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Money Transmission Licensing

FinCEN Compliance Filings for MSBs

MSB registration is only the first FinCEN filing a money services business meets. Beneficial ownership reports, suspicious activity reports, FinCEN identifiers, Form 8300, and FBAR each have their own trigger, form, and deadline. This guide maps the full federal filing set for an MSB operator.

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Reviewed by Cornerstone Staff28 years of financial services state licensing experienceLast verified August 6, 2026

Money Transmission Licensing

What FinCEN filings does an MSB have to make?

A money services business can face up to five distinct FinCEN filing regimes: the MSB registration itself (Form 107, generally within 180 days of establishment), suspicious activity reports (SARs), which the BSA rules call for on suspicious transactions of $2,000 or more, currency transaction reports for cash transactions over $10,000, a beneficial ownership information report (BOIR) where the Corporate Transparency Act still requires one, and FBAR (Form 114) if the business holds foreign financial accounts whose aggregate value passes $10,000. Under FinCEN's March 2025 interim final rule, companies formed in the United States are exempt from BOIR filing; the requirement currently applies to foreign companies registered to do business in the US. This is general information rather than legal or tax advice. Each filing has its own trigger and deadline, so MSBs generally run them off one compliance calendar.

What Is a BOIR and Do I Still Have to File One?
A BOIR is the beneficial ownership information report the Corporate Transparency Act requires certain companies to file with FinCEN, identifying the individuals who own or control the company. Under FinCEN's March 2025 interim final rule, companies formed in the United States are exempt from filing; the requirement currently applies to foreign companies registered to do business in the US. The rule has changed more than once, so verify the current status at fincen.gov/boi before filing or relying on the exemption.
Who Files Suspicious Activity Reports?
Banks, money services businesses, and other Bank Secrecy Act financial institutions file SARs. For an MSB the trigger is generally a known or suspected suspicious transaction of $2,000 or more conducted by, at, or through the business. The report is FinCEN Form 111, filed through BSA E-Filing within 30 days of detection, and its existence generally cannot be disclosed to the customer.

Money transmitter licensing by the numbers

US jurisdictions require a money transmitter license
51 of 52 US jurisdictions require a money transmitter license Source: state regulator statutes compiled in our state-law index, verified August 2026. Money transmitter license state laws
statutory surety bond range across licensing states
$10,000 to $1,000,000 statutory surety bond range across licensing states Source: state regulator statutes compiled in our state-law index, verified August 2026. Money transmitter license state laws

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One Regulator, Several Distinct Filings

FinCEN, the Financial Crimes Enforcement Network, administers several separate reporting regimes, and an MSB operator can touch most of them: the MSB registration itself, suspicious activity reports under the Bank Secrecy Act, beneficial ownership information reports under the Corporate Transparency Act, Form 8300 for large cash receipts, and FBAR for foreign accounts. Each filing has its own legal trigger, its own form, and its own deadline, and confusing them is common because they all say FinCEN on the letterhead. This page is general compliance information, not legal or tax advice; confirm your specific obligations with counsel.

BOIR Filing: Beneficial Ownership Reports Under the Corporate Transparency Act

The beneficial ownership information report, commonly called the BOIR or BOI report, comes from the Corporate Transparency Act. As originally written, it required most companies formed or registered in the United States to report their beneficial owners, the individuals who own or control the company, to FinCEN through the BOI E-Filing system.

The enforcement picture changed substantially in 2025. After court challenges and enforcement pauses, FinCEN issued an interim final rule in March 2025 that removed the BOIR filing requirement for companies formed in the United States and for US persons. Under that rule, the beneficial ownership reporting requirement currently applies to foreign reporting companies, meaning entities formed under foreign law that are registered to do business in a US state. Domestic companies, including domestic MSBs, are exempt from filing under the current rule.

