How to File FinCEN Form 107: FinCEN Registration Guide for MSBs

Filing FinCEN Form 107 is a critical step for money services businesses (MSBs) under U.S. law, but it can be daunting for first-time founders. In this guide, we’ll break down how to file FinCEN Form 107, what documents you need, common pitfalls, and what happens after you submit your registration. 

Throughout, we’ll also highlight why partnering with a specialized compliance firm like Brico can simplify the process, help you avoid costly mistakes, and provide strategic guidance beyond the form. Brico specializes in fintech compliance and MSB licensing, offering hands-on expertise for early-stage MSBs. 

By the end, you’ll understand how to register with FinCEN and why working with Brico as a trusted MSB compliance partner can save you time, money, and headaches.

What Is FinCEN Form 107 and Who Needs to File It?

FinCEN Form 107 is the form used to register your business as an MSB with the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN). Under the Bank Secrecy Act, most money services businesses are legally required to register with FinCEN. You must file Form 107 if your company provides any MSB activities such as:

• Money transmission (transferring funds for customers, including digital payments or cryptocurrency transfers)
  
  
• Currency exchange or dealing (converting one currency to another)
  
  
• Issuing or selling money orders, traveler’s checks, or stored value (prepaid cards, etc.)
  
  
• Check cashing services
  
  

If you provide one or more of these services, you’re an MSB and must register with FinCEN unless an exception applies. (Certain small-scale activity under $1,000 per person/day can be exempt for some categories, but money transmitters have no minimum threshold and they must register regardless of volume.) Note that banks and firms already regulated by the SEC or CFTC are not MSBs, and if you operate solely as an agent of another MSB, you don’t have to register on your own. However, if you conduct MSB activities on your own behalf (even while acting as an agent for another), you must register. When in doubt, it’s safest to file – failing to register when required can lead to serious penalties, as we’ll cover below.

Why FinCEN MSB Registration Matters (and the Risks of Non-Compliance)

Registering as an MSB is a legal obligation with teeth. Federal law requires MSBs to register with FinCEN within 180 days of starting operations. Skipping this step or filing late can put your startup in violation of the Bank Secrecy Act. Civil and even criminal penalties may apply if you fail to register. In fact, failing to register can trigger fines up to $5,000 per day for each day the violation continues, and in extreme cases, even criminal fines or imprisonment up to five years. Such penalties can be devastating to a young fintech company.

Beyond direct fines, operating unregistered creates knock-on risks. You could face difficulty securing bank accounts or investment (since banks and VCs check if you’re properly registered). You will also harm your reputation with regulators. In short, MSB registration is not optional: it’s foundational when launching a compliant fintech venture.

This is where Brico’s compliance expertise becomes invaluable. Brico’s team lives and breathes fintech regulations, ensuring you register correctly and on time, so you avoid costly fines or enforcement actions. Brico simplifies the Form 107 filing process and double-checks every detail, giving founders peace of mind. With Brico, you’re far less likely to make an error that could invite regulatory scrutiny. As we outline how to file the form, we’ll note opportunities where Brico can smooth the way.

Step-by-Step: How to File FinCEN Form 107

Filing FinCEN Form 107 is primarily done online through FinCEN’s BSA E-Filing portal. Below is a step-by-step guide:

1. Determine if you need to register – First, confirm that your business meets the MSB criteria (covered above). If yes, mark your calendar: you must file Form 107 within 180 days of starting the MSB’s operations. If unsure, Brico can provide clarity on your MSB status and obligations.
   
   
2. Gather required information – Collect all the business and ownership details needed for the form (see the checklist in the next section). This includes your company’s legal name, address, EIN, the types of MSB services you offer, information on the owners or controlling persons, and any branches or agents. Having these details organized in advance will make the online filing smoother. Brico helps clients compile all required information upfront, ensuring nothing critical is missing.
   
   
3. Create a BSA E-Filing account – If you don’t already have one, go to FinCEN’s BSA E-Filing System and register for an account. This is the online portal where you will submit FinCEN Form 107 (also called the RMSB – Registration of Money Services Business – report). Account approval may take a short time, so do this before you intend to file. Brico can guide you through the account setup or even handle the electronic filing on your behalf.
   
