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How to register (and renew) as an MSB with FinCEN

Checked against the cited sources: October 2026

You register with FinCEN (the Financial Crimes Enforcement Network, the Treasury bureau that administers the Bank Secrecy Act, or BSA) by filing Form 107, Registration of Money Services Business, through FinCEN's BSA E-Filing System. The first filing is due by the end of the 180-day period that starts the day after the business is established. After that, registration runs in two-calendar-year periods, and each renewal is due by December 31 before the next period begins.

Who has to register

Each money services business (MSB) must register with FinCEN, "whether or not licensed as a money services business by any State" (31 CFR 1022.380(a)(1)). The rule leaves out:

  • A business that is an MSB only because it acts as an agent of another MSB. But an MSB that offers MSB services both on its own behalf and as an agent for others must register (31 CFR 1022.380(a)(3)). Our guide on agents covers this, including an agent that also sells prepaid access.
  • A business that is an MSB only as a seller of prepaid access and is not already an agent (31 CFR 1022.380(a)(1)). See below.
  • The U.S. Postal Service, and federal, state and local government agencies.

A foreign-located MSB doing business in the United States must name a person who lives in the United States and is authorized, and has agreed, to accept legal papers about its compliance with FinCEN's rules. It must also give a U.S. address for its registration records (31 CFR 1022.380(a)(2)).

Seller or provider of prepaid access?

A seller takes money to load or reload prepaid access, as a store selling prepaid cards might. Under the rule, it is a seller only if it sells prepaid access offered under a prepaid program that can be used before the customer's identity is verified, or sells more than $10,000 of any prepaid access, store gift cards included, to one person in a day without policies and procedures reasonably adapted to prevent that (31 CFR 1010.100(ff)(7)).

FinCEN's form instructions say a seller of prepaid access "is typically an agent of another MSB and has no requirement to register."

A provider runs the prepaid program. It is the participant that agrees to be the provider or, if none registers as the provider, the one with "principal oversight and control" over the program. Organizing the program, setting its terms and choosing the other participants, such as the issuing bank, all point to that control (31 CFR 1010.100(ff)(4)). A provider must register and identify each prepaid program it provides (31 CFR 1022.380(a)(1)).

Who files and signs

Any person who owns or controls the MSB is responsible for registering it, but only one form is needed for each registration period (31 CFR 1022.380(c)). Co-owners can agree that one of them will file. If that person does not file, the others are still liable.

FinCEN says an owner or controlling person includes, for a corporation, its largest single shareholder; for a partnership, a general partner; and for a trust, a trustee. If that owner is itself a corporation, a duly authorized officer of that corporation may sign for it. For a foreign-located MSB, the person it named to accept legal papers (its agent for service of process) signs.

When the first registration is due

The deadline is "the end of the 180-day period beginning on the day following the date the business is established" (31 CFR 1022.380(b)(3)).

The rule does not define "established." FinCEN's 2006 guidance (FIN-2006-G006) counts the 180 days from the day a business is "established as money services businesses." Its 2019 virtual currency guidance says a non-exempt money transmitter must register "within 180 days of starting to engage in money transmission" (FIN-2019-G001).

A separate rule requires a written anti-money laundering (AML) program by the end of the 90-day period that starts the day after the business is established (31 CFR 1022.210(e)). Registering does not satisfy it.

What Form 107 asks for

Among other things, the form asks for:

  • the states and territories where you, your agents or your branches are located or provide MSB services, and whether you operate in a foreign country;
  • the numbers of branches and agents;
  • each MSB activity you conduct, and each prepaid program if you are a provider;
  • a compliance contact;
  • your primary transaction account; and
  • where you keep your supporting records.

Branches do not file their own forms, but the main form reports branch information (31 CFR 1022.380(b)(1)(ii)). If your primary transaction account is not yet known, FinCEN's instructions let you leave that part blank on the initial filing. You must then file a corrected registration once you know it.

FinCEN's instructions say supporting records kept at a U.S. location may include an estimate of the coming year's volume and the names and addresses of shareholders above 5 percent, general partners, trustees, directors and officers. The agent list is not optional: an MSB must prepare a list of its agents by its initial registration due date, revise it each January 1, keep it (not file it) at the U.S. location reported on the form, give it to FinCEN or law enforcement on request, and retain it for five years (31 CFR 1022.380(d)(1); 31 CFR 1010.430(d)).

