Who We Serve
Money Transmitter and MSB Compliance Services
InnReg provides compliance consulting and outsourcing for money transmitters and money services businesses, from FinCEN registration and state licensing to AML program development, ongoing compliance management, outsourced compliance officers, independent testing, and regulatory examination support.
Since 2013
100+ fintechs supported
Compliance specialists
SOC 2® Type 2 Report
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Compliance Support Built Around Your Money Services Business
Compliance Support Built Around Your Money Services Business
A money services business’s compliance needs depend on how value moves through the business. Products, customer types, transaction flows, geographic markets, payment methods, digital assets, banking relationships, agents, and service providers all affect the requirements and controls that apply.
Money transmitters are one category of MSB under federal Bank Secrecy Act regulations. Other categories include foreign exchange dealers, check cashers, certain money order and traveler’s check businesses, and providers and sellers of prepaid access. The applicable obligations vary by activity. FinCEN registration and state licensing are separate requirements: federal registration does not replace required state licenses or establish government approval of the business.
InnReg helps money transmitters and MSBs turn those requirements into operating compliance programs. Depending on the engagement, we can assess the regulatory model, support registration and licensing, develop AML and broader compliance programs, manage recurring obligations, provide an outsourced AML compliance officer or CCO, conduct independent testing, and assist with examinations and remediation.
Planning to Launch or Expand a Money Services Business?
InnReg supports FinCEN MSB registration and state licensing strategies, including jurisdiction assessment, application preparation, supporting documentation, and regulatory responses. We help connect the licensing plan with the financial, personnel, and compliance infrastructure needed to operate.
Firm Types
Who We Work With
InnReg supports broker-dealers with different business models, operating structures, and compliance needs.
Remittance and Cross-Border Payment Providers
Businesses transferring funds domestically or internationally for consumers and businesses, with compliance needs shaped by transaction corridors, customers, and payout arrangements.
Remittance and Cross-Border Payment Providers
Businesses transferring funds domestically or internationally for consumers and businesses, with compliance needs shaped by transaction corridors, customers, and payout arrangements.
Digital Wallet and Stored-Value Businesses
Platforms enabling users to hold, load, transfer, or spend value, including models requiring analysis of money transmission and prepaid access requirements.
Digital Wallet and Stored-Value Businesses
Platforms enabling users to hold, load, transfer, or spend value, including models requiring analysis of money transmission and prepaid access requirements.
Payment Platforms and Money Movement Infrastructure
Businesses facilitating collections, payouts, marketplace payments, and other transfers, including firms assessing whether licensing or an exemption applies to their operating model.
Payment Platforms and Money Movement Infrastructure
Businesses facilitating collections, payouts, marketplace payments, and other transfers, including firms assessing whether licensing or an exemption applies to their operating model.
Digital Asset Money Services Businesses
Businesses exchanging, transmitting, or providing custody-related services for digital assets where their activities trigger MSB, money transmission, or other licensing requirements.
Digital Asset Money Services Businesses
Businesses exchanging, transmitting, or providing custody-related services for digital assets where their activities trigger MSB, money transmission, or other licensing requirements.
Foreign Exchange, Check Cashing, and Other MSBs
Businesses offering foreign exchange, check cashing, money orders, or other regulated money services, with requirements specific to their activities and jurisdictions.
Foreign Exchange, Check Cashing, and Other MSBs
Businesses offering foreign exchange, check cashing, money orders, or other regulated money services, with requirements specific to their activities and jurisdictions.
New Applicants and Established Licensees
Firms entering the U.S. market, expanding into additional states, strengthening compliance programs, or supplementing an existing compliance team.
New Applicants and Established Licensees
Firms entering the U.S. market, expanding into additional states, strengthening compliance programs, or supplementing an existing compliance team.
Requirements
Key Money Transmitter and MSB Compliance Areas
Federal MSB requirements and state money transmission laws address different aspects of the business. Applicable obligations depend on the services provided, transaction types, customer relationships, jurisdictions, and any available exemptions.
AML Program Governance and Independent Review
31 CFR 1022.210 requires MSBs to develop, implement, and maintain an effective AML program reasonably designed to prevent money laundering and terrorist financing. The program must include internal controls, designated compliance responsibility, training, and independent review. Review frequency should reflect risk; the federal MSB rule does not prescribe an annual review for every business.
Federal Registration and State Licensing
31 CFR 1022.380 governs MSB registration with FinCEN, subject to specified exceptions, renewals, and agent-list requirements. Federal registration does not replace state licensing. State obligations can include money transmitter licenses, authorized delegate oversight, change-of-control approvals, reporting, and examination access, depending on the business model and jurisdiction.
