US MSB registration with FinCEN
Launch your fintech, payment, remittance, foreign exchange, or money services business in the United States with expert support for FinCEN MSB registration and AML compliance implementation.
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Why register an MSB in the USA
01
Legala authorisation to operate
02
Access to banking and payment partners
03
Build trust and enable growth
What is a US MSB?
A Money Services Business (MSB) is a company that provides certain financial services involving the movement, exchange, storage, or transmission of money. MSBs are regulated by the Financial Crimes Enforcement Network (FinCEN) under the Bank Secrecy Act (BSA).
Common Types of MSB Include:
Money Transmitters
Currency Dealers or Exchangers
Issuers/Sellers of Money Orders or Prepaid Access
Check Cashers
Our services for US MSB
If you are planning to launch a Money Services Business (MSB) in the United States, Advapay can support you with FinCEN registration, AML compliance programme development, regulatory readiness, and banking infrastructure.
01
FinCEN MSB Registration
Business model assessment
Review of products, services, and flow of funds
Preparation of FinCEN MSB registration filing
Review of ownership and control person information
Support throughout the registration process
02
AML Compliance Programme Development
BSA / AML Policy
Customer Identification Program (CIP)
Customer Due Diligence (CDD)
Enhanced Due Diligence (EDD)
Risk Assessment
OFAC Compliance Policy
Transaction Monitoring Procedures
SAR & CTR Reporting Procedures
03
Regulatory Readiness & Banking Support
Preparation of compliance documentation packages
Business plan and operational documentation support
Assistance with banking and payment partner onboarding
Support during due diligence reviews
Responses to compliance and regulatory questionnaires
Guidance on state licensing considerations where applicable
04
Compliance-as-a-Service
Compliance programme maintenance
Periodic policy reviews and updates
Independent compliance testing coordination
Regulatory reporting support
Communication with banking and payment partners
Ongoing compliance advisory services
US MSB registration with FinCEN: Requirements
Business and ownership information
Details of the legal entity, ownership structure, and key stakeholders involved in the business.
Identification of control persons
Information about individuals responsible for managing and controlling the company’s operations and compliance activities.
Description of products and services
A clear overview of the financial services offered, target customers, and intended business activities.
AML and BSA Compliance Framework
A documented Anti-Money Laundering (AML) programme designed to meet Bank Secrecy Act (BSA) requirements.
Internal Controls and Compliance Governance
Policies, procedures, and oversight mechanisms established to manage compliance risks and regulatory obligations.
It is important to note that FinCEN registration alone does not replace state-level licensing requirements where applicable.
Core AML compliance programme requirements
A compliant US MSB must maintain a documented AML programme that satisfies Bank Secrecy Act (BSA) requirements. A typical compliance framework includes:
Compliance Officer
A designated individual responsible for overseeing the compliance programme.
Policies and Procedures
Documented AML and OFAC controls designed to prevent financial crime.
Employee Training
Regular compliance training to ensure staff understand regulatory obligations.
Independent Testing
Periodic reviews and audits to assess programme effectiveness.
Monitoring and Reporting
Transaction monitoring, SAR filings, CTR filings, and ongoing compliance oversight.
US MSB application process and indicative timeline
1
Assessment and project scoping
Review of business model, products, target markets, and flow of funds.
Indicative timeline: 1 week
2
Compliance programme development
Preparation of AML policies, procedures, risk assessments, CIP, CDD, and EDD frameworks.
Indicative timeline: 1-4 weeks
3
FinCEN registration
Preparation and submission of the FinCEN MSB filing, review of control person information.
Indicative timeline: 1 week
US MSB legislation and regulation
Bank Secrecy Act (BSA)
Money Services Businesses (MSBs) operating in the United States must comply with the Bank Secrecy Act (BSA), the primary federal legislation governing anti-money laundering (AML) obligations.
The BSA establishes requirements for customer identification, transaction monitoring, recordkeeping, suspicious activity reporting, and internal compliance controls. It serves as the foundation of the US AML framework and applies to a wide range of financial institutions, including Money Services Businesses.
FinCEN
Companies conducting Money Services Business activities in the United States are generally required to register with the Financial Crimes Enforcement Network (FinCEN).
FinCEN is a bureau of the US Department of the Treasury and serves as the country’s financial intelligence unit (FIU). The agency is responsible for safeguarding the financial system from illicit activity, combating money laundering and terrorist financing, and administering the federal MSB registration regime. FinCEN also oversees compliance with reporting and AML requirements established under the Bank Secrecy Act.
US MSB vs Money Transmitter License (MTL)
Many companies entering the US payments market confuse MSB registration with Money Transmitter Licensing (MTL).
| MSB Registration | Money Transmitter License | |
|---|---|---|
| Level | Federal | State |
| Regulator | FinCEN | State regulators |
| Type | Registration | License |
| Cost | Low | High |
| Timeline | Days | Months to years |
| Compliance programme required | Yes | Yes |
| Main purpose | Federal registration for companies conducting Money Services Business activities in the United States. | State-level permission to receive, hold, and transfer money or monetary value on behalf of customers. |
| Important note | FinCEN MSB registration does not replace state money transmitter licensing where applicable. | MTL requirements vary by state and may involve surety bonds, net worth requirements, reporting, and examinations. |
Register for our online webinar “How to Launch Your US Fintech on a Fast Track: MSB USA Registration, Compliance & Payment Infrastructure”
Ready to Launch Your US Fintech?
Register your FinCEN MSB, build a compliant AML framework, and enter the US market with confidence.
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