“A compliant multi-state MSB needs all of the following: Maintaining a net worth greater than $1.5 Million; Securing millions of dollars in surety bond coverage to insure customer transactions in the event of insolvency; Completing a financial audit; Creating proper KYC, AML, and other compliance systems; Going through an independent compliance audit; Hiring a compliance officer with at least five years of experience; Extensive background checks and financial disclosures from officers and investors; Due diligence on every partner and intermediary that is involved in the flow of funds. After all these conditions are met, obtaining licenses can take as long as a year.”
http://pandodaily.com/2013/08/24/bitcoins-complex-and-changing-regulatory-environment/