Search FinCEN's MSB Registrant Search to confirm a business registered as an MSB, read the result correctly, and learn what registration does not prove.
Table of contents
To check whether a business is a registered money services business, search FinCEN's MSB Registrant Search by legal name, DBA name, or state. The result shows the registration number, the MSB activities the business declared, the states it serves, and the date FinCEN received the filing. Registration is self-reported, so a match confirms the business filed, not that it is licensed, supervised, or compliant.
How to check if a business is a registered MSB
- Open FinCEN's MSB Registrant Search.
- Enter what you know in one or more fields. You can search on MSB registration number or DCN, legal name, DBA name, street address, city, state, ZIP, the MSB activities declared, the states of those activities, or a foreign location. Partial entries work, which matters because the legal name on the filing is often not the trading name you know.
- Run the search and read the results table.
- Click the legal name of the business you want. FinCEN returns a printable MSB Registration Status Information sheet for that registrant, which is the document to keep for your file.
The search covers entities that have registered under the Bank Secrecy Act regulations at 31 CFR 1022.380, and FinCEN updates it weekly. A business that registered in the last few days may not appear yet.
What the search results actually show
Each row in the results table carries the following, all of it as filed by the business:
| Field | What it tells you |
|---|---|
| Legal name and DBA name | The registered entity and any trading name it declared |
| Street address, city, state, ZIP | The address on the filing, which may be a registered agent rather than an operating site |
| MSB activities | Which of the FinCEN activity categories the business declared for itself |
| States of MSB activities | The states it says it operates in, plus a flag if it claims all states and territories |
| Foreign location | Set where the registrant is located outside the United States |
| Number of branches | Branch count as declared |
| Authorised signature date | When the filing was signed |
| Received date | When FinCEN received it, which is the date that tells you how current the filing is |
Clicking through to a registrant gives the same information as a dated MSB Registration Status Information sheet, including the registration number. That sheet is what to attach to a due-diligence file, because it carries its own date.
What MSB registration does not prove
This is the part most people get wrong, and it is the reason a search result should never close a due-diligence question on its own.
It is not a licence
FinCEN operates a registration, not a licensing regime. There is no fee, no approval step, and no certificate issued. Filing Form 107 through the BSA E-Filing System puts a business on the list; nobody at FinCEN assesses whether it should be there. FinCEN states the position plainly on the registration status sheet itself: inclusion on the search page is not a recommendation, certification of legitimacy, or endorsement by any government agency.
FinCEN does not verify what is filed
Everything in the record was supplied by the registrant. FinCEN does not check it. If a business declares the wrong activity categories, lists states it does not serve, or gives an address it left two years ago, the search will show exactly that, because the register reflects what was submitted rather than what is true. Treat every field as an assertion by the business, not a finding by the regulator.
It says nothing about state licensing
Federal registration and state money transmitter licensing are separate obligations, and the state licence is the harder one to get. A business can be correctly registered with FinCEN and still be operating unlawfully in a state where it holds no licence. Check the states separately through NMLS Consumer Access, which is the public lookup for state-licensed financial-services companies.
And it is a point in time
Registration has to be renewed every two years. A record with an old received date may belong to a business that has since stopped renewing, so read the received date rather than treating the presence of a row as current standing.
What it means when a business is not in the results
An empty result is informative, but it is not proof of wrongdoing. Work through the ordinary explanations first:
- You searched the trading name and the business registered under a different legal name. Search the DBA field, or search by state and scan.
- The filing is very recent. The list is rebuilt weekly.
- The business is not an MSB. Banks and their agents are outside the definition, and so are businesses that only process payments for goods and services.
- The business should have registered and has not. Initial registration is due within 180 days of beginning MSB activities, and operating unregistered is a federal criminal offence rather than a paperwork lapse.
If you have exhausted the first three and the business is plainly transmitting money, the absence is the finding. Document the search you ran and the date you ran it.
Using this in an onboarding or KYB check
For a compliance team, the registrant search is one input and a weak one on its own. It tells you what a counterparty declared about itself to a federal agency that did not check. A defensible check on a money services business pairs it with the things registration does not cover:
- Verify the legal entity against the company register in its state of incorporation, not just the MSB record.
- Confirm state money transmitter licensing for every state the counterparty actually serves.
- Identify the ultimate beneficial owners and screen them, since the MSB filing names a signatory rather than an ownership chain.
- Screen the entity and its owners against sanctions and adverse media, and keep screening them, because a registration record never changes when a designation does.
- Keep the dated registration status sheet with the rest of the file, so the check can be evidenced later.
That is ordinary KYB work, and the MSB search is the cheapest step in it rather than a substitute for it. Zyphe runs the entity, ownership and screening layers in one workflow and keeps the audit trail, without holding a central store of your customers personal data.
Michelangelo Frigo (Co-Founder at Zyphe) Michelangelo Frigo is a privacy and identity infrastructure expert and co-founder of Zyphe.