App Store Reject

Guideline 3.1.5

Guideline 3.1.5 - Crypto: Exchange App Without Proper Licensing

High SeverityHard FixTypical Fix: 1-3 days0 Reports
Also known as:Cryptocurrency exchange app lacks proper licensing documentationTrading app unable to verify regulatory authorizationApp facilitates crypto exchange without demonstrated complianceMissing money transmitter license documentation for crypto app

Our Take

Apple is rejecting your cryptocurrency exchange or trading app because it does not demonstrate that the operating entity holds appropriate financial licenses for the jurisdictions it serves. Apple requires cryptocurrency exchanges to be operated by entities with proper regulatory compliance -- money transmitter licenses, money services business registration, or equivalent local regulations. This rejection is increasingly common as Apple tightens enforcement on crypto apps. The review team may ask for documentation of your MSB (Money Services Business) registration, state-level money transmitter licenses (in the US), FCA registration (UK), or equivalent regulatory approvals in your operating jurisdictions. The fix requires more than code changes -- you need to provide Apple with documentation of your regulatory status. If you do not have the required licenses, you either need to obtain them (which can take months) or partner with a licensed entity.

Resolution Guide

01

Gather all regulatory documentation

Collect copies of your MSB registration, state money transmitter licenses, FCA registration, or other relevant approvals.

02

Upload to App Store Connect

Attach documentation in the App Review Information section of your app version.

03

Explain in Review Notes

Clearly state which licenses you hold, which jurisdictions they cover, and how they relate to your app's functionality.

04

Limit app availability

In App Store Connect, restrict app availability to only the jurisdictions where you are licensed.

### If you do NOT have the required licenses:

05

Assess licensing requirements

Determine what licenses you need for each jurisdiction. In the US, this typically means FinCEN MSB registration plus state-level money transmitter licenses.

06

Partner with a licensed entity

Consider white-labeling or partnering with a licensed exchange provider rather than building your own.

07

Limit scope

If you cannot obtain full exchange licenses, consider limiting your app to wallet/portfolio tracking functionality (which has lower regulatory requirements) rather than trading.

Prevention

  • Secure all required licenses before submitting a crypto exchange app
  • Proactively attach regulatory documentation with your first submission
  • Restrict app availability to licensed jurisdictions only

    • Example Rejection Email

    From:Apple App Review Team
    Subject:Guideline 3.1.5 - Crypto: Exchange App Without Proper Lice
    Guideline 3.1.5 - Business - Payments - Cryptocurrencies We found that your app facilitates the exchange or trading of cryptocurrency, but we were unable to verify that your organization holds the appropriate licenses for the jurisdictions where the app is available. Apps that facilitate cryptocurrency exchange or trading must be offered by entities that are properly licensed and authorized to provide such services. Next Steps: Please provide documentation of your regulatory licenses and approvals in the App Review Information section of App Store Connect. This may include Money Services Business registration, money transmitter licenses, or equivalent authorizations for each jurisdiction where the app operates.

    Consider Appealing

    Respond by providing the requested documentation. If you have the licenses, this is a documentation issue, not a compliance issue. Attach copies of all relevant licenses and registrations in App Store Connect.

    Generate Appeal

    Before & After

    Before — Rejected

    Crypto exchange app submitted with no regulatory documentation, available globally

    After — Approved

    App resubmitted with MSB registration, state money transmitter licenses attached in App Review Information, and availability restricted to licensed US states

    What changed: Crypto exchange apps must demonstrate proper regulatory licensing for every jurisdiction where they operate.

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