US Montana — FinCEN MSB licence.

Montana is the only US state that does not require a state-level MSB or money transmitter licence. All other US states require money transmitter licences for businesses engaged in currency exchange, remittance, or crypto services — often with surety bond requirements, capital minimums, and extensive application processes. Montana eliminates this layer while still requiring federal FinCEN registration and BSA compliance.

If the business is physically located in Montana and only conducts activity within Montana or internationally, no additional state licences are generally required. However, if the business actively serves clients located in other US states, most of those states' money transmitter licence requirements may apply. Operators intending to serve US retail clients broadly should seek multi-state licence advice.

All US MSBs must: (1) register with FinCEN within 180 days of commencing operations; (2) implement a written AML programme under the Bank Secrecy Act; (3) designate a compliance officer; (4) file Currency Transaction Reports (CTRs) for cash transactions over USD 10,000; (5) file Suspicious Activity Reports (SARs) for transactions of USD 2,000 or more; (6) maintain detailed transaction records.

GSS Legal offers a Ready-Made MSB transfer package — an existing Montana company with FinCEN registration already in place and an operational bank account. This is the fastest path to a fully operational US MSB structure, bypassing the waiting period for FinCEN registration and initial bank account setup.

Yes — businesses engaged in crypto-to-fiat or crypto-to-crypto exchange, digital asset custody, or related money services qualify for MSB status under FinCEN rules and must register accordingly. Montana's state-level exemption applies to all of these activities. Note that securities-related crypto activities may additionally trigger SEC registration requirements.