What that means in practice for an MSB operator: check the current rule before you pay anyone to file a BOIR for a US-formed entity, and check again before you rely on the exemption, because the rulemaking is not finished and the requirement has already changed direction more than once. The authoritative source is FinCEN's BOI page and the BOI E-Filing system, not a filing-service ad. Note that beneficial ownership disclosure to FinCEN under the CTA is separate from the control-person and ownership disclosures every state money transmitter application requires; the state licensing layer at /money-transmitter-license never paused.

Who files a BOIR today

Under FinCEN's March 2025 interim final rule, foreign reporting companies registered to do business in the US file; companies formed in the United States are exempt. Verify the current rule at fincen.gov/boi before acting either way.

What the report contains

Identifying information for the company and for each beneficial owner: name, date of birth, address, and an identification document or a FinCEN ID standing in for those details.

Where it files

Electronically through FinCEN's BOI E-Filing system. There is no filing fee. Beware of look-alike paid filing sites; the government filing itself is free.

Not the same as state licensing disclosures

State money transmitter applications collect their own ownership and control-person disclosures with fingerprints and background checks. A BOIR exemption changes nothing on the state side.

SAR Filing: Suspicious Activity Reports for Money Services Businesses

A suspicious activity report, or SAR, is the Bank Secrecy Act filing an MSB makes when a transaction looks like money laundering, structuring, fraud, or otherwise has no lawful purpose the business can identify. For money services businesses the rule is 31 CFR 1022.320, which generally calls for a SAR when a transaction conducted or attempted by, at, or through the MSB involves at least $2,000 in funds or other assets and the business knows, suspects, or has reason to suspect it is suspicious. Issuers of money orders or traveler's checks reviewing their own clearance records use a $5,000 threshold.

The suspicious activity report form is FinCEN Form 111, filed electronically through the BSA E-Filing system. The filing deadline is generally 30 calendar days after the business becomes aware of the suspicious activity, with an additional 30 days available when no suspect was identified, and never more than 60 days in total. SARs are treated as strictly confidential: the BSA rules generally prohibit telling the customer, or anyone outside the reporting chain, that a SAR was filed.

For a licensed money transmitter, SAR discipline is not just a federal duty. State examiners test the monitoring program that generates SARs during routine examinations, and weak suspicious activity reporting is one of the most common examination findings. The person who owns this day to day is the designated compliance officer; see /money-transmitter-compliance-officer for what that role requires.

Trigger

A known, suspected, or reasonably suspected suspicious transaction of $2,000 or more conducted or attempted by, at, or through the MSB ($5,000 for issuers reviewing clearance records).

Form and system

FinCEN Form 111, the suspicious activity report form, filed electronically through BSA E-Filing.

Deadline

30 calendar days from detection, extendable to 60 when no suspect is identified. Ongoing activity is reported on a continuing basis.

Confidentiality

Disclosing the existence of a SAR to the subject is generally prohibited under the BSA rules. Records and supporting documentation are typically retained for five years.

What Is a FinCEN ID (FinCEN Number)?

The term FinCEN number gets used for two different things, and the difference matters.

A FinCEN ID, formally a FinCEN identifier, is a unique number an individual or company can request from FinCEN and then use in beneficial ownership reporting instead of resubmitting personal details on every report. Individuals request one through FinCEN's FinCEN ID application, provide the same identifying information a BOI report would contain once, and then give reporting companies the number instead of their documents. It exists for convenience and privacy in the BOI regime; with domestic BOIR filing currently paused, its day-to-day relevance follows wherever the BOI rule lands.

The other thing people mean by a FinCEN number is the MSB registration number, the identifier a money services business receives when its Form 107 registration is accepted. That number is what banks and partners look up in FinCEN's public MSB Registrant Search to confirm a business is registered. If a bank asks for your FinCEN number during onboarding, this registration number is almost always what it wants; see /msb-registration for how the registration works and /verify-msb-registration for how anyone can look one up.

Form 8300 and Currency Transaction Reports: Large Cash Filings

Two separate large-cash regimes exist, and which one applies depends on what kind of business receives the cash.

