Bank Secrecy Act: what you need to know if you run financing business “FinCEN Form 107”
FinCEN Form 107 is the official Registration of Money Services Business (MSB) form required by the Financial Crimes Enforcement Network (FinCEN) under the Bank Secrecy Act. It is used by dealers in foreign exchange, check cashers, issuers or sellers of traveler’s checks and money orders, providers of prepaid access, and money transmitters to register with the U.S. Department of the Treasury.
Key Requirements and Process:
Filing Method: Registrations must be filed electronically via the BSA E-Filing System portal; paper filings are no longer accepted.
Initial Deadline: MSBs must file within 180 days of establishing their business.
Renewal: Registration must be renewed every two years by December 31 of the second calendar year.
Re-registration: A new Form 107 is required if there is a >10% transfer of equity, a >50% increase in agents, or a change in ownership/control that triggers state law re-registration.
Required Information: The form collects legal name, EIN/SSN, physical address, MSB activities, owner/controlling person details, branch/agent counts, and primary transaction account information.
Compliance: MSBs must retain a copy of the form and supporting documents (such as agent lists and volume estimates) for five years.
Failure to register or renew can result in civil fines of up to $5,000 per day and potential criminal penalties of up to five years imprisonment. Registration is a federal requirement and does not replace state-level Money Transmitter License (MTL) obligations.
you can file this form via IRS site https://www.irs.gov/pub/irs-tege/fin107_msbreg.pdf, sign and mail it to Enterprise Computing Center - Detroit Attn: Money Services Business Registration P.O. Box 33116 Detroit, MI 48232-0116. YOu must file this and re-new, if you work with any financial services, every two years.
