Registration in approximately 2 to 3 months

US money services business registration

FinCEN registration gives fintech and crypto businesses a federally recognised framework for money transmission, virtual currency exchange, and digital asset services, without the capital requirements of a traditional financial license.

What this enables

Permitted
MSB activities

Money transmission services
Foreign currency exchange
Virtual currency exchange and transfer
Digital asset payment processing
Crypto-to-fiat and fiat-to-crypto settlement infrastructure
Issuance and redemption of stored value instruments
Cross-border remittance services
Who this Is for

This structure is suited to:

Licensing and regulatory strategy

Crypto exchanges and OTC brokerage desks requiring a US regulatory footprint

Banking and payment infrastructure

Fintech payment platforms processing cross-border or domestic US transactions

Fractional decision-making partner

Digital asset payment gateways serving US-based clients or counterparties

Regulatory and structural readiness assessment

Companies requiring a recognised US entity for banking and PSP relationships

Who this is for

This is not the right fit if:

You require state-level money transmitter licenses to operate in specific US states — FinCEN registration is a federal framework and does not replace state MTL requirements in most states

Your business model involves activities requiring a banking charter or broker-dealer registration

You are not prepared to maintain the ongoing AML/CTF compliance obligations required under the Bank Secrecy Act

Registration process

01

US company incorporation
Establishment of a US LLC or corporation. Company name verification and registration completed.
Your responsibility: confirm corporate structure preferences, provide UBO and director information.
EIN application
Employer Identification Number obtained from the IRS, required for banking, regulatory filings, and operational setup.
Your responsibility: provide required identification documentation.

02

03

Compliance framework setup
Preparation of AML/BSA compliance policies, KYC/KYB program, and transaction monitoring framework.
Your responsibility: review and approve compliance documentation.
FinCEN registration
Submission of FinCEN Form 107. Company listed in the FinCEN MSB public registry upon approval.
Your responsibility: none at this stage. DM Strategy manages submission and follow-up.

04

Total timeline: approximately 2 to 3 months, depending on business model and regulatory review.
Montana structure can be used to avoid state-level money transmitter license requirements in certain configurations. This is assessed and recommended where applicable.
What is included

Service Packages

Professional  package

Corporate Setup

UBO / executive director due diligence

Up to 3 persons  

Shareholders as physical persons

Company name verification

US company incorporation

Employer Identification Number (EIN) Application (IRS)  

Corporate Infrastructure

Legal registered address (1 year)

Corporate secretarial Support

Compliance documentation

MSB compliance documentation:

Standard

Business plan outline 

MSB Registration with FinCEN

Listing in FinCEN MSB Public Registry  

Full operational

Corporate Setup

UBO / executive director due diligence

Unlimited 

Shareholders as physical persons

Holding ownership structure accepted

Company name verification

US company incorporation

Employer Identification Number (EIN) Application (IRS)

Notarized corporate documents

Regulatory structuring consultation  

Corporate Infrastructure

Legal registered address (1 year)

Corporate secretarial Support

Mail forwarding support (1 year)

Digital infrastructure

Legal entity identifier (LEI)  

Non-connected SWIFT code   

Domain name registration   

Website development

Corporate email setup   

Virtual U.S. mobile number (eSIM)

Compliance documentation

MSB compliance documentation:

Advanced

Tailored business plan 

MSB Registration with FinCEN

Listing in FinCEN MSB Public Registry

Banking & Operational Support

Assistance with Operational Bank Account Opening 

Introduction to Payment Providers / EMIs

Payment infrastructure advisory

Crypto payment infrastructure advisory

Correspondent banking support

SWIFT Connectivity via Partner Banks

Not included in either tier: FinCEN filing fees, state filing fees, bank fees, third-party software costs.

What is included

Service packages

US MSB (FinCEN) – Service Packages
Professional
Full Operational
Corporate Setup
UBO and director due diligence
Up to 3 persons
Shareholders as physical persons
Holding ownership structure accepted
Company name verification
US company incorporation
Employer Identification Number (EIN) Application (IRS)
Notarized corporate documents
Regulatory structuring consultation
Corporate Infrastructure
Legal registered address (1 year)
Corporate secretarial Support
Mail forwarding support (1 year)
Digital infrastructure
Legal entity identifier (LEI)
Non-connected SWIFT code  
Domain name registration  
Website development  
Corporate email setup  
Virtual U.S. mobile number (eSIM)  
Compliance documentation
MSB compliance documentation
Standard
Business plan  
Business plan outline 
MSB Registration with FinCEN
Listing in FinCEN MSB Public Registry  
Banking & Operational Support
Assistance with Operational Bank Account Opening
Introduction to Payment Providers / EMIs
Payment infrastructure advisory
Crypto payment infrastructure advisory
Correspondent banking support
SWIFT Connectivity via Partner Banks

Not included in either tier: FinCEN filing fees, state filing fees, bank fees, third-party software costs.

Costs and regulatory requirements

Item
Detail
FinCEN registration fee
No federal fee
Renewal
Every two years — no fee, compliance review required
State-level MTL
Vary by state — a Montana structure avoids this in many configurations
Ongoing BSA obligations
AML program, transaction monitoring, suspicious activity reporting, recordkeeping
Common queries

Frequently asked questions

Does FinCEN registration allow me to operate in all US states?

FinCEN registration is a federal framework. Most states require a separate state-level money transmitter license to operate locally. A Montana-based structure avoids this in certain configurations. Each project is assessed individually to determine the right structure for your operational model.

Is there a capital requirement?

No. Unlike EMI or banking licenses, US MSB registration does not require minimum paid-in capital. The main financial commitment is the compliance infrastructure required under the Bank Secrecy Act.

What are the ongoing compliance obligations?

Registered MSBs must maintain a written AML/CTF compliance program, KYC/KYB procedures, transaction monitoring, suspicious activity reporting, and recordkeeping. Registration must be renewed every two years.

How does the Montana structure work?

Montana does not require a state-level money transmitter license for most MSB operations. Incorporating in Montana allows businesses to operate under the federal FinCEN framework without the additional cost and complexity of state MTL licensing. Eligibility depends on your operational model and is confirmed at the assessment stage.

Understand your regulatory path before starting

The initial call covers your business model, the appropriate tier, and whether a Montana structure is the right configuration for your situation.

Get in Touch
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