Money Services Business
MSB Registration
Every money transmitter is a money services business, and every MSB registers with FinCEN. The registration itself is free and fast; the compliance program behind it, and the state licenses layered on top, are where the real work lives. We handle both.
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Money Services Business
What is an MSB, and how does MSB registration work?
An MSB, or money services business, is FinCEN's category at 31 CFR 1010.100(ff) for non-bank businesses that move or exchange money: money transmitters, check cashers, foreign exchange dealers, money order and traveler's check sellers, and prepaid access providers. An MSB registers by filing FinCEN Form 107 through the BSA E-Filing system within 180 days of establishment. Registration is free, renews every two years, and never replaces state money transmitter licenses.
- How Much Does MSB Registration Cost?
- The FinCEN registration itself is free. There is no federal filing fee for Form 107 or for the biennial renewal. The real costs of operating as an MSB are the AML program build, the compliance officer, and the state money transmitter licenses, which carry application fees, surety bonds, and net worth requirements. See /money-transmitter-license-cost for those figures.
- Do I Need Both FinCEN Registration and State Licenses?
- In almost every case, yes. FinCEN registration is a federal requirement for operating as an MSB, and state money transmitter licenses are separate operating authority required by nearly every state. Montana is the one state with no money transmitter license, but FinCEN registration and federal BSA obligations still apply there.
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
The Cornerstone Way
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Federal Registration, State Licensing, One Program
MSB registration is the federal half of money transmission compliance. FinCEN, the Financial Crimes Enforcement Network, generally requires money services businesses to register, maintain a risk-based anti-money-laundering program under 31 CFR 1022.210, and file reports on certain transactions. Registration does not replace state licensing: a money transmitter typically needs both the FinCEN registration and a license in each state where its customers live. This page is general compliance information, not legal advice, and it covers who counts as an MSB, how the registration works, and how the federal and state layers fit together.
How Do You Register as an MSB With FinCEN?
The mechanics of FinCEN MSB registration are straightforward, which is exactly why it should never be the bottleneck in a licensing program.
1. Confirm you are an MSB
Check your activity against FinCEN's MSB categories: money transmission, check cashing, currency dealing or exchange, money order and traveler's check issuance or sale, and prepaid access. Classification drives everything downstream, so we confirm it with counsel where the model is novel.
2. Build the AML program first
FinCEN's risk-based AML-program rule at 31 CFR 1022.210 generally calls for a written BSA and AML program with a designated compliance officer, employee training, and independent review, scaled to the business's size and risk rather than a fixed checklist. The program should exist in practice, not just on paper, before you operate.
3. File FinCEN Form 107 through BSA E-Filing
The Registration of Money Services Business files electronically through FinCEN's BSA E-Filing system. There is no filing fee. The deadline is 180 days from the date the business is established.
4. Maintain the agent list and renew
MSBs that operate through agents keep a current agent list available to regulators. The registration renews every two years, and certain events, like a change in ownership or control, require re-registration.
The Six FinCEN MSB Categories and Their Thresholds
FinCEN defines a money services business at 31 CFR 1010.100(ff) as a person doing business in one or more of six regulated capacities (the regulation also lists the U.S. Postal Service, which registers under different rules). Three categories carry a dollar threshold of more than $1,000 per person per day; money transmission has no threshold at all. Banks, and companies registered with and functionally regulated by the SEC or CFTC, are excluded from the definition, and a business that acts solely as an agent of another MSB does not file its own registration.
Money transmitter (no dollar threshold)
Accepts currency, funds, or value that substitutes for currency from one person and transmits it to another location or person by any means. There is no threshold: transmitting any amount as a business makes you an MSB. Examples: remittance companies, payment apps that hold balances, many crypto exchanges.
Dealer in foreign exchange (more than $1,000 per person per day)
Exchanges the currency or monetary instruments of one country for another's in an amount greater than $1,000 for any one person on any day. Examples: currency exchange counters, FX kiosks, exchange houses.
