FinCEN MSB Registration: Form 107, Renewal, and AML Program

Any business that transmits money, cashes checks, exchanges currency, sells money orders or traveler’s checks, or provides prepaid access in the United States has to complete FinCEN MSB registration by filing Form 107 through the BSA E-Filing System within 180 days of opening. That filing is the entry ticket. Staying compliant then means renewing every two years, running a written anti-money laundering program, filing suspicious activity and currency transaction reports, and getting whatever state licenses your operations require.

Who Has to Register

Federal regulations recognize seven categories of money services business (MSB). One of them, money transmitter, has no dollar floor: if you accept funds from one person and send them to another person or place by any means, including electronic transfer, informal value transfer, or physical delivery of cash, you are a money transmitter no matter how small the transaction.

The other categories only make you an MSB when the activity exceeds $1,000 for any one person in a single day:

Dealer in foreign exchange
Check casher
Issuer of traveler’s checks or money orders
Seller of traveler’s checks or money orders
Provider of prepaid access
Seller of prepaid access

Who Is Exempt

Banks as defined by BSA regulations, entities regulated by the SEC or CFTC, and government agencies at every level are outside the MSB definition and do not register. A business that operates solely as an agent for a registered MSB also does not need its own registration; but if it performs any MSB activity on its own behalf, it must register independently. The principal MSB reports its authorized agent count on its own Form 107.²

Virtual Currency Businesses

FinCEN treats convertible virtual currency exchangers and administrators as money transmitters. A business that trades cryptocurrency for regular currency, funds, or other virtual currency, or that issues and can redeem a virtual currency, has the same registration and BSA obligations as any other transmitter. Users who simply buy goods or services with virtual currency are not transmitters and do not register.³ In 2019 guidance, FinCEN confirmed these rules reach foreign-located businesses operating in substantial part within the United States, even without a physical U.S. presence.⁴

How to File Form 107

Registration is done electronically. Create an account on the BSA E-Filing System, then submit FinCEN Form 107 (Registration of Money Services Business). The system returns a tracking ID and an acceptance email once the filing goes through.⁵

The deadline is 180 days after the MSB is established. An owner or controlling person signs the form. If ownership or control is shared, one person can be designated to file, but that designation does not relieve the others of liability if the filing never happens.²

Once filed electronically, the business generally shows up on FinCEN’s public MSB Registrant Search page within about two weeks.⁶ That listing carries weight beyond compliance. Banks and payment processors check it before opening accounts, and an unregistered business will have trouble establishing banking relationships at all.

What the Form Asks For

Gather this material before you start:

Legal name, any DBA names, permanent U.S. address, EIN (or SSN/ITIN for sole proprietors), and phone number
Owner or controlling person: full name, address, date of birth, SSN or ITIN, and a government-issued ID number. For corporations this is the largest single shareholder; for partnerships a general partner; for trusts a trustee; for sole proprietorships the individual owner
Which MSB activities the business performs
States and territories of operation, total branch count, and total authorized agent count
Name, address, and account number of the financial institution holding the primary transaction account

One Form 107 covers the entire MSB no matter how many branches or agents it has, provided the counts are reported.²

Renewal and Re-Registration

Registration lasts two years. Renewal means filing a fresh Form 107 by December 31 of the second calendar year of the registration period. A business first registered in 2024 renews by December 31, 2025, then every 24 months after that. A lapsed registration exposes the business to penalties and disrupts banking.²

Some changes require a new Form 107 within 180 days regardless of the renewal cycle. Under the form’s filing instructions, these include re-registering under state law, a transfer of more than 10 percent of the business’s equity interest, and a more than 50 percent increase in the number of authorized agents.⁷

Records You Have to Keep

Every MSB keeps a copy of its filed registration and supporting documentation at a U.S. location for at least five years. Supporting documentation includes an estimate of business volume for the coming year, ownership and control information, and a list of authorized agents. The storage address goes on Form 107. Records can be paper, microfilm, or electronic as long as they can be produced in a reasonable time. FinCEN or law enforcement may extend the retention window during an active investigation.²

