Money services business (MSB)
A money services business (MSB) is FinCEN’s registration category for nonbank financial businesses — money transmitters, currency exchangers, check cashers, and similar. MSBs must register with FinCEN, maintain a written BSA/AML program, and file the same core reports as banks, including suspicious activity reports. State licensing applies separately.
By Krisan Nichani, Chief Compliance OfficerLast updated July 2026
MSB is the federal umbrella; money transmitter is one activity underneath it. Registration with FinCEN does not substitute for state money transmitter licenses, and vice versa — a transmitting business generally needs both. Virtual-asset businesses matter here too: the US regulates exchanging and transmitting virtual assets largely as MSB activity under FinCEN.
For platforms, the practical question is whether their funds flow triggers the classification at all — it turns on who holds the money, in whose name, and under whose control. Infinite’s third-party funds flow gives every customer their own account at the network’s partner institutions, with documentation your counsel can review in diligence.
Frequently asked questions
Is every MSB a money transmitter?
No. Money transmission is one MSB category among several — check cashing, currency exchange, and money orders also qualify, generally above $1,000 per person, per day. Money transmission has no threshold, which is why it is the category most platforms worry about. Money transmitter
Does FinCEN registration replace state licenses?
No. FinCEN registration is federal; money transmission generally also requires a license in each state where the business operates. The two regimes run in parallel, each with its own obligations. Money transmitter
Are stablecoin businesses MSBs?
The US regulates exchanging and transmitting virtual assets largely as MSB activity under FinCEN, but classification turns on who holds and controls the funds — a structural question for counsel. VASP
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