Check casher (more than $1,000 per person per day)
Accepts checks or certain monetary instruments in return for currency in an amount greater than $1,000 for any one person on any day. Cashing your own checks, or holding a check as loan collateral, does not count.
Issuer or seller of traveler's checks or money orders (more than $1,000 per person per day)
Issues or sells traveler's checks or money orders in an amount greater than $1,000 to any one person on any day. Examples: money order issuers and the retail chains that sell them.
Provider of prepaid access (no dollar threshold)
The participant in a prepaid program that serves as the principal conduit for access to program information, or absent an agreement, the participant with principal oversight and control. Defined by role in the program, not by a dollar figure. Payroll-only and certain limited, non-reloadable arrangements are carved out.
Seller of prepaid access ($10,000 per person per day trigger)
Sells prepaid access usable before customer identification is verified, or sells prepaid access to funds above $10,000 to any one person in a day without policies reasonably adapted to prevent it. Sellers of prepaid access are MSBs but are generally not required to file the FinCEN registration.
AML Registration: Is There an Anti-Money Laundering Registration in the US?
People searching for AML registration or anti-money laundering registration are usually looking at the wrong country's system or the right obligation under a different name. In the United Kingdom, certain businesses literally register for anti-money laundering supervision with HMRC or another supervisor. The United States has no standalone AML register. The US equivalent, for a business that moves or exchanges money, is FinCEN MSB registration: filing Form 107 brings the business under the Bank Secrecy Act, and the written AML program, compliance officer, training, and independent review are conditions of operating as an MSB rather than a separate registration.
So if a bank, partner, or checklist asks for your AML registration and you operate in the US, what you can actually produce is your FinCEN MSB registration number, your written BSA and AML program, and your state money transmitter licenses. Securities firms have their own AML obligations under FINRA rules, and banks under their banking regulators, but for money services businesses the MSB registration on this page is the anti-money laundering registration that exists.
No standalone US AML register
The US does not run a general anti-money laundering registration. The Bank Secrecy Act attaches AML program duties to regulated status: MSB registration for money services businesses, charters for banks, FINRA membership for broker-dealers.
MSB registration is the US equivalent
For money transmitters, currency exchangers, check cashers, and prepaid access providers, filing FinCEN Form 107 is the registration that evidences AML coverage, with the written program standing behind it.
UK and US systems differ
HMRC's anti-money laundering registration is a UK regime. A US business does not file it, and a UK AML registration proves nothing about US authority to transmit money.
Is MSB Registration the Same as a Money Transmitter License?
No, and confusing the two is one of the most common and most expensive mistakes new payment companies make. FinCEN registration is a federal notice filing: it tells the Treasury Department you exist and are subject to the Bank Secrecy Act. It costs nothing, takes little time, and is never a grant of operating authority.
A money transmitter license is a state grant of authority to move customer money, with a surety bond, net worth minimum, and application review behind it. Nearly every state requires one before you transmit for residents of that state. A transmitter operating nationwide therefore typically holds one FinCEN registration and roughly 50 state licenses. Registering with FinCEN and starting to transmit without state licenses is generally treated as unlicensed money transmission, which can carry civil and, in many states, criminal penalties. Because the exposure is this serious, confirm your classification with counsel before relying on any registration-only position.
The state layer is its own project: almost every state licenses money transmitters through its banking or financial services regulator, most via NMLS, with Montana as the one state that has no money transmitter license statute. Our state-by-state money transmitter law pages at /mtl-state-laws cover each state's bond amount, net worth minimum, and regulator, and /who-needs-a-money-transmitter-license walks through which business models trigger licensing.
Are Crypto Businesses MSBs?
Usually, yes. FinCEN's March 2013 guidance on virtual currency (FIN-2013-G001) concluded that administrators and exchangers of convertible virtual currency are money transmitters under the BSA, while a user who buys virtual currency for their own purposes is not. FinCEN's May 2019 consolidated guidance (FIN-2019-G001) applied the same framework to newer models: a platform that accepts and transmits value on behalf of customers, including a custodial exchange or a hosted wallet provider that controls customer private keys, is a money transmitter. Non-custodial software, where the user keeps sole control of the keys and the provider never takes possession of value, generally is not.
