Free check
Do we need to register as an MSB?
Answer a few yes, no, or not sure questions about what your business does with money. You get a screening result that names which parts of the federal money services business (MSB) rule your answers touch, the rule behind each one, what is still open, and what to do next.
This is a screening based on your answers, not legal advice. The screening decides one question: whether your business may need to register with FinCEN as a money services business, under 31 CFR 1010.100(ff) and 31 CFR 1022.380. With a result, the check also lists, for information, federal deadlines that may apply to a business in the categories it names, such as those for CTRs, SARs, OFAC reports and FinCEN 314(a) requests. That list does not change the result, and it covers federal deadlines only, not state ones. Forteris is an independent firm and is not affiliated with FinCEN or any government agency.
The questions
Your result
You changed an answer and there are new questions above. Answer them and this result updates.
This is a screening based on your answers, not legal advice. It is only as good as the answers it was given, and the rules apply to the facts as they really are.
Add my federal deadlines to my calendar
A screening, not legal advice; state deadlines not included. The file holds, as reminders, the dated deadlines in the list above that your answers below place on it. Deadlines that start from an event, such as a suspicious transaction, a blocked payment or a FinCEN request, cannot be dated in advance, and the periods for keeping records are not dates to meet, so both stay in the list and are not put on the calendar. The file is made in your browser and nothing is sent.
Enter the first year of your current two-year period. For a first period, that is the year the note headed Your first period describes, under FinCEN registration renewal in the list above; after a re-registration event, it is the year the note headed Re-registration describes. It is not necessarily the year you filed the form. The renewal reminder is worked out from this year: if the year is wrong, the reminder can fall on the wrong date, even after the real due date. If you are not sure of the year, check your registration period before relying on the reminder, or leave this empty. Without the year, the registration renewal is left off the file.
Leave it empty if you do not share information under 314(b) or do not know the date. Without the date, the 314(b) notice is left off the file.
The yearly revision of the list of agents goes on the file only if you answer yes; otherwise it stays in the list above.
The OFAC annual report of blocked property goes on the file only if you answer yes; otherwise it stays in the list above.
Email me my result
Forteris emails you a short summary of this result: the verdict, the FinCEN registration line, and each category it names, with its rule. The reasons, the next steps and any federal deadline list are not in the email, so use Print or save as PDF below to keep them. Only your email address is needed.
From the free MSB check at forterisrisk.com/msb-check, . Forteris Risk and Compliance Group, LLC is not affiliated with FinCEN or any government agency.
Discuss your result with Forteris
Forteris will review your results and questions and respond, usually within one business day. There is no charge for a first 30-minute call.
What this check covers
A money services business is defined at 31 CFR 1010.100(ff). The definition lists seven kinds of activity, a set of limitations, and dollar thresholds for some of them. The check asks about each one that can apply to a private business, and about who has to register under 31 CFR 1022.380.
Outside this check
- State money transmitter licenses. Most states license money transmission under their own laws, and the state answer can differ from the federal one.
- The GENIUS Act and the rules under it for payment stablecoins. The Act takes effect January 18, 2027. The MSB questions still cover stablecoins.
- Other rules that apply to payment businesses whether or not they are MSBs, such as sanctions (OFAC) and consumer protection rules. The check does not screen for them; the deadline list under a result names federal OFAC reporting and record-keeping deadlines for information only.
- Rules outside the United States.