It does scale with transaction volume, but the floor is $500k. But it's explicitly payable via a surety bond, which works like insurance; applicants with good credit history might pay just a few thousand dollars to get one.
There is also a class of money transfer company ("A licensee that engages in receiving money for transmission") that only needs a $250k bond.
There is also a class of money transfer company ("A licensee that engages in receiving money for transmission") that only needs a $250k bond.