The practical consequence: most crypto exchanges, custodial wallet providers, OTC desks, and many stablecoin issuers generally register with FinCEN as MSBs within 180 days, build the same risk-based AML program, and then face the state licensing map on top. See /crypto-money-transmitter-license for how the state analysis runs for crypto models and /cryptocurrency-licensing for the dedicated state virtual currency regimes.
What Happens If You Do Not Register?
Operating an MSB without registering carries specific federal exposure, and the numbers are set by statute and adjusted annually for inflation.
On the civil side, 31 U.S.C. 5330(e) sets a penalty of $5,000 per violation as enacted, and each day a registration violation continues counts as a separate violation. Under FinCEN's inflation adjustment rule (31 CFR 1010.821), the maximum is $10,556 per violation for penalties assessed on or after January 17, 2025. On the criminal side, 18 U.S.C. 1960 provides that knowingly operating an unlicensed money transmitting business, which can include failing to comply with the FinCEN registration requirement, can be prosecuted as a federal crime punishable by a fine, up to five years in prison, or both. This is general information rather than legal advice; if you may have been operating outside these rules, confirm the exposure with counsel.
The enforcement paper trail is only part of the damage. The operational fallout usually arrives first.
Cease-and-desist orders
Federal and state regulators can order an unregistered MSB to stop operating, freezing revenue while the business scrambles to fix its filings.
Loss of banking relationships
Banks screen money services customers against the FinCEN MSB registry. An unregistered MSB is a red flag in bank due diligence and a common reason accounts get closed.
Failed investor and partner diligence
Acquirers, investors, and program partners check the registration during diligence. A missing or lapsed registration surfaces immediately and stalls the deal.
State license application denials
State money transmitter applications ask about federal compliance. Operating unregistered before you apply gives the state reviewer a character-and-fitness reason to deny or delay the license.
What Compliance Obligations Come With MSB Status?
Registration is the visible step, but MSB status carries a continuing federal compliance load under the Bank Secrecy Act.
Written AML program
A risk-based anti-money-laundering program, reviewed and approved by ownership, with policies, procedures, and internal controls matched to your products and customers.
Designated compliance officer
A named individual responsible for day-to-day BSA compliance. States reviewing your money transmitter applications look hard at who this person is and what they have done before. See /money-transmitter-compliance-officer for what the role requires.
Suspicious activity and currency reporting
MSBs file suspicious activity reports and currency transaction reports when transactions hit the applicable thresholds, and keep the records the BSA requires.
Training and independent review
Employees receive AML training on a recurring basis, and the program undergoes periodic independent review to test that it works in practice.
Common MSB Registration Mistakes
Most registration problems we clean up trace back to the same handful of mistakes. Each one is cheap to avoid and expensive to unwind.
Treating the registration as a license
Filing Form 107 and then transmitting money nationwide without state licenses is the classic error. The registration is a notice filing, not operating authority. See /money-transmitter-license for what the state layer requires.
Registering when you are only an agent
A business that is an MSB solely because it acts as an agent of another MSB does not file its own registration. Registering anyway creates a filing history you then have to maintain and explain.
Missing the renewal deadline
The renewal is due by December 31 of the calendar year before each new two-year period. It does not arrive as an invoice, so businesses without a compliance calendar simply forget, and the registration lapses.
Ignoring re-registration triggers
An ownership transfer above 10 percent of voting power or equity, a change requiring state re-registration, or a jump of more than 50 percent in agent count each restarts the clock. Deals close and nobody files the new Form 107.
Building a paper-only AML program
Regulators and state examiners test whether the program runs in practice: real training records, real independent reviews, a compliance officer who can answer questions. A template PDF fails that test.
Misclassifying the MSB category
Whether you are a money transmitter, a provider of prepaid access, or outside the definition entirely drives the reporting rules and the state licensing map. Novel models deserve a counsel-confirmed classification before the first filing.