How to file

You file online through FinCEN's BSA E-Filing System: enroll, complete Form 107, sign it, save a copy and submit it. FinCEN says filers should receive an acknowledgement with their MSB registration number (BSA ID) within about two business days.

Keep a copy of the form and your registration number at a U.S. location for five years (31 CFR 1022.380(b)(1)(iii); 31 CFR 1010.430(d)).

How renewal works

The first registration period is the two calendar years starting with the year you are first required to register. Each two-year period after that is a renewal period (31 CFR 1022.380(b)(2)). The renewal form is due "on or before the last day of the calendar year preceding the renewal period" (31 CFR 1022.380(b)(3)).

The rule does not say which year starts the first period when the 180-day window crosses a year end. FinCEN's 2006 guidance, written under the former rules, answers it: count from the year of the 180-day deadline if you register on that last day, or from the date you actually registered if you register earlier. So if your deadline falls in 2027, registering in December 2026 makes your first renewal due December 31, 2027, and registering in 2027 makes it due December 31, 2028.

A renewal is a new Form 107 marked as a renewal. Some ownership and agent changes require re-registration within 180 days, restarting the clock; see our guide on re-registration triggers.

If you miss a renewal, or stop being an MSB

Once a year, FinCEN removes businesses that did not renew from its MSB Registrant Search page. It tells any business whose activities still require registration to renew immediately. Its 2006 guidance says a business that misses its renewal deadline "will no longer be deemed 'registered.'"

There is no formal way to de-register. FinCEN's guidance says a business that has stopped operating as an MSB, or registered by mistake, can only refrain from renewing.

31 CFR 1022.380(e) makes it unlawful to do business without complying with 31 U.S.C. 5330 and the rule; filing false or materially incomplete information is a failure to comply. The rule's civil penalty is $5,000 per violation, each day a separate violation. For penalties assessed on or after January 17, 2025, FinCEN's inflation-adjusted maximum, replacing the $5,000, is $10,556 per violation, and it does not cap the total for a continuing violation (31 CFR 1010.821).

Separately, it is a federal crime to knowingly conduct, control, manage, supervise, direct, or own all or part of a money transmitting business that affects interstate or foreign commerce and fails to comply with the registration requirements. The penalty is a fine, up to five years in prison, or both (18 U.S.C. 1960).

Registration is not a state license

The federal registration statute does not override state law (31 U.S.C. 5330(a)(3)).

FinCEN's form instructions say registration "does not satisfy any state or local licensing or registration requirements." Check whether each state's law applies to you.

Next steps

Sources

  1. 31 CFR 1022.380, Registration of money services businesses: https://www.ecfr.gov/current/title-31/section-1022.380
  2. 31 CFR 1022.210(e), AML program compliance date: https://www.ecfr.gov/current/title-31/section-1022.210
  3. 31 CFR 1010.430(d), five-year retention: https://www.ecfr.gov/current/title-31/section-1010.430
  4. 31 CFR 1010.821, civil penalty inflation adjustments: https://www.ecfr.gov/current/title-31/section-1010.821
  5. 31 U.S.C. 5330, registration of money transmitting businesses: https://www.law.cornell.edu/uscode/text/31/5330
  6. 18 U.S.C. 1960, unlicensed money transmitting businesses: https://www.law.cornell.edu/uscode/text/18/1960
  7. FinCEN, Money Services Business (MSB) Registration: https://www.fincen.gov/resources/money-services-business-msb-registration
  8. FinCEN, Registration of Money Services Business (RMSB) Electronic Filing Instructions (July 2014): https://www.fincen.gov/system/files/shared/FinCENRMSB_ElectronicFilingInstructions.pdf
  9. FinCEN, FIN-2006-G006, Registration and De-Registration of Money Services Businesses (Feb. 3, 2006): https://www.fincen.gov/system/files/shared/msbregistration_de_registration.pdf
  10. FinCEN, FIN-2019-G001, Application of FinCEN's Regulations to Certain Business Models Involving Convertible Virtual Currencies (May 9, 2019): https://www.fincen.gov/sites/default/files/2019-05/FinCEN%20Guidance%20CVC%20FINAL%20508.pdf
  11. FinCEN, Questions and Answers, General Information about the MSB Registrant Search Web page: https://www.fincen.gov/questions-answers-general-information-about-msb-registrant-search-web-page
  12. FinCEN, Renewal Without Change of the Registration of Money Services Businesses Regulation and FinCEN Form 107, 91 FR 23348 (Apr. 30, 2026): https://www.federalregister.gov/d/2026-08363
  13. 31 CFR 1010.100(e), (ff)(4), (ff)(7) and (kkk), Bank Secrecy Act; provider and seller of prepaid access; closed loop prepaid access: https://www.ecfr.gov/current/title-31/section-1010.100
  14. FinCEN, Final Rule, Definitions and Other Regulations Relating to Prepaid Access, 76 FR 45403 (July 29, 2011): https://www.federalregister.gov/documents/2011/07/29/2011-19116/bank-secrecy-act-regulations-definitions-and-other-regulations-relating-to-prepaid-access
  15. 31 U.S.C. 310, FinCEN: https://www.law.cornell.edu/uscode/text/31/310
  16. 31 CFR 1010.810, enforcement and examination authority: https://www.ecfr.gov/current/title-31/section-1010.810

