdictions.
Pillar 01
FinTech Compliance‑as‑a‑Service
Scalable, high-level expertise providing strategic leadership and daily operational compliance support—on a subscription basis. We give growing FinTechs experienced compliance oversight without the burden of permanent executive staffing costs, ensuring the right structure, accountability, and alignment with your current stage.
Fractional CCO
Expert CCO leadership on a subscription basis, providing strategic guidance and compliance oversight — with optional regulatory reporting officer (e.g., FinCEN) appointments, without the full-time commitment.
Strategic Planning
Development and implementation of long-term compliance strategies aligned with your business objectives and the regulatory requirements applicable to your license footprint.
Board Reporting & Oversight
Comprehensive compliance reporting and board-level presentations that ensure proper governance, escalation, and regulatory alignment at the highest level of the company.
Exam Preparation
Proactive regulatory exam simulations and strategic advisory to fortify institutional readiness, manage examiner expectations, and help avoid 11th-hour findings during state or federal examinations.
Custom Policy & Procedure Suites
Generalized or bespoke governance documentation tailored to your specific risk profile — translating regulatory requirements into actionable, defensible internal controls.
Communications Review
Thorough review of customer communications and marketing materials to ensure regulatory compliance, consistent disclosures, and risk mitigation before anything goes out the door.
Third-Party Risk Management
Design and implementation of compliance-centric TPRM frameworks aligned with FFIEC guidance, including the governance, risk-tiering, and due-diligence standards regulators expect.
Complaint Management
Review, enhance, or build from the ground up a comprehensive complaint and dispute investigation and reporting process aligned to CFPB, state, and card-network expectations.
Specialized Projects
Targeted, high-impact consulting to build, refine, or transform foundational compliance infrastructure and governance frameworks — including remediation of exam or enforcement findings.
Pillar 02
License Acquisition
Services
State-level authorization for transmitting money or monetary value — including payments, fund transfers, crypto exchange and custody, and stored-value products — is required in most U.S. states and territories, on top of FinCEN MSB registration at the federal level. Now, with the GENIUS Act (and soon, the Clarity Act), crypto-asset licensing regimes have arrived in the U.S. at the national level. Moreover, foreign VASP or DASP regimes are often applicable to enterprises operating with a cross-border scope. Legal definitions are often broader than founders realize, and they vary state to state, between states and the federal government, and among foreign jurisdictions.
We run the full license lifecycle for FinTechs, payment companies, crypto brokers / OTC desks, exchanges, custodians and other VASPs, BTM / crypto-ATM operators, stored-value issuers, and other MSBs — from initial applicability analysis through multi-state and jurisdictional filings, regulator engagement, and ongoing post-licensure compliance.
Our Licensing Approach
In-depth knowledge across all 50 U.S. states plus territories, the federal government, and certain foreign jurisdictions (e.g., the Cayman Islands VASP and AMLRO regimes)—delivered as a consistent, efficient multi-jurisdictional licensing strategy rather than a string of one-off applications:
Applicability Assessment
Detailed analysis of your business model to determine whether (and where) MTL, virtual currency, MSB, VASP/DASP or other FinTech licensing obligations apply. We identify applicable jurisdictions, available exemptions, and sector-specific considerations.
Application Preparation & Submission
Prepare and submit all required documents, including NMLS filings, business plans, AML programs, policies, financial statements, and surety bond coordination. We manage the file, the deadlines, and the deliverables.
Multi-State Licensing Strategy
Sequenced, jurisdiction-aware go-to-market plans — including go / no-go state/jurisdiction grids — tuned to your net-worth, surety-bond, transaction-volume capacity, and transaction type—revisited as you scale.
Regulator Engagement
We coordinate directly with state & national banking and financial regulators, respond to requests for additional information, and manage correspondence so you’re not reacting to regulator emails in the middle of a product sprint.
Ongoing Compliance & Renewals
License renewals, regulatory-update monitoring, AML and KYC program guidance, and compliance audits — leveraging our regulator relationships and business-oriented approach.
Covered License Regimes
State Money Transmitter Licenses (MTLs), state and national virtual currency/crypto-asset licenses (e.g. NY “BitLicense,” CA DAFL, U.S. GENIUS/Clarity Acts, and foreign VASP/DASP Acts ), MSB / FinCEN registration, state lending and sales-finance licenses, and related FinTech authorizations.
What to Expect — Licensing Engagement
A structured path from first conversation to post-licensure
Our licensing engagements follow a consistent five-step arc. Scope varies by state footprint and business model, but the shape of the work does not.
Initial Consultation
We assess your business activities, license triggers, and regulatory exposure.
Tailored Compliance Plan
Jurisdiction-specific MTL / VCL strategy, including go / no-go state grid.
Application Support
We prepare, review, and submit all necessary filings and supporting documents.
Regulator Engagement
We liaise with state agencies to manage correspondence and resolve issues.
Post-Licensing Compliance
Ongoing legal support as regulations evolve — renewals, audits, and change-in-control filings.
