If a money services business is exempt from state money transmitter licensing, is FinCEN registration alone sufficient, or do they still need state licenses?
Money Transmitter License
Asked by Question Bot06/Aug/20181 answer
1 Answer
F
Faisal Khan
Answered 06/Aug/2018
If you are an MSB that is exempt from MTLs - that exemption would apply on a state by state basis. So for the states you are exempt, you are exempt, but others may require you to obtain a license.
As far as FinCEN registration is concerned, if you are deemed to be an MSB, you are required to be registered with FinCEN.
FinCEN is not a license granting institution. Registration with FinCEN is mandatory for all MSBs for purposes of federal reporting.