How To Get A MSB License

FAS CPA & Consultants

What are the requirements to obtain an MSB License in the US if I have a company abroad?

First the MSB license is the Money Services Business License is also known as the money transmitter license outside of the US, here in the US basically the MSB license is needed when one person is going to transfer money to another person, third party. Same thing as PayPal, as Western Union. The requirement for someone who is not US citizen or someone who is they are the same, they don’t change. But the basic requirement is that the company shows in addition to the application, shows a money laundering policy, this is a book that the company should show to provides with the application in addition of a business plan explaining how the company is going to operate and this needs to be attached to the application in the state. Here in the US, there is no 1 license application for money service business license, you must apply state by state just like PayPal has 48 MSB licenses in the US. So it all depends where you plan to operate and where your clients will be in addition to all this requirements you also need to submit fingerprints, so someone who is not in the US will need to come to the US and have their fingerprints taken and submitted to the financial division of the state and the state will provide you a code for those fingerprints to be submitted directly to the database of the state. Also, you need at least, it depends on the states because some require thousands of dollars in capital and some states require less, some states like new jersey or New York they are in the 5k to a 1 million dollar in capital. For non us and us citizens they need to have an office with an LLC or corporation already opened. Also, you rent an office, hire one employee, you have a telephone number, a fax number, an email address, and a website.


That is required to start the application, provide a business plan, anti-money laundering policy, fingerprints, identification like passport or driver’s license, if you’re not a us citizen you have to have one employee based in the US who is to be the contact on the application, to act as the shareholder of the company, once you have all this you deposit in the bank the capital and you need a CPA to audit that money, he will issue a report and that will mean that money is there and this report is attached to the MSB license application. If you have a company that has been doing business already you need to audit the financial statements by a CPA and attach that report to the MSB license application, once you have all this documentation you can submit the application to the finance commission of the state and then it will take at least 90 days for the application in addition to that some state require that you also post a bond which is like a guarantee that you give that you are able to provide the initial capital that is required that can go from 50 thousand to 1 million dollar.


When you have all this, you can submit the application, some states like Georgia and Tennessee have created like a joint application where you apply to one state and that application also works for other states and it can be done online. However, states like Florida don’t allow online application and has to be in paper and submitted some parts online. One final requirement is that you must appoint a compliance officer means that that person oversees enforcing the anti-money laundering and all the policies and procedures of the company which you also need to have to start the application. If the employee has experience in compliance and banking then that employee can work as the compliance offer otherwise you have to find one person who can do that, and that is a US Citizen.

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What is the procedure to apply for an MSB license in the US and how long does this process take?

The second is to hire an employee, rent an office, get a telephone, and fax number, get a website and email address.


The third step it will be the deposit of the initial capital in the bank and after that you can start the application, then do the business plan, the anti-money laundering policy and policies and procedures for the company and attach that to the application. If the owner is in the US, then get the fingerprints, if the owner is outside of the US come to the US to get the fingerprints and have the initial capital audited by a CPA in the US. If the company already started activities, it would need an audit report as well. If it is required, get the bond or guarantee, get the compliance officer and put all that information there in the application and all this documents must be attached to the application to be submitted and then it will take 90 days, it might be that the finance department of regulation will require more information and they will call the office to make sure someone is there, and to his has to be real. Remember that this is a license, and you have to comply with the requirements and if you provide false information that will be a felony and can be indicted later on.


If I have an MSB license in a US state, can I do business with other states and receive clients from other states? What to do if I want to cover several states in the US?

Yes, you can but to not a create a false impression that you have a license in multiple states you have to show in big letters that your license is only in Florida so people know. You cannot advertise outside of Florida, and you cannot say that you’re authorize to do business in any other state but in Florida. If you have businesses in other states and want to take those clients, you need a license also in those states. The licenses are not for prestige, they are for protection of the public in the US, so when you are a licensee in any state is not for you only and the only way to protect the client from other states is to get a license in that state where you have clients receiving money from those clients.

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What are the requirements and differences between using a credit card or an electronic Wallet for the transactions of my companies with MSB license in the US?

The MSB license will give you the authorization to do business with this electronic wallet for a third parties. Think similar to a bank account, in this case a electronic wallet doesn’t have the ability for example for accruing interest, so when you open a company you start implementing a system for the service of your clients where you offer this wallet that has crypto money and that money is transferred to a third party and you are doing the transfer, when that happens you need an addition level of policies and procedures to deal with this crypto transactions. The main difference between using a credit card and a electronic wallet is a that the credit card is accepted everywhere however the electronic wallet with crypto is currently not accepted in the US so you cannot pay with that, you would have to convert the money first and later on pay with your debit or credit card. So, the electronic wallet really is just a unit of accumulation you can accumulate money there, but you will not be able to use it in the US unless there is a business that will accept that kind of money specifically.


Readers should note that this article is only intended to convey general information on these issues and that FAS CPA & Consultants (FAS) in no way intends for the contents of this article to be construed as accounting, business, financial, investment, legal, tax, or other professional advice or services.  This article cannot serve as a substitute for such professional services or advice.  Any decision or action that may affect the reader’s business should not rely solely on the contents of this article, but should rather be consulted on with a qualified professional adviser. FAS shall not be responsible for any loss sustained by any person who relies on this presentation.  This article is subject to change at any time and for any reason.

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