Common Licensing Questions
A few of the questions we field most often from founders and GCs beginning to map a U.S. licensing strategy.
Do I need an MTL in the U.S. if I only work with cryptocurrency?
Likely yes. Many states treat virtual-currency activities as equivalent to money transmission, and some (like New York, California and Illinois) impose a dedicated virtual-currency regime on top. Each state’s rules differ—legal review is essential.
How long does it take to get an MTL or crypto-asset license?
Typically 3–12 months per state or other jurisdiction, depending on complexity, financials, and regulator workload. A phased multi-state strategy almost always outperforms a large number of simultaneous, uncoordinated filings (potentially up to 50+, for U.S. MTLs alone).
What financial requirements should I expect?
State and federal/national governments typically require minimum net worth and surety bonds, ranging from roughly $10,000 to well over $1 million depending on state/jurisdiction, transaction volume, transaction/relationship types, and risk profile.
Can I operate nationally in the U.S. with just one license?
No. Money transmission and crypto-asset transactions are primarily regulated at the state level (with the exception of the GENIUS Act for stablecoin issuers, and the upcoming Clarity Act for crypto custodial exchanges). Serving customers across the U.S. generally requires a coordinated portfolio of licenses—and/or a well-defined state-by-state go / no-go entry grid.
Pillar 03
AML Advisory
Sometimes you don’t need a program build—you need a seasoned second pair of eyes on the specific question in front of you today. Our ad hoc AML and FinTech regulatory advisory is designed for exactly those moments: a new product, an unusual customer, a sanctions hit, an examiner’s information request, or a board member’s pointed question. Coverage includes (but by no means is limited to):
- State, federal and international license-acquisition strategy
- BSA / AML applicability and program gap reviews
- KYC, CIP, and enhanced due diligence (EDD) questions
- OFAC and sanctions screening calls & escalation
- Transaction monitoring rule design and tuning input
- SAR & and other AML reporting quality review and narrative support
- Regulator letters, MRA / MRIA responses, and remediation plans
- New product / new market risk reviews
- Expert witness and internal investigation support
Who We Are
Krowne Law pairs technology-focused regulatory counsel with senior financial-crime compliance leadership — the combination growing FinTechs actually need. Our leads are:
Aaron Krowne
Principal Attorney, Krowne Law
Aaron is a technology-focused business and regulatory attorney advising startups, FinTech companies, and emerging-technology enterprises at the intersection of law, finance, and innovation. His practice concentrates on blockchain and digital-asset regulation, corporate finance, intellectual property, privacy and data security, and complex transactional matters.
Drawing on an earlier career as a research data scientist, software developer, and serial entrepreneur, Aaron brings practical technical fluency to engagements involving cryptocurrency infrastructure, token offerings, money-transmission and AML compliance, capital formation, and startup governance. He was an early adopter of blockchain technology, developed legal expertise shortly after the emergence of Bitcoin, and contributed to foundational intellectual-property and online-speech precedents prior to entering legal practice.
Admitted in New York, Aaron holds degrees in law, computer science, and mathematics, and is known for delivering business-oriented counsel that aligns regulatory compliance, innovation, and commercial execution for technology-driven organizations.
Scott Benson
AML & Compliance Executive | Regulatory Advisor
Scott is a senior financial-crime compliance executive and regulatory advisor with more than two decades of experience building, scaling, and remediating Anti-Money Laundering (AML), sanctions, and risk-management programs across banking, broker-dealer, payments, FinTech, and digital-asset environments.
He specializes in designing risk-based compliance frameworks aligned with the U.S. Bank Secrecy Act and global regulatory expectations, with deep expertise in KYC/CIP, enhanced due diligence, transaction monitoring, OFAC compliance, suspicious activity reporting, licensing readiness, and regulatory remediation.
Throughout leadership roles supporting both established financial institutions and high-growth FinTech platforms, Scott has guided organizations through examinations, enforcement actions, and rapid expansion — advising executive teams on governance, operational scalability, and compliance program maturity to enable sustainable innovation within complex regulatory landscapes.
Why Krowne Law
Six reasons founders trust us with the hardest compliance work
Regulatory Relationships
Established working relationships with state regulators that smooth the licensing and approval process, reducing friction and avoidable delays.
A Legal Privilege Shield
Advice provided under our engagement is protected by attorney-client privilege—limiting what regulators and civil litigants can compel you to disclose.
Peace of Mind
Focus on your core business knowing that your legal and compliance obligations are being handled by experienced, accountable experts.
Risk Mitigation
Avoid fines, penalties, and reputational damage by maintaining a defensible posture against applicable BSA/AML, state MT, and consumer-protection obligations.
Efficiency
Accelerate your program and licensing roadmap by avoiding common pitfalls and retread work, optimizing your regulatory posture engagement by engagement.
Strategic Growth
Business-oriented legal advice that aligns compliance with your broader operational and growth objectives — not against them.