FORTERIS.Risk & Compliance Group

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.

It takes about five minutes. Your answers stay in your browser unless you choose to send them to Forteris at the end, with a message or to get your result by email.

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

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.

You have not started the check yet. You can still send Forteris a question.

We use your details and answers to reply to you, to follow up on your inquiry and to prioritize the inquiries we receive. We do not sell or rent them, and there is no mailing list attached to this form. See our privacy notice.

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.