Financial Safeguards and Consumer Protection
State money transmission laws may require surety bonds, minimum net worth, permissible investments, and protection of outstanding transmission obligations. Consumer-facing products may also trigger Regulation E, including its remittance-transfer or prepaid-account provisions where applicable. Disclosures, cancellation rights, error resolution, refunds, and complaints should match the product and the firm's responsibilities.
Customer Identification and Transaction Monitoring
MSB AML controls should reflect customer, product, geographic, and transaction risks. Relevant areas can include identity verification, customer risk assessment, higher-risk relationship reviews, and monitoring for suspicious activity. These risk-based controls should be distinguished from the specific Customer Identification Program and beneficial-ownership rules that apply to covered banks and certain other financial institutions.
Funds Transfer Records and the Travel Rule
31 CFR 1010.410(e) and (f) establish recordkeeping and information-transmittal requirements for covered funds transfers and transmittals of funds. Applicability depends on the transaction, amount, and institution's role. Procedures should address required originator and recipient information, verification where required, retention, and transmission to the next financial institution.
Records, Cybersecurity, and Operational Resilience
MSBs must maintain the records required by their federal obligations and state licenses. Depending on the business and jurisdiction, additional requirements can address information security, breach notification, business continuity, and third-party oversight. New York's 23 NYCRR Part 500 applies to covered entities, subject to its exemptions and differentiated requirements.
Suspicious Activity and Currency Reporting
31 CFR 1022.320 imposes suspicious activity reporting requirements on specified MSB categories, including money transmitters. Currency transaction reporting under 31 CFR 1022.310 concerns qualifying transactions in currency, rather than every electronic transfer. Applicable thresholds, aggregation, filing deadlines, supporting documentation, and SAR confidentiality require distinct procedures.
Sanctions and Restricted Transactions
Applicable OFAC sanctions operate separately from BSA registration and AML-program requirements. Relevant controls can include screening customers and counterparties, geographic restrictions, transaction review, and handling blocked or rejected transactions. Reporting and recordkeeping depend on the relevant sanctions program and the facts of the transaction.
AML Program Governance and Independent Review
31 CFR 1022.210 requires MSBs to develop, implement, and maintain an effective AML program reasonably designed to prevent money laundering and terrorist financing. The program must include internal controls, designated compliance responsibility, training, and independent review. Review frequency should reflect risk; the federal MSB rule does not prescribe an annual review for every business.
Customer Identification and Transaction Monitoring
MSB AML controls should reflect customer, product, geographic, and transaction risks. Relevant areas can include identity verification, customer risk assessment, higher-risk relationship reviews, and monitoring for suspicious activity. These risk-based controls should be distinguished from the specific Customer Identification Program and beneficial-ownership rules that apply to covered banks and certain other financial institutions.
Suspicious Activity and Currency Reporting
31 CFR 1022.320 imposes suspicious activity reporting requirements on specified MSB categories, including money transmitters. Currency transaction reporting under 31 CFR 1022.310 concerns qualifying transactions in currency, rather than every electronic transfer. Applicable thresholds, aggregation, filing deadlines, supporting documentation, and SAR confidentiality require distinct procedures.
Federal Registration and State Licensing
31 CFR 1022.380 governs MSB registration with FinCEN, subject to specified exceptions, renewals, and agent-list requirements. Federal registration does not replace state licensing. State obligations can include money transmitter licenses, authorized delegate oversight, change-of-control approvals, reporting, and examination access, depending on the business model and jurisdiction.
Funds Transfer Records and the Travel Rule
31 CFR 1010.410(e) and (f) establish recordkeeping and information-transmittal requirements for covered funds transfers and transmittals of funds. Applicability depends on the transaction, amount, and institution's role. Procedures should address required originator and recipient information, verification where required, retention, and transmission to the next financial institution.
Sanctions and Restricted Transactions
Applicable OFAC sanctions operate separately from BSA registration and AML-program requirements. Relevant controls can include screening customers and counterparties, geographic restrictions, transaction review, and handling blocked or rejected transactions. Reporting and recordkeeping depend on the relevant sanctions program and the facts of the transaction.
Financial Safeguards and Consumer Protection
State money transmission laws may require surety bonds, minimum net worth, permissible investments, and protection of outstanding transmission obligations. Consumer-facing products may also trigger Regulation E, including its remittance-transfer or prepaid-account provisions where applicable. Disclosures, cancellation rights, error resolution, refunds, and complaints should match the product and the firm's responsibilities.
