MoonPay obtained in 2025 a New York Limited Purpose Trust Charter that changes its offering in the United States: after receiving in June the BitLicense and the money transmitter license, the New York regulator granted on Nov. 25, 2025 an authorization that enables custody of digital assets and OTC operations for institutional clients.
MoonPay established its new U.S. headquarters in SoHo, New York, in April 2025 and, under that presence, obtained in June 2025 the BitLicense and the Money Transmitter License from the New York State Department of Financial Services (NYDFS), permits that allow operating retail fiat-to-crypto services in the state.
The trust status represents a material change in the relationship with institutional clients: it legally obliges acting with fiduciary duties of loyalty and diligence, and requires clear segregation of customer assets from the firm’s operating assets, a key mechanism to mitigate counterparty risk and the risk of commingling of assets in insolvency scenarios.
Additionally, as a limited purpose entity, MoonPay may effect money transmissions in New York without requiring an additional transmitter license, which reduces operational complexity compared with some alternative regulatory models.
Ivan Soto‑Wright, CEO and co‑founder, described the combination of authorizations as acquiring the regulatory “golden stack,” referring to the ability to serve clients in all states without relying on external compliance solutions. The development places MoonPay in direct competition with entities that already operate under trust charters in New York, among them platforms with established institutional services.
The authorization arrives at a time when several firms in the sector are seeking to clarify their regulatory status through state and federal charters or licenses. The combination of a New York base and a package of permissions aimed at both retail and institutional clients strengthens MoonPay’s proposition as an integrated provider of regulated infrastructure in the U.S.
Regulation and compliance for MoonPay
The NYDFS maintains ongoing supervision over entities with trust charters; among its requirements is compliance with cybersecurity regulation 23 NYCRR 500, which imposes formal controls over risk management, cybersecurity programs, incident response plans and annual penetration testing. 23 NYCRR 500 is a regulatory set of cybersecurity requirements for financial institutions operating in New York. The trust charter also entails increased audit and transparency requirements in custody and settlement of operations.
For institutional investors the charter responds to two recurring barriers: concern about counterparty risk and the need for regulatory certainty that meets internal compliance frameworks. The authorization for OTC activities allows executing large-volume transactions off organized markets, reducing price impact and offering greater certainty in execution within a fiduciary and regulated framework.
The New York trust charter makes MoonPay a provider capable of offering fiduciary custody and OTC services under strict supervision, which may facilitate onboarding of asset managers and institutional investors.
