# MSB Registration ## 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. 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. ## 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. ## 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. ## How to get licensed 1. **Good Standing Assessment**, We analyze your business model and, in coordination with our attorney partners, help identify which licenses may apply in every state where you want to operate. 2. **Application Preparation**, We prepare all applications, gather required documentation, and coordinate background checks, financial statements, and surety bonds. 3. **Filing & Follow-Up**, We submit applications to each state and actively follow up with regulators to keep the process moving. 4. **Ongoing Filings**, After licensing, we manage your renewals, regulatory filings, and filing calendar so you never miss a deadline. ## Frequently asked questions ### 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. ### Who Counts as a Money Services Business? FinCEN's MSB categories cover money transmitters, check cashers, dealers in foreign exchange, issuers and sellers of money orders and traveler's checks, and providers and sellers of prepaid access, generally subject to activity thresholds. Money transmission is the category with no dollar threshold: transmitting any amount as a business makes you an MSB. ### What Happens If I Operate Without Registering? Operating an unregistered MSB violates federal law and can carry civil penalties and criminal exposure, and it compounds fast if state licenses are also missing. Registration is free and takes little time, so there is no economics in skipping it. If you have been operating past the 180-day window, register now and get counsel involved on the exposure. ### When Do I Have to Renew or Re-Register? The registration renews every two years. Certain events also trigger a re-registration outside the normal cycle, including a transfer of more than 10 percent of voting power or equity and a change in the entity's legal structure. We track these triggers as part of ongoing filings management.