Records, Cybersecurity, and Operational Resilience
MSBs must maintain the records required by their federal obligations and state licenses. Depending on the business and jurisdiction, additional requirements can address information security, breach notification, business continuity, and third-party oversight. New York's 23 NYCRR Part 500 applies to covered entities, subject to its exemptions and differentiated requirements.
AML Program Governance and Independent Review
31 CFR 1022.210 requires MSBs to develop, implement, and maintain an effective AML program reasonably designed to prevent money laundering and terrorist financing. The program must include internal controls, designated compliance responsibility, training, and independent review. Review frequency should reflect risk; the federal MSB rule does not prescribe an annual review for every business.
Customer Identification and Transaction Monitoring
MSB AML controls should reflect customer, product, geographic, and transaction risks. Relevant areas can include identity verification, customer risk assessment, higher-risk relationship reviews, and monitoring for suspicious activity. These risk-based controls should be distinguished from the specific Customer Identification Program and beneficial-ownership rules that apply to covered banks and certain other financial institutions.
Suspicious Activity and Currency Reporting
31 CFR 1022.320 imposes suspicious activity reporting requirements on specified MSB categories, including money transmitters. Currency transaction reporting under 31 CFR 1022.310 concerns qualifying transactions in currency, rather than every electronic transfer. Applicable thresholds, aggregation, filing deadlines, supporting documentation, and SAR confidentiality require distinct procedures.
Federal Registration and State Licensing
31 CFR 1022.380 governs MSB registration with FinCEN, subject to specified exceptions, renewals, and agent-list requirements. Federal registration does not replace state licensing. State obligations can include money transmitter licenses, authorized delegate oversight, change-of-control approvals, reporting, and examination access, depending on the business model and jurisdiction.
Funds Transfer Records and the Travel Rule
31 CFR 1010.410(e) and (f) establish recordkeeping and information-transmittal requirements for covered funds transfers and transmittals of funds. Applicability depends on the transaction, amount, and institution's role. Procedures should address required originator and recipient information, verification where required, retention, and transmission to the next financial institution.
Sanctions and Restricted Transactions
Applicable OFAC sanctions operate separately from BSA registration and AML-program requirements. Relevant controls can include screening customers and counterparties, geographic restrictions, transaction review, and handling blocked or rejected transactions. Reporting and recordkeeping depend on the relevant sanctions program and the facts of the transaction.
Financial Safeguards and Consumer Protection
State money transmission laws may require surety bonds, minimum net worth, permissible investments, and protection of outstanding transmission obligations. Consumer-facing products may also trigger Regulation E, including its remittance-transfer or prepaid-account provisions where applicable. Disclosures, cancellation rights, error resolution, refunds, and complaints should match the product and the firm's responsibilities.
Records, Cybersecurity, and Operational Resilience
MSBs must maintain the records required by their federal obligations and state licenses. Depending on the business and jurisdiction, additional requirements can address information security, breach notification, business continuity, and third-party oversight. New York's 23 NYCRR Part 500 applies to covered entities, subject to its exemptions and differentiated requirements.
How We Help
How InnReg Supports Money Transmitters and MSBs
InnReg can lead a registration or licensing project, supplement an established compliance team, or provide broader outsourced compliance support. The scope is structured around the firm’s activities, transaction flows, licensing footprint, risk profile, and internal resources.
Obtaining Registrations and Licenses
Launching or expanding a money services business requires a clear view of which activities the firm will perform, where it will operate, and which entity is responsible for each part of the transaction.
InnReg supports FinCEN registration and state licensing projects, coordinating the regulatory strategy with business plans, financial information, ownership disclosures, personnel, banking arrangements, and compliance documentation. Our work with fintech money movement models helps us connect the application with the operating structure the firm will need after approval.
Support can include:
Federal MSB classification and registration requirements
State licensing strategy, sequencing, and application readiness
FinCEN registration and NMLS application preparation
Business plans, funds-flow descriptions, and compliance materials
Coordination of financial statements, bonds, background checks, and ownership information
Regulatory questions, application amendments, and related communications
The scope can also address other MSB license categories where required by the firm’s activities.
Obtaining Registrations and Licenses
Launching or expanding a money services business requires a clear view of which activities the firm will perform, where it will operate, and which entity is responsible for each part of the transaction.
InnReg supports FinCEN registration and state licensing projects, coordinating the regulatory strategy with business plans, financial information, ownership disclosures, personnel, banking arrangements, and compliance documentation. Our work with fintech money movement models helps us connect the application with the operating structure the firm will need after approval.
