US MSB Registration | Manimama

U.S. MSB Registration

for Global Crypto & Fintech Projects

A legal alternative to MiCA for international operations.

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Launch a Money Services Business (MSB) in the United States,
Montana or Wyoming, and operate internationally without obtaining
an EU CASP license.

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What Is an MSB and Why It Matters

Launch regulated businesses without waiting

A Money Services Business (MSB) is a federally regulated category
of companies supervised by FinCEN (U.S. Department of the Treasury).

MSB registration is mandatory for businesses involved in:

  • crypto to fiat exchange
  • crypto to crypto exchange
  • crypto payment processing
  • money transmission and transfers

MSB registration:

  • grants federal regulatory recognition in the U.S.
  • ensures compliance with the Bank Secrecy Act (BSA)
  • requires AML, KYC, SAR and CTR procedures
  • is widely accepted by banks and payment providers worldwide

For crypto projects, MSB is not a limitation.
It is a gateway to global legitimacy.

Who This Is For

It is a gateway to global legitimacy.

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Crypto exchanges
and brokers

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Payment processors

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Web3 and DeFi platforms

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Crypto wallets and on-ramps

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Fintech startups seeking
global reach

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Founders looking for a MiCA alternative

Why Montana and Wyoming

Two U.S. states. One strategic advantage.
We help clients structure U.S. MSB registrations in jurisdictions
that allow international operations
without the burden of state-level licensing.

The U.S. regulatory framework operates on two levels:

  • Montana and Wyoming are unique in that they do not require a state-level MTL, allowing businesses to operate solely under MSB registration. This makes them particularly suitable for internationally focused crypto and fintech projects.
  • federal MSB registration with FinCEN and state-level Money Transmitter Licenses (MTL).
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Montana

MSB without state MTL

The corporate income tax rate of 6.75 percent applies only to Montana-sourced income.

No state sales tax.

Montana is well-suited for crypto and fintech businesses with international transaction flows and a limited U.S. nexus.

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Wyoming

MSB without state MTL

Zero corporate income tax.

No franchise tax.

Wyoming is one of the most crypto-friendly states in the U.S., offering support for innovative business models, including DAO LLC structures and blockchain-based projects.

MSB (USA) vs MiCA CASP (EU)

A side-by-side overview of two regulatory frameworks, highlighting key differences in licensing scope, compliance requirements, operational flexibility, and market access for crypto and fintech businesses.

Criteria
U.S. MSB
MiCA CASP (EU)
Jurisdiction
United States
European Union
Regulator
FinCEN (U.S. Treasury)
National EU regulators under MiCA
Legal Status
Federal registration
Full regulatory license
Time to Market
Weeks
9–18 months
Entry Cost
Low to medium
High
Capital Requirements
None
Mandatory minimum capital
State-Level Licensing
Not required in Montana & Wyoming
Not applicable, but national supervision applies
AML / KYC
Required under BSA
Required under MiCA + AMLD
Ongoing Compliance Cost
Moderate
High and increasing
Regulatory Flexibility
High
Low

Legal Architecture of an International Crypto Business

We show how to operate in the EU and other regions through a U.S. MSB structure, without unnecessary licenses, regulatory risks, or double taxation

MSB vs MTL. When a License
Is Required

Understanding the regulatory boundary
  • MSB registration is always required
  • MTL is required only if you serve U.S. residents
If your business:
  • does not provide services to U.S. clients
  • focuses on the EU, Latin America, 
Africa or Switzerland
  • does not create a U.S. tax nexus
Then:
  • MSB registration is sufficient
  • no state-by-state MTL licenses are required
  • U.S. federal and state taxes typically
do not apply to foreign income

This makes Montana and Wyoming one of the most
efficient entry points for global crypto businesses.

Reverse Solicitation.
The MiCA-Compliant Path

How MSB structures interact with the EU legally

MiCA prohibits active marketing of crypto services
in the EU by companies without CASP authorization.

However, MiCA explicitly allows reverse solicitation.

Reverse solicitation means:
  • the initiative comes from the client
  • no targeted advertising toward EU residents
  • services are provided after client-initiated contact

A U.S. MSB structure fits perfectly into this framework.

What we implement:
  • legally compliant disclaimers under Article 61 MiCA
  • internal evidence and logging of voluntary
client access
  • non-EU targeted marketing strategy
  • multilingual positioning (English, Spanish, French,
German) without EU targeting
Result:
  • lawful access to EU clients
  • no CASP license
  • no violation of MiCA marketing restrictions

Tax Efficiency
and International Operations

Global business without unnecessary taxation
If your MSB:
  • has no employees or offices in the U.S.
  • does not serve U.S. residents
  • focuses on international markets
Then:
  • no U.S. federal income tax on foreign profits
  • no state-bno state tax in Wyoming or limited
exposure in Montanay-state MTL licenses are required
  • no double taxation
This structure allows:
  • tax-efficient international operations
  • regulatory clarity
  • scalability without forced relocation

MSB setup and legal structuring
under one roof

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U.S. Company Formation

We register an LLC in Montana or Wyoming, selected based on your business model, transaction flows, and international focus.

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AML and KYC Framework

We develop AML and KYC programs aligned with the U.S. Bank Secrecy Act, tailored to crypto and fintech risk profiles.

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Legal Positioning and Documentation

We prepare reverse solicitation positioning, website disclaimers, and Terms of Service
to support compliant international operations.

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MSB Registration with FinCEN

We handle MSB registration at the federal level, ensuring correct scope of activities and regulatory positioning from day one.

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SAR and CTR Reporting Structure

We design internal procedures for Suspicious Activity Reports and Currency Transaction Reports in line with regulatory expectations.

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Banking and Payment Advisory

We advise on banking, payment providers, and operational setup for crypto and high risk business models.

Request Your MSB Structure Assessment

We will analyze your business model and design a compliant,
scalable and bank-ready MSB structure.

Get free consultation

FAQ

Yes. MSB registration and reverse solicitation are explicitly recognized under U.S. and EU law when implemented correctly.

Yes, provided advertising is not targeted at EU residents. We design compliant marketing strategies.

No, if you do not serve U.S. clients.

Yes. Crypto and fintech activities are core MSB use cases.

Timelines depend on business complexity but typically range from several weeks.

No. When structured correctly, this is a stable long-term regulatory model.

Talk to our experts

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