Form 8300, Report of Cash Payments Over $10,000 Received in a Trade or Business, is the IRS and FinCEN joint filing for ordinary businesses: a company that receives more than $10,000 in cash in one transaction or in related transactions files Form 8300 within 15 days. Since January 1, 2024, businesses required to e-file other information returns generally must e-file Form 8300 through BSA E-Filing as well.

Money services businesses mostly live under the other regime: as financial institutions under the Bank Secrecy Act, MSBs generally file currency transaction reports (CTRs) for cash-in or cash-out transactions over $10,000 in a business day, and a transaction reported on a CTR is generally exempt from Form 8300. The practical rule of thumb: the exchange counter and the transmission window generate CTRs, while Form 8300 catches large cash received outside that financial-institution role. Both regimes generally prohibit helping a customer structure amounts to stay under the threshold, and structuring can itself be prosecuted as a crime and is a classic SAR trigger. Because structuring exposure is this serious, confirm any close call with counsel before acting on it.

FBAR (FinCEN Form 114) for MSB Operators

The FBAR, FinCEN Form 114, is the Report of Foreign Bank and Financial Accounts. A United States person, including a US company, that has a financial interest in or signature authority over foreign financial accounts generally must file an FBAR when the aggregate value of those accounts exceeds $10,000 at any time during the calendar year. The FBAR files through the BSA E-Filing system, separately from any tax return, and is due April 15 with an automatic extension to October 15.

For most small businesses the FBAR never comes up. For an MSB it comes up quickly, because cross-border operations create exactly the accounts the rule covers: prefunded payout accounts with foreign banking partners, settlement accounts in destination corridors, and operating accounts at foreign subsidiaries. Officers with signature authority over those accounts can carry their own individual FBAR obligations alongside the company filing.

This is the edge of our lane: we flag the exposure as part of a licensing program because remittance and FX models create it, and your tax advisor or counsel owns the filing analysis. The point for an MSB founder is simpler: when you open the foreign payout account that makes your corridor work, put the FBAR on the same compliance calendar that tracks your state renewals.

Running the Filings on One Calendar

None of these filings is individually difficult. What sinks operators is that the triggers and deadlines are scattered: 180 days for the MSB registration, 30 days per SAR, 15 days per Form 8300, annual FBAR, biennial registration renewal, and a BOI rule that has changed direction more than once. A licensed money transmitter layers state renewals, call reports, and examinations on top.

The fix is boring and effective: one compliance calendar, owned by the designated compliance officer, holding every federal filing trigger next to every state deadline. That is how we run licensing programs at /money-transmitter-license, with the federal registration layer covered at /msb-registration and each state's requirements at /mtl-state-laws.

FAQ

Frequently Asked Questions

Related Pages

MSB Registration Money Transmitter License Money Transmitter Compliance Officer Verify an MSB Registration

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Money transmitter regulations by state

Money transmitter regulations by state

We are refreshing our state-by-state summaries for money transmitter. Browse the states we have published below.

