A currency exchange becomes a money services business at more than 1,000 dollars "for any other person on any day in one or more transactions" (31 CFR 1010.100(ff)(1)). FinCEN wrote that text into its final rule of 21 July 2011 (76 FR 43585, effective 19 September 2011) "to clarify which entities are covered".
The same line applies to check cashers and to issuers and sellers of money orders and traveler's checks, while a money transmitter qualifies at any amount. Crossing it brings registration, reporting and the AML transaction monitoring every MSB has to run.
What is a money services business (MSB)?
In January 2025 FinCEN found that Brink's Global Services USA, a carrier of bulk currency, had "operated as a money transmitter within the United States without registering" (consent order, p. 8). A carrier is exempt only when it moves currency "from one person to the same person" or to that person's own account. Brink's shipments ran "between parties, which were neither the same person ... nor to accounts owned by the person": about 800 million dollars (p. 9), and a 37 million dollar penalty (p. 27).
The case shows the key features of the money services business definition, which turns on what a business does: a person doing business "wholly or in substantial part within the United States" in one of seven capacities, "whether or not on a regular basis or as an organized or licensed business concern". Banks, SEC or CFTC registrants and a person acting "on an infrequent basis and not for gain or profit" are excluded ((ff)(8)). FinCEN writes "money services business"; "money service business" is the common spelling of the same term.
Which activities make a business an MSB? The seven types
- Dealer in foreign exchange. Exchanges currency of more than 1,000 dollars for any person on any day, such as a bureau de change.
- Check casher. Cashes checks or monetary instruments above the same daily line.
- Issuer or seller of traveler's checks or money orders. Above the same daily line.
- Provider of prepaid access. The participant in a prepaid program that agrees to be the principal conduit for access to information from the other participants.
- Money transmitter. Accepts value "from one person" and sends it "to another location or person by any means", at any amount. Western Union and MoneyGram are the household examples; an exchange of convertible virtual currency and the owner operator of a crypto ATM usually are too (FIN-2019-G001), and so is a hawala operator.
- US Postal Service. Except for sales of postage or philatelic products.
- Seller of prepaid access. Sells prepaid access usable before identity is verified, or more than 10,000 dollars to one person in a day without policies to stop it.
The 1,000 dollar test is counted per customer per day across all of a business's transactions of that type, "in one or more transactions". A currency counter that never sees a single 1,000 dollar exchange is still a dealer in foreign exchange if one customer changes 600 dollars in the morning and 600 in the afternoon (illustrative).
The advantages and disadvantages follow from the same definition. An MSB can work through agents, which it lists each 1 January instead of registering them, but the Bank Secrecy Act duties below apply to it in full, from the AML program to the travel rule.
How does an MSB register with FinCEN, and is that a license?
Registration and licensing are two layers. Each MSB, "whether or not licensed as a money services business by any State", registers with FinCEN on Form 107 within 180 days of being established (31 CFR 1022.380); agents, sellers of prepaid access that are not agents and the Postal Service are carved out. Registration renews every two calendar years, and a new filing is due after a change of ownership or control that requires re registration under state law, a transfer of more than 10 percent of the voting power or equity, or a rise of more than 50 percent in agents. The agent list is revised each 1 January and kept, not filed. The regulation prints a civil penalty of "$5,000 for each violation", each day counting separately; adjusted for inflation, FinCEN's Brink's order cites 10,556 dollars a day for willful failures to register (p. 27).
Licensing is the states' layer. Running a money transmitting business without a required state license, or without FinCEN registration, is a federal crime under 18 U.S.C. 1960; for the state license, that holds "whether or not the defendant knew" one was required. On 29 October 2026 the Conference of State Bank Supervisors reports that 31 states "have enacted the law in full or in part": its Money Transmission Modernization Act. A "US MSB license" is therefore one federal registration plus state licenses, each with its own requirements and fees. The factors to consider when choosing an MSB as a customer or partner start with those two layers: the FinCEN registration and, for a money transmitter, the state licenses.
What does an MSB have to do under the Bank Secrecy Act (BSA)?
MSB compliance under the BSA comes down to five duties:
- A written anti money laundering (AML) program with a designated compliance person, training and an independent review (31 CFR 1022.210).
