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

From scratch

From USD 11,000

Timeline

From 1 month

Ready made

From EUR 17,000

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

FAQ

An MSB is a business registered with FinCEN that provides regulated money services such as money transmission and foreign exchange.

It is a registration with FinCEN, not a comprehensive license. Depending on the activities and jurisdictions, additional state-level licenses may still be necessary.

In general, businesses that engage in money transfers, payment services, fiat exchange or custody, FX, or stored value are required to register as MSBs.

Yes. A US incorporated entity with an EIN and U.S. presence is required for FinCEN MSB registration.

Not automatically. Although MSB registration is federally mandated, numerous activities necessitate state Money Transmitter Licences (MTLs) in each state of operation.

MSBs are required to conduct KYC/CDD, monitor transactions, file SARs and CTRs, appoint a compliance officer, and perform independent AML evaluations. Additionally, they must maintain a written AML program.

The level of banking difficulty is generally high, as a result of the stronger AML scrutiny and risk controls.

Yes. It is necessary to conduct an independent AML audit or assessments. Financial audits are not mandatory on a federal level; however, they may be mandated by states or institutions.