money transmitter
Montana Money Transmitter Laws & Licensing
Montana is one of the few states that does not require a money transmitter license. However, businesses are generally still expected to register with FinCEN and comply with federal BSA/AML requirements.
Montana money transmitter requirements at a glance
| Surety bond | Not required (no state license) |
|---|---|
| Minimum net worth | Set by the state regulator |
| FinCEN MSB registration | Required |
Application process
Montana does not require a state money transmitter license. However, all money services businesses are generally expected to register with the Financial Crimes Enforcement Network (FinCEN) as a money services business (MSB) and implement a comprehensive BSA/AML filings program.
Renewals
No state renewal required. FinCEN MSB registration is generally renewed every 2 years.
While Montana does not require a state money transmitter license, companies are generally still expected to comply with all federal requirements including FinCEN registration, BSA/AML obligations, and suspicious activity reporting. Companies should also verify whether their activities require licensing in other states where they operate.
Key statutes
- Montana financial institutions code, no money transmission chapter (Mont. Code Ann. tit. 32) . Title 32 enumerates the financial businesses Montana licenses (banks, consumer loan businesses, escrow businesses, mortgage lenders and others). It contains no money transmission chapter, which is why no state licence exists.
Federal baseline
Federal law applies in every state, not just this one.
- Bank Secrecy Act (31 U.S.C. § 5311) . Federal anti-money-laundering registration and reporting requirements.
