How to Register as an MSB with FinCEN: A Step-by-Step Guide

If your business qualifies as a Money Services Business under the Bank Secrecy Act, federal registration with FinCEN is a legal requirement — not an optional step. Operating as an unregistered MSB is a federal crime, regardless of whether you have state money transmitter licenses or operate through a sponsor bank.

This guide covers exactly how to register, what information you need, how long the process takes, and what your ongoing obligations are after initial registration.

Do You Need to Register?

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

If your business falls into any of these categories, registration is required within 180 days of establishing your business. There is no application fee and no approval process — registration is effective upon submission.

What You Need Before You Start

Before beginning your registration, gather the following:

Your business's legal name, all trade names and DBA names, and your principal place of business address.

Your Federal Employer Identification Number from the IRS.

The name, title, address, and contact information of the individual completing the registration.

Information about all owners and controlling persons.

A description of the specific MSB activities your business conducts.

A list of the states where you conduct MSB activities.

Whether you operate as an agent of another MSB — and if so, the name and EIN of the principal MSB.

Step 1 — Create Your BSA E-Filing Account

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

Go to the BSA E-Filing website and register for a new organizational account. You will need to provide your organization name, EIN, and contact information for the primary account administrator.

Save your login credentials. You will use this account for all future FinCEN filings — including SARs, CTRs, and your two-year re-registration.

Step 2 — Access the RMSB Form

Once logged in, navigate to the FinCEN Registration of Money Services Business form — also called the RMSB or FinCEN Form 107. The form is completed entirely online and requires no document uploads.

Step 3 — Complete the Registration Form

Work through each section of the form.

Identifying information — your business legal name, trade names, address, EIN, and telephone and email contact information.

MSB activities — select every category that accurately describes your activities. If you conduct multiple MSB activities, select all applicable categories.

States — identify all states where you conduct MSB activities.

Ownership and control — identify the owner or controlling person of the MSB.

Agent status — disclose whether you act as an agent of another MSB.

Step 4 — Review and Submit

Before submitting, review every field carefully. Errors in your registration can create compliance complications.

Once satisfied the information is accurate, submit the form electronically. You will receive a confirmation of submission. Save this confirmation — it is your proof of registration. FinCEN registration is effective upon submission with no waiting period.

Ongoing Obligations After Initial Registration

Re-registration every two years is required from the date of initial registration. The re-registration uses the same RMSB form and must be completed within the 180-day period ending on your two-year anniversary.

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

Update your registration promptly when material information changes — new owners, new activities, significant address changes.

Frequently Asked Questions

How long does FinCEN MSB registration take?

Registration is completed online and takes effect upon submission. There is no waiting period or approval process. The actual time to complete the form is typically 30 to 60 minutes once you have all required information gathered.

Does FinCEN registration replace state money transmitter licensing?

No. FinCEN registration is a separate federal obligation. State money transmitter licensing is a parallel, separate requirement in most states. Both are required for most MSBs — neither replaces the other.

Is there a cost to register as an MSB with FinCEN?

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 MSB registration.

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.