What is a money transmitter?
A money transmitter is a business that accepts money, or value that substitutes for money, from one person and transmits it to another person or place. In the United States it must register with FinCEN as a money services business and is licensed and supervised by state regulators. Example (round numbers): a payments company receives 100,000 dollars from an importer and sends it to the importer's supplier in Colombia. Accepting funds from one person and transmitting them to another is money transmission.
- US rules define money transmission as accepting currency, funds or value that substitutes for currency from one person and transmitting it to another person or place by any means.
- Money transmitters register with FinCEN on Form 107 within 180 days of starting and renew every two years.
- Operating an unlicensed or unregistered money transmitting business is a federal crime.
- CSBS reports that 31 states have enacted the Money Transmission Modernization Act in full or in part.
- FinCEN treats crypto exchangers and administrators as money transmitters, but not ordinary users.
How money transmitter rules work
Federal. Under 31 CFR 1010.100(ff)(5), a money transmitter is a person that provides money transmission services or is otherwise engaged in the transfer of funds. The definition excludes, among others, a payment processor settling purchases for a seller, the operator of a clearing system acting only between regulated institutions, and armored car services moving a customer's own money. A money transmitter is a money services business (MSB) with Bank Secrecy Act duties.
State. States license and examine money transmitters. The Conference of State Bank Supervisors' Money Transmission Modernization Act sets nationwide standards on net worth, surety bonds and permissible investments.
| Requirement | Rule |
|---|---|
| FinCEN registration | Form 107, filed within 180 days of the MSB being established |
| Renewal | Every two years, by 31 December |
| Records | A copy of the registration kept in the United States for five years |
| Agents | A business acting only as another MSB's agent does not register |
| State licensing | MTMA enacted in full or in part in 31 states; licensees in MTMA states account for 99% of reported money transmission activity |
Sources: FinCEN, MSB registration; 31 CFR 1010.100; CSBS. As published on 29 October 2026.
Where a business meets it
Many business accounts and payment services offered by financial technology companies are provided through licensed money transmitters or banks. Stablecoin services are covered too: FinCEN's 2019 guidance states that an exchanger, which exchanges virtual currency for real currency or other virtual currency as a business, and an administrator, which issues and redeems a virtual currency, generally qualify as money transmitters, while a user buying goods or services does not.
Common mistakes
- Treating a money transmitter as a bank. It is licensed differently; ask where customer funds are held.
- Not checking the license. Ask for the provider's license details and its NMLS ID, and check them with the state regulator.
- Moving money for others yourself. A trading company that collects and pays on behalf of third parties as a business may itself be doing money transmission; take legal advice.
Related terms and how Helm handles it
Money transmitters carry AML duties, and stablecoin on-ramps and off-ramps are often licensed as money transmitters. Helm is a financial technology company, not a bank. Its US dollar account services are provided by Bridge Building, Inc. (NMLS ID 2450917), a licensed money transmitter, with customer funds held at Lead Bank. See global accounts.
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USD, EUR and GBP accounts in your company's name, with a named account manager.
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What counts as a money transmitter?
Under US federal rules, a person that accepts currency, funds or value that substitutes for currency from one person and transmits it to another person or place by any means, unless an exclusion applies. Exclusions include payment processors settling purchases for a seller and operators of clearing systems between regulated institutions.
Does a money transmitter need a license?
Yes. Money transmitters register with FinCEN as money services businesses and are licensed by the states where they operate. Operating an unlicensed or unregistered money transmitting business is a federal crime.
Is a crypto exchange a money transmitter?
Generally yes in the United States. FinCEN's 2019 guidance states that exchangers and administrators of convertible virtual currency generally qualify as money transmitters, while users do not.
Is a money transmitter the same as a bank?
No. A bank takes deposits under a bank charter. A money transmitter moves money under FinCEN registration and state licenses, and often holds customer funds at a partner bank.
References
- Legal Information Institute: 31 CFR 1010.100, general definitions (money transmitter)
- FinCEN: Money services business (MSB) registration
- Conference of State Bank Supervisors: Money Transmission Modernization Act
- FinCEN: Application of FinCEN's regulations to certain business models involving convertible virtual currencies (FIN-2019-G001, 9 May 2019)
- FinCEN: The Bank Secrecy Act
This guide is general information for businesses, not financial, legal or tax advice. Rules, fees and timings were checked against the sources listed on the review date and may change.