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NH money transmission remains governed by RSA 399-G, administered by the NH Banking Department via NMLS. HB 1207 (signed 2026-07-10) amends RSA 399-G's fee, renewal and authorised-delegate certificate-of-authority provisions, with staggered effective dates of 2027-07-01 and 2027-10-01.
The statute draws a firm bank/nonbank line: charterees of banks, trusts, savings and loan associations, credit unions, thrifts, and insurance companies, together with government agencies, are exempt from NH money-transmitter licensing altogether. Nonbank licensees, by contrast, must post a surety bond equal to the greater of $100,000 or 100% of their average daily transmission liability over the trailing three months, capped at $500,000 -- a graduated, scale-sensitive safeguarding mechanism that rises with a licensee's outstanding-obligation exposure rather than applying a flat requirement.
Taken together, the October 2024 reenactment and the bonding structure position New Hampshire as an actively maintained, NMLS-integrated licensing jurisdiction rather than a legacy statute left to atrophy. The bank-charter exemption is unambiguous and does not extend, on its face, to virtual-currency-only activity that converts to fiat (see W2), a distinction the Banking Department has since enforced directly (see W7).
Outlook
Watch for further NMLS-driven procedural updates flowing from the HB 1241 modernization, and for whether the Banking Department extends its 24-month examination cadence to newly licensed entrants given the enforcement activity documented elsewhere in this baseline (RAM Payment, River Financial). No further legislative amendments to RSA 399-G's licensing core are currently flagged in the regulatory horizon.
Licensing, Authorisation & Market Access
New Hampshire's money-transmitter regime under RSA 399-G saw an administrative reporting update effective 1 October 2026, enacted through 2026 session law chapter 294. RSA 399-G:15(II)(d), the provision requiring periodic reporting of average daily outstanding transmission liability, was repealed. At the same time, RSA 399-G:18(III) was tightened to require a licensee or applicant to file a correcting amendment within 30 days of discovering that previously filed information was inaccurate or incomplete. Neither change alters who must be licensed, what activities require licensure, or the licence application process itself; both are adjustments to the content and accuracy standard of ongoing regulatory reporting for existing and prospective licensees.
HB1207, a 2026-session bill requested by the New Hampshire Banking Department, is the probable legislative vehicle for these amendments. The bill would also raise licence application and renewal fees for money-transmitter and other consumer-credit licensees. This chapter-to-bill mapping has not been independently confirmed against the enrolled act text this period, so the fee-increase component in particular should be treated as plausible but unverified pending confirmation. The substantive licensing framework established by 2024's HB1241 modernisation remains the governing structure into which this period's reporting amendments and possible fee changes are layered.
Outlook
Confirming the enrolled-act chapter-to-bill mapping — specifically, whether HB1207 is in fact the vehicle for chapter 294, and whether its fee increases were enacted alongside the reporting changes — is the key open item. Market participants maintaining or applying for an NH money-transmitter licence should watch for a revised fee schedule as the practical, bottom-line consequence of this period's legislative activity.
2 earlier distinct update(s)
Licensing, Authorisation & Market Access
New Hampshire's money-transmitter licensing regime tightened materially this cycle for mixed fiat/crypto operators. The New Hampshire Banking Department issued an Order to Show Cause on May 27, 2025 against BAM Trading Services Inc. (Binance.US), seeking revocation of its money-transmitter licence. The action is grounded in the federal Bank Secrecy Act guilty plea of the licensee's controlling indirect owner, who holds approximately 80 percent indirect ownership, for willfully causing the broader Binance enterprise to fail to maintain an effective anti-money-laundering program. This is a direct exercise of the state's licensing-authority revocation power against an existing, previously-authorised market participant, not a new-entrant screening decision.
The timing of this enforcement action coincides with a separate structural change to the licensing statute itself: a transition provision within RSA 399-G that had shielded existing money-transmitter licensees from newer or conflicting provisions expired on January 1, 2026. With that protection sunset, every existing licensee, including BAM Trading Services, is now fully subject to current revocation standards and compliance expectations without the benefit of grandfathered treatment. The practical effect is that the regulatory bar for maintaining a New Hampshire money-transmitter licence has risen for the state's existing licensee population at precisely the moment one of that population's members faces an active revocation proceeding.