This guide is general information, not legal advice. Forteris is not a law firm.

Last checked: October 2026

Short answers

How long does a new MSB have to register with FinCEN?

For an MSB that must register, the deadline under the rules of FinCEN (the Financial Crimes Enforcement Network, the Treasury bureau that administers the Bank Secrecy Act, or BSA) is the end of the 180-day period that begins the day after the business is established (31 CFR 1022.380(b)(3)). A business that is an MSB only because it acts as an agent of another MSB is not required to register; one that offers MSB services both on its own behalf and as an agent for others must register (31 CFR 1022.380(a)(3)). The rule does not define "established"; FinCEN's 2019 virtual currency guidance says a non-exempt money transmitter must register within 180 days of starting to engage in money transmission. Registration is filed on FinCEN Form 107, Registration of Money Services Business (RMSB), through the BSA E-Filing System (FinCEN, MSB Registration page; RMSB Electronic Filing Instructions). After that, registration is renewed every two calendar years, and certain ownership and agent changes require re-registration within 180 days (31 CFR 1022.380(b)(2)-(4)).

How often does an MSB have to renew its FinCEN registration?

Every two years. Registration with FinCEN (the Financial Crimes Enforcement Network, the Treasury bureau that administers the Bank Secrecy Act) runs in two-calendar-year periods, and each renewal is filed on or before December 31 of the year before the next period (31 CFR 1022.380(b)(2)-(3)), on a new FinCEN Form 107, Registration of Money Services Business (RMSB), through the BSA E-Filing System (RMSB Electronic Filing Instructions; FinCEN, MSB Registration page). The rule starts the first period with the calendar year in which the business is first required to register. FinCEN's 2006 guidance, written under the former rules, says that if a business registers before its 180-day deadline, its renewal dates are based on the date it actually registered; on that basis, a business that registers in December 2026 has its first renewal due December 31, 2027. Separately, re-registration is due not later than 180 days after a triggering event (for a state-registered MSB, a change in ownership or control requiring re-registration under state law; a transfer of more than 10 percent of voting power or equity interests, unless the MSB must report it to the Securities and Exchange Commission; or a more than 50 percent increase in agents during a registration period), and the event's calendar year starts a new two-year period (31 CFR 1022.380(b)(4)).

Can an MSB de-register with FinCEN?

There is no formal process for de-registering with FinCEN (the Financial Crimes Enforcement Network, the Treasury bureau that administers the Bank Secrecy Act). FinCEN's guidance says a business that has stopped operating as an MSB, or registered by mistake, can only refrain from renewing. FinCEN removes businesses that did not renew from its MSB Registrant Search page once a year, and tells any business whose activities still require registration to renew immediately. That 2006 guidance, written under the former rules, adds that a business ceases to be an MSB when it implements written policies and procedures that take it outside the MSB definition; an MSB that should have renewed but did not is no longer deemed registered, and the consequences can include civil and criminal penalties.

General information, not legal advice. Checked against the cited primary sources in October 2026.