California DFAL is now in force
The July 1 deadline has passed and DFPI can assess civil penalties of up to $100,000 per day for unlicensed digital financial asset activity. Whether your application is under review, you've paused California, or you're re-checking whether DFAL applies to you at all, Brico gets you to licensed and keeps you there.
DFAL isn't a rebrand of the Money Transmission Act
DFAL creates an entirely separate licensing regime for anyone who exchanges, transfers, custodies, or issues redeemable digital assets for California residents. It has its own capital requirements, custody rules, consumer disclosure obligations, and examination authority.
A few things that trip companies up:
"We're non-custodial, so we're out of scope."
Not necessarily. DFAL's definitions include activity conducted through control-services vendors. You'll want to map exactly who has control at each step in your flow before assuming you're exempt.
"We'll file when we get to it."
The DFPI's proposed rules tie the transition safe harbor to a completed application, not a placeholder. An incomplete filing doesn't preserve your ability to keep operating.
"We already have a California MTL."
DFAL may still apply. Crypto-related activities are assessed separately, and you'll need to determine whether your existing license covers the digital asset components of your business or whether a DFAL license is also required.
What non-compliance actually costs now
DFAL applications go through NMLS, the same system used for money transmitter and mortgage licenses. But the requirements are specific to digital asset activity and include:
Business plan covering your digital asset products and target markets
Description of custody arrangements and control structures
AML/BSA compliance program documentation
Financial statements meeting DFAL capital requirements
Background checks for control persons
Cybersecurity and operational resilience documentation
If your application is already in, this is the same list DFPI is working through right now. Gaps come back as deficiency requests, and every round trip adds weeks.
How Brico’s crypto licensing software works
State MTL licensing is fragmented across agencies, license types, and changing rules. Even experienced compliance teams struggle to keep up, and manual tools make every new state feel like starting from scratch.
Onboard and centralize your data
Import your entities, owners, licenses, and key documents into Brico and connect your existing records where applicable. This creates a clean foundation and a single view of your licensing posture.
Sail through state-specific workflows
Apply Brico’s prebuilt checklists and automations for each state you operate in or plan to enter. Tailor tasks, approvals, and responsibilities to match your internal processes and team structure.
Streamline applications, renewals, and exams
Use the platform to manage new license applications, renewals, periodic reporting, and exam responses. Track every task and filing in one dashboard so you always know what’s done, what’s overdue, and what’s coming next.
Related Crypto Licensing Content
Dive deeper into crypto licensing essentials with these expert blog posts from Brico, covering key requirements for U.S. operations.
Get licensed in your next state. Faster.
Brico's licensing experts manage your crypto licenses in every state, including New York BitLicense and California DFAL, from application to renewal.
