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.
- All 50 states
- Specialist support
- Human review on every filing
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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 for non-bank businesses that move or exchange money: money transmitters, check cashers, currency exchangers, issuers and sellers of money orders and traveler's checks, and certain prepaid access providers. An MSB registers with FinCEN by filing the Registration of Money Services Business (FinCEN Form 107) electronically through the BSA E-Filing system within 180 days of beginning operations. The registration is free, must be renewed every two years, and requires the business to maintain a written anti-money-laundering program with a designated compliance officer. Registration is not a license: money transmitters also need a state money transmitter license in nearly every state where they serve customers.
- 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.
The Cornerstone Way
A repeatable method, from first filing to every renewal
Faster licenses, less effort on your side, fewer mistakes, and fewer headaches. It is the way we combine experienced specialists, intentional AI, and the Atlas platform across one sequenced process.
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Discover
We connect you with independent attorneys to pin down which licenses you need.
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Prepare
Your licensing specialist assembles each application; our software handles the repetitive work.
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Review
That same specialist reviews every filing before it reaches a regulator.
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Approve
We submit, track each application, and keep you posted until the license is granted.
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Renew
We file every renewal ahead of its deadline in Atlas so licenses stay current.
Anyone can list five steps. Here is what makes ours hold up.
The shortcut
The common approach is to scrape the web for an answer and hope it is current. When the rules change, or the page was wrong to begin with, the mistake surfaces as a deficiency after the filing is in, when it costs the most time.
The Cornerstone Way
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Specialists who know the answer
Decades of licensing specialists, so the answer is right rather than guessed.
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Trusted relationships with the regulator
Direct, trusted relationships with regulators, so we ask the question instead of assuming the answer.
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Living internal checklists
Checklists that update the moment we learn something new, so deficiencies are caught before they happen.
Federal Registration, State Licensing, One Program
MSB registration is the federal half of money transmission compliance. FinCEN, the Financial Crimes Enforcement Network, requires money services businesses to register, maintain an anti-money-laundering program, and file reports on certain transactions. Registration does not replace state licensing: a money transmitter needs both the FinCEN registration and a license in each state where its customers live. This page 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
Federal rules require a written BSA and AML program with a designated compliance officer, employee training, and independent review. The program must 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.
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 holds one FinCEN registration and roughly 50 state licenses. Registering with FinCEN and starting to transmit without state licenses is unlicensed money transmission, which carries civil and, in many states, criminal penalties.
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.
FAQ
Frequently Asked Questions
Ready for licensing the Cornerstone way?
Anyone can file paperwork and hand you a license. Licensing the Cornerstone way is the same outcome done right: fewer deficiencies, a faster path to approval, less work on your plate, and renewals that stay managed long after you go live.
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100%
accepted by the second submission
Right the First Time
We prepare and file it correctly the first time, so most applications are accepted on the first submission instead of bouncing back with correction notices. The few that need a second pass are accepted then, with no avoidable back and forth.
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25 to 30x
faster than doing it yourself
Faster to Licensed
Start applications for 12 to 15 states on your own and it crawls. Hand those same states to a Cornerstone Licensing Specialist and they get you licensed 25 to 30 times faster, pursuing every state at once and knowing what each examiner expects.
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97-98.5%
of the work handled for you
Less Work for You
You answer questions once, then Cornerstone generates and files the license. Your part is the few minutes it takes to confirm the details.
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99.995%
on-time submissions in 2025
Renewals That Stay Managed
Every license, bond, and renewal date lives in Atlas and is tracked for you, so nothing lapses once you are approved.
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Money transmitter regulations by state
Money transmitter regulations by state
Where you operate shapes what you file
52 of 52 jurisdictions documented. Pick a state to see the regulator, the license rule, and the bond.
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Stay Ahead of the Rules
Recent rule changes, deadline announcements, and state agency updates we are tracking for you.
No regulatory updates to report right now. Our team is monitoring the agencies and will surface changes here as soon as they land.
Get Registered and Licensed the Right Way
We file the FinCEN registration immediately and run your state license applications in parallel, so the free federal step never delays the program and the state licenses never get skipped.