US Financial Licensing — MSB, Money Transmitter, RIA & Broker-Dealer

FinCEN MSB (Money Services Business) registration is a federal requirement for money transmission, currency exchange, check cashing, and cryptocurrency operations. It runs online through BSA E-Filing and takes 1–2 days. But it grants no right to operate in any given state. State money transmitter licenses (MTLs) are separate: 49 states plus DC, fees from $1,000 to $100,000+, surety bonds of $25,000–$1M+, and 6–18 months of processing per state.

A company transmitting money nationwide technically needs a license in each of the 49 states that require one, plus DC. Montana is the sole state with no money transmitter licensing requirement; every other, including Wyoming, requires one. The Nationwide Multistate Licensing System (NMLS) holds the applications, but each state approves separately, with its own fees and surety bonds. Fintech startups usually start with 5–10 states and expand. Total licensing costs across the country exceed $1M in fees and bond premiums.

New York's BitLicense (issued by the NYDFS) is required of any company that transmits, stores, buys, sells, or exchanges virtual currency with or on behalf of New York residents. It's one of the strictest crypto licenses in the world: a $5,000 application fee, capital requirements, cybersecurity mandates, and AML-program requirements. The process runs 12–24 months. You can't serve New York customers without it.

A broker-dealer registers with the SEC and FINRA (Form BD) and holds net capital requirements (Rule 15c3-1). An investment adviser managing $110M+ in assets registers with the SEC (Form ADV); below that threshold, with the state securities regulator. Both roles require qualifying exams: Series 7/63 for broker-dealers, Series 65/66 for investment advisers.

A Prepaid Access provider — anyone who sells, redeems, or issues stored-value products (gift cards, payroll cards, prepaid debit cards) — must register as an MSB with FinCEN under the Bank Secrecy Act if prepaid access exceeds $1,000 per person per day or allows international fund transfers. Sellers of that access (retailers) fall under thresholds too. Plus a full AML program under 31 CFR Part 1022.