About U.S. MSB
We make it easy for you to start your own:
Money Service Business (MSB) Payment Processing – Currency Exchange
We can offer a complete entity package complete with Federal registration as a Money Service Business (MSB). Business activities can include but are not limited to:
● Money Transmission (Payment Services)
● Crypto/Fiat Exchange
● Foreign Exchange (Forex)
The MSB is often used as a legal vehicle in combination with our Swedish Trust Companies in order to widen the range of permissible financial activities.
Our MSB package includes:
● Company documentation in English
● Registration with IRS for Employer Identification Number (EIN)
● Registration with FINCEN as Money Service Business (MSB)
● AML/CFT Policy and Compliance Program
● Resident Agent and registered office fees (year 1)
Total cost for legal entity package: EUR/USD 25,000.00 50% payment of legal entity fees are due upon ordering, with the remaining balance due upon the finalized registration of the Company in accordance with your instructions. Payment of our fees is accepted in EUR, USD, GBP, USDT, ETH, BTC and XRP.
MSB Company Structure
Minimum amount of partners/founders: 1
Qualification requirements: none
Minimum paid up capital: none
Timeframe for new formation: 4 weeks
We choose to structure the MSB as a Limited Liability Company (LLC) in Montana, USA. Montana is the only US state with no state level regulation or license requirements for MSB’s. This means that you only need to register with FINCEN on a federal level. This helps to keep the structure cost effective and straightforward while obtaining the same legal capacity as any state licensed MSB. It should be noted that if you plan on offering financial services in other US states, you will need to comply with state licensing requirements in those jurisdictions.
Questions? Please send a message to ceo@global-money.com.
The registration status of a Montana MSB company can easily be verified online.
To verify our own Montana MSB company registration, please go here and search on the company name, DX MONEY.
To verify the registration as BSA Regulated Provider with FINCEN, please go here and search on the company name, DX MONEY or FINCEN MSB number, 31000228678640.
We sometimes get asked by clients and leads where they can offer services with a specific financial license. In most cases there is of course no list of countries where you can offer your services without further licensing and no list of countries where you cannot (except for of course sanctions lists). Another exception would be for example a EU Electronic Money License or Payment Institution License which could be ‘passported’ to conduct business in all 27 EU member states. In addition to that, they are by no means restricted from taking a non EU customer onboard, but more on that below.
As with any license, if you target a specific jurisdiction with targeted marketing or if you can be considered to be soliciting customers in that jurisdiction in some other way, you are likely to trigger regulatory requirements there regardless of where you were incorporated and licensed. Operating with a physical presence within a jurisdiction would be another potential trigger regardless of where the customers are located.
Look at for example international financial licenses, often referred to as offshore licenses or Class II/B licenses. Say you obtain an international bank license from Puerto Rico (could be Bahamas, Dominica, Panama or any other) which lets you offer services to residents of any jurisdiction except Puerto Rico. In exchange for not offering services to the local population (which the regulators are tasked with protecting) you are subject to lower capital requirements and regulatory requirements in general. If the mere fact that having a customer in a certain jurisdiction would require you to also obtain a bank license there, this would clearly render the Puerto Rico license completely useless and with the legal capacity of offering services in a grand total of zero jurisdictions. This is of course not the case. However, if your Puerto Rico Bank would start advertising in say UK media, running TV and newspaper ads, soliciting deposits specifically from the UK investor public, you will quite quickly hear from the UK Financial Conduct Authority (FCA) and other regulators. The mere circumstance of having UK customers on your books would not necessarily trigger UK regulation, but actively soliciting UK customers and deposits specifically would.
So this logic of course applies to any financial license. You can have a Canada MSB registered with FINTRAC, a Montana MSB registered with FINCEN, a fully licensed bank in Lithuania, the same applies. Targeting a specific jurisdiction where you are not regulated would likely trigger local regulatory and licensing requirements regardless of where you are incorporated and licensed. Also, for MSBs operating in multiple US states, the lack of a license requirement in Montana might not offer any advantage. These businesses would still need to obtain licenses in other US states where they operate.
When it comes to financial regulations, the United States is a patchwork of federal and state laws. One area where this mosaic is particularly pronounced is in the realm of money services businesses (MSBs). Montana stands out as the only U.S. state that doesn’t require an MSB license on the state level. Here’s a look at the implications and reasoning behind Montana’s unique stance.
