FinCEN MSB Registration: A Step-by-Step Guide for Fintechs

If your fintech qualifies as a Money Services Business under the Bank Secrecy Act, registration with FinCEN — the Financial Crimes Enforcement Network — is a federal legal requirement. Operating as an unregistered MSB is a federal crime. And yet it is one of the most commonly overlooked compliance steps for early-stage fintechs.

This guide covers exactly what FinCEN MSB registration involves, who needs to do it, what information is required, how to complete the process step by step, and what ongoing obligations apply after initial registration.

Who Needs to Register With FinCEN?

FinCEN registration is required for businesses that qualify as Money Services Businesses under federal law. The seven MSB categories are money transmitters, currency dealers and exchangers, check cashers, issuers of traveler's checks, money orders, or stored value, sellers or redeemers of traveler's checks, money orders, or stored value, dealers in foreign exchange, and cryptocurrency businesses that accept and transmit value.

If your fintech falls into any of these categories, you are required to register with FinCEN as an MSB within 180 days of establishing your business. There is no application fee and no approval process — registration takes effect upon submission.

Who Is Exempt

Banks, credit unions, and other federally regulated financial institutions subject to examination by a federal banking regulator are not required to register as MSBs. Other financial institutions that are already subject to comprehensive federal oversight under separate regulatory frameworks are also generally exempt.

What You Need Before You Start

Before beginning your FinCEN registration, gather the following information. Your legal business name and any trade names or DBA names. Your principal place of business address. The name, title, and contact information of the individual completing the registration. Your Tax Identification Number — EIN for business entities. Information about the owners and controllers of the business including names and addresses of all principals. The specific MSB activities your business conducts and the states where you conduct them. Whether you are registering as a principal MSB or as an agent of another MSB.

If you operate as an agent of another MSB — for example, if you are a prepaid card program manager acting as an agent of a card issuer — your registration obligations differ from those of the principal MSB. Clarify your role before registering.

Step 1 — Create Your BSA E-Filing Account

FinCEN registration is completed through the BSA E-Filing System at bsaefiling.fincen.treas.gov.

If your organization does not already have a BSA E-Filing account, you need to create one. Go to the BSA E-Filing website, select the option to register for a new account, and complete the organization and user registration process. You will need to provide your organization name, EIN, and contact information for the primary account administrator.

Save your login credentials securely. You will need them for your MSB registration, for filing SARs and CTRs in the future, and for your re-registration every two years.

Step 2 — Access the RMSB Form

Once logged into the BSA E-Filing System, navigate to the FinCEN Registration of Money Services Business form — also called the RMSB or FinCEN Form 107.

The form is completed entirely online. It does not require uploading documents — only entering information.

Step 3 — Complete the Registration Form

Work through each section of the RMSB form.

The identifying information section covers your business's legal name, trade name if different, business address, mailing address if different, Employer Identification Number, and telephone and email contact information.

The MSB activities section is where you identify which specific MSB categories apply to your business. Select every category that accurately describes your activities. If you conduct multiple MSB activities — for example if you are both a money transmitter and an issuer of stored value — select all applicable categories.

The state section requires you to identify all states where you conduct MSB activities. List every state where you have customers or conduct regulated activities.

The ownership and control section requires identifying the owner or controlling person of the MSB — for most fintechs this is the primary founder or CEO.

The agent section requires disclosing whether you act as an agent of another MSB, and if so, the name and EIN of the principal MSB.

Step 4 — Review and Submit

Before submitting, review every field carefully. Errors in your FinCEN registration can create compliance complications — including mismatches between your registration and your actual activities that may raise questions in examinations.

Once you are satisfied the information is accurate and complete, submit the form electronically through the BSA E-Filing System. You will receive an electronic confirmation of submission. Save this confirmation — it is your proof of registration.

FinCEN registration is effective upon submission. There is no waiting period or approval notification.

Step 5 — Record Your Registration Details

Note and retain your FinCEN registration confirmation number, the date of registration, and the activities and states covered in your registration. Your registration date starts your two-year re-registration clock.

Ongoing Obligations After Initial Registration

Re-Registration Every Two Years

MSBs are required to re-register with FinCEN every two years from the date of initial registration. The re-registration process uses the same RMSB form in the BSA E-Filing System. Re-registration must be completed within the 180-day period ending on the two-year anniversary of your initial registration.

Failure to re-register on time is a BSA violation. Build your re-registration deadline into your compliance calendar immediately after completing initial registration.

Updating Your Registration When Business Information Changes

If material information about your business changes — new owners, new business activities, significant changes to your principal address — you should update your FinCEN registration promptly. FinCEN guidance indicates that changes should be reflected in your registration when re-registration occurs, but material changes to ownership or business activities should be addressed promptly rather than waiting for the next scheduled re-registration.

BSA/AML Program Requirement

FinCEN registration is separate from your BSA/AML compliance program. Registration establishes your status as a covered financial institution — but the compliance obligations that flow from that status, including maintaining a written AML program, filing SARs and CTRs, and maintaining required records, must be implemented independently.

Frequently Asked Questions

Can I register with FinCEN before my business is fully operational?

Yes. You can register with FinCEN when you establish your business even if you have not yet processed your first transaction. Registration must be completed within 180 days of establishing the business — not within 180 days of your first transaction. Registering early rather than waiting until the 180-day deadline is good practice.

Does FinCEN registration cost anything?

No. FinCEN MSB registration through the BSA E-Filing System is free. There are no application fees, annual fees, or renewal fees associated with federal FinCEN registration. State money transmitter licensing — a separate parallel obligation — does involve significant fees.

Does my FinCEN registration appear publicly?

Yes. FinCEN maintains a public MSB registrant search tool that allows anyone to search for registered MSBs by business name or EIN. Being registered and verifiable in the public database is a positive compliance signal for sponsor banks and business partners.

If I use a sponsor bank, do I still need to register with FinCEN?

Potentially yes. Whether your fintech independently qualifies as an MSB subject to FinCEN registration depends on your specific business model — not on whether you operate through a sponsor bank. If your fintech qualifies as an MSB independent of your sponsor bank relationship, you have independent FinCEN registration obligations. This determination requires analysis of your specific business model.

How ComplyOne Helps

ComplyOne helps fintechs determine whether they qualify as MSBs, complete FinCEN registration correctly, and build the BSA/AML compliance programs that MSB status requires — through advisory services, compliance technology, or both.


Talk to the ComplyOne team to get started.

The information in this article is for general educational purposes and does not constitute legal or regulatory advice. Consult a qualified compliance professional for guidance specific to your situation.