Money Transmitter License Solutions | Pre-licensing Assessment | Money Transmitter License Application Management | Post-licensing Risk and Compliance Management

We offer a comprehensive set of solutions to help you obtain and maintain a U.S. money transmitter license, issued on a state-by-state basis by the state regulators, tailored to:

• Your business goals and objectives
• Your client demographics
• Your countries of operation
• The size of your business
• The available human and technology resources
• Your risk appetite
• Your governance structure
• The products that you offer
• U.S. regulated money transmitters' obligations covering risk and compliance management under financial laws and regulations, the applicable financial licensing requirements, AML/CFT laws, privacy laws, consumer protection laws, and more

We have designed our regulatory licensing solutions to help you navigate the complexities of the U.S. money transmitter licensing regime in a commercially oriented and goal-focused manner, providing effective support for all stages of the U.S. money transmitter licensing process, including but not limited to the following aspects:

• Money Transmitter License Guidance: Advising on a wide range of aspects associated with a money transmitter license as it relates to your specific situation
• Pre-licensing assessment: Covering compliance gap analysis as well as risk and compliance assessment
• Pre-licensing support:
• Drafting the necessary policies and procedures to help you comply with the money transmitter license conditions and financial markets' regulations
• Developing internal controls to help you meet your obligations under the U.S. money transmitter licensing regime
• Money Transmitter License Application Support: Covering the entire licensing process
• Post-licensing Support: Covering
• Ongoing compliance advice
• Comprehensive second-line risk and compliance support, including leading the implementation of your risk management framework (RMF), compliance management framework (CMF), compliance monitoring program (CMP), compliance calendar and checklist, ongoing risk assessments, internal and external reporting, outsourced providers' management, and more
• AML/CFT advice
• AML/CFT compliance management
• Compliance assurance solutions, including compliance assurance program (CAP) development, implementation, and internal control testing

 

 

Service Coverage

This page is about U.S. Money Transmitter licensing. In the United States, money transmission businesses — including international remittance providers, payment processors, and digital currency exchanges - must generally obtain a Money Transmitter Licence (MTL) in each state where they operate. Licensing requirements are set under state money transmission laws, with supervision by state banking or financial services regulators.

At the federal level, money transmitters are often required to also register with FinCEN (Financial Crimes Enforcement Network) as Money Services Businesses (MSBs) under the Bank Secrecy Act (BSA). This subjects them to extensive AML/CFT obligations, including:

• Customer Identification Program (CIP/KYC) requirements,
• Suspicious Activity Report (SAR) filing,
• Currency Transaction Report (CTR) filing, and
• Ongoing AML programme maintenance and independent review.

Because licensing is state-specific, requirements differ, but common obligations for MTL holders include:

• Minimum net worth and surety bond requirements,
• Maintenance of permissible investments to safeguard customer funds,
• Annual reporting and examinations,
• Consumer protection obligations, including receipt disclosures and error resolution, and
• Compliance with federal AML/CFT requirements.

We offer comprehensive support for a wide range of money transmitter license applications in different states, tailored to meet the specific needs of the following businesses:

• Peer-to-Peer Payment Services
• Domestic Money Remitters
• Consumer Money Remitters
• Commercial Money Remitters
• Mobile Payment Providers
• Cryptocurrency Remittance Platforms
• E-Wallet Providers
• Prepaid Card Issuers
• Remittance Service Providers
• Foreign Exchange Dealers
• International Money Remitters
• Digital Money Remitters

You can find more information about our money transmitter license solutions below:

 

US Money Transmitter Licensing Preparation

Pre-licensing Compliance Assurance

Our money transmitter license solutions cover the following focus areas:

• Compliance Goals Analysis: We review your business-specific goals and resources against the suitability criteria for a money transmitter license
• Initial Consultation: We provide guidance on potential risk and compliance issues that may arise during the money transmitter licensing process
• Choosing the Right Jurisdiction: We assist in evaluating regulatory, risk, and compliance environments to determine the most suitable jurisdictions for your money transmitter license, tailored to suit your:

• business objectives,
• operational capacity,
• client base,
• markets of operations,
• and other relevant factors

• Gap Analysis: We identify gaps between your existing operations and regulatory requirements and help you align them in a commercially oriented manner
• Money Transmitter License Application Plan: We help you establish a roadmap to effectively meet the money transmitter license requirements

 

Money Transmitter License Guidance

Selecting the right compliance model is crucial not only for navigating the licensing process but also for maintaining ongoing compliance and avoiding potential breaches. Our U.S. money transmitter licensing solution covers:

• Compliance Model Selection: To help you best comply with the U.S. money transmitter licensing regime and related risk and compliance obligations.
• Corporate Governance Model Selection: We offer practical guidance on establishing effective corporate governance practices that support your risk and compliance oversight.
• Operations Model Advisory: We advise you on optimising your operational and governance models to help you efficiently comply with the licensing requirements for money transmitters and other applicable U.S.-regulated money transmitters' obligations, keeping in mind your specific circumstances, available resources and business goals.

 

Money Transmitter License and Entering a Regulated Environment

We help businesses transition from an unregulated environment to operating under the U.S. money transmitter licensing regime, helping them meet their obligations as a money transmitter license holder.