  • Alabama
    Regulator: Alabama Securities Commission
    License: yes
    Bond: Not less than $100,000, or the average daily outstanding money-received-for-transmission obligations in Alabama plus 50% of average daily outstanding payment-instrument and stored-value obligations in Alabama, whichever is greater; commission may raise to a maximum of $5,000,000
    Open Alabama guide Official regulator site
  • Alaska
    Regulator: Alaska Department of Commerce, Community, and Economic Development, Division of Banking and Securities
    License: yes
    Bond: $25,000 plus $5,000 for each location, not exceeding a total addition of $125,000 (base + additions); department may raise to a maximum of $500,000 based on financial condition
    Open Alaska guide Official regulator site
  • Arizona
    Regulator: Arizona Department of Insurance and Financial Institutions
    License: yes
    Bond: Greater of $25,000 or 100% of the licensee's average daily money transmission liability in Arizona (most recent three-month period), up to a maximum of $500,000; $25,000 if tangible net worth exceeds 10% of total assets
    Open Arizona guide Official regulator site
  • Arkansas
    Regulator: Arkansas Securities Department
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in Arkansas (most recent three-month period), up to a maximum of $500,000; $100,000 if tangible net worth exceeds 10% of total assets
    Open Arkansas guide Official regulator site
  • California
    Regulator: California Department of Financial Protection and Innovation (DFPI)
    License: yes
    Bond: $250,000 to $7,000,000 for receiving money for transmission; selling or issuing payment instruments or stored value carries a separate $500,000 to $2,000,000 bond, and the two are cumulative
    Open California guide Official regulator site
  • Colorado
    Regulator: Colorado Department of Regulatory Agencies, Division of Banking
    License: yes
    Bond: Greater of $250,000 or 100% of the licensee's average daily money transmission liability in Colorado (most recent three-month period), up to a maximum of $1,000,000
    Open Colorado guide Official regulator site
  • Connecticut
    Regulator: Connecticut Department of Banking
    License: yes
    Bond: Non-virtual-currency transmitters: not less than $300,000 (avg weekly transmissions < $300,000), $500,000 ($300,000-$500,000), or $1,000,000 (> $500,000); virtual-currency transmitters: amount set by the commissioner
    Open Connecticut guide Official regulator site
  • Delaware
    Regulator: Delaware Office of the State Bank Commissioner
    License: yes
    Bond: $25,000, plus $5,000 for each location in excess of one, not to exceed $250,000 total
    Open Delaware guide Official regulator site
  • District of Columbia
    Regulator: District of Columbia Department of Insurance, Securities and Banking
    License: yes
    Bond: $50,000, increased by $10,000 per additional location, not to exceed $250,000 total
    Open District of Columbia guide Official regulator site
  • Florida
    Regulator: Florida Office of Financial Regulation
    License: yes
    Bond: Amount specified by rule, but not less than $50,000 and not exceeding $2,000,000 (rule allows for financial condition, number of locations, and anticipated volume)
    Open Florida guide Official regulator site
  • Georgia
    Regulator: Georgia Department of Banking and Finance
    License: yes
    Bond: $250,000 minimum; the Department may require additional coverage, capped at $2,000,000
    Open Georgia guide Official regulator site
  • Hawaii
    Regulator: Department of Commerce and Consumer Affairs, Division of Financial Institutions
    License: yes
    Bond: $100,000 for the initial 12 months of licensure; commissioner may increase up to a maximum of $500,000 based on impaired financial condition
    Open Hawaii guide Official regulator site
  • Idaho
    Regulator: Idaho Department of Finance
    License: yes
    Bond: $10,000, increased by $5,000 per additional location/authorized representative, up to a maximum of $500,000
    Open Idaho guide Official regulator site
  • Illinois
    Regulator: Illinois Department of Financial and Professional Regulation, Division of Financial Institutions
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in Illinois for the most recently completed quarter, capped at $2,000,000
    Open Illinois guide Official regulator site
  • Indiana
    Regulator: Indiana Department of Financial Institutions
    License: yes
    Bond: Greater of $300,000 or the licensee's average daily money transmission liability in Indiana for the most recent calendar quarter, capped at $500,000
    Open Indiana guide Official regulator site
  • Iowa
    Regulator: Iowa Division of Banking
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in Iowa for the most recent 3-month period, capped at $500,000
    Open Iowa guide Official regulator site
  • Kansas
    Regulator: Office of the State Bank Commissioner
    License: yes