Support can include:
Federal MSB classification and registration requirements
State licensing strategy, sequencing, and application readiness
FinCEN registration and NMLS application preparation
Business plans, funds-flow descriptions, and compliance materials
Coordination of financial statements, bonds, background checks, and ownership information
Regulatory questions, application amendments, and related communications
The scope can also address other MSB license categories where required by the firm’s activities.
Obtaining Registrations and Licenses
Launching or expanding a money services business requires a clear view of which activities the firm will perform, where it will operate, and which entity is responsible for each part of the transaction.
InnReg supports FinCEN registration and state licensing projects, coordinating the regulatory strategy with business plans, financial information, ownership disclosures, personnel, banking arrangements, and compliance documentation. Our work with fintech money movement models helps us connect the application with the operating structure the firm will need after approval.
Support can include:
Federal MSB classification and registration requirements
State licensing strategy, sequencing, and application readiness
FinCEN registration and NMLS application preparation
Business plans, funds-flow descriptions, and compliance materials
Coordination of financial statements, bonds, background checks, and ownership information
Regulatory questions, application amendments, and related communications
The scope can also address other MSB license categories where required by the firm’s activities.
Building or Rebuilding the Compliance Program
A money transmitter’s compliance program needs to reflect how customers enter the platform, how transactions are funded and processed, where value moves, and how exceptions are handled.
InnReg develops AML and broader compliance programs for new firms and helps established businesses revise frameworks that no longer match their operations. Our experience with remittance, wallet, cross-border payment, and digital asset models informs how we connect policies with customer workflows, transaction controls, vendors, and supporting records.
Representative areas of support include:
AML/BSA risk assessment, policies, and internal controls
Customer identification, due diligence, and escalation processes
Transaction monitoring, investigations, SAR procedures, and recordkeeping
Sanctions screening and resolution of potential matches
Consumer disclosures, complaints, refunds, and error-resolution workflows
Agent oversight, vendor management, privacy, cybersecurity, continuity, and training
We also help define owners, approvals, system requirements, and evidence of implementation so the program can function within the business.
Building or Rebuilding the Compliance Program
A money transmitter’s compliance program needs to reflect how customers enter the platform, how transactions are funded and processed, where value moves, and how exceptions are handled.
InnReg develops AML and broader compliance programs for new firms and helps established businesses revise frameworks that no longer match their operations. Our experience with remittance, wallet, cross-border payment, and digital asset models informs how we connect policies with customer workflows, transaction controls, vendors, and supporting records.
Representative areas of support include:
AML/BSA risk assessment, policies, and internal controls
Customer identification, due diligence, and escalation processes
Transaction monitoring, investigations, SAR procedures, and recordkeeping
Sanctions screening and resolution of potential matches
Consumer disclosures, complaints, refunds, and error-resolution workflows
Agent oversight, vendor management, privacy, cybersecurity, continuity, and training
We also help define owners, approvals, system requirements, and evidence of implementation so the program can function within the business.
Building or Rebuilding the Compliance Program
A money transmitter’s compliance program needs to reflect how customers enter the platform, how transactions are funded and processed, where value moves, and how exceptions are handled.
InnReg develops AML and broader compliance programs for new firms and helps established businesses revise frameworks that no longer match their operations. Our experience with remittance, wallet, cross-border payment, and digital asset models informs how we connect policies with customer workflows, transaction controls, vendors, and supporting records.
Representative areas of support include:
AML/BSA risk assessment, policies, and internal controls
Customer identification, due diligence, and escalation processes
Transaction monitoring, investigations, SAR procedures, and recordkeeping
Sanctions screening and resolution of potential matches
Consumer disclosures, complaints, refunds, and error-resolution workflows
Agent oversight, vendor management, privacy, cybersecurity, continuity, and training
We also help define owners, approvals, system requirements, and evidence of implementation so the program can function within the business.
Managing Ongoing Compliance and License Maintenance
Registration and licensing create continuing operational obligations. As transaction volumes, customer profiles, products, and state coverage change, firms need to maintain both their compliance controls and their regulatory records.
InnReg can supplement an internal compliance team or provide broader ongoing program management. In a public engagement involving a digital asset money transmitter, our team supported licensing and surety bond deadlines, AML-related regulatory responses, and continuity planning during a compliance leadership transition.
Ongoing support can include:
Compliance calendars, state renewals, and FinCEN registration maintenance
NMLS records, MSB Call Reports, state reports, and change filings
Coordination of bond, net worth, and permissible investment monitoring with finance
Customer reviews, transaction alerts, investigations, and SAR workflows
Sanctions controls, agent oversight, vendor reviews, and personnel training
Policy updates, complaints, regulatory developments, and remediation tracking
The scope defines the activities InnReg administers and the decisions, approvals, financial inputs, or certifications assigned to management and other responsible personnel.
