The Problem
A U.S. bank account and a U.S. Money Transmitter License are not the same thing.
A Bolivian company can have access to USD banking and still be prohibited from receiving or transmitting money for customers unless the business operates under the appropriate regulatory structure.
We help determine whether the business can remain outside the regulated flow of funds or whether it needs licensed coverage.
The Solution: Build the Banking Structure Around the Transaction
Before approaching a bank, MSB, payment company, or settlement provider, we first determine:
Who owns the funds?
Where do the funds originate?
What is the original currency?
Is stablecoin involved?
What is the commercial purpose?
Which account needs to receive the money?
Which payment rail is required?
Who is the final beneficiary?
What is the average and maximum transaction size?
How much volume is expected each month?
Are the funds the company's own money or customer money?
Is licensing coverage required?
Only then do we determine the right account and provider structure.
What We Can Potentially Structure
Business Requirement | Potential Infrastructure |
|---|---|
Move own corporate funds | Banking structure may be sufficient |
Receive customer money | Licensing analysis required |
Transmit between third parties | Licensed money-transmission coverage may be required |
Operate payment platform | Principal MSB / Authorized Delegate structure |
Hold customer balances | FBO + licensed program |
Need nationwide route | Principal with relevant state coverage |
Not every business needs every component.
The objective is to build the smallest compliant structure that actually works.
Typical Flow of Funds
CUSTOMER
|
v
YOUR BUSINESS / PLATFORM
|
v
AUTHORIZED DELEGATE / AGENT
|
v
LICENSED U.S. PRINCIPAL MSB
|
v
BANK / FBO / PAYMENT RAILS
|
v
BENEFICIARY
The precise flow will depend on the real ownership of funds, source of funds, jurisdictions, provider approvals, and whether the transaction involves the company's own money or money belonging to customers.
When MTL Coverage May Be Needed
The key question is whether the company is accepting money from one person or business for transmission to another. The exact legal analysis depends on the states, transaction model, and role of each party.
Authorized Delegate Model
A licensed Principal MSB may appoint an approved business as an Authorized Delegate or agent, allowing it to operate within the principal's licensed program under defined contractual and compliance requirements.
Own Licenses vs. Sponsorship
Obtaining state licenses directly can provide greater control but is usually more expensive, slower, and operationally demanding. Sponsorship may be a faster route for a qualified business with the right volume and compliance capacity.
What the Principal Will Review
Expect due diligence on ownership, management, business model, customer types, financial strength, volumes, AML/KYC controls, transaction monitoring, technology, jurisdictions, and source of funds.
Compliance Is Part of the Product
A workable banking or payment solution is not simply an account number.
Depending on the structure, the provider may require:
corporate formation documents;
directors and UBO information;
KYC/KYB;
beneficial-owner verification;
source-of-funds evidence;
bank statements;
invoices and purchase orders;
counterparty details;
sanctions screening;
transaction monitoring;
wallet screening where crypto is involved;
expected monthly volume;
average and maximum transaction size;
beneficiary countries;
customer types;
transaction purpose;
reconciliation procedures;
and a complete flow-of-funds explanation.
The stronger the documentation, the easier it is for a regulated provider to understand the opportunity.
Own Funds vs. Customer Funds
This distinction is critical.
If a company is moving only its own money for its own commercial activity, the problem may primarily be one of banking, treasury, and cross-border settlement.
If the company:
accepts money from customers;
holds customer balances;
transmits money to third parties;
instructs payments on behalf of customers;
operates a remittance or payment platform;
or provides payment accounts to underlying users,
then a normal corporate account may not be sufficient.
The structure may require:
a licensed payment provider;
an FBO or pooled account;
an Authorized Delegate relationship;
Money Transmitter License coverage;
or another regulated program structure.
A Typical Operational Roadmap
PHASE 1
Business + Flow-of-Funds Review
|
v
PHASE 2
Account / Payment / Licensing Structure
|
v
PHASE 3
Provider Selection
|
v
PHASE 4
KYC / KYB / Compliance Package
|
v
PHASE 5
Account / Program Configuration
|
v
PHASE 6
Pilot Transactions
|
v
PHASE 7
Scale Volumes / Add Corridors
Timelines vary substantially depending on the provider, business model, account type, licensing structure, ownership, transaction profile, and technology requirements.
Information We Need From You
Please provide:
Company name
Country of incorporation
Website
Principal / UBO LinkedIn profile
Short description of the business
Whether funds belong to the company or third parties
Required account type
Required payment rails
Countries from which funds arrive
Countries to which funds are sent
Original funding currency
Whether USDT or USDC is involved
Monthly incoming volume
Monthly outgoing volume
Average transaction size
Maximum expected transaction
Main counterparties
Main beneficiary countries
Existing banking relationships
Current banking or payment problem
Expected growth over the next 6–12 months
A flow-of-funds diagram, if available
If you do not have a diagram, describe the transaction in plain English.
We can convert it into one.
Frequently Asked Questions
Is approval guaranteed?
No.
All account, banking, payment, licensing, and provider approvals remain subject to the relevant institution's compliance, underwriting, risk, and onboarding requirements.
Does a U.S. account automatically allow me to operate a payment business?
No.
Banking access and money-transmission authority are separate issues.
Can the account be in the company's own name?
Potentially, depending on the provider and use case.
Can stablecoin be part of the transaction?
Potentially, where disclosed and approved by the relevant providers.
Can the structure support SWIFT or Fedwire?
Potentially, depending on the account and provider selected.
Can you help if I need a more complex payment program rather than one account?
Yes. Where appropriate, we can assess FBO, virtual-account, API, white-label, licensed-partner, or Authorized Delegate structures.
What We Actually Do
We are not simply selling an account.
We help structure the opportunity.
BUSINESS
|
v
FLOW OF FUNDS
|
v
RISK + REGULATORY ANALYSIS
|
v
ACCOUNT REQUIREMENTS
|
v
PAYMENT-RAIL REQUIREMENTS
|
v
PROVIDER / BANK / MSB MATCHING
|
v
PRELIMINARY FEASIBILITY
|
v
INTRODUCTION
|
v
KYC / KYB / DUE DILIGENCE
|
v
ACCOUNT / PROGRAM APPROVAL
|
v
IMPLEMENTATION
The objective is to avoid wasting months with providers that were never able to support the transaction in the first place.
Request an MTL Coverage Assessment
Do not start by asking for a random account.
Start with the transaction.
Tell us:
Where does the money come from?
Who owns it?
How much moves each month?
What is the average transaction size?
Which currencies are involved?
Where does the money ultimately need to go?
Do you need named accounts, SWIFT, Fedwire, FBO infrastructure, stablecoin settlement, or licensing coverage?
We will review the flow and determine what account, banking provider, payment company, licensed intermediary, or settlement architecture may realistically support it.
Related Pages
Important: Availability, pricing, corridors, account structures, payment rails, and regulatory requirements are profile-specific and subject to third-party approval. Faisal Khan LLC provides advisory, structuring, and introductions; it is not a bank and does not hold client funds.