WhatsApp and Telegram +44 7563 115980
[email protected]
Every money services business operating in the United States, foreign-located businesses included, files this federal registration alongside its state licences, which it does not replace.
Selected engagements from more than 250 licences obtained since 2013, for payment, e-money and cryptoasset firms.
Volkswagen
Payment InstitutionObtained Nexpay’s FCA Authorised Payment Institution licence.
Electronic Money InstitutionObtained Dzing Finance’s FCA Authorised Electronic Money Institution licence.
Obtained Orbital’s FCA Authorised Payment Institution licence.
Our realistic timeline from submission to decision.
Safeguarding, operating and settlement accounts opened alongside the application, so you trade on authorisation.
We assemble your team: a compliance officer and a US agent.
The licence, the requirements, the cost and the timing for your business.
You will need a compliance officer to run your anti-money laundering programme, a separate independent reviewer and, if based abroad, a US agent to receive legal papers.
One programme, from scoping to launch. Speak to an expert about this licence.
Requirements, capital, timing, fees and common questions, drawn from the regulator’s own publications.
A money services business must register with FinCEN under 31 CFR 1022.380 whether or not it is licensed as a money services business by any state. A business that is an MSB solely as an agent of another MSB, the US Postal Service and federal, state and local government agencies are excluded; a business acting both for itself and as an agent registers. A foreign-located MSB doing business in the United States registers in the same way. The registration confers no right to operate: money transmission remains licensed state by state under the state money transmitter licences, and the two run in parallel.
| Activity | Threshold |
|---|---|
| Money transmitter | No threshold |
| Currency dealer or exchanger | More than US$1,000 per person per day |
| Check casher | More than US$1,000 per person per day |
| Issuer, seller or redeemer of money orders or traveler’s checks | More than US$1,000 per person per day |
| Provider or seller of prepaid access (stored value) | More than US$1,000 per person per day; each prepaid programme listed on the form |
| Requirement | Amount |
|---|---|
| Capital requirement | None |
| Surety bond | None at federal level; set by each state licence |
Capital, net worth and bonds are matters for the state money transmitter licences, which run in parallel with the federal registration.
| Figure | Value | Source |
|---|---|---|
| Statutory decision period | No decision period: the registration is a filing, due within 180 days of establishment | 31 CFR 1022.380 |
| Application preparation | 3 to 4 weeks | From instruction to submission, including banking in parallel |
| Our realistic timeline | Effective on filing; the AML programme in place within 90 days of establishment | Our own figure, from the regulator’s published data and our applications |
Regulator figures are quoted as published and converted to months. Our realistic timeline assumes a complete, well-prepared application.
| Item | Amount | Notes |
|---|---|---|
| Registration fee | None | No fee is stated in 31 CFR 1022.380 or on the FinCEN registration page |
| Renewal fee | None | Renewal every two calendar years by 31 December |
| Professional fees | Fixed | Quoted after scoping |
A business that is an MSB solely as an agent of another MSB does not register; nor do the US Postal Service and government agencies. Currency dealers, check cashers and issuers or sellers of money orders, traveler’s checks and stored value are MSBs only above US$1,000 per person per day; money transmitters have no threshold.
The registration covers the whole United States and confers no right to operate: the regulation applies whether or not the business is licensed by any state, and each state’s money transmitter licence remains required. Groups serving the United States from abroad pair the registration and the state licences with their home authorisation, such as a UK payment institution licence.
Registration takes effect on filing, so FinCEN publishes consequences rather than causes of delay. Operating without complying with the registration rule is unlawful; a false or materially incomplete filing counts as non-compliance; the civil penalty is US$5,000 per violation with each day a separate violation, and 18 USC 1960 provides criminal penalties of up to five years’ imprisonment. The points settled before filing are the MSB type and threshold, the AML programme, the agent list and the US location for records.
An MSB needs US bank accounts, and banks review the FinCEN registration, the AML programme and the state licences before opening them. We open them alongside the registration. See banking and payment processing.
No. Registration is required whether or not the business is licensed by any state, and the state money transmitter licences remain required to operate.
No. Neither the regulation nor FinCEN’s registration page states a fee, and renewal is free.
Within 180 days of establishment, then every two calendar years with the renewal due by 31 December of the preceding year. Re-registration follows a change of control, a transfer of more than 10% of equity or a more than 50% increase in agents.
No. The US$1,000 per person per day threshold applies to currency dealers, check cashers and issuers or sellers of money orders, traveler’s checks and stored value, not to money transmitters.
Yes, where it does business in the United States: it files the same form, designates a US resident agent for service of process and keeps its records at a US location.
A regulatory advisory firm to payment, e-money and cryptoasset companies since 2013, with more than 250 licences obtained in more than 60 countries. The firm builds licensed payment, e-money, crypto and stablecoin businesses: the licence, the team, the technology, the bank accounts and card issuing.
This guide is general information, not legal advice. Requirements and fees change, and the regulator’s own publications take precedence.
The licence, your team, banking and technology, delivered as one programme.