MSB License in
Montana 2025
Montana has emerged as one of the most cost-effective U.S. jurisdictions for obtaining a Money Services Business (MSB) license. Unlike the traditional Money Transmitter License (MTL) regime, which requires separate applications and approvals in each U.S. state, Montana offers a streamlined MSB registration pathway under federal oversight via FinCEN (Financial Crimes Enforcement Network).
This makes Montana highly attractive for businesses operating in crypto, fiat money transmission, payment processing, and remittances — particularly for non-U.S. founders seeking access to the American financial system with lower costs and faster turnaround.
Legalaes provides turnkey MSB licensing services in Montana, including company incorporation, compliance documentation, due diligence, bank account assistance, and full representation before authorities.
Regulations for MSB in Montana
Money Services Businesses in Montana are primarily regulated under the Bank Secrecy Act (BSA) and supervised by FinCEN on the federal level. Montana distinguishes itself by not requiring a separate Money Transmitter License (MTL) at the state level, which significantly reduces regulatory costs and complexity.
MSBs operating in Montana must:
- Register with FinCEN as required under the BSA.
- Maintain and implement a compliant AML/CFT program.
- File Currency Transaction Reports (CTR) and Suspicious Activity Reports (SAR).
- Keep financial and client records for at least 5 years.
- Submit to federal inspections and audits.
This combination of federal registration and lighter state-level oversight makes Montana one of the most accessible entry points to the U.S. market for crypto and payment businesses.
Types of MSB Licenses in Montana
Unlike states with separate licensing classes, Montana MSBs are registered federally with FinCEN under categories of activity. Businesses must specify their services during registration, including:
| License type | Description |
|---|---|
| Money Transmitters | Transferring funds domestically or internationally. |
| Currency Dealers/Exchangers | Exchanging fiat currencies. |
| Check Cashers | Cashing checks or money orders. |
| Issuers of Traveler’s Checks, Money Orders, or Stored Value | |
| Crypto Businesses | Exchanges, wallets, custodians, and OTC desks. |
| Payment Processors & Remittance Services | Facilitating online or cross-border payments. |
Each business can register under multiple categories, allowing flexibility to expand services without re-licensing at state level.
Overview of Requirements to Obtain an MSB License in Montana
Main requirements:
- Incorporation of a Montana LLC
- U.S. Registered Agent and business address.
- Federal Employer Identification Number (EIN) from the IRS.
- MSB registration with FinCEN under the Bank Secrecy Act.
- Drafting and adoption of AML/KYC/CFT policies.
- Appointment of a Compliance Officer (local or part-time possible).
Additional requirements:
- Detailed business plan covering services, revenue streams, and risk controls.
- Preparation of Suspicious Activity Reporting (SAR/CTR) procedures.
- Fit and Proper checks for directors, shareholders, and key personnel.
- Secure data protection and cybersecurity framework.
- Periodic renewal of MSB registration (every two years).
- Ongoing compliance reporting to FinCEN and recordkeeping in line with BSA.
Legal Services for Obtaining an MSB License in Montana
Legalaes offers three service models — Basic Package for startups, Comprehensive Package for full-scale readiness, and Ready-Made MSB for instant U.S. market entry. All packages ensure compliance with FinCEN and the Bank Secrecy Act (BSA).
Basic Package
11,900 USD
for startups incorporating in Montana
- Montana LLC incorporation
- AML/KYC compliance framework (policies, onboarding manuals, SAR/CTR procedures)
- Business plan preparation aligned with FinCEN requirements
- Due diligence & Fit & Proper checks for directors/shareholders
- Preparation & submission of FinCEN MSB registration
- Legal guidance during the registration process
Comprehensive Package
for full-scope MSB readiness
- Full compliance documentation (AML, risk, governance, reporting)
- Tailored business plan for banking and regulator acceptance
- Regulatory advisory & representation with FinCEN
- Guidance on accounting and recordkeeping under BSA
- Support with bank/payment provider onboarding
- Legal guidance on international operations & U.S. tax efficiency
- Ongoing advisory during regulatory review
Ready-Made MSB Company
for instant U.S. market entry
- Pre-formed Montana LLC with valid EIN
- Active FinCEN MSB registration included
- Complete compliance package (AML/KYC manuals)
- Ownership transfer & share transfer agreement
- Banking & payment provider introductions
- Post-transfer legal advisory & update of MSB registration
- Expansion support for additional state licenses if required
Jegor Kupratsevits
Head of Fintech
Requirements for MSB Licensing in Montana
List of Required Documents
- Corporate documents:
- Articles of Organization and Operating Agreement.
- EIN registration confirmation.
- Shareholder register and UBO disclosure.
- Proof of registered office address in Montana.
- AML/CFT & compliance framework:
- AML/CFT manual in line with BSA.
- KYC onboarding procedures and monitoring framework.
- Suspicious Activity Reporting (SAR/CTR) templates.
- Sanctions screening policy.
- Governance & operational policies:
- Compliance manual.
- Cybersecurity and data protection policy.
- Segregation of client funds policy.
- Business continuity and disaster recovery plan.
- Complaints handling procedures.
- Personnel documentation:
- Passport/ID and proof of address for each director/shareholder.
- CV and professional references.
- Police clearance (where required).
- Fit and Proper declarations.
Business Premises Requirements
- A registered business address in Montana is mandatory.
- Physical office presence is not strictly required, but recommended for credibility.
