You've got your money transmitter license. You've registered with FinCEN. You've built an AML compliance program that checks all the boxes.
Then you call your first bank and they reject you.
Or worse—you get onboarded, run smoothly for six months, and they suddenly close your account with two weeks' notice.
If this is your story (or your worst fear), you're not alone. Banking has become one of the most painful and unpredictable parts of running an MSB. Most founders don't see it coming, and most don't know how to fix it.
This guide walks you through why banks treat MSBs the way they do, what actually makes an MSB "bankable," and concrete steps to find a bank that will stay committed to your partnership.
The Hard Truth: Why Banks Decline MSBs (Even Licensed Ones)
Here's what no one tells you: having a money transmitter license and being FinCEN-registered doesn't mean you're bankable.
Banks see MSBs as inherently higher risk. Not because you're doing anything wrong, but because:
Regulatory burden. Banks are ultimately responsible for their customers' compliance. If an MSB customer violates AML/OFAC rules or files suspicious activity reports, the bank gets scrutinized too. Banks must monitor MSBs more closely than typical business accounts, which costs money and requires dedicated compliance resources.
Reputational risk. A single compliance failure by one MSB customer can trigger regulatory examination of the entire bank's MSB program. If the regulators find gaps, the bank gets fined. This means banks are extremely risk-averse about who they partner with.
Cost-benefit math doesn't always work. For many regional and community banks, the fees they can charge an MSB don't justify the compliance overhead. The result: blanket refusals to bank MSBs, even well-run ones.
Offboarding is becoming the default. Banks increasingly terminate MSB relationships at the slightest sign of regulatory scrutiny or unexplained transaction spikes. This is common enough that many MSBs treat banking relationships as temporary.
The good news? This landscape is shifting. In early 2026, federal regulators issued an order restricting banks from making blanket "we don't bank MSBs" statements. Going forward, banks must document specific reasons for account decisions—which means banks with the resources to monitor MSBs have a competitive advantage.
But that advantage only goes to MSBs who make a bank's job easier, not harder.
What "Bankable" Actually Means
A bankable MSB is one a bank can confidently onboard and monitor without regulatory risk.
Here are the core components banks actually look for:
1. Clear Licensing Status and Strategic Coverage
Banks want to know: Are you licensed everywhere your customers are?
If you're operating in a patchwork of states without clear coverage, banks see that as a red flag. It signals either:
- You don't know your regulatory requirements (bad).
- You're intentionally avoiding licensing (worse).
What banks need: clarity on which states you're licensed in, which you're applying to, and why. A visual map of your licensing strategy shows maturity. If you're in pre-license phase and banking for future operations, be explicit about your go-to-market strategy and licensing roadmap.
Pro tip: State your licensing status upfront in the onboarding process. Don't make banks hunt for it. If you're unlicensed in some corridors, explain why: whether it's geographic, regulatory, or strategic reasons.
2. A Documented, Mature BSA/AML Program
This is the single biggest factor in bank decisions.
Banks don't just want to know that you have an AML program. They want to see evidence of a documented, operationalized, and tested program that mirrors what a bank's compliance team would build.
A strong AML program includes:
- Written BSA/AML Policy & Risk Assessment: A formal document that outlines your compliance framework, identifies your specific ML/TF risks (by customer type, geography, product, transaction volume), and details how you're mitigating them.
- Designated Compliance Officer: A named individual responsible for AML oversight, with clear authority and reporting lines.
- Customer Identification Program (CIP): Evidence that you're verifying customer identity before onboarding and maintaining Know Your Customer (KYC) records.
- Transaction Monitoring & OFAC Screening: Policies and procedures for monitoring transactions for suspicious activity and screening customers/transactions against sanctions lists.
- Independent Testing & Audits: Annual independent audits of your AML program by a third-party firm that banks trust (not just self-assessment).
- Staff Training & Documentation: Records showing your team has received compliance training and understands their roles.
- Recordkeeping: Centralized records of compliance processes, policies, and decisions.
The more mature and documented your program, the lower the perceived risk to a bank. This directly reduces onboarding friction and ongoing monitoring requirements.
Pro tip: Don't just say you have an AML program. Bring the actual documentation to the bank's due diligence process. A polished one-pager with your risk assessment summary, org chart, and key metrics builds confidence immediately.
3. Clear Business Model and Customer Profile
Banks need to understand who you are and what you do.
Vague business models are a massive red flag. Specific, transparent business models reduce perceived risk.
Banks will want to know:
- Your core MSB activities. Are you a money transmitter? Remittance provider? Crypto on/off-ramp? Prepaid card issuer? Be specific.
- Customer types and sizes. Are you serving B2B, B2C, or both? Retail customers or wholesale partners? SMBs or enterprises?
