The licensing and compliance terms a money transmitter actually uses, defined in plain language by practitioners. For the full walkthrough, see the money transmitter compliance guide, or browse all guides in the Learn hub.
A business appointed to receive payment on behalf of a seller of goods or services. In many states this arrangement is exempt from money transmitter licensing on the right facts, because the money is treated as paid to the seller once it reaches the agent. The exemption is state-specific and fact-specific.
The yearly filing each licensed state requires, typically submitted through NMLS. It covers transaction volume, updated financial statements, and any changes to the program, ownership, or key personnel.
A third party a licensee appoints to conduct money transmission on its behalf, sometimes called an agent. The licensee remains responsible for the delegate's compliance, which is why states require sample delegate agreements at licensing.
A transfer of ownership or control above a state-defined threshold, often from an acquisition, an equity raise, or an executive change. It triggers notice or prior-approval filings within set deadlines in most states.
An individual who directs the management or policies of a licensee, whether through ownership or otherwise. Control persons are identified, disclosed, and background-checked during licensing, generally on an NMLS individual record.
The Conference of State Bank Supervisors, the organization of state banking regulators. CSBS developed the Money Transmission Modernization Act and operates NMLS, which makes it the center of gravity for multi-state licensing.
A periodic review by a state regulator of a licensee's financial condition and compliance, on a cycle of roughly 12 to 36 months. It may be on-site, off-site, or hybrid, and some states accept an independent CPA audit in its place.
The Financial Crimes Enforcement Network, the US Treasury bureau that administers the Bank Secrecy Act. It receives MSB registrations and SAR and CTR filings.
The FinCEN form used to register a money services business. It is filed within 180 days of starting business, renewed every two years, and refiled on a change of ownership.
The NMLS filings used in licensing. MU1 is the company record, MU2 covers individual control persons, MU3 covers branches, and MU4 covers branch managers.
A federal category of non-bank financial business that includes money transmitters, currency dealers and exchangers, check cashers, sellers of money orders and traveler's checks, and providers and sellers of prepaid access. MSBs must register with FinCEN and carry AML obligations.
The act of accepting money or value from one person and transmitting it to another by any means. This activity is what triggers the state licensing requirement.
A business that engages in money transmission. Federally it is a money services business, and it is licensed state by state. As of late 2025, 49 states plus the District of Columbia license money transmitters, with Montana the only state lacking a dedicated regime.
The federal registration of a money services business with FinCEN under 31 CFR 1022.380. It is necessary but not sufficient. It does not authorize money transmission in any particular state, which is what the state license does.
A state license authorizing a business to transmit money within that state. It carries minimum net worth, a surety bond, permissible investments, a BSA/AML program, annual reporting, and an examination cycle.
A model law developed by CSBS and adopted by most states plus the District of Columbia as of late 2025. It standardizes the definitions of money transmission, stored value, and payment instrument, sets tiered net worth and bond requirements, defines permissible investments, and provides for examination coordination among adopting states.
A minimum tangible net worth a licensee must maintain, demonstrated through audited financial statements. Under the MTMA it starts at a base amount and increases with the number of states and with transmission volume, up to a cap.
The Nationwide Multistate Licensing System, the online system most states use for money transmitter applications, renewals, reporting, and surety bond submission. It was originally built for mortgage licensing and later expanded to money services businesses.
Multi-state coordination of examinations among MTMA-adopting states. It lets a licensee operating in many states face shared, coordinated exams rather than a separate full examination from each state.
Liquid, low-risk assets a licensee must hold, such as cash, cash equivalents, and government securities. They are generally required in an amount equal to outstanding obligations to customers, so customer funds are effectively backed dollar for dollar and cannot be used as working capital.
Access to funds or value paid in advance and retrievable through a device, card, code, or other means. Providers and sellers of prepaid access fall within the MSB category and may trigger licensing depending on the model.
Monetary value represented in electronic or other form and available to a holder. The MTMA standardizes how stored value is defined for the purpose of licensing.
A financial guarantee a licensee posts to protect customers and the state if the licensee fails its obligations. Bond amounts tier from a base figure and scale with transmission volume, up to a statutory cap. It is in addition to net worth and permissible investments, not a substitute.
A Bank Secrecy Act requirement that certain originator and beneficiary information travel with qualifying funds transfers, under 31 CFR 1010.410. It is increasingly applied to crypto transfers.
How a given state regulates crypto activity in relation to money transmission. The treatment is heterogeneous: some states have bespoke virtual-currency regimes, some require a separate license, some apply the existing money transmitter rules, and some exempt certain custody-only or wallet-only models. Research it per state.
Compliance Command Center is the money transmitter compliance solution that turns these concepts into a defensible, examiner-ready program across every state you operate in, run by practitioners and leveraged by software.
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