What is an MSB?
First, it’s essential to understand what an MSB is. The term “Money Services Business” encompasses a broad range of financial service providers that don’t quite fit into the traditional banking mold. This can include money transmitters, currency exchangers, and cryptocurrency-related services. Given their potential for misuse in money laundering or other illicit activities, many states have introduced stringent licensing requirements for MSBs on a state level to promote transparency and maintain consumer trust.
Montana’s Unique Stance
While every other state has imposed some sort of licensing requirement for MSBs, Montana remains an exception. This isn’t because Montana has lax regulations across the board; the state has its fair share of financial and business regulations. Instead, the decision seems to be a combination of Montana’s traditionally libertarian-leaning regulatory environment, a comparatively small market size for MSBs, and perhaps a different risk assessment than other states. It should be mentioned that a Montana MSB is still subject to regulation by the US Bank Secrecy Act (BSA) and needs to be registered with FINCEN as a AML/CFT regulated provider on the Federal level, just like any MSB from any other US state.
Attractive Environment for MSB Startups
Without the regulatory hurdles associated with obtaining a license on the state level, Montana may attract entrepreneurs looking to start or pilot an MSB. It provides a more accessible point of entry for those wishing to dip their toes into the financial services industry without entry requirements such as minimum capital limits. With extremely intricate regulation of for example cryptocurrencies coming up in other jurisdictions, such as the Markets in Crypto-Assets Regulation (MiCA) in Europe, we predict that Montana’s popularity as a jurisdiction for MSBs will only increase.
Interstate Operations:
For MSBs operating in multiple US states, the lack of a license requirement in Montana might not offer a significant advantage. These businesses would still need to obtain licenses in other states where they operate. We see the most demand for Montana MSBs from international clients who are offering services globally but without necessarily targeting any other specific jurisdiction in ways that would trigger regulation there, something that would defy the purpose of having established the Montana MSB in the first place.
Crypto Exchanges in the US are generally regulated as Money Service Businesses. There are some exceptions with more intricate regulations in New York (BitLicense) and Washington. This would likely be the reason why the Crypto Exchange giant KRAKEN offers services in all US states except NY and WA. There are also other potential regulations to consider depending on the nature of the crypto activities in question.
Federal Regulation
Money Transmission Laws: At the federal level, cryptocurrency exchanges have to register as money services businesses (MSBs) with the Financial Crimes Enforcement Network (FINCEN), a bureau of the U.S. Department of the Treasury. MSBs must adhere to anti-money laundering (AML) and know-your-customer (KYC) regulations. Our MSB packages comply with these requirements.
Securities Regulation: If an exchange lists tokens or coins that are deemed to be securities, then the exchange must be registered with the SEC and follow SEC guidelines.
Commodities Regulation: The CFTC has classified Bitcoin and other major cryptocurrencies as commodities. Exchanges that offer derivatives or futures contracts based on cryptocurrencies are subject to CFTC regulations.
State Regulation
Money Transmitter/MSB Licenses/: Many states require cryptocurrency exchanges to obtain a money transmitter license to operate. All US states except Montana have state level license requirements of varying complexity applying to MSBs.
Crypto Friendly Montana
Montana is generally considered very crypto friendly and as recently as mid 2023 a new bill was passed protecting the right to mine Bitcoin “without being subjected to undue discrimination or requirements”. The proposed law would also ban unequal utility rates for digital asset mining, restrict the authority of local governments over digital asset mining, and disallow targeted taxes on using cryptocurrency for payments. Furthermore, the legislation classifies digital assets as personal property. It stipulates that the Montana Public Service Commission is prohibited from setting up a rate category for digital asset mining, commercial digital asset mining operations, or residential digital asset mining that results in unfairly biased rates. The bill also asserts that the use of digital assets for payment cannot be subjected to extra taxes or fees by either the state or local authorities.
White-label banking is a type of banking service where a financial institution provides its services to other companies, which in turn can offer the same services to their customers under their own brand name. This type of banking has become increasingly popular in recent years due to its ability to offer financial services to customers under a brand name that they trust.
In essence, white-label banking allows companies to offer financial services without having to invest in the infrastructure and technology necessary to provide these services themselves. This is particularly useful for startups or companies that want to expand their range of services quickly without incurring additional costs.