We also assist already regulated businesses in aligning their existing risk and compliance management structures with the U.S. money transmitter licensing regime requirements.

Our focus areas for this service include:

• New businesses
• Existing money remitter providers operating in unregulated markets
• Regulated money transmitters expanding into foreign jurisdictions
• Financial institutions and/or service providers with established risk and compliance frameworks seeking to offer regulated money transfer services as a new product.

 

Multi-Jurisdictional Compliance

With years of experience managing risk and compliance obligations for businesses operating under multiple financial licenses across various jurisdictions, we help businesses remain compliant with the regulated money transmitters' obligations globally.

 

Money Transmitter License Application

We assist with your license application through ongoing engagement in the U.S. money transmitter licensing process:

• Document Compilation and Review: We compile and review all required supporting documents to support your money transmitter license application.
• Application Form Completion: We help you complete the forms so that all material information is accurate and complete.
• Pre-Submission Review: We can arrange a pre-submission review session with key stakeholders to ensure all parts of your application are understood and agreed upon. This session aligns application details with the actual situation, removing ambiguity.
• Regulatory Liaison: We manage the end-to-end submission process, maintaining clear and effective communication channels throughout the regulated money transmitters' licensing process.
• Timeline Management: We closely monitor and adhere to all necessary deadlines, providing timely updates and adjustments to keep the application process on track.

 

Resolving Money Transmitter License Issues

Having competent compliance advisors is crucial when licensing issues arise. Therefore, our money transmitter license solutions include a range of services to address and resolve these issues effectively:

• Remediation Solutions for Money Transmitter License Applicants: We address and remediate risk and compliance issues identified by regulators, helping your operations align with U.S. money transmitter licensing regime requirements.
• Specific License Conditions Compliance: We can help you manage additional conditions imposed on your money transmitter license, developing a tailored action plan to maintain compliance and facilitate the eventual removal of these conditions with minimal disruption to your business operations.
• Licensing Issues Handling: We address common licensing issues encountered during the U.S. money transmitter licensing process, providing you with solutions to navigate and resolve these challenges efficiently.
• Further Information: You can visit our Compliance Remediation Solutions page for more information.

 

Post-Licensing Support

We offer a full range of ongoing risk and compliance solutions for regulated money transmitters. Our services include, but are not limited to:

Ongoing Risk and Regulatory Compliance

• Regulated Money Transmitters’ Obligations Guidance: We can advise your risk, compliance, management and other teams on meeting the requirements of the U.S. money transmitter licensing regime and other regulatory compliance obligations. You can visit our Compliance Advisory page for more information.
• Regulatory Risk and Compliance Management: We provide dedicated compliance managers to manage your overall compliance. For more information, visit our global Compliance Management Solutions page for Money Transmitters.
• Compliance Assurance Solutions: As part of our compliance assurance solutions, we offer:
• Compliance Assurance Program (CAP) development and testing options
• Internal Controls Design option
• Internal Controls Testing option
• Internal AML/CFT Review option
• Statutory AML/CFT Audit option
• Compliance Training Solutions: We offer training programs to different teams on complying with:

• U.S. regulated money transmitters’ obligations for risk and regulatory compliance management. You can visit our Compliance Training page for more information.
• U.S. regulated money transmitters’ AML/CFT obligations and operational best practices for fraud prevention. You can visit our AML/CFT Training page for more information.

• Crisis Management Planning: We can develop proactive strategies to manage potential compliance crises effectively.
• Anti-Money Laundering (AML) and Counter Terrorist Financing Solutions: We provide a full range of AML/CFT solutions for money transmitters. For more information, visit our Specialised AML/CFT Solutions page for Money Transmitters.
• Advanced Compliance Technologies: We can assist you with selecting and integrating advanced technology solutions, such as compliance automation tools and regulatory technology (RegTech), to streamline compliance processes without disrupting operations.
• Risk and Compliance Framework Adjustments: Including adjustments to risk management frameworks (RMFs), compliance monitoring programs (CMPs), compliance management frameworks (CMFs), and other core procedures and policies to align them with:
• new business goals
• regulatory changes
• changes in your operations
• evolving market conditions
• changes in stakeholders’ risk appetites (your banking partners, insurance companies, liquidity providers, etc.).

 

 

Risk and Compliance Obligations for Money Transmitter License Holders

Money transmitter license holders are subject to various obligations set out in applicable laws and regulations. They are also expected to uphold standards for their conduct and internal operations, as outlined in regulatory guidance or accepted industry practices.

