US money transmission: FinCEN MSB registration vs state MTLs

Businesses moving money for customers in the United States typically need both federal registration with FinCEN as a Money Services Business and licences in individual states.

Federal layer

FinCEN registration requires an AML programme, a designated compliance officer, independent testing and recordkeeping and reporting procedures.

State layer

Most states require a money transmitter licence with surety bonds, net-worth requirements and examinations. Many applications are filed through NMLS, and multi-state strategies can reduce duplication.

Sequencing

We help clients prioritise states by customer demand, consider partner-bank models in the interim, and build a compliance programme that scales across jurisdictions.