Regulatory Licencing and Compliance Advisory for Money Services Businesses and Money Transmitters
Money services business and money transmitter regulation is jurisdictional. There is no single international MSB licence, and the same product can be a registration in one country, a licence in another, and an activity requiring a payment institution authorisation in a third.
FINTRAC money services business and foreign money services business registration in Canada
FinCEN money services business registration and state money transmitter licencing in the United States
AUSTRAC remittance and digital currency exchange registration in Australia
UK routes: payment institution, e-money and, where applicable, HMRC supervision
EU routes: payment institution and electronic money institution authorisation
One financial crime framework designed to satisfy multiple supervisors
How we advise money services businesses & money transmitters
Regulatory Counsel advises remittance businesses, currency exchange providers, payout networks and cross-border payment platforms on where they need to be registered or licenced, what each regulator expects, and how to run one coherent financial crime framework across several regimes.
This page explains how the main regimes differ. The licence pages carry the detailed application requirements for each jurisdiction.
What is the difference between an MSB and a money transmitter?
Money services business is a regulatory category used in jurisdictions such as Canada and the United States that covers several activities, including money transmission, currency exchange, cheque cashing and dealing in virtual currency. Money transmitter is narrower: it describes the specific activity of receiving money for transmission, and in the United States it is licenced state by state in addition to federal registration.
The terminology matters commercially, because the two words describe different levels of regulatory burden. Federal MSB registration in the United States is comparatively quick. State money transmitter licencing is a multi-year, multi-jurisdiction programme with surety bonds, net worth requirements, permissible investment rules and individual state examinations.
The United Kingdom and the European Union do not operate an MSB regime at all. Firms that describe themselves as needing a UK MSB licence usually need a payment institution or electronic money institution permission instead.
How is money transmission regulated in each priority market?
Each of our priority markets applies a different structure. The table below sets out the regulator and the primary route for cross-border money transmission in each.
| Jurisdiction | Regulator | Primary route |
|---|---|---|
| Canada | FINTRAC, with the Bank of Canada for retail payment activities | MSB or foreign MSB registration with FINTRAC, plus registration as a payment service provider under the Retail Payment Activities Act where applicable |
| United States | FinCEN, state regulators through NMLS | Federal MSB registration with FinCEN plus a money transmitter licence in each state where the activity requires one |
| Australia | AUSTRAC | Remittance network, independent or affiliate provider registration, and digital currency exchange registration where relevant |
| United Kingdom | FCA, with HMRC for certain supervised businesses | No universal MSB licence. Authorisation or registration under the Payment Services Regulations 2017 or the Electronic Money Regulations 2011 according to the activity |
| European Union | National competent authorities | No EU MSB licence. Payment institution or electronic money institution authorisation under the applicable EU framework |
| Singapore | MAS | Payment Services Act licence covering cross-border money transfer and related services |
| Hong Kong | Customs and Excise Department | Money Service Operator licence for money changing and remittance |
Which regulator supervises money services businesses in Canada?
FINTRAC registers and supervises money services businesses and foreign money services businesses in Canada for anti-money laundering purposes. Separately, the Bank of Canada oversees payment service providers under the Retail Payment Activities Act, which is a distinct registration with its own operational risk and safeguarding-equivalent requirements.
Treating these as one obligation is a frequent error. A firm can be correctly registered with FINTRAC and still be outside the scope of what the Retail Payment Activities Act requires of it, or the reverse. Foreign firms directing services at Canadian customers should assess foreign MSB registration even where they have no Canadian establishment.
Do United States money transmitters need federal and state approval?
Usually both. Federal registration with FinCEN as a money services business is an anti-money laundering obligation. It does not confer the right to transmit money in any given state. Money transmitter licences are granted by state regulators, most of them through NMLS, each with its own application, bonding, net worth and examination requirements.
Firms entering the United States should plan a state sequencing strategy rather than attempting national coverage at once. Sequencing is driven by customer concentration, agent relationships, bond capacity and the practical review times of individual states.
How is remittance regulated in Australia?
AUSTRAC operates the Remittance Sector Register. Providers register as a remittance network provider, an independent remittance dealer or an affiliate of a network, and must comply with the AML/CTF Act, including an AML/CTF programme, customer identification, reporting of threshold and international funds transfer instructions, and suspicious matter reporting.
Firms dealing in digital assets should assess digital currency exchange registration separately, because it is a distinct AUSTRAC registration from remittance.