Managing Ongoing Compliance and License Maintenance
Registration and licensing create continuing operational obligations. As transaction volumes, customer profiles, products, and state coverage change, firms need to maintain both their compliance controls and their regulatory records.
InnReg can supplement an internal compliance team or provide broader ongoing program management. In a public engagement involving a digital asset money transmitter, our team supported licensing and surety bond deadlines, AML-related regulatory responses, and continuity planning during a compliance leadership transition.
Ongoing support can include:
Compliance calendars, state renewals, and FinCEN registration maintenance
NMLS records, MSB Call Reports, state reports, and change filings
Coordination of bond, net worth, and permissible investment monitoring with finance
Customer reviews, transaction alerts, investigations, and SAR workflows
Sanctions controls, agent oversight, vendor reviews, and personnel training
Policy updates, complaints, regulatory developments, and remediation tracking
The scope defines the activities InnReg administers and the decisions, approvals, financial inputs, or certifications assigned to management and other responsible personnel.
Managing Ongoing Compliance and License Maintenance
Registration and licensing create continuing operational obligations. As transaction volumes, customer profiles, products, and state coverage change, firms need to maintain both their compliance controls and their regulatory records.
InnReg can supplement an internal compliance team or provide broader ongoing program management. In a public engagement involving a digital asset money transmitter, our team supported licensing and surety bond deadlines, AML-related regulatory responses, and continuity planning during a compliance leadership transition.
Ongoing support can include:
Compliance calendars, state renewals, and FinCEN registration maintenance
NMLS records, MSB Call Reports, state reports, and change filings
Coordination of bond, net worth, and permissible investment monitoring with finance
Customer reviews, transaction alerts, investigations, and SAR workflows
Sanctions controls, agent oversight, vendor reviews, and personnel training
Policy updates, complaints, regulatory developments, and remediation tracking
The scope defines the activities InnReg administers and the decisions, approvals, financial inputs, or certifications assigned to management and other responsible personnel.
Providing Outsourced AML Compliance Officers and CCOs
A money services business may need an experienced individual to lead its AML program, oversee broader compliance, or provide interim coverage during a leadership transition.
InnReg provides outsourced AML compliance officer and CCO services based on the firm’s activities, regulatory requirements, and agreed scope. The designated professional works with the broader engagement team and the client’s management, operations, technology, and finance personnel.
Depending on the engagement, support can include:
Appointment as the designated AML compliance officer or CCO
Day-to-day AML program oversight and coordination
Review and escalation of significant customer, transaction, and sanctions issues
Coordination of reporting, recordkeeping, training, and policy updates
Management reporting and regulatory communications
Oversight of findings, remediation, and independent-review follow-up
The federal AML rule requires a designated person responsible for day-to-day compliance; a separate CCO position depends on the firm’s broader requirements and structure. Responsibilities, authority, access, and management support are defined for the role.
Providing Outsourced AML Compliance Officers and CCOs
A money services business may need an experienced individual to lead its AML program, oversee broader compliance, or provide interim coverage during a leadership transition.
InnReg provides outsourced AML compliance officer and CCO services based on the firm’s activities, regulatory requirements, and agreed scope. The designated professional works with the broader engagement team and the client’s management, operations, technology, and finance personnel.
Depending on the engagement, support can include:
Appointment as the designated AML compliance officer or CCO
Day-to-day AML program oversight and coordination
Review and escalation of significant customer, transaction, and sanctions issues
Coordination of reporting, recordkeeping, training, and policy updates
Management reporting and regulatory communications
Oversight of findings, remediation, and independent-review follow-up
The federal AML rule requires a designated person responsible for day-to-day compliance; a separate CCO position depends on the firm’s broader requirements and structure. Responsibilities, authority, access, and management support are defined for the role.
Providing Outsourced AML Compliance Officers and CCOs
A money services business may need an experienced individual to lead its AML program, oversee broader compliance, or provide interim coverage during a leadership transition.
InnReg provides outsourced AML compliance officer and CCO services based on the firm’s activities, regulatory requirements, and agreed scope. The designated professional works with the broader engagement team and the client’s management, operations, technology, and finance personnel.
Depending on the engagement, support can include:
Appointment as the designated AML compliance officer or CCO
Day-to-day AML program oversight and coordination
Review and escalation of significant customer, transaction, and sanctions issues
Coordination of reporting, recordkeeping, training, and policy updates
Management reporting and regulatory communications
Oversight of findings, remediation, and independent-review follow-up
The federal AML rule requires a designated person responsible for day-to-day compliance; a separate CCO position depends on the firm’s broader requirements and structure. Responsibilities, authority, access, and management support are defined for the role.
