MSB Registration
Federal registration with FinCEN for money services business activities involving virtual currency exchange, transmission, or administration.
31 USC 搂 5330, 31 CFR 搂 1022.380, Bank Secrecy Act
Capital Required
No federal minimum; state requirements vary USD 25,000-500,000
Timeline
1-2 months (federal); 6-18 months (all state licenses)
Fees
Federal registration free; state fees USD 100-2,000 per state
Regulatory Body
FinCEN / SEC / CFTC / FINRA / State Regulators / NY DFS
Legislative Framework
Bank Secrecy Act, State Money Transmitter Laws, Securities Exchange Act of 1934, Investment Advisers Act of 1940, 23 NYCRR Part 200 (BitLicense)
Last updated: June 2025
Key Requirements
Register with FinCEN as Money Services Business (MSB) covering virtual currency activities per 31 CFR 搂 1022.210.
Establish written AML/CFT program with designated compliance officer, audit procedures, and training requirements per 31 CFR Part 1022.
Implement customer due diligence (CDD) program including beneficial ownership identification and verification for all customers.
Implement Suspicious Activity Reporting (SAR) procedures with reporting to FinCEN within 30 days of detection of transactions exceeding $5,000.
Maintain transaction records including customer identity, transaction amount, date, and destination for minimum 5 years.
Register with applicable state regulators and maintain minimum net capital requirements per state money transmitter laws (typically $25,000-$500,000).
Establish surety bond requirements per state regulations covering customer fund protection (typically $25,000-$500,000 per state).
Implement written policies for customer fund handling, segregation, and protection against business failure per state requirements.
Application Process
Complete FinCEN MSB registration form (FinCEN 107) online through FinCEN's BSA E-Filing System with organization details.
Develop comprehensive AML/CFT program including compliance policies, customer due diligence procedures, and suspicious activity detection procedures.
Establish operating capital and secure surety bond coverage for state money transmitter license amounts.
Identify applicable states where virtual currency exchange/transmission services will be offered and compile state-specific requirements.
Submit state money transmitter license applications with application fees, capitalization evidence, and AML/CFT documentation (varies 48+ states).
Respond to state regulatory inquiries and examinations regarding AML/CFT procedures, customer verification, and capital adequacy.
Receive FinCEN MSB registration confirmation and state money transmitter license approvals before commencing operations.
Expected Total Timeline
1-2 months (federal); 6-18 months (all state licenses)
Ongoing Obligations
After obtaining your MSB Registration, these are the continuing compliance requirements you must maintain.
File annual FinCEN MSB registration renewal to maintain active status (currently voluntary but increasingly required).
Report Suspicious Activities (SARs) to FinCEN within 30 days of detection with detailed transaction and customer information.
Conduct quarterly or annual AML/CFT compliance audits and document findings with management sign-off.
Maintain complete transaction records with customer identity information, amounts, dates, and destination for minimum 5 years.
Update and maintain written AML/CFT policies addressing emerging risks, staff training, and compliance procedures.
File annual certifications of compliance with state money transmitter regulations and capital maintenance per state requirements.
Respond to regulatory inquiries and examination requests from FinCEN and state regulators within specified timeframes (typically 10-30 days).
Cost Summary
Capital Requirement
No federal minimum; state requirements vary USD 25,000-500,000
Application & Licensing Fees
Federal registration free; state fees USD 100-2,000 per state
Jurisdiction Setup Cost
$100,000-$500,000+
Annual: $200,000-$1,000,000+
Other United States Licenses
Explore other license types available in United States.
State Money Transmitter License
Broker-Dealer Registration
BitLicense
Investment Adviser Registration
Alternative Trading System (ATS)
Need help with MSB Registration?
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