Regulatory Alerts2006-02-03
Added
Registration and De-Registration of Money Services Businesses
This guidance clarifies Bank Secrecy Act requirements for money services businesses (MSBs) regarding initial registration and renewal with the Financial Crimes Enforcement Network (FinCEN) using FinCEN Form 107. MSBs must renew their registrations every two years by December 31st, with initial registration deadlines varying based on establishment date. While there is no formal de-registration process, FinCEN will omit non-renewing businesses from its public list, deeming them unregistered, which can incur civil and criminal penalties. A business that implements written policies and procedures to no longer meet the MSB definition, such as a check casher falling below the $1,000 daily threshold, ceases to be an MSB and should not renew its registration.