Testing the Program and Preparing for Examinations
Independent review provides an assessment of whether the AML program is adequate and whether the firm’s procedures and controls are being followed. Its scope and frequency need to reflect the business’s risks and applicable requirements.
InnReg provides independent AML testing, targeted control reviews, and examination support. Our money transmitter experience also includes developing and managing remediation plans following a multi-state examination, with follow-up on AML issues and regulatory requests.
Testing and regulatory support can address:
AML risk assessment, governance, policies, and training
Customer identification and due diligence samples
Transaction monitoring, investigations, SARs, and supporting records
Sanctions screening, agent oversight, and relevant system controls
License conditions, consumer compliance, and broader operational controls
Findings, corrective actions, and remediation validation
Independent testing is structured around applicable independence requirements and kept separate from the responsibilities of the personnel operating the program. During an examination, InnReg can also assist with document requests, response preparation, interviews, deficiency analysis, and remediation. Financial statement audits are separate from this compliance-testing service.
Testing the Program and Preparing for Examinations
Independent review provides an assessment of whether the AML program is adequate and whether the firm’s procedures and controls are being followed. Its scope and frequency need to reflect the business’s risks and applicable requirements.
InnReg provides independent AML testing, targeted control reviews, and examination support. Our money transmitter experience also includes developing and managing remediation plans following a multi-state examination, with follow-up on AML issues and regulatory requests.
Testing and regulatory support can address:
AML risk assessment, governance, policies, and training
Customer identification and due diligence samples
Transaction monitoring, investigations, SARs, and supporting records
Sanctions screening, agent oversight, and relevant system controls
License conditions, consumer compliance, and broader operational controls
Findings, corrective actions, and remediation validation
Independent testing is structured around applicable independence requirements and kept separate from the responsibilities of the personnel operating the program. During an examination, InnReg can also assist with document requests, response preparation, interviews, deficiency analysis, and remediation. Financial statement audits are separate from this compliance-testing service.
Testing the Program and Preparing for Examinations
Independent review provides an assessment of whether the AML program is adequate and whether the firm’s procedures and controls are being followed. Its scope and frequency need to reflect the business’s risks and applicable requirements.
InnReg provides independent AML testing, targeted control reviews, and examination support. Our money transmitter experience also includes developing and managing remediation plans following a multi-state examination, with follow-up on AML issues and regulatory requests.
Testing and regulatory support can address:
AML risk assessment, governance, policies, and training
Customer identification and due diligence samples
Transaction monitoring, investigations, SARs, and supporting records
Sanctions screening, agent oversight, and relevant system controls
License conditions, consumer compliance, and broader operational controls
Findings, corrective actions, and remediation validation
Independent testing is structured around applicable independence requirements and kept separate from the responsibilities of the personnel operating the program. During an examination, InnReg can also assist with document requests, response preparation, interviews, deficiency analysis, and remediation. Financial statement audits are separate from this compliance-testing service.
Assessing Products, Payment Flows, and Regulatory Gaps
Changes to payment flows, account structures, customer types, jurisdictions, digital assets, or partner relationships can alter the firm’s regulatory position and the controls it needs.
InnReg assesses how a proposed model fits within federal MSB definitions, state licensing frameworks, and related compliance requirements. Our work with technology-driven financial products includes evaluating how multiple regulated entities and providers fit together; for Uphold, that included regulatory and operational support for integrating equities services with an existing crypto platform.
Assessments can address:
Money transmission and other MSB activities
Federal exclusions and state licensing exemptions
Bank, licensed transmitter, agent, and payment processor arrangements
Wallets, prepaid value, digital assets, and cross-border flows
New products, jurisdictions, ownership changes, and authorization needs
Gaps in AML, sanctions, consumer, licensing, and operational controls
The analysis identifies practical next steps for filings, program changes, and operating arrangements, with legal counsel involved where needed.
Assessing Products, Payment Flows, and Regulatory Gaps
Changes to payment flows, account structures, customer types, jurisdictions, digital assets, or partner relationships can alter the firm’s regulatory position and the controls it needs.
InnReg assesses how a proposed model fits within federal MSB definitions, state licensing frameworks, and related compliance requirements. Our work with technology-driven financial products includes evaluating how multiple regulated entities and providers fit together; for Uphold, that included regulatory and operational support for integrating equities services with an existing crypto platform.
