US Money Services Business registration.
Montana is the only US state with no separate state-level money transmitter licence requirement. Federal FinCEN registration under the Bank Secrecy Act is the sole mandatory step for crypto exchangers and money services businesses — with no government fee and renewal every two years. Combined with a straightforward corporate structure, Montana offers the lowest-overhead US MSB footprint available for digital asset operators.
A considered route,
not a shortcut.
This jurisdiction rewards operators who treat the application as the start of a supervisory relationship.
When this is the right choice
When to consider an alternative
Permissions under
one Act.
Choosing the right tier and scope is the most consequential decision in the application.
FinCEN Registration (Federal MSB)
All MSBs in the US must register with the Financial Crimes Enforcement Network (FinCEN) within 180 days of starting operations and renew every two years. This is the primary federal compliance requirement and applies regardless of the state of incorporation.
Bank Secrecy Act (BSA) Compliance Programme
All US MSBs must implement a written AML programme, designate a compliance officer, conduct employee training, and undergo independent audits. Currency Transaction Reports (CTRs) must be filed for cash transactions over USD 10,000. Suspicious Activity Reports (SARs) for transactions of USD 2,000 or more.
Montana State Formation (no state MSB licence)
Montana is the only US state that does not require a state-level MSB or money transmitter licence. Businesses registered in Montana and operating within the state's framework are exempt from state MSB licensing — a unique advantage that eliminates a major regulatory hurdle.
Phases to licence grant.
Montana company formation
Week 1Montana LLC or corporation registered. EIN (Employer Identification Number) obtained from the IRS. Registered agent and Montana address secured for one year.
AML/BSA compliance programme build
Weeks 2—4Written AML programme developed in accordance with Bank Secrecy Act requirements. Compliance officer designated. SAR and CTR reporting procedures established. Employee training materials prepared.
FinCEN MSB registration
Weeks 3—4MSB registration submitted to FinCEN online (must be completed within 180 days of commencing operations). Registration covers money transmission, currency exchange, and/or digital asset services as applicable.
Banking & operational launch
Weeks 4—8Corporate account opening assistance. Ready-Made MSB package includes an existing operational bank account. Company fully operational with FinCEN registration confirmed.
Cost and regulatory
burden.
Year-one spend is dominated by substance — resident director, office, compliance officer, external audit — not the licence fee itself.
| Cost item | Amount |
|---|---|
Basic package (company + FinCEN registration)
|
USD 4,900 |
Advanced package (+ AML programme)
|
USD 9,900 |
Ready-Made MSB (existing company + bank account)
|
USD 15,900 |
| State-level MSB licence required | None (Montana only) |
| FinCEN registration fee | Free (federal online system) |
| FinCEN renewal | Every 2 years |
| Year-1 total | ~USD 5—20K (yr 1, package fee only — zero state-level licence fee required) |
Montana imposes no state-level money transmitter licence — federal FinCEN registration under the Bank Secrecy Act is the only mandatory regulatory step. FinCEN registration carries no government fee and is completed through an online portal. The primary ongoing cost is maintaining a compliant AML programme that meets Bank Secrecy Act requirements.
What founders
ask before filing.
The questions we get on every diagnostic call. If yours isn't here, raise it in the consultation.
Tell us where
you want to
operate.
Forty-five minutes with a partner. Jurisdiction memo within seven days. No retainer required to start.
No retainer required.