- Geographies and corridors. Where are your customers located? Which countries or states do you operate in?
- Anticipated volumes. What dollar amounts are you moving monthly? This helps banks size the monitoring workload.
- Use cases and transaction types. What are your customers actually doing with the service? Are they cross-border remittances, business payments, e-commerce settlements, crypto trades?
- Tech stack and partners. Which third-party vendors do you use for KYC, transaction monitoring, payment processing? Banks want to know the ecosystem.
A clear, detailed narrative of your business actually reduces perceived risk because it eliminates ambiguity.
Pro tip: Create a one-pager or pitch deck for banks that covers these points visually. Include transaction volume trends, SAR history (if applicable), fraud rates, and customer quality metrics. This turns abstract risk into concrete, measurable data.
4. Robust Governance and Ownership Transparency
Banks run enhanced due diligence on MSB ownership and governance to ensure there are no red flags.
They'll want: beneficial ownership documentation, background checks on principals, and clear org charts showing reporting lines and decision-making authority.
If there are any complications (complex ownership structures, international owners, previous regulatory issues), be transparent upfront. Banks will find these anyway during due diligence, and concealing them erodes trust.
Pro tip: Have your KYB (Know Your Business) documentation ready before banks ask for it. This includes articles of incorporation, cap tables, shareholder info, and background check authorizations for all principals.
Why Banks Actually Close MSB Accounts
Understanding the most common reasons for account termination helps you avoid them:
Weak AML Program. Banks often close accounts when independent audits reveal gaps in transaction monitoring, customer screening, or documentation. The solution: invest in a strong independent audit and remediate findings immediately.
Unexplained transaction anomalies. Sudden spikes in volume, new geographies, or new customer segments without notification trigger bank reviews. If approved for $5M monthly volume and you hit $20M out of nowhere, banks get nervous. Communicate changes proactively.
Rising SAR trends. If your SAR filing count climbs year-over-year, banks assume your compliance controls are failing. The solution: don't just file SARs—also demonstrate your monitoring procedures are working as designed.
Failed independent audit findings. If your annual compliance audit flags control breakdowns, banks may decide the risk isn't worth it. Follow up with documented remediation plans and evidence of improvement.
Regulatory examination findings. If your state regulator finds issues during exam, banks assume the same problems exist in your bank controls. Being transparent with your bank before they hear from regulators helps.
Unexplained or high-risk customers. If a bank notices you're onboarding customers in sanctioned countries or from high-risk geographies without documented risk assessment, they'll terminate.
The pattern: banks close accounts when they detect gaps between what you told them about your program and what they observe in practice.
How to Find an MSB-Friendly Bank (Strategic Search)
So where do you look?
Types of banks that actually work with MSBs:
- Community banks and regional banks with established fintech/MSB lending or payment practices. They often have dedicated MSB relationship managers and understand the compliance realities better than mega-banks.
- Banks with crypto/digital asset experience. If you're a crypto-related MSB, banks already credentialed for crypto compliance are more likely to understand your business.
- Specialized fintech-focused banks (BaaS sponsors, digital banks, neobanks, etc.). These banks expect compliance complexity and have scaled teams.
- Banks with correspondent relationships. Some banks specialize in serving other banks' overflow customers, including MSBs others won't take.
- Credit unions with MSB experience. Some credit unions actively seek MSB relationships.
Practical search strategies:
- Ask your lawyer or compliance advisor. If you're working with a fintech law firm, they have relationships with MSB-friendly banks and know which ones are accepting new customers.
- Reach out to other MSBs. Private Slack groups, conferences (Money 20/20, Payments Industry conferences), and trade associations often have founders willing to share their banking story. Get specific names of banks that have worked out.
- Connect through fintech platforms. Banking-as-a-Service (BaaS) platforms like Treasury Prime, Galileo, and Synapse often have established relationships with multiple banks and can facilitate introductions.
- Explore banking networks and consortia. Organizations like the Remittance Industry Network or Blockchain Association sometimes maintain lists or relationships.
- Use financial services recruiters or consultants. Fintech consultants with banking relationships can make warm introductions.
Red flags when evaluating banks:
- Vague risk appetite ("We might work with MSBs").
- No documented MSB experience or track record.
- No dedicated compliance resources for MSBs.
- Unclear or unpredictable pricing/SLAs.
- Long sales cycles with no timeline or next steps.
- Unwillingness to discuss ongoing monitoring or review cadence.
A good MSB bank will have a clear process, a dedicated point of contact, and explicit expectations about documentation and monitoring. If they're evasive or act like they're doing you a favor, move on.
Preparing Your "Bank-Ready" MSB Due Diligence Package
Once you've identified a promising bank, your goal is to make their due diligence as smooth as possible.