Assessments can address:
Money transmission and other MSB activities
Federal exclusions and state licensing exemptions
Bank, licensed transmitter, agent, and payment processor arrangements
Wallets, prepaid value, digital assets, and cross-border flows
New products, jurisdictions, ownership changes, and authorization needs
Gaps in AML, sanctions, consumer, licensing, and operational controls
The analysis identifies practical next steps for filings, program changes, and operating arrangements, with legal counsel involved where needed.
Assessing Products, Payment Flows, and Regulatory Gaps
Changes to payment flows, account structures, customer types, jurisdictions, digital assets, or partner relationships can alter the firm’s regulatory position and the controls it needs.
InnReg assesses how a proposed model fits within federal MSB definitions, state licensing frameworks, and related compliance requirements. Our work with technology-driven financial products includes evaluating how multiple regulated entities and providers fit together; for Uphold, that included regulatory and operational support for integrating equities services with an existing crypto platform.
Assessments can address:
Money transmission and other MSB activities
Federal exclusions and state licensing exemptions
Bank, licensed transmitter, agent, and payment processor arrangements
Wallets, prepaid value, digital assets, and cross-border flows
New products, jurisdictions, ownership changes, and authorization needs
Gaps in AML, sanctions, consumer, licensing, and operational controls
The analysis identifies practical next steps for filings, program changes, and operating arrangements, with legal counsel involved where needed.
Our Methodology
How We Work With Money Transmitters and MSBs
Money services engagements can span federal obligations, multiple state licenses, banking relationships, agents, and transaction-monitoring systems. InnReg uses a structured working model to coordinate those workstreams, identify dependencies, and organize the responsibilities needed for launch, expansion, and ongoing compliance.
01
Understand the Money Services Model and Set Priorities
We begin by reviewing the firm's services, customers, transaction flows, jurisdictions, registrations, licenses, ownership, banking relationships, agents, technology, and existing AML and compliance programs.
From there, we identify priority workstreams and dependencies, such as financial statements, ownership information, banking arrangements, system data, or management approvals. Licensing plans, program development, testing, and ongoing obligations are organized around the agreed scope and the firm's operating stage.
01
Understand the Money Services Model and Set Priorities
We begin by reviewing the firm's services, customers, transaction flows, jurisdictions, registrations, licenses, ownership, banking relationships, agents, technology, and existing AML and compliance programs.
From there, we identify priority workstreams and dependencies, such as financial statements, ownership information, banking arrangements, system data, or management approvals. Licensing plans, program development, testing, and ongoing obligations are organized around the agreed scope and the firm's operating stage.
02
Establish the Team and Assign Workstream Owners
A primary InnReg project lead coordinates the engagement and serves as the day-to-day contact. Additional licensing consultants, AML specialists, senior reviewers, or an outsourced AML officer may be involved depending on the scope.
We clarify responsibilities across InnReg, management, the AML officer, finance, operations, technology, legal counsel, and relevant partners. Each workstream identifies the people responsible for information, decisions, submissions, and follow-up.
02
Establish the Team and Assign Workstream Owners
A primary InnReg project lead coordinates the engagement and serves as the day-to-day contact. Additional licensing consultants, AML specialists, senior reviewers, or an outsourced AML officer may be involved depending on the scope.
We clarify responsibilities across InnReg, management, the AML officer, finance, operations, technology, legal counsel, and relevant partners. Each workstream identifies the people responsible for information, decisions, submissions, and follow-up.
03
Execute and Track Licensing and Compliance Work
Applications, renewals, reports, regulator questions, policy reviews, testing requests, deadlines, and open findings are tracked through an organized project-management process. Requests for client documents and transaction data are linked to the work they support.
InnReg commonly uses Asana and Google Drive and can work within agreed client systems. Regular progress meetings and agreed communication channels help coordinate work across jurisdictions and follow up on outstanding inputs.
03
Execute and Track Licensing and Compliance Work
Applications, renewals, reports, regulator questions, policy reviews, testing requests, deadlines, and open findings are tracked through an organized project-management process. Requests for client documents and transaction data are linked to the work they support.
InnReg commonly uses Asana and Google Drive and can work within agreed client systems. Regular progress meetings and agreed communication channels help coordinate work across jurisdictions and follow up on outstanding inputs.
04
Review, Escalate, and Adapt
Complex licensing questions, significant AML findings, examination requests, and other higher-risk matters may involve senior personnel, subject matter specialists, the AML officer, or legal counsel.
We adjust the working plan as products, transaction patterns, agents, banking partners, or the licensing footprint change. Regulatory feedback, control deficiencies, and remediation actions are tracked with the relevant owners and escalated through agreed channels.
