MSBs & Money Transmitters

FinCEN Registration, State Licensing & AML Compliance

Money services businesses and money transmitters operate within one of the most closely scrutinized areas of U.S. financial regulation.

Friling Law advises U.S. and international businesses on whether their activities may constitute regulated money transmission or another category of money services business, and the resulting federal and state requirements.

Services include:

• MSB regulatory classification
• FinCEN MSB registration
• AML compliance programs for MSBs
• Money transmitter regulatory analysis
• State licensing considerations
• Multi-state licensing strategy
• Agent and correspondent oversight
• KYC/CDD requirements
• Transaction monitoring
• SAR and CTR compliance
• Cross-border money transmission
• Foreign MSBs conducting U.S.-related activities
• Regulatory examinations and investigations

For new business models, we can analyze the proposed flow of funds before launch to identify potential registration, licensing, AML, sanctions, and banking issues.

AML & Financial Crime

Anti-Money Laundering, Financial Crime Compliance, Investigations & Enforcement

Friling Law advises U.S. and international businesses, financial institutions, fintech companies, payment providers, money services businesses, digital asset companies, investors, and individuals on U.S. anti-money laundering and financial crime laws.

Our practice combines AML/BSA compliance, FinCEN regulatory matters, KYC and beneficial ownership due diligence, financial investigations, cross-border payments, banking compliance, and OFAC sanctions. We assist clients in developing preventive compliance frameworks, responding to financial institutions and regulators, investigating potentially problematic transactions, remediating compliance deficiencies, and defending against regulatory and enforcement actions.

For international clients, we place particular emphasis on matters involving cross-border financial flows, U.S. dollar transactions, correspondent banking, high-risk jurisdictions, complex ownership structures, and the intersection between AML and U.S. economic sanctions.