US money transmitter compliance checklist

The deadlines in this template

• FinCEN MSB registration renewalFinCEN · Every 2 years, by December 31

  Renew your money services business registration (FinCEN Form 107) through BSA E-Filing every 2 years. Registration runs in 2-calendar-year periods from the year you first had to register, and each renewal is due by December 31 of the year before the next period starts (31 CFR 1022.380(b)). Re-register within 180 days of a change of control, a transfer of more than 10% of the voting power or equity, or a more than 50% increase in agents.

• NMLS annual license renewalNMLS · November 1 to December 31

  Renew your state money transmitter licenses in NMLS. The renewal period runs from November 1 to December 31, and the reminder comes as it opens. Before submitting, update your company record, resolve outstanding license items and attest. Some states close earlier (Georgia on December 1) or charge fees outside NMLS, so check each state's renewal checklist.

• NMLS MSB Call ReportNMLS · 45 days after each calendar quarter

  Submit the MSB Call Report in NMLS within 45 days of each calendar quarter end, for every state license you held in the quarter. The destination country sections are annual and go with the fourth-quarter report. The dates here are the 14th of February, May, August and November, a day early for the first quarter.

• Audited financial statements to state regulatorsState regulators · 90 days after year end

  Most states that license money transmitters require audited financial statements for the licensee, prepared under US GAAP by an independent accountant, within 90 days of the fiscal year end, usually filed through NMLS. Some states set a different deadline or don't accept consolidated statements. The date here is set a few days early to stay inside 90 days.

• Independent review of the AML programFinCEN · Risk-based, often yearly

  Have your AML program reviewed by someone other than your compliance officer. The rule sets no fixed interval: the scope and frequency follow the risk of your services (31 CFR 1022.210(d)(4)). A yearly review is common and easiest to evidence; change the interval if your risk assessment supports it.

• Update the list of agentsFinCEN · Each January 1

  Revise your list of agents each January 1 for the previous 12 months, with each agent's name, address and phone number, the services they provide, the months their transactions for you exceeded $100,000, their bank and the number of branches or subagents (31 CFR 1022.380(d)). Keep it at the US location on your registration and give it to FinCEN or law enforcement on request; it isn't filed. Only applies if you use agents.

• Annual report of blocked property to OFACOFAC · By September 30

  If you hold blocked property, report everything held as of June 30 to OFAC by September 30 (31 CFR 501.603(b)(2)). Each new blocking is reported separately within 10 business days.

• New York annual report for licensed money transmittersNYDFS · 120 days after December 31

  Licensees of the New York State Department of Financial Services submit the annual report for the calendar year within 120 days of December 31. The date here is April 29, which is inside 120 days in leap years too.

• NYDFS cybersecurity compliance notice (Part 500)NYDFS · By April 15

  By April 15, submit a certification of material compliance with 23 NYCRR Part 500 for the previous calendar year, or an acknowledgment of noncompliance that lists the gaps and the remediation timeline (500.17(b)). It's signed by your highest-ranking executive and your CISO. Keep the supporting documents for 5 years.

• NYDFS transaction monitoring certification (Part 504)NYDFS · By April 15

  By April 15, submit the certification that your transaction monitoring and sanctions filtering program met 3 NYCRR Part 504 in the previous calendar year, through the DFS Portal. Licensed money transmitters and check cashers are covered.

State rules vary: some states close NMLS renewal early or set their own deadline for audited statements. Check each state you're licensed in and move the dates if yours differ. Check the New York items only if you hold a New York license.

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Every quarter

The MSB Call Report in NMLS, within 45 days of each calendar quarter end: February 14, May 15, August 14 and November 14.

Every year

The NMLS annual renewal between November 1 and December 31, audited financial statements within 90 days of your fiscal year end, and an independent review of your AML program on a date you choose. If you use agents, revise your agent list each January 1. If you hold blocked property, report it to OFAC by September 30.

Every 2 years

Your FinCEN MSB registration renewal, due by December 31 of the year before each new 2-year period. Enter the date once and it repeats.

New York licensees

The Part 500 cybersecurity certification and the Part 504 transaction monitoring certification by April 15, and the annual report within 120 days of the year end. They start unchecked; check them if you hold a New York license.

Who it's for

Money transmitters and other money services businesses registered with FinCEN and licensed by one or more states through NMLS. State rules vary, so check each state you're licensed in. Suspicious activity reports aren't on a calendar: see the SAR filing deadline for MSBs.

Sources

• 31 CFR 1022.380: Registration of money services businesses
• 31 CFR 1022.210: Anti-money laundering programs for money services businesses
• 31 CFR 501.603: Reports of blocked property
• NMLS: MSB Call Report reporting frequency
• NMLS: Annual renewal overview for companies
• NYDFS: Annual report for licensed transmitters of money on NMLS, 2025

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