We can help you address these obligations and expectations through comprehensive support across various areas. The list below is not exhaustive:

Money Remitter’s License and Regulatory Compliance Obligations

• Compliance Management Systems: We can help you establish effective compliance programs, compliance monitoring plans, controls testing methodologies, compliance calendars and more.
• Risk Management Frameworks: We can help you develop comprehensive risk management frameworks to fulfil money transmitters’ obligations for identifying, assessing, and mitigating operational, regulatory, strategic, financial and other types of risks.
• Policy and Procedure Development: We can help you draft and implement policies and procedures aligned with the money remitters’ licensing requirements.
• Compliance Monitoring Plans: We can oversee the execution of your CMPs, covering ongoing monitoring of your compliance obligations under the money remitters’ licensing regime.
• Internal Control Testing and Compliance Assurance: We can conduct internal reviews and audits of your controls to test their effectiveness and compliance with the applicable regulatory standards.
• Financial Auditing Standards: We can assist in establishing procedures to help you comply with the audit and assurance requirements under the money remitters’ licensing regime.
• Digital Payment Token Services: If your MSB supports digital assets or stablecoin-based transfers, we can help you develop controls to meet AML/CFT requirements and applicable licensing conditions for digital payment token services, including transaction monitoring, wallet screening, and Travel Rule compliance..

 

Money Remitter’s License and Operational Oversight Obligations

• Oversight of Outsourcing: We can establish a set of effective controls to comply with money transmitters’ obligations for overseeing outsourced services, also covering related obligations under AML/CFT compliance, ISO requirements, and more.
• Structures for Governance: We can help you establish effective governance structures to comply with money transmitters’ obligations and develop an effective approach to overseeing your risk exposure and compliance status across different functions of your business.
• Senior Management Accountability: We can help you comply with money transmitters’ obligations for senior management and key staff conduct and competence.
• Maintaining Operational Resilience: We assist in developing continuity plans to meet money transmitters’ obligations for operational resilience and transaction flow continuity, helping critical business services withstand disruptions.
• Managing Technology Risks: We provide guidance on technology risk management obligations under the money remitters’ licensing regime.

 

Money Remitter’s License and Market Integrity/Transparency Requirements

• Principles for Fair Treatment: We can help you implement controls to comply with expectations that cover adherence to principles of fair treatment and transparent communications with clients.
• Standards for Conduct and Disclosure: We can help you comply with money remitters’ licensing standards for conduct and disclosure.
• Protection of Client Assets: We can help you comply with money remitters' licensing obligations to protect and segregate client assets.
• Resolution of Disputes: We can help you establish effective mechanisms for dispute resolution and complaints management, particularly for retail clients.

 

Money Remitter’s License and Resource Management Obligations

We can help you comply with the following requirements of the money remitters’ licensing regime:

• Adequacy of Resources: Covering financial, technological, human and other resources.
• Competence of Professionals: Covering key personnel, their necessary skills, knowledge, and professional competence.
• Our focus areas include:

• Assessment and Gap Analysis: We can help you evaluate the adequacy of your financial, technological, and human resources against the requirements of the licensing regime.
• Resource Allocation Plans: We can help you develop strategies to optimise resource allocation, covering sufficient capacity for compliance, trading, operations, banking, customer support and other functions and departments.
• Technological Solutions: We can recommend and implement RegTech tools to streamline compliance processes, such as transaction monitoring, reporting, and audit trails.
• Key Personnel Assessment: We can help you assess the skills, qualifications, and experience of key personnel to identify areas for improvement.
• Training and Development Programs: We can design and deliver targeted compliance training programs to upskill personnel in compliance, risk management, and money transfer regulations.
• Representative Vetting: We can help establish a framework for assessing the competence and suitability of advisors and representatives before appointment.
• Compliance Monitoring: We can help develop controls to monitor representatives' adherence to conduct and disclosure obligations.
• Ongoing Training: We can help you create a framework to support continuous education for advisors and representatives on licensing obligations, market integrity, and client interaction standards.
• Regulator Liaison: We can act as an intermediary with regulators to address queries and help you demonstrate compliance with resourcing obligations.

 

Money Remitter’s License and Reporting

• Regulatory Reporting: We can help you prepare and submit periodic and ad-hoc reports covering:
  • Money transmitters’ licensing obligations
  • Money transmitters’ AML/CFT obligations (SMRs, STRs, SARs, cross-border transaction reports, cash transaction reports, and other reporting obligations)
• Compliance Documentation: We can help you develop and maintain the necessary documentation to meet record-keeping obligations under various laws and regulations.
• Audit Readiness: We can prepare you for audits and reviews to demonstrate compliance with regulatory requirements, provisions of the money remitters' licensing regime, applicable operational standards, and more.

 

Related Services

We assist in obtaining money transmitter license equivalents in the following jurisdictions:

• Australia: For more information on the Australian equivalent of a money transmitter license, the AUSTRAC money remitter registration, you can visit our AUSTRAC Money Remitter Registration page.
• United Kingdom: For more information on the UK equivalent of a money transmitter license, the FCA payment institution authorisation, you can visit our FCA Payment Institution Authorisation page.
• New Zealand: For more information on the New Zealand equivalent of a money transmitter license, the DIA money remitter registration, you can visit our DIA Money Remitter Registration page
• Singapore: For more information on the Singaporean equivalent of a money transmitter license, the SPI licence, you can visit our Singaporean SPI License page.
• Prominent Financial Centres and Offshore Tax Havens: We also offer licensing solutions for money remittance businesses in the prominent financial centres and offshore tax havens, including:

• Seychelles
• Cayman Islands
• British Virgin Islands (BVI)
• Belize
• Mauritius
• Gibraltar