   
4. Complete FinCEN Form 107 online – Once logged in, start a new RMSB (FinCEN Form 107) filing. Fill out the form fields with your business information. Key parts of the form include:
   
   
   
   • Business identifying information (name, “doing business as” names, address, EIN/tax ID, etc.)
     
     
   • Owner or controlling person information (the individual who is responsible for the registration – typically a founder/CEO or compliance officer, who will electronically sign).
     
     
   • MSB activities provided (check the boxes for money transmitter, exchanger, check casher, etc., as applicable).
     
     
   • Number of branches and number of agents (if you have outlets or authorized agents, you report how many).
     
     
   • FinCEN Form 107 also lets you indicate if this is an Initial Registration (Box 1a) or a Renewal (Box 1b) or other filings like Corrections or Re-registration (if applicable for changes in ownership, etc.). For a first-time filing, you’ll select initial registration.
     
     
5. Pro Tip: Ensure every required field (often marked with an asterisk) is completed accurately. Missing critical info (like your EIN/tax ID) can cause issues – e.g. FinCEN uses the business’s Tax ID to index your registration; leaving it out could prevent your MSB from appearing in FinCEN’s public registration list. Brico’s compliance specialists double-check all form entries so nothing vital is omitted. Brico’s hands-on service means an expert can walk you through each question on Form 107, or even fill it with you, to avoid errors that a first-timer might make.
   
   
6. Submit the form electronically – When everything is filled in, submit the form through the E-Filing system. E-filing is mandatory (FinCEN stopped accepting paper MSB registrations after 2012). The good news is that electronic submissions are processed faster. Typically, FinCEN will add your company to its MSB registrant database within approximately two weeks of filing. Before you log off, save a copy of the submitted form (or confirmation page) for your records. FinCEN no longer mails acknowledgment letters for MSB registrations; your proof of filing is the electronic receipt and the public listing on FinCEN’s site.
   
   
7. Save records and mark your calendar – After submission, retain a copy of the filed Form 107 and any supporting documentation for at least five years (a regulatory requirement). Regulators will ask to see this during exams. Also, note your assigned registration number/BSA ID, as you’ll need that for renewals. Most importantly, set a reminder to renew your FinCEN registration every two years by filing an updated Form 107 (we’ll discuss renewal more below). Brico’s MSB licensing platform assists customers in tracking deadlines to ensure you won’t accidentally miss your biennial renewal.
   
   

By following these steps, you can successfully register your fintech as an MSB. However, the process can be much less stressful with experienced guidance. Brico’s team streamlines each step – from preparing your info, to navigating FinCEN’s portal, to post-filing follow-ups – so you can focus on growing your startup while staying compliant.

Checklist: Information Required to Register as an MSB (FinCEN Form 107)

Before you file, make sure you have the following information and documents on hand. This checklist covers the key items FinCEN Form 107 will ask for:

• Business Details: Legal name of your business (and any DBA or trade names), principal business address (U.S. location required), and your EIN (Employer Identification Number) or other Tax ID. Also gather contact information like business phone number.
  
  
• Owner/Controlling Person: Name, title/position, and contact details of the owner or controlling person who will be listed on the form. This is the individual responsible for the MSB (for a startup, likely the CEO or a co-founder). If your business is a corporation, an authorized officer can sign on behalf of the company. Ensure this person’s information is accurate and that they will be the one to electronically sign the submission.
  
  
• MSB Activities and Services: A description of the money services your business provides. FinCEN Form 107 has checkboxes for categories like money transmitter, currency dealer or exchanger, check casher, issuer/seller of money orders or traveler’s checks, etc. Mark all that apply to your business’s operations. (If you’re not sure which categories fit your model, Brico’s experts can help interpret FinCEN’s definitions so you register under the correct business types.)
  
  
• Locations and Agents: The number of branches or physical locations your MSB has, and the number of agents or authorized delegates (if any) that provide services on your behalf. New startups might have zero in both categories (which is fine), but the form will ask for this count. If you have agents, you are also required to maintain a separate agent list updated annually (including agent names, addresses, etc.), though that list is not submitted with Form 107 – it’s part of your recordkeeping. Brico can advise on how to set up proper recordkeeping for agent information if your business model involves agents.
  
