FinCEN registration & filings
Registration renewal tracking plus SAR, CTR and Form 110 filing produced from the case file and validated before submission.
MSB & money transmitter compliance · United States
AML compliance for US MSBs and money transmitters.
One platform for FinCEN-registered money transmitters, check cashers, prepaid programmes and virtual-currency exchangers: risk-based onboarding, OFAC screening on every transfer, Recordkeeping and Travel Rule enforcement, SAR and CTR filing, agent oversight and the state-by-state reporting evidence your licences depend on.
The obligation set
Federal rules plus every state you operate in.
MSBs carry a double burden: FinCEN's requirements under 31 CFR Chapter X, and a separate money transmitter licence in each state where they do business, each with its own reporting cycle, net-worth and permissible-investment tests, and examination programme. Multi-state operators fail examinations far more often on evidence and reporting hygiene than on the underlying controls.
ComplianceSuite keeps the federal programme and the state evidence in the same system of record, so a state examiner and a FinCEN review draw on one consistent, timestamped history.
- FinCEN MSB registration and renewal tracking
- SAR filing above the $2,000 MSB threshold
- CTR filing with same-day currency aggregation
- $3,000 transmittal recordkeeping and Travel Rule
- $3,000 identity verification for money orders
- Agent and authorised-delegate oversight
- Per-state volume and complaint reporting inputs
- Independent review evidence pack
Capabilities
Built for transfer volume and agent networks.
Recordkeeping & Travel Rule
$3,000 transmittal records and $3,000 identity verification for money orders enforced at the point of transaction.
State-by-state reporting
Volume, agent and complaint reporting inputs organised per state licence, with per-jurisdiction calendars.
Agent & delegate oversight
Risk-rated agent register with activity monitoring, periodic review cycles and remediation tracking.
OFAC on every transfer
Sender, receiver and corridor screening on each transmittal, with the 50 Percent Rule applied to business customers.
Independent review evidence
Rule inventories, tuning history, alert statistics and training records exported for your independent review.
Related: BSA/AML compliance, OFAC screening, crypto Travel Rule.
FAQ
MSB compliance, answered.
Who counts as a money services business?
Under 31 CFR 1010.100(ff) an MSB includes money transmitters, currency dealers or exchangers, check cashers, issuers or sellers of traveller's cheques and money orders, prepaid access providers and sellers, and — per FinCEN's 2019 guidance — most convertible virtual currency exchangers and administrators. MSBs must register with FinCEN, maintain an AML programme, and hold state money transmitter licences where they operate.
What does an MSB AML programme have to include?
Written policies and procedures reasonably designed to prevent money laundering, a designated compliance officer, ongoing employee training, independent review, and risk-based customer due diligence. MSBs also file SARs (over $2,000), CTRs (over $10,000 in currency in one day), keep records for funds transfers of $3,000 or more under the Recordkeeping and Travel Rules, and verify identity for money orders and traveller's cheques over $3,000.
How does ComplianceSuite handle the $3,000 Travel Rule threshold?
Transmittal orders of $3,000 or more capture and pass the required originator and beneficiary information, with completeness validation before release and an exception queue for missing fields. Virtual-asset transfers follow the same logic against your VASP counterparty data — see the crypto Travel Rule page.
Does it help with state money transmitter licensing?
It maintains the operational evidence licensing examiners request: transaction volumes by state, agent and authorised-delegate registers with oversight records, permissible-investment and net-worth reporting inputs, complaint logs, and per-state reporting calendars. Legal filing itself stays with your licensing counsel.
Can it monitor an agent network?
Yes. Agents and authorised delegates are modelled as entities with their own risk rating, activity monitoring, periodic review cycle and remediation tracking, so outlier locations surface before an examiner finds them.
Does it work for crypto exchangers and payment fintechs?
Yes — the same programme covers convertible virtual currency exchangers, prepaid programme managers and payment fintechs operating under a sponsor bank, with wallet screening, VASP counterparty due diligence and blockchain-analytics enrichment alongside fiat monitoring.
How quickly can we deploy?
Typical MSB deployments run 4-8 weeks: onboarding and CDD configuration, monitoring rules tuned to your corridors and product mix, FinCEN filing setup, then parallel run and cutover with your historical alert and SAR record migrated.
Walk through a multi-state MSB programme.
We'll map your corridors, products and state licences to the controls, filings and reporting calendar in a 30-minute session.