FinCEN MSB Registration Services
ComplyFactor supports U.S. Money Services Businesses, and businesses assessing whether they qualify as one, with FinCEN MSB registration under 31 CFR § 1022.380. This is a federal Bank Secrecy Act registration, filed with FinCEN on Form 107; it is separate from, and not a substitute for, state money transmitter licensing.
We help determine whether registration applies, prepare the required information, and support an accurate, timely filing.
31 CFR § 1022.380
Federal MSB registration is a Bank Secrecy Act registration requirement administered by FinCEN. It doesn't itself grant state authorization to transmit money or conduct any other regulated activity.
MSB Registration Requirements
Once registration applies, Form 107 requires the business's identifying information, an estimate of MSB business volume for the coming year, information on ownership or control of the business, and, where the MSB uses agents, the number of agents authorized to conduct MSB activity on the business's behalf. Registration is the responsibility of the business's owner or controlling person, who must sign the form; only one registration is filed per registration period, even where ownership is shared.
A copy of the filed form and its supporting documentation must be kept at a location in the United States for five years. We help clients assemble this information accurately to reduce avoidable filing issues and inconsistencies.
Related reading: common FinCEN Form 107 renewal and re-registration errors
A distinction worth getting right
How ComplyFactor Supports Your FinCEN MSB Registration
ComplyFactor supports FinCEN MSB registration end to end, coordinated with the AML program and compliance-officer requirements that follow MSB status where relevant.
Classification & Applicability
Working through whether your business model falls within FinCEN's MSB categories.
Information Gathering
Identifying the ownership, control, and business-volume information the filing requires.
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RMSB / Form 107 Preparation
Preparing the Registration of Money Services Business (RMSB) filing itself.
Filing-Readiness Review
Reviewing the filing for completeness before it goes in.
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Electronic Submission Support
Supporting electronic submission through FinCEN's BSA E-Filing System.
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Renewal / Correction / Re-Registration Support
Tracking deadlines afterward and supporting corrections where information needs to be updated.
Who Needs to Register as an MSB with FinCEN?
FinCEN's MSB definition is activity-based, regardless of what a business calls its main line of work.
Activity Categories & Thresholds
Dealers in foreign exchange, check cashers, and issuers or sellers of money orders or traveler's checks are captured only once activity exceeds $1,000 for any person on any day. Money transmission carries no dollar threshold at all.
Prepaid Access
Prepaid access uses different tests again. A seller of prepaid access is generally captured only in specific circumstances, such as access usable before identity verification, or sales exceeding $10,000 to one person in a day without adequate safeguards.
The Agent Exception
A person who is an MSB solely because they act as an agent of another registered MSB is generally not required to register separately, unless they also conduct MSB activity on their own account.
Foreign-Located Businesses
A foreign-located person conducting MSB activity wholly or in substantial part within the United States can fall within FinCEN's rules and must then register and designate a U.S.-based agent for service of legal process.
Virtual Currency
Whether a specific virtual-currency business model qualifies depends on the actual activity involved, not the label “crypto.”
Where We Start
Where classification isn't straightforward, that assessment is where our engagements typically begin.
Preparing the MSB Registration Information
Before filing Form 107 we confirm the business's MSB classification, collect the ownership and control details, and estimate the coming year's MSB business volume. Where the business uses agents, we also confirm the number of agents to report.
Accurate answers at this stage reduce avoidable corrections later, and the draft is checked against the classification assessment before submission.
Who signs the form
How to Register as an MSB with FinCEN
Registration follows a consistent sequence, and ComplyFactor supports each step:
Confirm Status
Confirm MSB status and registration applicability.
Gather Information
Gather ownership, control, and business-volume information.
Prepare the Filing
Prepare the Form 107 / RMSB filing.
File Electronically
Submit electronically through FinCEN's BSA E-Filing System. Paper filing is no longer accepted.
Retain Records
Retain the filed form and supporting records.
Track Deadlines
Track renewal and re-registration deadlines going forward.