  
• Estimated MSB Volume (Optional): It’s good practice to know your expected transaction volumes, as supporting documentation. FinCEN guidance suggests keeping an estimate of your business’s projected volume for the coming year on file. While the form itself might not explicitly ask for a dollar volume, being prepared with this data is wise for your own compliance program and in case regulators ask.
  
  
• Other Supporting Info: Any state-level registrations or licenses you’ve obtained (if applicable) and relevant documents about your business’s ownership/control structure. While FinCEN doesn’t require you to upload these with Form 107, you should have them handy and keep copies with your registration file. Also, if you previously registered and are renewing, you’ll need your prior registration’s BSA ID number for the renewal form.
  
  

Having all this information ready will make the FinCEN registration process much smoother. Brico assists customers in compiling these details via an organized onboarding process – we’ll provide you with tailored checklists and gather the needed data efficiently. This reduces the likelihood of an “oops, I forgot that detail” moment during filing.

Related: What Is a Money Services Business (MSB)? MSB Registration Explained

Common Mistakes to Avoid When Filing FinCEN Form 107

Even a straightforward form can lead to errors if you’re unfamiliar with it. Here are some common mistakes fintech founders should avoid:

• Missing the 180-Day Deadline: A frequent pitfall is not realizing when you must register. Remember, you have 180 days from the day your MSB is established to file the initial FinCEN Form 107. Delaying beyond that is a violation. Mark this deadline early. Brico’s compliance team helps new MSBs get registered well before the cutoff, avoiding any lapse.
  
  
• Incomplete or Inaccurate Information: Submitting Form 107 with blank required fields or typos can cause problems. Certain fields are mandatory for FinCEN to accept the registration. For example, forgetting to include your Taxpayer Identification Number (EIN) is a known mistake. FinCEN relies on the TIN to index your registration; if it’s missing or incorrect, your MSB might not show up on FinCEN’s public registration list, defeating the purpose of registering. Always double-check the form. (With Brico, every application undergoes a thorough review by our experts to catch errors like this before submission.)
  
  
• Wrong Filing Type (Initial vs Renewal vs Update): Ensure you select the proper filing type on the form. If it’s your first registration, check Initial Registration. If renewing, check Renewal (and include your previous registration ID). For changes like certain ownership transfers or error corrections, the form has specific options (Re-registration or Correction). Selecting the wrong box can lead to confusion, a negative finding during a future state or federal exam, or an incomplete registration. When Brico manages your filing, we’ll ensure the form is filed under the correct designation.
  
  
• Not Retaining Proof and Documentation: After filing, don’t forget to save a copy of the submitted form and any confirmation. Also retain the supporting documents we discussed (like the business volume estimate, ownership info, etc.) for five years. Many founders file and move on – only to scramble later when asked for proof of registration or during an exam. Avoid that scramble by keeping a dedicated compliance file. (Brico maintains organized records for all client filings, so you can produce any needed document at a moment’s notice.)
  
  
• Forgetting to Renew Every 2 Years: An initial MSB registration isn’t “once and done.” You must renew your FinCEN registration every two years to stay active. The renewal must be submitted by December 31 of the second calendar year after your initial registration. For example, if you registered in 2025, your renewal is due by December 31, 2027. Missing a renewal deadline technically means your MSB is no longer in compliance until you re-file – which could expose you to penalties. Mark your calendar far ahead. Brico’s licensing platform automatically tracks renewal deadlines and can even handle the biennial renewal filing for you, so you never risk falling out of compliance.
  
  
• Assuming FinCEN Registration Equals State Licensing: Many first-timers mistakenly believe that registering with FinCEN gives them permission to operate everywhere. In reality, FinCEN registration is not a license to operate an MSB – it’s a federal compliance requirement. FinCEN explicitly notes that whether you have registered or not “has no relevance to whether a person must obtain a state license” to engage in the business. Don’t neglect state licensing (more on this below). Brico’s specialists frequently help customers to understand the difference and ensure you pursue the required state licenses in parallel. (Put simply: FinCEN registration doesn’t replace the need to apply for, say, a money transmitter license in states where you plan to serve customers.)
  
  

Avoiding these mistakes will save you time, money, and regulatory trouble. Working with Brico dramatically lowers these risks – our experience with early-stage MSBs means we know exactly where founders tend to slip up, and we proactively guide you around those pitfalls.

