US MSB Licence & Compliance
Register as a Money Services Business in the United States with specialist regulatory support.
We assist crypto firms, payment platforms, remittance providers, and financial technology businesses with federal MSB registration, multi-state licencing strategy, and ongoing compliance.
Connect with our US MSB licencing specialists
Speak with Our MSB Licence Experts
Complete the form and one of our consultants will contact you to discuss your business model, target states, and licencing strategy.
Alternatively, you can call us directly to speak with a specialist.
Successful Licence Client Testimonial
"We highly recommend Buckingham Capital Consulting to any business seeking to obtain an MSB registration. Their team understood our specific business requirements and guided us through each regulatory requirement with clarity. The registration process was completed efficiently, and their ongoing compliance support has been instrumental in maintaining our operational standards. We are grateful for their practical expertise and professional approach."
Why Buckingham Capital Consulting: Trusted Experts in MSB Licencing
Expert Guidance Through Every Step of MSB Licence Application
Deep payments and digital asset regulatory expertise
We advise payment institutions, remittance firms, and crypto platforms on US MSB registration and state licencing strategies across multiple jurisdictions.
End-to-end licencing support
We manage the process from federal registration through to multi-state licencing strategy, working with specialist US counsel where required.
Ongoing compliance and governance
After registration and licencing, we support firms with AML reviews, policy updates, and regulatory readiness as they scale across states.
Our Service is Trusted by Leaders in Financial Services
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Our Simple 3-Step MSB Licence Process
Step 1:
Business model and state strategy
We review your services, customer base, and target markets and define a practical licencing roadmap.
Step 2:
Federal registration and state licencing
We prepare the federal MSB registration with FinCEN and coordinate the required AML framework.
Step 3:
Ongoing Compliance
After registration and licencing, we provide ongoing AML, governance, and regulatory support as your business expands across additional states.
Expert US MSB Licence & Compliance Services
Since 2013, we’ve guided several businesses through successful MSB licencing. Our fast-track, end-to-end support ensures a smooth, compliant, and efficient process from start to finish.
Federal MSB registration
Preparation and submission of the MSB registration with the Financial Crimes Enforcement Network (FinCEN).
State money transmitter licencing strategy
Assessment of which states require licences based on your activities and customer locations, with a clear multi-state roadmap.
Compliance policies and procedures
Drafting of internal policies covering customer due diligence, transaction monitoring, reporting, and governance.
Ongoing compliance support
Post-licence advisory, AML reviews, and support as your operations expand across multiple states.
Our People
Our team combines payments, crypto, and regulatory expertise to guide firms through US MSB registration and multi-state licencing. We work directly with founders, legal teams, and compliance leads to deliver practical, regulator-ready solutions.
Key information and requirements for the MSB licence in the US
Key requirements
Money transmission in the United States is regulated at two levels:
1. Federal level (FinCEN)
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Businesses must register as a Money Services Business with FinCEN.
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This is a federal registration for anti-money laundering purposes.
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It does not authorise operations in individual states.
2. State level
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Each state has its own money transmitter licencing regime.
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Licences are required in states where you serve customers.
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There are 50 states plus additional US jurisdictions with their own rules.
Most businesses operating nationally require:
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Federal MSB registration, and
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Multiple state money transmitter licences.
Key federal requirements
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Registration with FinCEN as an MSB.
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Appointment of an AML compliance officer.
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Written AML and counter-terrorist financing programme.
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Customer due diligence and recordkeeping procedures.
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Transaction monitoring and suspicious activity reporting.
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Ongoing AML training and independent review.
Typical state licencing requirements
While requirements vary by state, common elements include:
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State money transmitter licence application.
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Minimum net worth or capital requirements.
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Surety bond or other financial security.
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Detailed business plan and compliance framework.
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Background checks for directors and beneficial owners.
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Ongoing reporting and examination obligations.
Some states have more complex regimes, while others have lighter requirements.
Required Documentation
Typical documentation includes:
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Business plan and services description.
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Corporate structure and ownership details.
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Director and beneficial owner information.
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AML and compliance policies and procedures.
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Financial projections and capital details.
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Compliance officer credentials.
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State-specific application forms and disclosures.
Exact requirements depend on the states and business activities.
Other important Information
Federal MSB registration alone does not allow nationwide operations.
