FIN Compliance · Payments & money services businesses

MSB Launch Checklist

A free 24-item readiness checklist for payment companies and money services businesses: federal registration, state licensing, ownership records, AML controls and provider selection.

Federal registration and state licenses are separate. Service fees quoted by scope; specialist availability confirmed before engagement.

Six launch-readiness areas

Business model and jurisdiction

Document products, customer types, payment flows and who holds or controls funds.
List intended states, countries, currencies and any virtual-currency activity.
Ask qualified counsel to determine MSB status, state licensing obligations and possible exemptions.
Identify any prior activity before registration or licensing for counsel review.

Entity and ownership records

Collect formation documents, EIN, addresses and organizational chart.
Identify owners, control persons, officers and authorized delegates where applicable.
Prepare ownership history and supporting agreements for specialist review.
Assign a launch owner and a secure document-access process.

FinCEN registration readiness

Confirm federal registration applicability and deadlines with the specialist.
Gather Form 107 information and identify the authorized filer.
Review agent-list and re-registration obligations where applicable.
Retain filing evidence and calendar renewals and change events.

State application readiness

Obtain each applicable regulator's current application checklist, through NMLS where used.
Confirm required entity and individual filings, disclosures and background checks.
Coordinate financial statements, net-worth requirements, permissible investments and surety bonds as required.
Create a state-by-state document, fee and deficiency-response tracker.

BSA/AML and operational controls

Scope a risk-based AML program and designate the responsible compliance officer.
Document applicable identification, due diligence, monitoring and escalation procedures.
Address applicable SAR, CTR, sanctions, recordkeeping and funds-transfer obligations with specialists.
Plan staff training and independent testing appropriate to the business.

Providers and launch decision

Select counsel/licensing specialists, banking/payment providers and a surety broker as needed.
Document security, privacy, complaints, reconciliation and vendor controls.
Confirm approvals and provider onboarding conditions before offering regulated services.
Record remaining gaps, responsible owners, budget, reporting dates and go-live sign-off.

Free MSB Launch Checklist

Download the checklist and record the owner, status and next action for each readiness item. No signup required.

Download MSB Launch Checklist

FinCEN registration is not a state money-transmitter license or government endorsement. Requirements depend on activities and jurisdiction. FIN Group provides readiness and specialist coordination; qualified counsel/licensing specialists handle legal determinations and application work under separate agreed scopes. No license, bank account, launch date or regulatory outcome is guaranteed.

Discuss your launch and target states

Tell us about your business and launch stage. We will assess fit and define the coordination scope before quoting. Specialist fees, filing fees, bonds, background checks and accounting work are separate.

Frequently asked questions

Does FinCEN registration let us transmit money in every state?

No. Federal MSB registration and state money-transmitter licensing are separate. Counsel and the relevant regulators must determine the requirements for your activities and locations.

Who prepares and submits the license applications?

Qualified counsel/licensing specialists perform application work under separately agreed scopes. FIN Group coordinates readiness, document collection, the application tracker and handoffs; this package does not represent FIN Group as the direct application preparer.

What does the coordination package include?

A scoped readiness review, document inventory, specialist handoff, application-status tracker and agreed follow-up coordination. Target states, deliverables, revision rounds, responsibilities and timing are defined in the written engagement.

How much does the package cost?

Fees are quoted after reviewing the business model, target states and existing materials. Counsel/licensing specialists, government and NMLS fees, bonds, background checks, accounting work and software are separately scoped and priced. No fixed package price is being advertised.

Can you guarantee licensing or a bank account?

No. Regulators determine licensing, and banks/payment providers make their own onboarding decisions. Approval, launch timing, bank accounts and regulatory outcomes are not guaranteed.

Related resources and official guidance

State application coordination package FinCEN MSB registration renewal guide FinCEN: MSB registration NMLS: state licensing resources Texas Department of Banking: applicant guidance