After You Register: Renewal, Re-Registration, and Ongoing Duties
The initial Form 107 starts a lifecycle, not a one-time task. Under 31 CFR 1022.380, the registration covers a two-calendar-year period, and the renewal must be filed by December 31 of the calendar year before each new period, again through BSA E-Filing and again with no fee.
Three events force a re-registration outside the normal cycle: a change in ownership or control that requires the business to re-register under state law, a transfer of more than 10 percent of the voting power or equity interests (for companies that do not report such transfers to the SEC), and an increase of more than 50 percent in the number of agents during a registration period. The new filing is due within 180 days of the event, and the year it happens becomes year one of a fresh two-year period.
Alongside the registration itself, MSB status carries continuing duties: filing suspicious activity reports and currency transaction reports when thresholds are met, keeping BSA records, maintaining the agent list, and keeping the AML program current as products change. Our /money-transmitter-compliance-officer page covers the role that owns this day to day, and /money-transmitter-license-timeline shows how the federal and state clocks run in parallel.
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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.
- AlabamaRegulator: Alabama Securities CommissionLicense: yesBond: 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
- AlaskaRegulator: Alaska Department of Commerce, Community, and Economic Development, Division of Banking and SecuritiesLicense: yesBond: $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
- ArizonaRegulator: Arizona Department of Insurance and Financial InstitutionsLicense: yesBond: 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
- ArkansasRegulator: Arkansas Securities DepartmentLicense: yesBond: 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
- CaliforniaRegulator: California Department of Financial Protection and Innovation (DFPI)License: yesBond: $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
- ColoradoRegulator: Colorado Department of Regulatory Agencies, Division of BankingLicense: yesBond: 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
- ConnecticutRegulator: Connecticut Department of BankingLicense: yesBond: 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
- DelawareRegulator: Delaware Office of the State Bank CommissionerLicense: yesBond: $25,000, plus $5,000 for each location in excess of one, not to exceed $250,000 total
- District of ColumbiaRegulator: District of Columbia Department of Insurance, Securities and BankingLicense: yesBond: $50,000, increased by $10,000 per additional location, not to exceed $250,000 total
- FloridaRegulator: Florida Office of Financial RegulationLicense: yesBond: 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)
- GeorgiaRegulator: Georgia Department of Banking and FinanceLicense: yesBond: $250,000 minimum; the Department may require additional coverage, capped at $2,000,000
- HawaiiRegulator: Department of Commerce and Consumer Affairs, Division of Financial InstitutionsLicense: yesBond: $100,000 for the initial 12 months of licensure; commissioner may increase up to a maximum of $500,000 based on impaired financial condition
- IdahoRegulator: Idaho Department of FinanceLicense: yesBond: $10,000, increased by $5,000 per additional location/authorized representative, up to a maximum of $500,000
- IllinoisRegulator: Illinois Department of Financial and Professional Regulation, Division of Financial InstitutionsLicense: yesBond: 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
- IndianaRegulator: Indiana Department of Financial InstitutionsLicense: yesBond: 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
- IowaRegulator: Iowa Division of BankingLicense: yesBond: 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
- KansasRegulator: Office of the State Bank CommissionerLicense: yesBond: 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)
- KentuckyRegulator: Kentucky Department of Financial InstitutionsLicense: yesBond: At least $500,000; commissioner may increase up to a maximum of $5,000,000 based on financial condition, net worth, or transaction volume
- LouisianaRegulator: Louisiana Office of Financial InstitutionsLicense: yesBond: 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
- MaineRegulator: Bureau of Consumer Credit ProtectionLicense: yesBond: $100,000
- MarylandRegulator: Office of the Commissioner of Financial RegulationLicense: yesBond: 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
- MassachusettsRegulator: Massachusetts Division of BanksLicense: yesBond: 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
- MichiganRegulator: Department of Insurance and Financial Services (DIFS)License: yesBond: $500,000 for the first location, plus $10,000 for each additional location and authorized delegate, up to a maximum of $1,500,000
- MinnesotaRegulator: Minnesota Department of CommerceLicense: yesBond: 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
- MississippiRegulator: Mississippi Department of Banking and Consumer FinanceLicense: yesBond: 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)
- MissouriRegulator: Missouri Division of FinanceLicense: yesBond: 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
- MontanaRegulator: Montana Division of BankingLicense: noBond: Not required (no state license needed)
- NebraskaRegulator: Nebraska Department of Banking and FinanceLicense: yesBond: 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
- NevadaRegulator: State of Nevada Department of Business and Industry, Financial Institutions DivisionLicense: yesBond: Greater of $100,000 or 100% of average daily money transmission liability in Nevada (most recently completed quarter), capped at $500,000
- New HampshireRegulator: New Hampshire Banking DepartmentLicense: yesBond: 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
- New JerseyRegulator: New Jersey Department of Banking and InsuranceLicense: yesBond: 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.