For market access purposes, this signals a jurisdiction where the licensing authority is both willing and evidently able to pursue revocation against a licensee with international scale and a federal enforcement history, and where the statutory protections that might have delayed or complicated such action have themselves expired. A prospective mixed fiat/crypto money-transmission business evaluating New Hampshire as an operating jurisdiction should treat the currently pending BAM Trading matter, and its still-unretrieved September 2025 docketed follow-on order, as a live indicator of how the post-sunset standard will be applied in practice, rather than treating RSA 399-G as a static compliance target.
Outlook
The resolution of the BAM Trading Services Order to Show Cause, including the substantive disposition of its September 9, 2025 docketed follow-on order, is the key near-term signal for this module. A full revocation would demonstrate that the post-sunset standard is being applied with maximum severity, while a negotiated consent outcome, comparable to the $60,000 civil-penalty and wind-down arrangement Connecticut's Department of Banking reached with the same corporate family, would suggest a more calibrated enforcement approach. Either outcome will shape how other mixed fiat/crypto money-transmission businesses assess New Hampshire's licensing-authority posture going forward.
Licensing, Authorisation & Market Access
New Hampshire's money-transmitter licensing perimeter moved in two directions simultaneously this cycle, both changes anchored to RSA 399-G. First, the transition-period shield under RSA 399-G:39, which had allowed previously-licensed money transmitters to continue operating under prior compliance terms during a grace period, expired January 1, 2026. Licensees must now demonstrate full compliance with the current text of RSA 399-G without that grace period, a tightening of the conventional money-transmission licensing environment that applies across the state's existing licensee population.
Second, and in the opposite direction, HB639, enacted as Chapter 286 of the 2026 session with main provisions effective September 8, 2026, exempts home and business digital-asset mining, node operation, and staking from RSA 399-G money-transmitter licensing entirely. This is confirmed by a Tier-1 legislative record establishing the enactment and effective date. The carve-out narrows the population of activities requiring a money-transmitter license precisely as the compliance bar for the remaining licensed population rises, producing a bifurcated regulatory posture within a single statute: tightening for conventional non-bank payment institutions and electronic-money issuers, liberalising for blockchain infrastructure participants.
Supervisory practice around the licensed population continues under an established cadence: the New Hampshire Banking Department requires money-transmitter licensees to be examined at least every 24 months, a standing baseline confirmed directly by the regulator and unaffected by either this cycle's tightening or liberalising development. The distinction between bank and non-bank market access is material here, since RSA 399-G's licensing perimeter applies to non-bank payment institutions and electronic-money issuers rather than to bank-chartered entities, which access the payments system through separate prudential channels untouched by this cycle's developments.
Outlook
The key event to watch is HB639's September 8, 2026 commencement, at which point the crypto carve-out becomes fully operative alongside the already-tightened conventional-licensee compliance requirement. Whether the New Hampshire Banking Department issues supervisory guidance clarifying the boundary between exempt crypto-infrastructure activity and activity still requiring licensure, particularly for hybrid business models combining node operation with other money-transmission functions, would be the clearest indicator of how administrable the bifurcated regime proves in practice.
Sources and findings (7)
- T1https://www.banking.nh.gov/consumer-credit-licensees-registrants/money-transmitters
- T1https://www.banking.nh.gov/news-and-media/new-hampshire-banking-department-announcement-regarding-hb-1241-relating-moneyretrieved
- T1https://gc.nh.gov/rsa/html/xxxvi/399-g/399-g-mrg.htmretrieved
- T1https://gc.nh.gov/rsa/html/xxxvi/399-g/399-g-mrg.htmretrieved
- T2https://legiscan.com/NH/text/HB1241/id/2868262retrieved
- T3https://moneytransmitterlaw.com/cryptocurrency-state-laws/new-hampshire/retrieved
- T1https://www.banking.nh.gov/about-usretrieved