The Anti-Money Laundering Program

Filing Form 107 does not end your BSA obligations. Every MSB must maintain a written anti-money laundering program with four required elements:

Internal policies and procedures covering customer identification, report filing, record creation, and responses to law enforcement requests
A designated compliance officer responsible for day-to-day oversight, regulatory updates, and training
Ongoing employee training scaled to each role and the business’s risks
Independent review of the program by someone not involved in running it

An MSB acting solely as an agent for a principal can allocate some program-development work by agreement, but each party stays independently responsible for compliance at its own operations.⁸ Without a functioning AML program, the business is in violation from day one, and examiners look for it early.

Reports You File on an Ongoing Basis

Suspicious Activity Reports

File a Suspicious Activity Report (SAR) for any transaction of $2,000 or more that the business knows, suspects, or has reason to suspect involves illegal funds, is designed to evade BSA requirements, or has no apparent lawful purpose after review. For issuers of money orders or traveler’s checks identifying suspicious patterns through clearance records, the threshold is $5,000. SARs are due within 30 calendar days of first detecting the facts, with a phone call to law enforcement if the situation is urgent.⁹

Currency Transaction Reports

Any cash transaction over $10,000 requires a Currency Transaction Report (CTR), covering deposits, withdrawals, currency exchanges, and other transfers. Multiple cash transactions by the same customer in one business day that together exceed $10,000 are aggregated and reported as a single transaction. CTRs are due by the 15th calendar day after the transaction.¹⁰ A cash transaction that is both suspicious and over $10,000 requires both a SAR and a CTR.

State Licensing Sits on Top of Federal Registration

FinCEN registration does not substitute for state licensing. Most states require money transmitters and other MSBs to hold a separate state license before operating within their borders, with their own application fees, surety bond amounts, and processes. Many states use the Nationwide Multistate Licensing System (NMLS) to manage applications, agent lists, and license status across jurisdictions from a single platform. Operating in a state without its required license can trigger state penalties on top of any federal consequences.

What Happens If You Don’t Register

Civil penalties for failing to register run up to $5,000 per violation, with each day of noncompliance treated as a separate violation. Filing false or materially incomplete information carries the same penalty, and FinCEN can seek a court injunction to stop the business from operating.²

Criminal exposure is heavier. Knowingly running an unlicensed money transmitting business carries fines and up to five years in prison under 18 USC 1960. “Unlicensed” includes operating without FinCEN registration, operating without a required state license, or transmitting funds known to come from criminal activity or intended to promote illegal conduct.¹¹

The practical fallout can arrive before any enforcement action. An unregistered MSB will struggle to open or hold bank accounts, process transactions through payment networks, or partner with other financial institutions. Losing banking access can shut the business down on its own.

1
eCFR. 31 CFR 1010.100 – General Definitions
2
Financial Crimes Enforcement Network. Money Services Business (MSB) Registration
3
Financial Crimes Enforcement Network. FIN-2013-G001 – Application of FinCEN’s Regulations to Persons Administering, Exchanging, or Using Virtual Currencies
4
Financial Crimes Enforcement Network. FIN-2019-G001 – Application of FinCEN’s Regulations to Certain Business Models Involving Convertible Virtual Currencies
5
Financial Crimes Enforcement Network. Frequently Asked Questions – Electronically Filing Your Registration of Money Services Business (RMSB) Form
6
Financial Crimes Enforcement Network. Questions and Answers – General Information About the MSB Registrant Search Web Page
7
Internal Revenue Service. Registration of Money Services Business – FinCEN Form 107
8
eCFR. 31 CFR 1022.210 – Anti-Money Laundering Programs
9
eCFR. 31 CFR 1022.320 – Reports by Money Services Businesses of Suspicious Transactions
10
Financial Crimes Enforcement Network. FinCEN Currency Transaction Report Electronic Filing Instructions
11
Office of the Law Revision Counsel. 18 USC 1960 – Prohibition of Unlicensed Money Transmitting Businesses