Money Services Business (MSB) Services

Do you need to register with Financial Crimes Enforcement Network (FinCen) as an MSB? Do you need to apply for state Money Transmitter Licensure? Gilbert Reese will help you obtain state licenses and register with the regulators.

FinCEN defines Money Services Businesses (MSBs) as those business entities doing business in one or more of the following capacities:

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

Money Services Businesses are subject to the full range of BSA regulatory requirements, including the anti-money laundering program rule, suspicious activity and currency transaction reporting rules, and various other identification and record-keeping rules. Existing FinCEN regulations require certain MSBs to register with FinCEN. Many states have established supervisory requirements, often including the requirement that an MSB be licensed with the state(s) in which it is incorporated or does business.

At Gilbert Reese, we specialize in helping MSBs meet both deferral and state regulatory requirements. For money transmitters, we work hard for our clients to ensure the MSBs’ agents comply, to reduce the likelihood of exposing the MSBs to undue risk of noncompliance.

BSA/AML compliance program requirements:

Written policies, procedures, and internal controls
Designation of a BSA Compliance Officer
Ongoing employee training program
Periodic independent review of the compliance program
Customer due diligence procedures