After Submission: What to Expect Next

Once you’ve successfully filed FinCEN Form 107, here’s what happens and what you should do post-submission:

• FinCEN Registration Confirmation: As mentioned, FinCEN no longer sends paper acknowledgment letters for MSB registrations. Instead, your proof of registration is the electronic confirmation and your business’s inclusion on FinCEN’s MSB Registrant Search list. Roughly two weeks after e-filing, check FinCEN’s online MSB Registrant Search tool to find your company name. This public list is used by banks and regulators to verify that an MSB is registered. If you don’t see your business after a few weeks, there might be an issue (e.g. an error in your submission like a missing TIN as noted above). In that case, a correction filing may be needed. Brico monitors the status of client registrations – we’ll confirm your MSB appears on the FinCEN list and quickly resolve any hiccups.
  
  
• Internal Compliance Program: FinCEN registration is just one aspect of MSB compliance. After registering, you are expected to implement and maintain an effective Anti-Money Laundering (AML) program and comply with recordkeeping, reporting, and other Bank Secrecy Act requirements applicable to MSBs. This includes steps like appointing a compliance officer, training staff on AML obligations, establishing written policies, and filing reports such as Suspicious Activity Reports (SARs) if needed. While Form 107 doesn’t cover these, regulators will assume that once you’re registered, you will follow through on these obligations. Brico provides strategic compliance guidance beyond just Form 107, so you remain in good standing post-registration.
  
  
• Renewals and Updates: Mark your calendar for renewal (every 2 years by year-end, as discussed). FinCEN does not typically send reminders; it’s on you to remember. Also, if certain changes occur in your business, you may need to file an update. For instance, if you undergo a major ownership change or a 50% increase in agents, FinCEN rules call for a re-registration (essentially filing a new Form 107 to update the details). Similarly, if you discover you made an error in your original filing, you should file a corrected Form 107 (check the “Correction” box and attach the prior report or acknowledgment). Staying on top of these changes is important to keep your registration accurate. Brico assists clients with any necessary updates or renewals – if your business changes or grows, we’ll ensure your FinCEN filings keep pace.
  
  
• State and Other Registrations: After your federal MSB registration is done, you should turn your focus to any state-level requirements (if not already in progress). We’ll dive deeper into this next, but be aware that federal registration does not grant you authority to operate as an MSB in any particular state. Many states require separate licenses (like Money Transmitter Licenses) to legally offer services to residents. It’s wise to start those applications early, as they can take months. Brico’s core service is helping fintech startups navigate these state licensing hurdles quickly and efficiently.
  
  

In summary, after submitting Form 107, verify your registration, maintain required compliance practices, and prepare for renewals and additional licenses. With Brico by your side, you won’t be left to figure out these next steps alone. We continue supporting your compliance journey long after the initial FinCEN form is filed.

Beyond FinCEN: Don’t Forget State MSB Licensing

One of the biggest misconceptions among new fintech MSB founders is that FinCEN registration is the only step needed to launch their service. In truth, FinCEN registration is just the first federal step in MSB compliance. Operating as an MSB often requires obtaining state licenses in each state where you do business (especially for money transmitters). FinCEN itself makes clear that its registration is separate from state licensing – you must consult each state’s rules to determine licensing needs. In other words, being listed with FinCEN does not mean you have a “license to operate” as an MSB in any given state.

For example, if your fintech will transmit money or crypto for customers in California, New York, Texas, etc., you’ll likely need a money transmitter license (MTL) from those states’ regulators. Each state has its own licensing process, fees, application requirements, and ongoing compliance obligations. Navigating 50 states (or even a handful of key states) can be a massive undertaking – far more complex than the FinCEN Form 107 filing. State regulators also expect a higher bar of compliance readiness (detailed business plans, compliance policies, minimum net worth or surety bond, background checks for executives, and more).

This is where Brico’s support is invaluable on a broader scale. Brico specializes not only in FinCEN registration but also in state-level MSB licensing. Our platform and experts help fintech startups map out which state licenses are needed and manage the end-to-end licensing process. Rather than juggling a maze of state forms and deadlines on your own (which can be overwhelming and confusing, even for experienced teams), you can leverage Brico to streamline it. We keep track of the ever-changing state requirements – from one state’s fingerprinting rules to another’s cybersecurity questionnaire – so you don’t have to. Our hands-on service ensures your applications are complete and compliant, vastly improving approval chances and speed.