    Bond: Greater of $200,000 or 100% of the licensee's average daily money transmission liability in Kansas for the most recent 3-month period, capped at $1,000,000 (or $200,000 if tangible net worth exceeds 10% of total assets)
    Open Kansas guide Official regulator site
  • Kentucky
    Regulator: Kentucky Department of Financial Institutions
    License: yes
    Bond: At least $500,000; commissioner may increase up to a maximum of $5,000,000 based on financial condition, net worth, or transaction volume
    Open Kentucky guide Official regulator site
  • Louisiana
    Regulator: Louisiana Office of Financial Institutions
    License: yes
    Bond: Minimum $100,000, up to a maximum of $500,000, or a higher amount deemed appropriate by the Commissioner up to a maximum of $1,000,000
    Open Louisiana guide Official regulator site
  • Maine
    Regulator: Bureau of Consumer Credit Protection
    License: yes
    Bond: $100,000
    Open Maine guide Official regulator site
  • Maryland
    Regulator: Office of the Commissioner of Financial Regulation
    License: yes
    Bond: Greater of $150,000 or 100% of the applicant's average daily money transmission liability in the State for the most recent quarter, capped at $2,000,000
    Open Maryland guide Official regulator site
  • Massachusetts
    Regulator: Massachusetts Division of Banks
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in Massachusetts over the most recently completed three months, capped at $500,000
    Open Massachusetts guide Official regulator site
  • Michigan
    Regulator: Department of Insurance and Financial Services (DIFS)
    License: yes
    Bond: $500,000 for the first location, plus $10,000 for each additional location and authorized delegate, up to a maximum of $1,500,000
    Open Michigan guide Official regulator site
  • Minnesota
    Regulator: Minnesota Department of Commerce
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in Minnesota (most recent 3-month period), capped at $500,000
    Open Minnesota guide Official regulator site
  • Mississippi
    Regulator: Mississippi Department of Banking and Consumer Finance
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in Mississippi (most recent 3-month period), capped at $500,000 (commissioner may raise up to $1,000,000)
    Open Mississippi guide Official regulator site
  • Missouri
    Regulator: Missouri Division of Finance
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in Missouri (most recent 3-month period), capped at $500,000
    Open Missouri guide Official regulator site
  • Montana
    Regulator: Montana Division of Banking
    License: no
    Bond: Not required (no state license needed)
    Open Montana guide Official regulator site
  • Nebraska
    Regulator: Nebraska Department of Banking and Finance
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in Nebraska (most recent 3-month period), capped at $500,000
    Open Nebraska guide Official regulator site
  • Nevada
    Regulator: State of Nevada Department of Business and Industry, Financial Institutions Division
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in Nevada (most recently completed quarter), capped at $500,000
    Open Nevada guide Official regulator site
  • New Hampshire
    Regulator: New Hampshire Banking Department
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in New Hampshire (most recent 3-month period), capped at $500,000
    Open New Hampshire guide Official regulator site
  • New Jersey
    Regulator: New Jersey Department of Banking and Insurance
    License: yes
    Bond: Amount set by the Commissioner by regulation, not less than $100,000 and not more than $1,000,000 (money transmitter). Foreign money transmitters use a volume-based schedule starting at $25,000.
    Open New Jersey guide Official regulator site
  • New Mexico
    Regulator: New Mexico Regulation and Licensing Department, Financial Institutions Division
    License: yes
    Bond: Greater of $300,000 or 1% of the licensee's total yearly dollar volume of money transmission business in New Mexico (or projected first-year volume), up to a maximum of $2,000,000
    Open New Mexico guide Official regulator site
  • New York
    Regulator: New York State Department of Financial Services
    License: yes
    Bond: Set by the Superintendent of Financial Services for each licensee; New York Banking Law Article 13-B fixes no dollar amount, so confirm the required bond with DFS before relying on a figure
    Open New York guide Official regulator site
  • North Carolina
    Regulator: North Carolina Office of the Commissioner of Banks
    License: yes
    Bond: $150,000 base (transmission volume in NC up to $1,000,000); increases with NC transmission volume (e.g., $175,000, $200,000, and higher tiers)
    Open North Carolina guide Official regulator site
  • North Dakota
    Regulator: North Dakota Department of Financial Institutions
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in North Dakota (most recent 3-month period), capped at $500,000