FinCEN Form 107: Preparation and Filing Support
FinCEN Form 107, now filed as the Registration of Money Services Business (RMSB) report, is the single filing used for a business's initial registration, its two-year renewals, required re-registrations, and corrections to previously filed information. There's no separate form for each of these. Because the form asks the business to classify its own MSB activity, accuracy matters: a classification that doesn't match how the business actually operates can create problems well beyond the registration itself, including for the AML program built around it.
Our part in this
How Long Does MSB Registration Take?
Three different timelines apply here, and they're easy to conflate.
1. Legal Deadline
180-Day Filing Window
Form 107 must be filed within 180 days, counted from the day after the business is established.
2. Preparation Time
Varies by Business
How long it takes to confirm classification, gather ownership and volume information, and get the filing right before submission. This is the stage an engagement is scoped around.
3. Registrant Search Visibility
~2 Weeks (Not an Approval)
FinCEN's own guidance states an electronically filed registration is generally added to the public MSB Registrant Search page within about two weeks, updated weekly. FinCEN doesn't issue an approval notice or certificate.
MSB Registration Renewal, Corrections and Re-Registration Support
Updates fall into three distinct filing types.
Renewal
Registration runs in two-calendar-year periods, with renewal due by December 31 of the year before each new period begins, filed on a fresh Form 107.
Correction
Updates previously filed information that was inaccurate or has changed, without necessarily restarting the two-year clock.
Re-Registration
Required following one of three triggering events: a qualifying ownership/control change, a transfer of more than 10% of voting power or equity not reported to the SEC, or a more-than-50% increase in agents. Each is due within 180 days and resets the two-year clock.
We help clients determine which filing type applies to a particular change, since not every update is a re-registration.
FinCEN MSB Registration vs State Money Transmitter Licensing
Registration with FinCEN and licensing by a state are separate processes, each with its own authority and timeline.
FinCEN MSB Registration
State Money Transmitter Licensing
FinCEN MSB registration is sometimes referred to informally as an “MSB license,” but that's not an accurate description of what the federal filing does: a business can be correctly registered with FinCEN and still be operating without the state authorization its activities require.
Common MSB Registration Issues We Help Identify
Category Mismatch
A business model that is hard to place in one of FinCEN's MSB categories, or that has been placed in the wrong one.
Outdated Registration Data
Registration information that no longer matches how the business actually operates.
Federal/State Confusion
Confusion between federal registration status and state licensing status.
Missed Re-Registration Trigger
A missed re-registration trigger following an ownership or agent-count change.
Agent/Principal Confusion
An agent-principal relationship that isn't reflected accurately in the registration.
Why Work With ComplyFactor
Specialist AML/BSA Focus
Our work is focused on AML and BSA compliance.
Sector Familiarity
MSB, remittance, and payment-sector experience.
Coordinated Compliance
Registration coordinated with the AML program and compliance-officer requirements that follow it.
Reviewed Filings
Filing reviewed for completeness before submission.
FAQs
No. There's no FinCEN filing fee for MSB registration, for the initial filing, a renewal, a correction, or a re-registration.
FinCEN updates the MSB Registrant Search page weekly and generally adds electronically filed registrations within about two weeks. FinCEN doesn't send an acknowledgment letter, so this public listing, together with your own e-filing confirmation, is the way to confirm a registration was received.
No. FinCEN doesn't issue a certificate, license, or approval notice for MSB registration. Registration is completed by filing Form 107; the business's e-filing confirmation and its later appearance on the MSB Registrant Search page are the available proof that a filing was made.
Yes. A single registration covers the registrant's branches directly, since branches operate under the same registered business rather than as separate entities. The registration form records the number of branches; branches aren't registered separately.
Yes. FinCEN Form 107 is also used to correct previously filed registration information. A correction is different from a full re-registration, which is only required following specific triggering events such as certain ownership changes.
Yes. The public search can be used by banks, payment partners, regulators and other counterparties to verify registration information. That is one reason keeping registration information accurate matters beyond the legal requirement itself.
Discuss Your FinCEN MSB Registration With Our Team
Tell us about your business model and your current registration status, and we'll confirm the relevant requirements, scope, and timing before anything begins.