How does Regulatory Counsel support MSBs and money transmitters?
We map the regulatory footprint created by the corridors a firm actually serves, prioritise the registrations and licences that unlock revenue, and build a single financial crime framework that can be evidenced to several supervisors without being rewritten for each.
- -Jurisdictional scoping across the corridors and customer base
- -Registration and licence applications, including FINTRAC, FinCEN, state MTL and AUSTRAC routes
- -Enterprise-wide AML and sanctions risk assessment and programme design
- -Transaction monitoring and screening calibration for remittance risk
- -Agent and network oversight frameworks
- -Independent review, examination readiness and remediation
Practitioner observations from money services businesses engagements
The corridor drives the licence map
Founders often ask which licence to obtain first. The better question is which corridors generate revenue in the first eighteen months, because that determines which registrations are commercially blocking and which can be sequenced.
A global template AML programme fails examinations
Supervisors expect the risk assessment to reflect the firm's own corridors, customer types, agent model and payout mechanics. A programme that could belong to any remittance business signals to an examiner that the firm has not assessed its own exposure.
Registration is not authorisation
Registration regimes generally confirm that a firm is within a supervisory perimeter. Authorisation regimes assess whether a firm is fit to operate. Firms that treat a registration as a mark of regulatory approval frequently overstate their status to banks and partners, which damages relationships when tested.
Licences and registrations for this sector
Canada MSB Registration
FINTRAC money services business and foreign MSB registration.
View licenceUS MSB Registration
Federal FinCEN registration and BSA programme requirements.
View licenceUS Money Transmitter Licence
State by state licencing through NMLS.
View licenceAustralia AUSTRAC Remittance
Remittance sector registration and AML/CTF obligations.
View licenceHow we support firms in this sector
Regulatory Licencing & Authorisation
Multi-jurisdiction registration and licencing programmes.
AML & Financial Crime
Risk assessment, programme design, monitoring and screening.
Ongoing Compliance Support
Ongoing supervision, reporting and examination readiness.
Compliance Audit
Independent review of AML and regulatory compliance arrangements.
Map your international MSB and money transmission obligations
Tell us your business model, the markets you serve and the permissions you hold. We will tell you what is actually in scope and what the credible route looks like.
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Related insights
FCA Registration for Money Services Businesses - A Complete UK Guide
Everything UK money services businesses need to know about FCA registration under the MLR 2017, including requirements, timelines and common pitfalls.
MSBsAML Compliance for Money Services Businesses - Practical UK Guide
How UK money services businesses can build and maintain effective AML compliance programmes that satisfy the FCA and avoid enforcement action.
MSBsHigh-Risk Jurisdictions and MSB Compliance - What UK Firms Must Know
How UK MSBs should manage remittance corridors to high-risk jurisdictions while maintaining FCA compliance and managing financial crime risk.
Frequently asked questions
No. The United Kingdom does not issue an MSB licence. Depending on the activity, a firm needs authorisation or registration under the Payment Services Regulations 2017 or the Electronic Money Regulations 2011, and certain businesses such as currency exchange offices may fall under HMRC supervision for money laundering purposes.
No. The European Union does not operate an MSB regime. Cross-border money transmission in the EU is generally provided under a payment institution authorisation, or an electronic money institution authorisation where stored value is involved, granted by a national competent authority.
FINTRAC registration is an administrative process that is usually measured in weeks rather than months, provided the application is complete and the compliance programme is in place. The substantive work is building the compliance programme that FINTRAC will later examine, not the registration form.
As many as the states in which it conducts licensable activity, subject to each state's own exemptions and interpretations. Most firms sequence applications by customer concentration and bond capacity rather than attempting all states at once.
Potentially yes. Canada operates a foreign money services business registration category for firms directing services at persons in Canada without a Canadian place of business. Serving Canadian customers remotely does not automatically place a firm outside the regime.
It depends on the jurisdiction. In Canada, dealing in virtual currency falls within the MSB category. In Australia, digital currency exchange registration is a separate AUSTRAC registration from remittance. In the UK and the EU, cryptoasset activity is regulated under distinct regimes rather than a money transmission permission.
Yes, if it is designed as a group framework with jurisdictional annexes that address local reporting, record keeping and identification requirements. What does not work is a single generic document that ignores the specific obligations of each supervisor.
Primary regulatory sources
This page summarises regulatory requirements for orientation. It is not legal advice. The primary sources below govern.