MSB Registration Checklist: Everything You Need to Apply

FinCEN MSB registration is one of the first compliance steps most fintechs need to complete — and unlike state money transmitter licensing, it is fast and free. The key is having the right information ready before you start. This checklist covers everything you need to gather before opening the BSA E-Filing System.

Business Information

☐ Legal business name — exactly as it appears in your formation documents

☐ All trade names and DBA names your business operates under

☐ Principal place of business address — physical address, not a P.O. Box

☐ Business mailing address if different from principal address

☐ Federal Employer Identification Number (EIN) from the IRS

☐ Primary business telephone number and email address

☐ Date the business was established

MSB Activity Categories

Review each of the seven MSB categories and identify which apply to your business. You must select all categories that describe your activities — not just the primary one.

☐ Money transmitter — transmitting funds on behalf of the public

☐ Currency dealer or exchanger — exchanging currency for another currency including cryptocurrency

☐ Check casher — cashing checks for a fee

☐ Issuer of money orders, traveler's checks, or stored value

☐ Seller or redeemer of money orders, traveler's checks, or stored value

☐ Dealer in foreign exchange

☐ Cryptocurrency business — accepting and transmitting virtual currency

If you are uncertain whether a specific category applies to your business, seek qualified compliance counsel before registering.

Owner and Controlling Person Information

☐ Full legal name of each owner and controlling person

☐ Business address for each owner and controlling person

☐ Title or role of each person

☐ Contact information

States of Operation

☐ A complete list of all states where your business conducts MSB activities — this means every state where you have customers, not just where you are incorporated or headquartered

Agent Status

☐ Determination of whether your business acts as an agent of another MSB — and if so, the legal name and EIN of the principal MSB

BSA E-Filing Account

☐ BSA E-Filing System account — create at bsaefiling.fincen.treas.gov if you do not already have one

☐ Account administrator name and contact information

☐ Secure storage for your BSA E-Filing login credentials

After Registration — Keep These Records

☐ Confirmation number from your FinCEN registration submission

☐ Date of registration — this starts your two-year re-registration clock

☐ Re-registration deadline added to your compliance calendar

What Happens After You Submit

Registration is effective upon submission — there is no waiting period or approval process. FinCEN does not send a confirmation letter. Your submission confirmation number is your proof of registration.

Your business will appear in FinCEN's public MSB registrant database, which is searchable by business name and EIN. Sponsor banks and regulatory partners may use this database to verify your registration status.

Frequently Asked Questions

Do I need an attorney to complete MSB registration?

No. MSB registration is a straightforward online process that most businesses can complete without legal assistance. However, if you are uncertain whether your business qualifies as an MSB or which categories apply to your activities, qualified compliance counsel should be consulted before you register.

What if I registered late — after the 180-day window?

Register immediately. Late registration does not eliminate your obligation to register and does not eliminate liability for the period of unregistered operation. However, registering voluntarily is treated more favorably than being discovered unregistered through a regulatory inquiry.

Do I need to re-register if my business changes?

Material changes to your business — new owners, new activities, significant changes to your operations — should be reflected in your registration at the time of your next two-year re-registration. Significant changes should be addressed promptly rather than waiting for the next scheduled re-registration cycle.

How ComplyOne Helps

ComplyOne helps fintechs determine their MSB status, 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.