By using Brico for state licensing, fintech startups have saved significant time and money. We replace the need for expensive law firms or endless spreadsheets with an all-in-one licensing platform, expert guidance included. Brico’s fintech compliance specialization means we understand the nuances of money transmitter laws and how they apply to modern fintech models (payments apps, crypto exchanges, remittance platforms, etc.). We’ve assisted numerous early-stage MSBs in quickly obtaining multiple state licenses, enabling them to scale across the U.S. with confidence. Simply put, Brico helps you launch faster and stay compliant, turning the daunting patchwork of state regulations into a manageable process.

In summary, don’t stop at FinCEN registration. Ensure you address state MSB licensing early in your roadmap. By partnering with Brico, you’ll have a dedicated ally to tackle these challenges efficiently, avoiding the delays and frustrations that can come with DIY licensing attempts.

Simplify MSB Registration and Compliance with Brico

Filing FinCEN Form 107 and navigating MSB regulations can feel like a heavy lift, but you don’t have to do it alone. Brico is here to simplify the entire compliance journey for fintech startup founders and CEOs. We pride ourselves on being a trusted MSB compliance partner that offers more than just paperwork assistance:

• Expert Guidance: Brico’s team consists of compliance specialists who focus exclusively on fintech and MSB regulations. We stay on top of FinCEN rules and state regulator expectations, so you get up-to-date advice without having to research every law change. This strategic guidance helps you make informed decisions (for instance, which states to prioritize for licensing, or how to design an AML program that regulators will approve).
  
  
• Hands-On Service: When you work with Brico, you’re not getting a generic software that leaves you to figure things out. You get personalized, white-glove service. Our experts will walk you through forms like FinCEN 107 step-by-step, review your entries, and even handle submissions. We’re available to answer your questions at every turn. It’s like having an in-house compliance officer, at a fraction of the cost.
  
  
• Fintech Compliance Specialization: Unlike general consultants, Brico works day in and day out with fintech startups and financial institutions. We understand novel business models (from digital wallets to crypto platforms) and how they fit into MSB definitions. This specialization means we can anticipate challenges unique to fintech and address them proactively. Early-stage MSBs often face skepticism from regulators: Brico helps present your business in the best light to authorities by ensuring applications are complete and compliance programs sound.
  
  
• Avoiding Costly Mistakes: The stakes are high in MSB compliance. A simple oversight on Form 107 or a missed license could cost you thousands in fines or lost business opportunities. Brico’s involvement drastically reduces the risk of such costly mistakes. We’ve seen where others go wrong, and we put those learnings to work for you. By getting it right the first time, you save money in the long run – and avoid the pain of having to fix compliance issues under stressful conditions.
  
  
• State Licensing and Beyond: Brico shines when it comes to multi-state licensing strategy. We’ll help you prioritize which licenses to get based on your growth plans, prepare all required documentation, and manage the submission and follow-up process. Our track record includes accelerating licensing timelines (clients often get licensed 5x faster than industry norms) and cutting direct costs (our flat-fee model and efficiency can save 70–90% vs. traditional law firms on licensing costs). Once licensed, we continue to support you with renewal management and ongoing compliance (so you keep those licenses in good standing).
  
  
• Peace of Mind: Perhaps most importantly, partnering with Brico gives you peace of mind. Instead of losing sleep over regulatory requirements, you can focus on building your product and serving customers. You’ll know that professionals are handling the compliance heavy lifting, and that your startup is meeting its obligations. This peace of mind is invaluable when you’re juggling all the other aspects of growing a company.
  
  

Ready to simplify your FinCEN registration and MSB licensing? Get a demo of Brico to learn how we can tailor our solutions to your fintech startup. Whether you need help filing FinCEN Form 107, guidance on state money transmitter licenses, or a comprehensive compliance strategy, Brico is the partner you can trust. Don’t let regulatory complexity hold back your innovation – with Brico’s expertise, you can confidently meet all MSB requirements and accelerate your business growth.

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Disclaimer: This article is for informational purposes only and does not constitute legal, financial, or regulatory advice. Brico is not a law firm and does not provide legal counsel. Licensing requirements vary by state and depend on your specific business model and circumstances. You should consult with qualified legal counsel before making any licensing decisions or taking action based on this content.