Most banks will send a detailed due diligence questionnaire. Expect questions about:
- Business model, products, and customer segments
- Regulatory licenses and registrations
- Financial health and projections
- AML/OFAC/sanctions program details
- Beneficial ownership and governance
- Transactional data and SAR history
- Independent audit results
- Third-party vendor relationships
Rather than waiting for the questionnaire, prepare a proactive "bank readiness package" that includes:
- Executive Summary (1–2 pages)
- Your company, core MSB activities, customer profile, scale.
- Highlight regulatory status, compliance maturity, and banking value prop.
- Regulatory & Licensing Documentation
- FinCEN registration confirmation and renewal proof.
- Money transmitter licenses for all relevant states (or clear roadmap if in-progress).
- State examination results (if available).
- Any regulatory correspondence (especially good-news items like clean exams).
- AML Program Documentation
- BSA/AML Policy (written, formal, version-dated).
- Risk Assessment (summary and detailed, if bank asks).
- Transaction Monitoring Policy and procedures.
- OFAC Screening procedures and sanctions list maintenance.
- Independent audit report (most recent full audit).
- Training records and certifications.
- Business & Financial Snapshot
- Historical and projected financials (3–5 years if available).
- Transaction volumes, customer growth, SAR trends (visualized).
- Beneficial ownership documentation.
- Key personnel bios and background check authorizations.
- Governance & Risk Management
- Org chart with compliance roles and responsibilities.
- Board minutes or governance docs showing compliance oversight.
- Third-party vendor risk assessment (list of key vendors, their role, your monitoring approach).
- Specific Bank Questions (Anticipated)
- Responses to common onboarding questionnaire items.
- Use cases and transaction examples (anonymized).
- Dispute/complaint process and resolution history.
The goal isn't to overwhelm with documents, but to show preparedness and transparency. Banks appreciate founders who come organized, with evidence already compiled.
Pro tip: Build this package incrementally as you grow. Each compliance document you create for regulators can be repurposed for banks. This is another reason to invest in compliance maturity early—it pays dividends when banking time comes.
The Ongoing Bank Relationship: What to Expect
Getting onboarded is just the beginning.
Once your account is open, banks conduct ongoing due diligence.
Typical cadence:
- Annual reviews (minimum). Your bank will refresh your KYC/KYB, update risk assessment, and review compliance performance.
- Ad-hoc reviews. If transaction patterns change, SAR volume spikes, or new geographies emerge, banks may request updated information.
- Regular check-ins. Good MSB banks will have quarterly or semi-annual calls to review key metrics, flag issues, and maintain relationships.
Proactive steps to keep your bank happy:
- Communicate changes early. New products, geographies, customer segments, or velocity increases should be flagged to your bank before they see it in transaction data.
- Share audit findings and remediation proactively. If your annual AML audit flags an issue, tell your bank immediately and present your fix. Don't wait for them to ask.
- Update compliance documentation annually. Refresh your BSA/AML policy, risk assessment, and vendor risk documentation each year. This shows active management.
- Maintain SAR quality. If you're filing SARs, make sure they're well-documented and explained. Banks use SAR quality as a proxy for compliance program maturity.
- Establish a relationship, not just a transaction. Meet your bank's compliance team, know your relationship manager by name, invite them to company events. Banking relationships that involve actual relationships survive challenges.
- Report financial health. Banks want to know your company is stable. Share relevant financial updates, funding news, and growth milestones.
Banks are constantly reassessing MSB relationships. The more proactive and transparent you are, the more secure your relationship becomes.[web:49]
How Brico Helps You Become Bankable
Most MSB founders approach compliance as a licensing problem, not a banking one.
You get your money transmitter license, check the box, and move on. Then six months later, you're scrambling to assemble an AML program because a bank's due diligence team just asked for it.
Brico is built to short-circuit this.
Our platform helps MSBs manage not just licensing applications and renewals, but the compliance documentation banks actually need. Rather than leaving compliance to last-minute panic, Brico helps you build a mature, documented program that's ready for banks from day one.
The result: faster onboarding, fewer surprises, and a banking relationship that sticks.
The Bottom Line
Getting banked as an MSB isn't impossible, but it requires more than a license and good intentions.
It requires:
- Clear visibility into your regulatory status across all relevant states.
- A documented, mature AML program that mirrors what banks build themselves.
- Transparent business model and customer profile documentation.
- Robust governance with clean beneficial ownership and background checks.
- Proactive relationship management with your bank, before and after onboarding.
The MSBs that stay banked are the ones that treat compliance as a core business function, not a checkbox. They invest in documentation, communicate changes transparently, and understand that banks' caution isn't personal: it's regulatory necessity.
If you're ready to build the kind of MSB that banks want to partner with, start by taking inventory of your compliance program maturity. Map it against the requirements above. Close the gaps. Then start your bank search from a position of strength.
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.
