Every money services business operating in the United States, foreign-located businesses included, files this federal registration alongside its state licences, which it does not replace.
Selected engagements from more than 250 licences obtained since 2013, for payment, e-money, cryptoasset and consumer credit firms.
Volkswagen
Payment InstitutionObtained Nexpay’s FCA Authorised Payment Institution licence.
Electronic Money InstitutionObtained Dzing Finance’s FCA Authorised Electronic Money Institution licence.
Obtained Orbital’s FCA Authorised Payment Institution licence.
Our realistic timeline from submission, set against the regulator’s own published figures.
Safeguarding, operating and settlement accounts opened alongside the application, so you trade on authorisation.
Candidates introduced for a compliance officer and a US agent, each assessed against the regulator’s standard.
A reply within three business hours and a written proposal the same day: the licence, the requirements, the cost and the timing.
You will need a compliance officer to run your anti-money laundering programme, a separate independent reviewer and, if based abroad, a US agent to receive legal papers.
One engagement and one timetable, from scoping to launch. Speak to an expert about the people, the banking and the technology for this licence.
The regulator’s requirements, capital, timing, fees and the questions firms ask, from the regulator’s own publications.
A money services business must register with FinCEN under 31 CFR 1022.380 whether or not it is licensed as a money services business by any state. A business that is an MSB solely as an agent of another MSB, the US Postal Service and federal, state and local government agencies are excluded; a business acting both for itself and as an agent registers. A foreign-located MSB doing business in the United States registers in the same way. The registration confers no right to operate: money transmission remains licensed state by state under the state money transmitter licences, and the two run in parallel.
| Activity | Threshold |
|---|---|
| Money transmitter | No threshold |
| Currency dealer or exchanger | More than US$1,000 per person per day |
| Check casher | More than US$1,000 per person per day |
| Issuer, seller or redeemer of money orders or traveler’s checks | More than US$1,000 per person per day |
| Provider or seller of prepaid access (stored value) | More than US$1,000 per person per day; each prepaid programme listed on the form |
| Requirement | Amount |
|---|---|
| Capital requirement | None |
| Surety bond | None at federal level; set by each state licence |
Capital, net worth and bonds are matters for the state money transmitter licences, which run in parallel with the federal registration.
| Figure | Value | Source |
|---|---|---|
| Statutory decision period | No decision period: the registration is a filing, due within 180 days of establishment | 31 CFR 1022.380 |
| Application preparation | 3 to 4 weeks | From instruction to submission, including banking in parallel |
| Our realistic timeline | Effective on filing; the AML programme in place within 90 days of establishment | The firm’s own figure, from the regulator’s published data and its own applications |
Figures published by the regulator are quoted as published and converted to months. The realistic timeline is the firm’s own, for a complete, well-prepared application.
| Item | Amount | Notes |
|---|---|---|
| Registration fee | None | No fee is stated in 31 CFR 1022.380 or on the FinCEN registration page |
| Renewal fee | None | Renewal every two calendar years by 31 December |
| Professional fees | Fixed, in writing | Quoted after scoping |
A business that is an MSB solely as an agent of another MSB does not register; nor do the US Postal Service and government agencies. Currency dealers, check cashers and issuers or sellers of money orders, traveler’s checks and stored value are MSBs only above US$1,000 per person per day; money transmitters have no threshold.
The registration covers the whole United States and confers no right to operate: the regulation applies whether or not the business is licensed by any state, and each state’s money transmitter licence remains required. Groups serving the United States from abroad pair the registration and the state licences with their home authorisation, such as a UK payment institution licence.
Registration takes effect on filing, so FinCEN publishes consequences rather than causes of delay. Operating without complying with the registration rule is unlawful; a false or materially incomplete filing counts as non-compliance; the civil penalty is US$5,000 per violation with each day a separate violation, and 18 USC 1960 provides criminal penalties of up to five years’ imprisonment. The points settled before filing are the MSB type and threshold, the AML programme, the agent list and the US location for records.
An MSB needs US bank accounts, and banks review the FinCEN registration, the AML programme and the state licences before opening them. The firm arranges accounts through institutions that serve money services businesses and prepares the pack they review. See banking and payment processing.
No. Registration is required whether or not the business is licensed by any state, and the state money transmitter licences remain required to operate.
No. Neither the regulation nor FinCEN’s registration page states a fee, and renewal is free.
Within 180 days of establishment, then every two calendar years with the renewal due by 31 December of the preceding year. Re-registration follows a change of control, a transfer of more than 10% of equity or a more than 50% increase in agents.
No. The US$1,000 per person per day threshold applies to currency dealers, check cashers and issuers or sellers of money orders, traveler’s checks and stored value, not to money transmitters.
Yes, where it does business in the United States: it files the same form, designates a US resident agent for service of process and keeps its records at a US location.
A regulatory advisory firm to payment, e-money and cryptoasset companies since 2013, with more than 250 licences obtained in more than 60 countries. The firm advises on authorisation, compliance, safeguarding, banking and transactions, and builds the white-label payment and card technology its clients launch on.
A written proposal on cost, timing and requirements, the same day: speak to an expert.
This guide is general information for firms considering authorisation and is reviewed against the regulator’s published requirements. It is not legal advice; requirements and fees change, and the regulator’s current publications take precedence.
The requirements, the cost and the timing for your business, in a written proposal the same day.