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Most payment and crypto businesses require multiple state licences.
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Licencing across all states can take significant time and planning.
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A phased, state-by-state strategy is often more practical for early-stage firms.
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Early structuring decisions can affect licencing timelines and costs.
Our services
We support clients through the full US MSB licencing process, including:
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Business model and regulatory assessment.
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Federal MSB registration with FinCEN.
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Multi-state licencing strategy.
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Coordination with US counsel for state applications.
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AML policy and compliance framework design.
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Ongoing compliance advisory and reviews.
Our Publications for the MSB/MTL Licence
Frequently Asked Questions
Is FinCEN MSB registration the same as a Money Transmitter License?
No. FinCEN MSB registration is a federal registration under the Bank Secrecy Act. It brings the business within the federal anti-money-laundering, reporting and recordkeeping framework, but it does not authorise the business to transmit money in any US state.
A Money Transmitter License, commonly referred to as an MTL, is a separate state authorisation. There is no single nationwide US money transmitter licence. Each state determines whether your activities require a licence and whether you can serve customers located in that state.
Do I need both FinCEN registration and state money transmitter licences?
Usually, yes. A business that accepts money, funds, cryptocurrency or other monetary value from one person and transmits it to another person or location will generally need to register federally with FinCEN and obtain a Money Transmitter License in every state where it serves customers.
FinCEN registration and state licensing address different obligations. Completing one does not satisfy the other. Operating under a FinCEN registration without the necessary state licences remains unlicensed money transmission.
How long does FinCEN MSB registration take?
The registration can normally be prepared and filed within several days once the corporate information, ownership structure, services and US arrangements are available. FinCEN does not conduct a conventional approval process before accepting the registration.
An electronically filed registration normally appears on FinCEN’s public MSB register within approximately two weeks. This public listing is not an endorsement or confirmation that the business holds the state licences it needs. Registration must be filed within 180 days after the MSB is established. That is a filing deadline, not a grace period allowing the business to conduct money transmission without the required state licences.
How long does it take to obtain a Money Transmitter License?
A single state application commonly takes between three and nine months after submission. More demanding jurisdictions, including New York and California, can take nine to eighteen months or longer depending on the business model, ownership structure and quality of the application.
Applications to several states can be submitted in parallel through the Nationwide Multistate Licensing System, so the timelines do not need to run consecutively. The main causes of delay are incomplete financial information, inadequate compliance documentation, unresolved ownership disclosures, unsuitable management and repeated regulator questions.
What are the requirements for a US MSB and Money Transmitter License?
At federal level, the business must file FinCEN Form 107, implement a risk-based anti-money-laundering programme, appoint a compliance officer, establish customer due diligence and transaction monitoring procedures, provide staff training and arrange independent testing. It must also comply with suspicious activity reporting, currency transaction reporting and recordkeeping obligations where applicable.
State applications generally require a detailed business plan, flow of funds, financial statements and forecasts, ownership and management disclosures, criminal background checks, a surety bond, minimum net worth, permissible investments, compliance policies, a registered agent and evidence that the business can operate safely and compliantly.
How much does a US Money Transmitter License cost?
FinCEN charges no fee for initial MSB registration or renewal. The substantial costs arise from state licensing.
Each state can impose application, investigation, fingerprinting, renewal and examination fees. State application fees range from a few hundred dollars to around $10,000 in the most expensive jurisdictions. Applicants must also fund surety bond premiums, corporate registrations, registered agents, compliance preparation and professional support. A nationwide licensing programme can require approximately $250,000 to $350,000 in direct first-year state fees, bond premiums and administrative costs before professional fees, internal compliance staff and required capital are included.
Do I need a Money Transmitter License in every state?
You need a licence in each state where your activities and customer relationships trigger that state’s money transmission laws. The relevant question is generally where your customers are located, not simply where your company is incorporated or where its bank account is maintained.
Forty-nine states and the District of Columbia generally require money transmitters to be licensed. Montana currently has no dedicated state Money Transmitter License. US territories may have their own separate requirements. Most new businesses begin with a defined group of commercially important states and expand their licence footprint as customer demand and transaction volumes grow.
Which state should I apply to first?
The correct starting point is determined by your customer locations, commercial priorities, banking arrangements and intended payment flows. Incorporating in a particular state does not automatically make that the only state in which you require a licence.
