美国联邦金融犯罪管理局FinCEN监管下的Money Service Business（MSB）许可证
General Information
Who Must Register
Generally money services businesses (MSBs) must register with the Department of the Treasury, using this report, Registration of Money Services Business (RMSB). However, not all MSBs are required to register. For example, if you are an MSB solely because you are an agent of another MSB, you are not required to register. The discussion below will help you determine whether or not you are an MSB that is required to register.
The term “money services business” includes:
1. Dealer in foreign exchange who transacts in an amount greater than $1,000 for any one customer on any day, whether or not for same day delivery.
2. Check casher who accepts checks or other monetary instruments in an amount greater than $1,000 in return for currency or a combination of currency and other monetary instruments for any one customer on any day.
3. Issuer or seller of traveler’s checks or money orders who issues or sells more than $1,000 in traveler’s checks or money orders for any one customer on any day. “Issuer” is defined or determined by virtue of the amount at which its monetary instruments or traveler’s checks are sold, as opposed to the amounts at which they are issued. For example, the amount of the sale includes the face value of the monetary instruments plus any fees.
4. Provider of prepaid access who agrees to be the provider with respect to a prepaid access program or is determined to have principal oversight and control over the prepaid access program. The provider serves as the principal conduit for access to information from its fellow program participants. Considerations for a provider determination include whether a party organizes the program; sets the terms and conditions of the prepaid program and determines that the terms have not been exceeded; determines the other businesses that will participate in the prepaid program, which may include the issuing bank, the payment processor, or the distributor; controls or directs the appropriate party to initiate, freeze, or terminate prepaid access; and engages in activity that demonstrates oversight and control of the prepaid program.
5. Money transmitter.
6. U.S. Postal Service.
7. Seller of prepaid access. A seller of prepaid access is any person that receives funds or the value of funds in exchange for an initial loading or subsequent loading of prepaid access, if that person: (1) sells prepaid access offered under a prepaid program that can be used before verification of customer identification; or (2) sells prepaid access, including closed loop prepaid access, in excess of $10,000 to any person on any one day and has not implemented policies and procedures reasonably adapted to prevent such a sale.
The following are not required to register:
1. A business that is an MSB solely because it serves as an agent of another MSB. An agent is a person authorized to represent the principal and to transact business on its behalf with third parties. See further discussion of “agent” below. For example, a supermarket corporation that sells money orders for an issuer of money orders is not required to register. This is true even if the supermarket corporation serves as an agent for two or more issuers. However, an MSB that serves as an agent of another MSB and engages in MSB activities on its own behalf must register. For example, a supermarket corporation must register if, in addition to acting as an agent of the money order issuer, it also provides check cashing or foreign currency exchange services on its own behalf in an amount greater than $1,000 for any one person on any day. Most sellers of prepaid access will qualify under this exemption from registration.
2. The United States Postal Service, any agency of the United States, of any state, or of any
political subdivision of any state.
When to Register:
Initial registration: File the report within 180 days after the date the business is established.
Renewal: Each MSB must renew its registration every two years, on or before December 31. For example, if an MSB registered on October 15, 2003, it must file a renewal by December 31, 2004, and then every 24 months thereafter (on or before December 31, 2006, then December 31, 2008, etc.). Renewals must be submitted on a new RMSB. Photocopies of previously submitted forms/reports or facsimiles will not be accepted for renewal purposes.
