FinCEN MSB Registration Checklist

Federal registration with FinCEN is the foundation of all money transmitter licensing. FinCEN MSB registration is required for any person engaging in money services business activities, regardless of state licensing status. Failure to register is a federal violation with criminal penalties.

Pre-Registration Assessment

• Determine whether your business activities require registration. Does your business accept currency, funds, or value and transmit it by any means? If yes, registration is required. Do not make assumptions about exemptions.
• Identify all legal entities that will be registered. Each legal entity must register separately. If you have multiple entities, you'll have multiple registrations.
• Assign one person to be responsible for registration and compliance with FinCEN requirements. This person should have authority to make representations to FinCEN.

Information Gathering

• Obtain the full legal name of your business exactly as it appears on your business license or articles of incorporation.
• Identify the primary business address where you maintain your principal place of business.
• Identify all additional locations where you conduct money services business activities.
• Identify all states where you will conduct money services business. This includes states where you have agents.
• Gather beneficial ownership information for all owners with 20% or more ownership stake. You'll need their full legal names, dates of birth, and addresses.
• For corporate entities, identify the CEO, CFO, and any other officers.
• Document your specific money services business activities (money transmission, check cashing, currency exchange, prepaid cards, stored value, virtual currency administration or exchange, etc.).
• Document your estimated annual transaction volume and transaction value.
• Identify any financial institution where you maintain accounts. You'll need the bank name and account number.

FinCEN Registration Steps

1. Visit FinCEN.gov and navigate to the Money Services Business registration portal. You cannot register by mail. Registration is entirely electronic.

2. Create an account. You'll need a valid email address. FinCEN will send confirmation to that email.

3. Complete the MSB registration form. Fields include:

4. Business name and all aliases
5. Principal address
6. Phone and email
7. Type of money services business (check all that apply)
8. All beneficial owners with 20%+ ownership
9. Business structure (sole proprietor, LLC, corporation, partnership, etc.)
10. Estimated annual volume and value of transactions
11. Financial institution used for accounts
12. Description of business model

13. Website URL if applicable

14. Submit the registration. FinCEN will provide a confirmation and assign you an MSB registration number. Take note of this number—you'll use it in state license applications and annual compliance filings.

15. You will receive an FinCEN MSB number via email within 2-5 business days. This number is valid for two years unless you update your registration information.

Post-Registration Obligations

• Keep all registration information current. If your beneficial ownership changes, your business address changes, or your activities change, update FinCEN within 30 days.
• Renew your registration every two years. FinCEN will send a reminder email approximately 60 days before expiration. Renew online using the same portal.
• File Suspicious Activity Reports (SARs) with FinCEN within 30 days of detection. Use FinCEN's Suspicious Activity Report system.
• File Currency Transaction Reports (CTRs) for transactions over $10,000. Most operators use automated reporting through their financial institutions.
• Respond to any inquiries from FinCEN within the specified timeframe. FinCEN may request updates to registration information or additional documentation.
• Maintain records of registration and all communications with FinCEN for at least five years.
• Do not assume registration with FinCEN is sufficient for state licensing. FinCEN registration is federal. You must also comply with state licensing requirements.

Common Registration Errors

• Incomplete beneficial ownership disclosure. FinCEN requires disclosure of all owners with 20% or more ownership. Failing to disclose beneficial owners is a violation and can result in penalties.
• Incorrect business type selection. Some operators check money transmission but not currency exchange, or miss virtual currency administration. If you're uncertain, include all applicable categories.
• Vague business descriptions. "Financial services" is not adequate. Describe what you actually do: "Accept cash and wire transfers domestically and internationally" is specific enough.
• Failing to update registration. If your beneficial ownership changes due to a sale of shares or if your business address changes, update FinCEN. Many operators register once and never update, which creates compliance gaps.
• Not renewing on time. FinCEN sends reminders, but it's your responsibility to renew. Set a calendar reminder 60 days before expiration.
• Confusion between FinCEN registration and state licensing. These are separate requirements. You must do both.

How Long the Process Takes

FinCEN registration is typically approved within 2-5 business days. The system is straightforward and automated. This is one of the faster compliance processes.

What Happens if You Don't Register

Failure to register with FinCEN is a federal crime. Penalties include: - Civil penalties up to $100,000 per day of non-compliance - Criminal penalties up to $250,000 in fines and imprisonment up to 5 years for willful violations - Federal prosecution by the Department of Justice

Do not operate without FinCEN registration if you're required to register. The risk is extreme.

FinCEN's Contact Information

FinCEN Help Desk: (800) 949-2732 Email: [email protected] Website: fincen.gov

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