FinCEN MSB registration renewal deadline

Working out your renewal year

The initial registration period is the 2 calendar years starting with the year you were first required to register. Each 2-year period after that is a renewal period. If you first registered in 2025, your initial period is 2025 and 2026, and the renewal for 2027 and 2028 is due by December 31, 2026.

A new business files its first registration within 180 days of the day after it's established.

When you re-register early

• A change in ownership or control that requires you to re-register under state law
• A transfer of more than 10% of the voting power or equity interests, if you have to report it to a state
• A more than 50% increase in the number of your agents during a registration period

After a change

Re-register within 180 days of the change. The calendar year it happens in becomes the first year of a new 2-year period, which moves your renewal date.

If you don't register

Doing business without a current registration is unlawful. The civil penalty is set per violation, and each day it continues counts as a separate violation. After the yearly inflation adjustment it was $10,556 in the July 2025 edition of the regulations (31 CFR 1010.821).

Also on the calendar

Your registration sits alongside the NMLS annual renewal of your state licenses and the quarterly MSB Call Report. If you use agents, revise your agent list each January 1 (31 CFR 1022.380(d)).

Sources

• 31 CFR 1022.380: Registration of money services businesses
• 31 CFR 1010.821: Penalty adjustment and table

This page is a summary, not legal or regulatory advice. The rules in the sources above take precedence.