money transmitter
Massachusetts Money Transmitter Laws & Licensing
Complete guide to money transmitter licensing in Massachusetts. Covers application requirements, surety bond amounts, net worth minimums, FinCEN registration, and key statutes governing money transmission in Massachusetts.
Massachusetts money transmitter requirements at a glance
| Surety 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 |
|---|---|
| Net worth requirement | Greater of $100,000 or a sliding scale of total assets (3% of the first $100 million, 2% of $100 million to $1 billion, 0.5% above $1 billion) |
| Renewal cadence | Annual |
| FinCEN MSB registration | Required |
Application process
Massachusetts money transmitters are licensed by the Division of Banks. Chapter 312 of the Acts of 2024 created M.G.L. c. 169B, and the Division began licensing and regulating money transmitters under it on January 1, 2026. The former foreign transmittal agency and check seller licenses transition into the money transmitter license.
Post security of the greater of $100,000 or 100% of your average daily money transmission liability in the Commonwealth over the most recently completed three months, capped at $500,000. Maintain tangible net worth of at least $100,000 or the sliding-scale amount for larger balance sheets (M.G.L. c. 169B, section 9).
You also provide audited financial statements, run a full BSA/AML program, register with FinCEN as a money services business, and pass background checks for all control persons.
Renewals
Money transmitter licenses in Massachusetts generally require annual renewal. Renewal typically requires submission of audited financial statements, updated surety bond, quarterly or annual transaction reports, BSA/AML filing documentation, and payment of renewal fees. Some states require call report filings on a quarterly basis throughout the year.
Money transmitters operating in Massachusetts are also generally expected to register with FinCEN as a money services business (MSB) and implement a comprehensive BSA/AML filings program. This includes appointing a filings officer, developing written policies and procedures, conducting employee training, filing Currency Transaction Reports (CTRs), and submitting Suspicious Activity Reports (SARs). Massachusetts may have specific requirements for cryptocurrency and virtual currency businesses.
Key statutes
- Money transmission, net worth, bond and permissible investments (M.G.L. c. 169B, § 9) . Requires tangible net worth of the greater of $100,000 or the sliding-scale percentage of total assets, and security of the greater of $100,000 or 100% of average daily money transmission liability in the Commonwealth over the most recently completed three months, capped at $500,000.
Federal baseline
Federal law applies in every state, not just this one.
- Bank Secrecy Act (31 U.S.C. § 5311) . Federal BSA/AML requirements for money services businesses