Businesses should normally prioritise states containing their largest expected customer base while beginning slower applications, such as New York or California, early in the programme. Applying first to an inexpensive or faster state provides authority only in that state and does not unlock the wider US market.
I am based outside the United States. Can I register with FinCEN?
Yes. FinCEN’s rules apply to foreign-located businesses conducting MSB activities wholly or substantially within the United States. A foreign business can register without first incorporating a US company.
A foreign-located MSB must appoint a person residing in the United States as its agent for service of legal process and identify a US location where required registration records will be maintained. State licensing is more complicated. State regulators, banks and commercial partners will normally expect an appropriately registered legal entity and sufficient US operational substance. For many international applicants, establishing a US subsidiary is therefore the more practical route even where federal registration alone does not require it.
Do I need a US-resident director or compliance officer?
FinCEN does not impose a general requirement for every MSB director or compliance officer to reside in the United States. The compliance officer must nevertheless have sufficient experience, authority, access to information and resources to oversee the programme effectively.
A foreign-located MSB must appoint a US-resident agent for service of legal process. State applications also commonly require a registered agent and extensive disclosures concerning directors, owners and key individuals. Although not always legally mandatory, credible US compliance presence can materially strengthen state applications, bank onboarding and regulator confidence.
Do cryptocurrency and stablecoin businesses need MSB and MTL registration?
Often, yes, but the analysis depends on what the business actually does. A custodial exchange, hosted wallet, crypto payment processor or business that accepts and transmits cryptocurrency for customers will generally be treated as a money transmitter by FinCEN. Fiat-to-crypto, crypto-to-fiat and crypto-to-crypto transmission can all fall within scope.
Non-custodial software providers and businesses dealing solely for their own account may fall outside the definition, depending on the precise arrangement.
State rules differ. New York may require a BitLicense as well as a money transmitter licence for fiat activity, while California now operates its separate Digital Financial Assets Law licensing regime.
Can I buy an existing US MSB or licensed money transmitter?
A company holding registrations and licences can be acquired, but its regulatory permissions do not transfer automatically without scrutiny. State regulators commonly require prior approval for a change of control, fresh ownership and management disclosures, background checks and updated financial and compliance information.
FinCEN re-registration is generally triggered where more than ten per cent of the voting power or equity is transferred. Surety providers, banks and payment partners may also reconsider or terminate their arrangements following the acquisition.
Buying an existing company can save some time, but it is not a clean shortcut. The buyer inherits the company’s regulatory history, liabilities, examinations, complaints and potential compliance failures, so comprehensive regulatory, financial and operational due diligence is essential.
Is there a minimum capital requirement for a US MSB?
FinCEN registration itself has no minimum capital requirement. State Money Transmitter Licenses generally impose minimum tangible net worth requirements, which vary by jurisdiction and can increase according to the applicant’s assets, transaction volume or outstanding customer obligations.
The required net worth is not an application fee. It must remain within the licensed business and be maintained continuously after authorisation.
States may also require permissible investments equal to outstanding transmission obligations, meaning the business must maintain sufficient eligible liquid assets to cover customer funds and unsettled payments.
What is a money transmitter surety bond?
A surety bond is a financial guarantee required by most state regulators to protect customers and the state if the licensed business fails to meet its legal obligations.
The bond amount varies by state and may increase with transaction volume, authorised delegates or outstanding transmission liabilities. Required bond values can range from tens of thousands of dollars to $1 million or more.
The applicant usually pays an annual premium rather than depositing the full bond amount. The premium depends on the company’s financial strength, credit profile, ownership and perceived risk. A claim paid by the surety remains recoverable from the licensed business.
How do I renew a FinCEN registration and state Money Transmitter Licenses?
FinCEN MSB registration must be renewed every two years by submitting a new Form 107 through the BSA E-Filing System. FinCEN charges no renewal fee.
Re-registration may be required earlier following certain material changes, including the transfer of more than ten per cent of the business’s voting power or equity, a state-defined change of control or an increase of more than fifty per cent in the number of agents.
State Money Transmitter Licenses generally renew annually through NMLS. Licensees must also maintain bonds, net worth and permissible investments, submit regulatory reports, update authorised delegate information and obtain approval before certain ownership or business changes.