FinCEN MSB Registration: Requirements, Form 107 and Registry Search
Who must register with FinCEN as a money services business, how to file Form 107, when to renew, and how to check if an MSB is registered.
Quick answer: Most money services businesses (MSBs) in the United States must register with FinCEN, the US Treasury's financial intelligence unit, within 180 days of starting business. You register by filing FinCEN Form 107 through the BSA E-Filing System, renew every two years, and re-register after certain changes. Registering with FinCEN is not a licence. Most states also require their own money transmitter licence.
What is FinCEN MSB registration?
FinCEN registration puts your business on the federal list of money services businesses. It tells regulators who you are, who owns you, what services you offer and where you operate. It is required under the Bank Secrecy Act (BSA).
Registration doesn't mean FinCEN has approved or checked your business. It's a filing obligation, not a licence. That's why banks and partners will still look closely at your AML program and your state licences.
Who has to register with FinCEN?
You're an MSB if you offer any of these services in the United States:
- Money transmission: sending money for other people, including many crypto and payment businesses. There is no minimum amount.
- Currency dealing or exchange: more than $1,000 for any person on any day
- Check cashing: more than $1,000 for any person on any day
- Issuing or selling traveler's checks or money orders: more than $1,000 for any person on any day
- Providing prepaid access, such as prepaid card programs
Foreign-located businesses that offer these services to people in the US must register too, even without a US office.
Who doesn't have to register?
- Businesses that are MSBs only because they act as an agent of another MSB. The principal MSB registers, and lists its agents.
- Banks, and businesses regulated by the SEC or CFTC, which fall outside the MSB definition.
- The US Postal Service and government agencies.
- Businesses that are MSBs only because they sell prepaid access, in most cases.
If you're not sure which side of the line you're on, get advice before you launch. Operating without a required registration is a federal offence.
How to register: FinCEN Form 107
- Confirm your MSB activities. List every service you offer, so you file under the right categories.
- Gather your details: legal name, EIN, addresses, owners and controlling persons, the states you operate in, your bank accounts, and how many branches and agents you have.
- Create a BSA E-Filing account at FinCEN's BSA E-Filing System.
- File Form 107, "Registration of Money Services Business". One form covers the whole business, however many branches or agents you have.
- Keep a copy of the filing and your acknowledgment. You must keep supporting records, including your agent list, for five years at a location in the US.
Deadline: within 180 days of the date your business is established.
When to renew or re-register
- Renewal: every two years. File by December 31 of the year before each new two-year period starts.
- Re-register within 180 days if any of these happen:
- a change in ownership or control that requires re-licensing under state law
- more than 10% of voting power or equity changes hands
- your number of agents grows by more than 50%
Missed renewals are one of the most common reasons MSB registrations lapse, and banks notice quickly.
What else does FinCEN require?
Registration is only the first step. Every MSB also needs:
- A written AML program with policies, procedures and internal controls based on your risk
- A compliance officer, often called the BSA Officer. Many smaller firms use a fractional BSA Officer.
- Ongoing training for staff and agents
- An independent review of the program
- Reporting: suspicious activity reports (generally $2,000 and up for MSBs) and currency transaction reports for cash over $10,000
- Record keeping, including information that must travel with funds transfers of $3,000 or more
What happens if you don't register?
FinCEN can impose civil penalties of up to $5,000 per violation, and each day of continuing violation counts separately. Operating an unregistered money transmitting business can also be a federal crime. Filing false or incomplete information counts as a failure to register too.
How to check if an MSB is registered with FinCEN
FinCEN publishes a public MSB Registrant Search. You can search by name, state and activity. Banks, partners and customers use it to confirm a business is registered before working with it.
You can also check both FinCEN and FINTRAC status in one place with our free MSB Registry Search.
FinCEN registration vs state licensing vs FINTRAC
| FinCEN registration | State money transmitter licence | FINTRAC registration (Canada) | |
|---|---|---|---|
| Who | Federal, US | Each US state | Federal, Canada |
| Is it a licence? | No, a registration | Yes | No, a registration |
| Approval process | Filing only | Full review, often with bonding and capital requirements | Review before registration is granted |
| Renewal | Every 2 years | Varies by state | Every 2 years |
Doing business in both countries? Read our guide to banking in the US as a Canadian MSB and see FINTRAC MSB registration.
Frequently asked questions
How long does FinCEN MSB registration take?
The filing itself can be done in a day once you have your information ready. FinCEN doesn't review or approve the registration in advance. Your acknowledgment comes back through BSA E-Filing.
Is there a fee to register with FinCEN?
FinCEN doesn't charge a fee to file Form 107. State licences usually do have fees and bonding costs.
Do crypto businesses need to register with FinCEN?
Usually, yes. Businesses that accept and transmit virtual currency for others are generally money transmitters under FinCEN's rules, and must register and run a full AML program.
Does FinCEN registration let me operate in every state?
No. FinCEN registration is federal. Most states also require a money transmitter licence before you can serve customers there.
Do foreign companies need to register with FinCEN?
Yes, if they offer MSB services to people in the US. Foreign-located MSBs must register and name a person in the US to act as their agent.
AML Incubator helps fintech, crypto and payment companies register with FinCEN, build US AML programs and provide fractional BSA Officers.