White-label banking services can include a range of products such as loans, savings accounts, credit cards, and payment solutions. The services offered are usually tailored to the specific needs of the company that is offering them, so they can be customized to suit the brand and the target market of the company.
One of the key benefits of white-label banking is that it allows companies to focus on their core competencies while leaving the financial services to the experts. This means that companies can concentrate on building their brand and growing their customer base, while the white-label banking partner handles the backend processes such as compliance, risk management, and regulatory reporting.
Another advantage of white-label banking is that it can help companies to enter new markets or expand their offerings in existing markets. By partnering with an established financial institution, companies can leverage their expertise and reputation to offer financial services to a wider audience. This can help companies to gain a competitive advantage and increase their revenue streams.
However, there are also some potential drawbacks to white-label banking. For example, companies may lose some control over the customer experience, as the financial services are being offered under a different brand name. This can be mitigated by choosing a white-label banking partner that is aligned with the company’s values and brand, and by maintaining open communication with the partner to ensure that the customer experience is consistent with the company’s vision.
Another potential challenge with white-label banking is that it can be difficult to switch providers once the services are up and running. This is because the technology and infrastructure used by the white-label banking partner may be proprietary and difficult to migrate to a different platform. Companies should therefore choose their white-label banking partner carefully and ensure that they are committed to a long-term partnership.
In conclusion, white-label banking offers a range of benefits for companies that want to offer financial services to their customers under their own brand name. By partnering with an established financial institution, companies can leverage their expertise and reputation to offer high-quality financial services to a wider audience. While there are some potential challenges to consider, the benefits of white-label banking make it an attractive option for companies that want to expand their offerings quickly and efficiently. We offer our Swedish Trust Company packages complete with the leading white-label banking platform EBANQ.
White label debit card issuing has become increasingly popular in recent years as more and more businesses seek to offer payment services to their customers. In essence, a white label debit card is a card that is branded with the logo and other identifying features of the issuing company, but is actually issued by a third-party financial institution.
The concept of white label debit card issuing is relatively simple. A business or organization that wants to offer its customers the ability to make payments using a branded debit card enters into a partnership with a financial institution that provides the necessary infrastructure for issuing and managing the cards. The financial institution typically handles all the back-end processing, including transaction processing, fraud detection, and account management, while the business is responsible for marketing the card and providing customer service.
One of the primary benefits of white label debit card issuing is that it allows businesses to offer their customers a convenient and branded payment solution without having to invest in the technology and infrastructure required to manage the cards themselves. This can be especially beneficial for small and medium-sized businesses that may not have the resources to develop and manage their own payment systems.
Another advantage of white label debit card issuing is that it can help businesses build brand loyalty and increase customer engagement. By offering a branded payment card, businesses can create a more personalized and immersive customer experience, which can help to foster stronger relationships and drive repeat business.
In addition, white label debit card issuing can also help businesses generate new revenue streams. Many financial institutions offer revenue-sharing models that allow businesses to earn a portion of the fees generated by the use of the cards. This can be a significant source of income for businesses that have large customer bases or high transaction volumes.
However, it is important to note that white label debit card issuing is not without its challenges. One of the biggest challenges is managing the relationship with the financial institution that provides the back-end processing. Businesses must ensure that they have a clear understanding of the terms and conditions of the partnership, including fees, revenue sharing arrangements, and liability for fraud and other losses.
Another potential challenge is ensuring that the white label debit card program is properly marketed and promoted to customers. Businesses must have a clear strategy for promoting the card and educating customers on its benefits, features, and limitations.
Overall, white label debit card issuing can be a powerful tool for businesses looking to offer branded payment solutions to their customers. By partnering with a financial institution that provides the necessary infrastructure and expertise, businesses can create a more personalized and engaging customer experience while also generating new revenue streams. However, businesses must be prepared to navigate the challenges of managing the partnership and promoting the card to customers.
This document is intended to be confidential and only for use by the company or individual to whom it is addressed. You should not copy it or use it for any purpose, nor disclose its contents to anyone else. Any information contained in this document is intended to be general in nature and should not be taken as tax, financial, or legal advice in any jurisdiction. The recipient should obtain legal, tax and financial advice in any jurisdiction in which he, she or the company intends to transact business.
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