If a money services business is exempt from state money transmitter licensing, is FinCEN registration alone sufficient, or do they still need state licenses?

Asked Aug 6, 2018· 1 answer
Faisal KhanAnswered Aug 6, 2018

If you are an MSB that is exempt from MTLs - that exemption would apply on a state by state basis. So for the states you are exempt, you are exempt, but others may require you to obtain a license.

As far as FinCEN registration is concerned, if you are deemed to be an MSB, you are required to be registered with FinCEN.

FinCEN is not a license granting institution. Registration with FinCEN is mandatory for all MSBs for purposes of federal reporting.

Money Services Business (MSB)Money Services Business LicenseMoney Transmitter Licenses (MTL)MSB Registration (US)
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