04
Review, Escalate, and Adapt
Complex licensing questions, significant AML findings, examination requests, and other higher-risk matters may involve senior personnel, subject matter specialists, the AML officer, or legal counsel.
We adjust the working plan as products, transaction patterns, agents, banking partners, or the licensing footprint change. Regulatory feedback, control deficiencies, and remediation actions are tracked with the relevant owners and escalated through agreed channels.
Case Studies
Our Money Transmitter and MSB Stories
Resources
Latest Content
Articles
Downloads
Why InnReg
Why Money Transmitters and MSBs Work With InnReg
InnReg combines money services regulatory experience with a structured delivery model that connects licensing and compliance requirements to the firm’s transaction flows, customer relationships, technology, and operations.
Full Money Services Compliance Lifecycle
InnReg supports firms from regulatory analysis, FinCEN registration, and state licensing through program development, ongoing management, testing, examinations, and remediation. Our support can evolve as products, transaction volumes, and geographic coverage change.
Experience With Evolving Money Movement Models
Our work spans remittance, digital wallets, cross-border payments, and digital asset businesses. We consider how customers, funds flows, banking relationships, agents, and technology affect the regulatory framework and the controls needed to operate.
Compliance Connected to Transaction Operations
Customer onboarding, funding, transfers, settlement, refunds, investigations, and reporting all shape compliance risk. We connect policies with the people, systems, approvals, and records used to carry out those activities.
Practical Compliance Execution
Where included in the engagement, InnReg prepares applications and reports, administers recurring compliance work, supports customer and transaction reviews, performs testing, and manages regulatory responses and remediation. Our team helps carry recommendations into operating processes.
Structured, Team-Based Delivery
Each engagement has a primary day-to-day lead supported by consultants, specialists, senior reviewers, or a designated compliance officer as needed. Priorities, communication, project management, and collaboration tools keep the work organized.
Clear Responsibilities and Escalation
We define responsibilities across InnReg, management, compliance officers, finance, operations, technology, and relevant partners. Client inputs, reporting decisions, approvals, dependencies, and significant compliance matters follow agreed review and escalation paths.
FAQ
Money Transmitter and MSB Compliance FAQs
Money Transmitter and MSB Compliance FAQs
Can InnReg help us launch a money services business?
Does InnReg support both FinCEN registration and money transmitter licensing?
Can InnReg build our AML compliance program?
Can InnReg manage our ongoing compliance work?
Can InnReg provide an outsourced AML compliance officer or CCO?
Does InnReg conduct independent AML testing?
Can InnReg help us prepare for an examination or address findings?
Can InnReg support bank partner due diligence or work alongside our existing team?
Our Team
Meet the Team Supporting Money Transmitter and MSB Compliance
Talk to Our Money Transmitter and MSB Compliance Team
Talk to Our Money Transmitter and MSB Compliance Team
Who We Serve
By Regulated Firm Type
Services
How We Help
Resources
Downloads
About InnReg
© 2026 InnReg LLC
305-908-1160
The content provided on this website is for informational purposes only and does not constitute legal, investment, tax, or other professional advice. InnReg LLC is not a law firm, tax advisor, or regulated financial institution. Viewing this site or contacting InnReg does not create a client relationship. Results described in case studies or testimonials may not be typical and do not guarantee future outcomes. Tools, spreadsheets, or guides available on this site are provided for illustrative purposes only and should not be relied upon without professional guidance. Any links to third-party websites are provided for convenience and do not constitute endorsement or responsibility for their content. The information on this site may not be applicable in all jurisdictions. While we strive to provide accurate content, we make no representations as to its completeness or timeliness. Some visual assets on this site are sourced from Freepik.
9100 S Dadeland Blvd
Suite 1500
Miami, Florida 33156
Who We Serve
By Regulated Firm Type
Services
How We Help
Resources
Downloads
About InnReg
© 2026 InnReg LLC
305-908-1160
The content provided on this website is for informational purposes only and does not constitute legal, investment, tax, or other professional advice. InnReg LLC is not a law firm, tax advisor, or regulated financial institution. Viewing this site or contacting InnReg does not create a client relationship. Results described in case studies or testimonials may not be typical and do not guarantee future outcomes. Tools, spreadsheets, or guides available on this site are provided for illustrative purposes only and should not be relied upon without professional guidance. Any links to third-party websites are provided for convenience and do not constitute endorsement or responsibility for their content. The information on this site may not be applicable in all jurisdictions. While we strive to provide accurate content, we make no representations as to its completeness or timeliness. Some visual assets on this site are sourced from Freepik.
9100 S Dadeland Blvd
Suite 1500
Miami, Florida 33156