- Certain banking partners may require a lease agreement.
Share Capital and Government Fees
- No fixed statutory share capital requirement for Montana LLCs.
- Incorporation fee: approx. $70–100.
- Annual renewal fee: approx. $20–50.
Personnel Requirements
- At least one Compliance Officer (may be outsourced).
- At least one Director (can be non-U.S. resident).
- Demonstrated relevant experience in financial services or crypto.
- Governance should follow the three-line structure: management, compliance oversight, and audit.
Roadmap to Obtaining a Montana MSB License
Jegor Kupratsevits
Head of Fintech
Strategic Planning
We begin by defining your business model, selecting MSB categories (transmission, crypto, remittance), and identifying compliance requirements. This ensures that the foundation of your application aligns with federal and Montana regulatory expectations.
Incorporation
We establish your Montana LLC, draft organizational documents, and obtain the EIN. This provides your business with a legal identity recognized both in Montana and federally.
Compliance Documentation
Our team prepares AML/KYC/CFT manuals, reporting frameworks, and operational policies in line with the BSA. This ensures your business meets FinCEN standards from day one.
MSB Registration
We handle the FinCEN registration, filing all required forms and declarations. This process secures your federal recognition as a Money Services Business.
Regulatory Representation
Throughout the review process, we respond to FinCEN queries, provide clarifications, and maintain communication to avoid unnecessary delays.
Banking & Operations
We assist in opening MSB-friendly bank or EMI accounts, ensuring your company can transact and operate effectively once licensed.
Advantages of Obtaining an MSB License in Montana
01
No State-Level License Requirement
Unlike most U.S. states, Montana does not require a separate Money Transmitter License, cutting costs and saving months of processing time.
02
Low Costs and Fees
Montana offers one of the lowest incorporation and renewal costs nationwide, making it highly attractive for startups and scale-ups.
03
Crypto-Friendly Environment
Montana is known for its openness to digital asset companies, with local banking and service providers experienced in working with crypto MSBs.
04
Global Accessibility
The Montana MSB license, combined with federal registration, allows international founders to operate in the U.S. market while servicing clients worldwide.
Estimated Timeframes to Obtain a Montana MSB License
1. Business Planning & Documentation
Time Frame: 1-2 weeks
Defining service scope, drafting AML/CFT manuals, risk procedures, and collecting shareholder/management due diligence.
2. Company Incorporation
Time Frame: 1-2 weeks
Filing Articles of Organization, setting up Operating Agreement, and securing EIN.
3. Application Submission to FinCEN
Time Frame: 1-2 days
Submitting MSB registration with required documentation.
4. FinCEN Review & Acknowledgement
Time Frame: 2-4 weeks
Regulator confirms registration, may request clarifications.
5. Banking & Operational Setup
Time Frame: 3-6 weeks
Opening a corporate bank account, often the most time-consuming step.
6. License Activation
Time Frame: Immediate after approval
Once acknowledged by FinCEN, your MSB license is active.
Tips to Reduce Delays
Work with experienced counsel, notarize and apostille personal documents if required, and prepare banking relationships in advance. Proactive communication can significantly shorten approval and setup time.
Taxation of MSB Companies in Montana
Most clients operating under a Montana MSB license generate income outside the U.S., but tax obligations remain a crucial consideration.
Federal Corporate Tax
Federal Corporate Tax
- U.S. corporations are subject to a flat 21% corporate tax on worldwide income. However, if structured properly (e.g., through non-U.S. parent companies), effective tax exposure can be optimized.
Montana State Corporate Tax
Montana State Corporate Tax
- 6.75% applies on income sourced from Montana, though most MSBs operating globally will have limited in-state revenue.
Withholding Tax on Dividends
Withholding Tax on Dividends
- Dividends paid to foreign shareholders may be subject to 30% withholding tax, reduced under applicable double-tax treaties.
Personal Income Tax for Local Staff
Personal Income Tax for Local Staff
- Montana has progressive personal tax rates (1%–6.75%). Local compliance officers and staff hired in-state will be subject to these rates.
Sales Tax
Sales Tax
- Montana has no state sales tax, reducing operational burdens for financial services.
Legalaes advises clients on international structuring to optimize tax exposure while maintaining compliance.
Key Legal Resources for Montana MSB Licensing
Primary guidance on U.S. MSB registration requirements.
Core U.S. law governing AML/CFT obligations for MSBs.
State laws covering financial services, money transmission, and company operation.
Official guidance on incorporating and maintaining a Montana company.
U.S. tax identification requirements for LLCs with foreign ownership.
FAQ Montana
Do I need a Money Transmitter License in Montana?
No. Montana does not require a state-level MTL, only federal FinCEN MSB registration.
Can non-U.S. residents own a Montana MSB?
Yes, non-residents can incorporate and own 100% of a Montana MSB.
How long does it take to get licensed?
On average, 1–2 months including banking setup.
Is a physical office required in Montana?
No, only a registered address is required, but a physical office can improve banking relationships.
What banking options are available?
MSBs may use U.S. banks that accept fintech/crypto clients or partner with EMIs and PSPs.
What are the compliance obligations after licensing?
Annual renewals, ongoing AML/KYC monitoring, SAR/CTR filings, and proper recordkeeping.
Can one company operate multiple services?
Yes, a single MSB registration can cover several activities (crypto, remittances, transmission).
Each of our projects receives unique and tailored solutions in accordance with the initial objectives and vision of the shareholders.
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