General information only. CryptoRegHub provides summaries for informational purposes and does not constitute legal or compliance advice. Always verify with official sources and consult qualified legal counsel before making compliance decisions.
United States — FederalTransfer / paymentsExchange / tradingLive
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General information only — not legal advice
CryptoRegHub provides plain-English summaries of crypto regulations for informational purposes only. This does not constitute legal, compliance, or financial advice. Regulations change frequently — always verify information with official sources and consult qualified legal counsel before making any compliance decisions.
The federal baseline nearly every US crypto business needs. Exchangers and administrators of convertible virtual currency are money transmitters under FinCEN's 2019 guidance — crypto-to-crypto counts the same as crypto-to-fiat. Registration is free, immediate and carries no capital requirement, but it is an AML credential, not permission: it satisfies nothing at state level, and operating unregistered is a federal crime under 18 U.S.C. § 1960. Around 24,856 MSB principals were registered as of April 2026.
Application process
1
Confirm you are an MSB
Exchangers and administrators of CVC are money transmitters (2019 guidance); exemptions include persons regulated by the SEC or CFTC for that activity and agent-only MSBs.
2
Set up BSA E-Filing
Account setup takes around 5–7 business days.
3
File FinCEN Form 107 (RMSB)
Signed by the owner or controlling person, within 180 days of the business being established; maintain the agent list if applicable.
4
Renew every two years
By the 31 December renewal cycle; re-register on any change of ownership or control.
Ongoing obligations
Written AML program — with a designated compliance officer, independent testing and training.
Reporting — SARs, CTRs above $10,000, and the Travel Rule.
Recordkeeping and renewal — biennial renewal; records retained per BSA requirements.
Common rejection & delay reasons
Registration mistaken for permission
It does not authorise anything at state level — the state licence stack applies in full on top.
Missing the 180-day window
Late registration is the most common technical violation; unregistered operation risks criminal liability under § 1960 and civil penalties.
What's changing
CLARITY Act (Senate combined text released 23 Jul 2026; passage uncertain as of late July) would layer CFTC registration categories for digital commodity intermediaries above this baseline — no licensable process exists until rulemaking even if enacted
· proposed
Frequently asked questions
At a glance
JurisdictionUnited States — Federal
RegulatorFinCEN (US Treasury)
TypeRegistration
CapitalNone — registration, not authorisation
Application feeNone — registration is free.
Ongoing feesNo FinCEN fees; the cost is the compliance program itself.
Statutory clockEffective on filing; BSA E-Filing account setup takes around 5–7 business days. Initial registration due within 180 days of establishment.
PassportingNone — federal AML layer only
Last verified28 Jul 2026
Local presence
No US entity requirement for registration itself — but state licensing (separate) usually imposes one.
This guide is for general informational purposes only and does not constitute legal advice. Figures change — always verify with the regulator and consult qualified counsel before applying.