- A currency transaction report for cash of more than 10,000 dollars in a day.
- A suspicious activity report (SAR) from 2,000 dollars, within 30 calendar days of detection (31 CFR 1022.320).
- Funds transfer records and the travel rule for transmittals of 3,000 dollars or more (31 CFR 1010.410).
- Records kept five years (31 CFR 1010.430).
For a payment MSB these are a bank's duties, usually with a smaller team and higher volumes, so the checks regulators expect from payment providers run as part of the payment, not after it.
What is an MSB called outside the United States?
Table 1. The same activity, jurisdiction by jurisdiction (as of October 2026).
| Jurisdiction | Legal name | Register or license | Supervisor | Source and status |
|---|---|---|---|---|
| United States | Money services business (MSB) | FinCEN registration, plus state licenses for money transmitters | FinCEN; state regulators | 31 CFR 1010.100(ff), revised 2011 |
| United Kingdom | Money service business | Register with HMRC unless FCA supervised; for applications since 10 January 2020, no trading until HMRC confirms | HMRC or FCA | HMRC guidance, updated 18 August 2023 |
| Canada | Money services business | Register with FINTRAC "before beginning to operate"; FINTRAC charges no registration fee | FINTRAC | FINTRAC MSB page, modified 1 October 2025 |
| European Union | No MSB category; currency exchange offices are obliged entities | Payment and e money institutions are licensed; exchange offices fall under AML law | National supervisors | Directive (EU) 2015/849, Art 3(2)(a); the AMLR applies from 10 July 2027 |
| Australia | Remitter | Registration with AUSTRAC as a remittance provider | AUSTRAC | AML/CTF Amendment Act 2024, Schedules 1 to 3 from 31 March 2026 |
| FATF standard | Money or value transfer services (MVTS) | "Licensed or registered"; agents licensed, registered or listed | National authority | Recommendation 14, June 2026 |
The common thread is FATF Recommendation 14: countries should make MVTS providers licensed or registered and act against those that run without either. The labels differ, so a firm that transmits money in five markets holds five permissions under five names. In the EU the payment side is licensed under PSD2, which has no single MSB equivalent.
What changed for MSBs in 2026?
- 31 March 2026. Australia's AML/CTF reforms (Schedules 1 to 3 of the 2024 Amendment Act) took effect.
- 2 September 2026. FinCEN reissued its southwest border geographic targeting order (91 FR 56776). Until 1 March 2027, an MSB in a listed ZIP code in Texas or New Mexico files a currency transaction report from 1,000 dollars in cash, not only above 10,000.
- As of 29 October 2026. CSBS counts 31 states that have enacted its Money Transmission Modernization Act in full or in part.
A crypto exchange that is a money transmitter here carries two more names abroad. The FATF calls it a virtual asset service provider, and in the EU it needs a MiCA authorization as a crypto asset service provider.
Related terms
- Currency transaction report. The US report for cash of more than 10,000 dollars in a day.
- Suspicious activity report. The report a firm files with FinCEN when it suspects a transaction.
- Hawala. Informal money transfer through brokers who settle among themselves.
- Geographic targeting order. A FinCEN order that lowers reporting lines in named places for a set period.
- VASP. The FATF name for a firm that exchanges, moves or keeps virtual assets on a customer's behalf.
- Bank Secrecy Act. The US law behind the MSB registration and reporting rules.
How this entry was checked. Written by Burçak Aydın (Finance Manager, complead) and checked line by line by Javid Khasayev, Senior Anti Fraud Specialist at GoldenPay, this entry rests on the rule texts as they read on 29 October 2026: 31 CFR 1010.100(ff), 1022.210, 1022.320, 1022.380, 1010.410 and 1010.430, 18 U.S.C. 1960, FinCEN's final rule of 21 July 2011 (76 FR 43585), its guidance FIN-2019-G001 and its Brink's consent order of 31 January 2025, the CSBS Money Transmission Modernization Act page, HMRC's and FINTRAC's MSB guidance, Directive (EU) 2015/849, Regulation (EU) 2024/1624, Australia's AML/CTF Amendment Act 2024 and FATF Recommendation 14 (June 2026). Only the currency counter is illustrative. Last reviewed: 30 October 2026.