- New MexicoRegulator: New Mexico Regulation and Licensing Department, Financial Institutions DivisionLicense: yesBond: 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
- New YorkRegulator: New York State Department of Financial ServicesLicense: yesBond: 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
- North CarolinaRegulator: North Carolina Office of the Commissioner of BanksLicense: yesBond: $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)
- North DakotaRegulator: North Dakota Department of Financial InstitutionsLicense: yesBond: 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
- OhioRegulator: Ohio Department of Commerce, Division of Financial InstitutionsLicense: yesBond: 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
- OklahomaRegulator: Oklahoma State Banking DepartmentLicense: yesBond: $50,000 plus $10,000 per authorized-delegate location, not exceeding a total of $500,000
- OregonRegulator: Oregon Department of Consumer and Business Services, Division of Financial RegulationLicense: yesBond: $25,000, increased by $5,000 per additional location/authorized delegate (amount otherwise set by rule/Director)
- PennsylvaniaRegulator: Pennsylvania Department of Banking and SecuritiesLicense: yesBond: Bond in the penal sum of $1,000,000 (department may require additional bond based on average daily outstanding transmission balance)
- Puerto RicoRegulator: Puerto Rico Office of the Commissioner of Financial Institutions (OCIF)License: yesBond: $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)
- Rhode IslandRegulator: Rhode Island Department of Business Regulation, Division of BankingLicense: yesBond: $50,000 (currency transmission licensees); department may accept an alternative security form if a surety bond is not commercially available at reasonable cost
- South CarolinaRegulator: South Carolina Attorney General (Commissioner under the South Carolina Uniform Money Services Act)License: yesBond: 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
- South DakotaRegulator: South Dakota Division of BankingLicense: yesBond: 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
- TennesseeRegulator: Tennessee Department of Financial InstitutionsLicense: yesBond: Greater of $50,000 or 100% of average daily money transmission liability in Tennessee (most recent calendar quarter), capped at $800,000
- TexasRegulator: Texas Department of BankingLicense: yesBond: 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
- UtahRegulator: Utah Department of Financial InstitutionsLicense: yesBond: Flat minimum surety bond of $50,000
- VermontRegulator: Vermont Department of Financial RegulationLicense: yesBond: Greater of $100,000 or 100% of average daily money transmission liability in Vermont (most recent 3 months), capped at $2,000,000
- VirginiaRegulator: Virginia State Corporation Commission, Bureau of Financial InstitutionsLicense: yesBond: 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
- WashingtonRegulator: Washington State Department of Financial InstitutionsLicense: yesBond: Surety bond based on prior year's money transmission and payment instrument dollar volume; minimum $10,000, not to exceed $550,000
- West VirginiaRegulator: West Virginia Division of Financial InstitutionsLicense: yesBond: $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
- WisconsinRegulator: Wisconsin Department of Financial InstitutionsLicense: yesBond: Greater of $100,000 or 100% of average daily money transmission liability in Wisconsin (most recent 3 months), capped at $500,000
- WyomingRegulator: Wyoming Division of BankingLicense: yesBond: $10,000 or 2.5 times outstanding payment instruments, whichever is greater, not to exceed $500,000
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