Hello my name is Faisal Khan.
I’m a banking and payments consultant and I will answer the question today of why FinCEN registration is important and does a FinCEN registration constitute a money transmitter license. So let’s address the second part which is the most important one a FINCEN registration is not a grant of a money transmitter license. It is simply a federal registration that every money services business has to do.
If you are a MSB licensed in your state, whether you need an MTL license or not is a separate matter but if you’re an MSB in your state you need to register on a federal level with FinCEN.
FinCEN stands for Financial Crimes Enforcement Network. And it is a body under the United States Government’s Department of Treasury.
FinCEN registration is mandatory because it does reporting on a statewide level up to the federal level so that the government can keep track of all things you know, illicit funding you know money laundering terrorist financing etc. and all that stuff. But many people make the mistake that the goal of the FinCEN Web site they register they click on check on all the states that they are active in. And they assume that they have received a money transmission license or an MTL that is not the case. FinCEN registration you simply informing FinCEN that I am active in these states and that you will pursue the money transmitter licenses in those states, separately. So registering on FinCEN is mandatory. But it does not grant your licenses for MTLs. I hope that answers the question if you have any other question hashtag #askfaisal you should see on the screen. Tweet it to me or I will eventually have a page up for this on my Web site. But you can go to my Web site faisalkhan.com it’s in the link below submit a form and you know if you have a question to ask. I’ll be happy to answer.
It is very important to note that there is no federal licensing for MTLs in the United States. There is something of the OCC charter for fintech charter, but that is not in place yet. The only licensing that you have is on a state level basis.