Money Services Business (MSB) - USA
A US Montana MSB registration is a FinCEN-registered money services business incorporated in Montana, commonly used by fintech, payment, remittance, and crypto companies seeking a streamlined US regulatory structure
On this page
Quick facts
Regulator / authority
Financial Crimes Enforcement Network (FinCEN)
Coverage
Cross-border payment platforms, remittance businesses, digital wallet providers, and international transfer services
Best for
US MSB is the first stage for fintech businesses requiring a federal AML-compliant registration to legally provide money services in the United States
Local presence
Required (US legal entity)
Substance level
Medium (it is required to have a local resident director and preferably a local resident compliance officer). The office or address of the company should be local. The shareholder can be non-US based
Banking friendliness
Medium
Who this is for
Best fit
- Money transfers (fiat)
- Custodial wallet services
- Dealer in Foreign Exchange (FX Services)
- Money Transmitter / Remittance Services
- Prepaid Access
What you can do (scope)
- Money transfers and fiat payments
- Custodial wallet services
- Non-bank money exchange
- Sells prepaid access (including closed loop prepaid access)
Requirements overview
Company & presence
A registered address is required, a local director is advised, and a compliance officer can be a foreigner.
Key persons / governance
1 shareholder, 1 director, 1 compliance officer.
Capital / safeguarding / bonds
No minimum capital requirement at the federal (FinCEN) level, but in practice banks expect adequate capital.
AML/CTF baseline expectations
A written anti-money laundering (AML) program is required in accordance with the Bank Secrecy Act (BSA). KYC/CDD procedures that are risk-based. Sanctions surveillance and transaction monitoring. The appointment of an AML Compliance Officer. Filing of Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs).
Reporting / audits
An independent AML audit or evaluation is necessary, whether it is internal or external. External AML or financial evaluations may be requested by banks.
Process (end-to-end steps)
Step 1: Business Structuring & Regulatory Assessment
Defining the MSB activities (money transmission, currency exchange, prepaid access, check cashing, etc.). Determining target markets and U.S. states of operation. Assessing whether state Money Transmitter Licenses (MTLs) are required. Identifying shareholders, UBOs, directors, and compliance officer. Confirming operational thresholds and applicability of Bank Secrecy Act (BSA) requirements.
Step 2: Incorporation of the U.S. Legal Entity
Incorporation of a U.S. LLC or C-Corporation (commonly in Delaware, Wyoming, or Montana). Obtaining a registered office in the United States. Appointment of directors and registered agent of the company. Identification of beneficial owners and controlling persons.
Step 3: Tax Registration & Operational Setup
Before registering with FinCEN, the company must obtain: Employer Identification Number (EIN) from the IRS. Operational structure for the financial service model.
Step 4: AML/BSA Compliance Framework Preparation
Under the Bank Secrecy Act, MSBs must establish a written Anti-Money Laundering (AML) program before operating. The AML program must include: internal compliance policies and procedures, appointment of an AML Compliance Officer, employee AML training program, independent audit / review procedures.
Step 5: FinCEN MSB Registration
Creating an account in the BSA E-Filing system. Completing and submitting FinCEN Form—Registration of Money Services Business. Initial registration must be filed within 180 days of starting MSB activities.
Step 6: Post-Registration Compliance & State Licensing
After FinCEN registration: the company appears in the public MSB registry. The business must implement ongoing BSA compliance and reporting obligations. Maintain transaction monitoring and recordkeeping systems. The MSB must also renew its registration every two years with FinCEN. If operating in certain U.S. states, the business must additionally obtain state Money Transmitter Licenses via NMLS.
What's included in our support
- Obtaining MSB Registration
- Reservation of the company's preferred name, US LTD registration
- Provision of a local US registered agent for a company
- Preparation of individual AML policy
- Set of documents (incorporation application, share certificate, certificate of incorporation, articles of incorporation, register of shareholders and directors, etc.)
- Liaising with FinCEN
MSB - USA
From EUR 17,000
FAQ
An MSB is a business registered with FinCEN that provides regulated money services such as money transmission and foreign exchange.
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