US Financial Licensing — MSB, Money Transmitter, RIA & Broker-Dealer
FinCEN MSB registration, 50-state money transmitter licenses, SEC/state RIA registration, broker-dealer licensing. Strategy and full application support.
What Licensing — MSB / VASP / EMI includes in the US
What you receive
How it works
Useful materials
Where to register and how we differ
Licensing — MSB / VASP / EMI in the US — frequently asked questions
FinCEN MSB (Money Services Business) registration is a federal requirement for businesses transmitting money, exchanging currency, cashing checks, or dealing in cryptocurrency. Registration is free, done online at BSA E-Filing, and takes 1–2 days. It does NOT authorize you to operate in any state. State money transmitter licenses (MTLs) are separate: 49 states plus DC require their own license to transmit money, with fees ranging from $1,000 to $100,000+, surety bond requirements of $25,000–$1M+, and processing times of 6–18 months per state.
A company transmitting money in all US states technically needs a license in each of the 48 states that require one (plus DC) — up to 49 licenses total. Wyoming and Montana are exceptions with lighter regimes. The Nationwide Multistate Licensing System (NMLS) manages applications across most states but each still requires separate approval, fees, and surety bonds. Many fintech startups initially operate in 5–10 states and expand. Total licensing costs across all states can exceed $1M in fees and bond premiums.
New York's BitLicense (issued by the NYDFS) is required for any company transmitting, storing, buying, selling, or exchanging virtual currency with or on behalf of New York residents. It is one of the most stringent state crypto licenses globally, with application fees of $5,000, capital requirements, cybersecurity mandates, and AML program requirements. The application process typically takes 12–24 months. Companies serving New York customers must hold a BitLicense or operate under a charter.
A broker-dealer must register with the SEC and FINRA (Form BD) and comply with net capital requirements (Rule 15c3-1). Investment advisers managing $110M+ in assets must register with the SEC (Form ADV). Advisers below $110M register with their state securities regulator. Both require passing qualifying exams (Series 7/63 for broker-dealers, Series 65/66 for investment advisers). INNOVA CG assists with SEC, FINRA, and state registration filings.
A Prepaid Access provider — any entity that 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 it issues prepaid access that exceeds $1,000 per person per day or allows international fund transfers. Sellers of prepaid access (retailers) also have registration obligations under specific thresholds. Prepaid access providers must also implement full AML programs under 31 CFR Part 1022.