FinCEN Notice And Request For Comment On MSB Registration Form

On April 30, 2026, the Financial Crimes Enforcement Network (“FinCEN”) published a notice and request for comment (the “Notice”) in connection with its renewal of Form 107, which Money Services Businesses utilize for registration and renewal purposes. FinCEN’s Notice proposes a renewal without change to Form 107, and the comment period remains open until June 29, 2026.

The Bank Secrecy Act (“BSA”) and its implementing regulations require MSBs to file an initial registration form, to renew the registration every two years, and maintain a list of their agents (if applicable).

As part of the Paperwork Reduction Act, FinCEN is required to periodically review Form 107. FinCEN must justify the necessity of the collection form and intended use, as well as provide an estimate of the burden in completing the form.

According to FinCEN’s analysis of Form 107 filings from the past three years, the number of MSBs filing an initial or renewal form has increased. The estimated burden associated with the initial filing is 50 minutes, depending on the number of fields an MSB must complete, 40 minutes for renewal, and 30 minutes for maintaining an agent list. FinCEN acknowledged that maintaining an MSB agent list may require additional time for purposes of auditing and verifying the list; however, FinCEN does not account for this time in estimated burdens.

Efforts to Implement AMLA

The Notice asks for comments on the following questions related to FinCEN’s efforts to implement the Anti-Money Laundering Act (“AMLA”):

• Is there publicly available data that went unmentioned in this Notice, but that FinCEN should consider when estimating the number of MSB agents? If possible, please comment on the generalizability and other usability feature of the data.
• How would changes in the size or composition of the MSB population affect FinCEN’s estimated burden? Are there other assumptions that are more likely to contribute to substantive inaccuracies in the total burden and cost estimates? If so, please describe.
• What changes to FinCEN Form 107 would reduce common errors or omissions?

Section 6216 of the AMLA directs FinCEN to review BSA regulations and guidance to ensure there are appropriate safeguards to protect the financial system from threats posed by various forms of financial crime. To meet this objective, FinCEN has previously sought input through formal requests for information (“RFI”) on regulations, reporting, and recordkeeping requirements that protect the U.S. financial system while also minimizing regulatory burdens posed. Although the previous RFI did not expressly mention burdens on MSBs, FinCEN is using this Notice as an opportunity to assess the regulatory burdens imposed on MSBs. 

Risks Posed by Unregistered MSBs

According to Treasury’s most recent National Money Laundering Risk Assessment, MSBs, like other financial institutions, continue to face money laundering risks. Treasury cited the large number of current MSB principals and agents and highlighted the “outsized risks” posed by unregistered MSBs. Unregistered MSBs may include individuals and entities acting as part of an informal value transfer system (“IVTS”) or may include individuals and entities using their personal or business accounts to engage in money transmission. Treasury highlighted a recent enforcement action against an unregistered MSBs that resulted in a $37 million civil money penalty.

Regulatory and Operational Impact

As a reminder, accurate and complete MSB registration and agent maintenance is part of the MSB examination procedures.

Second, the AMLA‑related questions highlight where FinCEN wants industry input. The agency is probing data sources for agent counts and recurring Form 107 errors. This is an opportunity to identify gaps between agent rosters and operations and fields prone to stale or mis‑keyed entries.

Third, banks serving MSBs should read the 2026 National Money Laundering Risk Assessment. Recent enforcement actions illustrate that registration is closely tied to BSA/AML program effectiveness. Onboarding and periodic reviews of MSB customers should confirm proper registration.

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