    Open North Dakota guide Official regulator site
  • Ohio
    Regulator: Ohio Department of Commerce, Division of Financial Institutions
    License: yes
    Bond: Security device (surety bond or permitted alternative) of not less than $300,000, up to a maximum of $2,000,000 as the Superintendent finds appropriate
    Open Ohio guide Official regulator site
  • Oklahoma
    Regulator: Oklahoma State Banking Department
    License: yes
    Bond: $50,000 plus $10,000 per authorized-delegate location, not exceeding a total of $500,000
    Open Oklahoma guide Official regulator site
  • Oregon
    Regulator: Oregon Department of Consumer and Business Services, Division of Financial Regulation
    License: yes
    Bond: $25,000, increased by $5,000 per additional location/authorized delegate (amount otherwise set by rule/Director)
    Open Oregon guide Official regulator site
  • Pennsylvania
    Regulator: Pennsylvania Department of Banking and Securities
    License: yes
    Bond: Bond in the penal sum of $1,000,000 (department may require additional bond based on average daily outstanding transmission balance)
    Open Pennsylvania guide Official regulator site
  • Puerto Rico
    Regulator: Puerto Rico Office of the Commissioner of Financial Institutions (OCIF)
    License: yes
    Bond: $500,000 for a single office, increased by $10,000 per additional office or authorized agent (Commissioner may require a higher bond based on business volume/financial condition)
    Open Puerto Rico guide Official regulator site
  • Rhode Island
    Regulator: Rhode Island Department of Business Regulation, Division of Banking
    License: yes
    Bond: $50,000 (currency transmission licensees); department may accept an alternative security form if a surety bond is not commercially available at reasonable cost
    Open Rhode Island guide Official regulator site
  • South Carolina
    Regulator: South Carolina Attorney General (Commissioner under the South Carolina Uniform Money Services Act)
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in South Carolina (most recent 3 months), capped at $500,000; alternatively $100,000 if tangible net worth exceeds 10% of total assets
    Open South Carolina guide Official regulator site
  • South Dakota
    Regulator: South Dakota Division of Banking
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in South Dakota (most recent 3 months), capped at $500,000; alternatively $100,000 if tangible net worth exceeds 10% of total assets
    Open South Dakota guide Official regulator site
  • Tennessee
    Regulator: Tennessee Department of Financial Institutions
    License: yes
    Bond: Greater of $50,000 or 100% of average daily money transmission liability in Tennessee (most recent calendar quarter), capped at $800,000
    Open Tennessee guide Official regulator site
  • Texas
    Regulator: Texas Department of Banking
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in Texas (most recent 3 months), capped at $500,000; alternatively $100,000 if tangible net worth exceeds 10% of total assets
    Open Texas guide Official regulator site
  • Utah
    Regulator: Utah Department of Financial Institutions
    License: yes
    Bond: Flat minimum surety bond of $50,000
    Open Utah guide Official regulator site
  • Vermont
    Regulator: Vermont Department of Financial Regulation
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in Vermont (most recent 3 months), capped at $2,000,000
    Open Vermont guide Official regulator site
  • Virginia
    Regulator: Virginia State Corporation Commission, Bureau of Financial Institutions
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in Virginia for the most recent quarter, capped at $1,000,000; a flat $100,000 where tangible net worth exceeds 10% of total assets
    Open Virginia guide Official regulator site
  • Washington
    Regulator: Washington State Department of Financial Institutions
    License: yes
    Bond: Surety bond based on prior year's money transmission and payment instrument dollar volume; minimum $10,000, not to exceed $550,000
    Open Washington guide Official regulator site
  • West Virginia
    Regulator: West Virginia Division of Financial Institutions
    License: yes
    Bond: $300,000 for money transmission; $100,000 for check or money-order sale or currency exchange; increased by 1% of annual West Virginia volume over $10 million, capped at $1,000,000
    Open West Virginia guide Official regulator site
  • Wisconsin
    Regulator: Wisconsin Department of Financial Institutions
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in Wisconsin (most recent 3 months), capped at $500,000
    Open Wisconsin guide Official regulator site
  • Wyoming
    Regulator: Wyoming Division of Banking
    License: yes
    Bond: $10,000 or 2.5 times outstanding payment instruments, whichever is greater, not to exceed $500,000
    Open Wyoming guide Official regulator site

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