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Licensing

Money Transmission and Payments

Navigate state money transmitter licensing and federal MSB registration requirements for payment, remittance, stored-value, and related financial business models.

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How we work through it

  1. StrategyMap your flow of funds, identify which states may require a license, assess exemptions with counsel, and set a filing sequence.
  2. PreparationBusiness plan, financial projections, AML program, and every policy the states ask for, plus surety bonds, fingerprints, and background checks.
  3. SubmissionFinCEN MSB registration where required, and state applications, most of them through NMLS.
  4. Follow-upResponses to regulator questions and deficiency letters until each state decides. Timing is set by the regulator.
  5. MaintenanceRenewals, quarterly reports, permissible-investment and net-worth tracking, change-of-control filings, and new states.

Licensing areas

Common licensing and registration areas. Whether each applies depends on your activities, your flow of funds, and the states you serve.

01

State money transmitter licenses

Assess state-by-state applicability, prepare license applications, and coordinate regulator follow-up where required. Whether a license is needed turns on the activity, control of the funds, and each state's law and exemptions.

02

FinCEN MSB registration

Assess federal registration obligations and support filings when applicable. Registration is distinct from state licensure: it is not a license, a federal authorization, or a government endorsement.

03

Stored value and prepaid access

Wallets, prepaid products, and stored balances. Many states treat issuing or selling stored value as money transmission; treatment and exemptions vary.

04

Currency exchange and check cashing

Licensed separately in some states, and treated differently under federal MSB rules. Requirements depend on the state and the activity.

05

Authorized delegate and agent arrangements

Operating as an authorized delegate or agent of a licensed transmitter. Whether this covers your own licensing obligation, and what oversight each side carries, varies by state.

What the license expects of you

Regulators review the program behind a license application, and examine it afterward. We help build it through our compliance service.

  1. Written AML program and risk assessment
  2. Named compliance officer
  3. Surety bonds, net worth, and permissible investments
  4. Audited financial statements
  5. Consumer disclosures, receipts, and complaint handling

Who regulates what

FinCENFederal registration and anti-money laundering rules for money services businesses.
State regulatorsMost states license money transmission under their own law, with their own exemptions. No single license covers every state.
NMLSThe shared system most states use for applications, renewals, and reports. Each state agency makes its own licensing decision.
OFACSanctions rules apply to all U.S. persons, licensed or not.

Who it's for

Payments, remittance, wallet, payout, bill-pay, and FX businesses, whether applying for the first time or adding states.

Unsure which of these apply to your model? Start with a regulatory applicability assessment →

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Let's discuss your regulatory needs.

Tell us about your business, product, or licensing challenge. We'll review your inquiry and discuss the appropriate next steps.

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