Due to the absence of a mandatory MSB License in Montana, this jurisdiction becomes a strategically advantageous jurisdiction for cryptocurrency companies focused on international markets. Businesses operating as Money Service Businesses in Montana can conduct cross-border activities without state-level licensing while maintaining a legal presence in the US. All that is required is registration with FinCEN and compliance with basic AML standards.

Montana’s flexible financial regulation reduces the compliance burden, simplifies launch, and minimizes operating costs. The state is particularly attractive for the following categories of companies:

  • сryptocurrency exchanges and wallets;

  • DeFi projects and blockchain platforms;

  • payment providers and crypto acquirers;

  • international fintech companies that do not work with US residents.

This approach allows businesses to focus on growth and attracting investment while maintaining their international reputation and legal transparency.

In parallel with the current liberal position, the state is developing a policy for more structured regulation of the digital economy. In 2025, Senate Bill 265 (SB 265), known as the Financial Freedom and Innovation Act, was passed. The document aims to combat crypto fraud, restricts the use of CBDCs by government agencies, and establishes the right of individuals and companies to accept digital assets, use wallets, and interact with blockchain protocols.

However, the state has not yet introduced Money Service Business licensing requirements for money transfer operations. This keeps Montana an open and attractive jurisdiction for international crypto projects, especially those operating outside the US.



Who needs an MSB license in Montana

There is no requirement for a separate Montana MSB License in this jurisdiction. However, businesses providing certain financial services are still required to register with FinCEN at the federal level.

MSB registration is required if you engage in:

  • Money transfers on behalf of customers, including domestic and international transactions

  • Currency exchange, including fiat currencies and digital assets (including cryptocurrencies)

  • Transactions with electronic money or stablecoins

  • Cryptocurrency transfers, purchase, sale, or storage of virtual assets on behalf of customers

  • Acting as a financial intermediary, for example, within payment platforms and gateways

It is important to note that even though Montana does not require a separate Montana Money Service Business License, federal FinCEN requirements remain mandatory for all companies providing these services.

Key Benefits for Montana MSBs

No state license

Montana does not require a separate MSB license, which simplifies business start-up and reduces administrative barriers.

Minimal registration costs

Setting up and maintaining an MSB company is less expensive compared to other US jurisdictions.

No sales tax

A favorable tax regime increases profitability and reduces operating costs.

Maximum legal flexibility

You can combine registration in Montana with the use of foreign licenses and international structures.

Access to global payment solutions

US registration increases trust from foreign banks and payment providers.

Favorable regulatory climate

Minimal state oversight makes Montana a convenient entry point into the US market for international crypto and fintech companies.

Requirements for obtaining an MSB license in Montana

Although an MSB License in Montana is not required at the state level, companies engaged in money transmission or currency exchange are required to comply with federal requirements established by FinCEN (Financial Crimes Enforcement Network):

  • A legal entity must register with FinCEN by completing FinCEN Form 107 within 180 days of commencing operations.

  • The company is required to provide complete information about its structure, beneficiaries, management, areas of activity, target markets, and office addresses.

  • Appointment of a Compliance Officer. An authorized employee must be appointed within the company to be responsible for compliance with all FinCEN regulations, including risk control and internal audits.

  • MSBs must have a written and documented internal policy for combating money laundering and identifying customers. The program must include procedures for monitoring transactions, internal auditing, and staff training.

  • If the company operates through agents, it is required to maintain a register of agents and update it annually, retaining the data for at least 5 years.

  • MSBs are required to use the BSA E-Filing system to file regular reports, including suspicious activity reports (SARs) and large currency transaction reports (CTRs).

FinCEN registration is renewed every two years. Despite the absence of state licensing, compliance with these requirements is mandatory for all MSB operators operating in Montana.

Procedure for Obtaining the MSB License in Montana

To start operating in the money services business in the United States, companies registered in Montana are not required to obtain a local MSB License. Instead, the federal procedure established by FinCEN applies. It is this procedure that ensures the legality of operations and provides access to international financial channels. The MSB status application process consists of several steps, each of which is designed to ensure transparency and compliance with regulatory standards:

Preparation of initial documentation

1 week

Result: A basic package of documents and information is compiled to start the registration process with FinCEN and launch compliance procedures.

  • Determination of the proposed company name

  • Copies of passports of all founders and managers

  • Documents confirming the address of residence (e.g., utility bill)

  • Brief description of the business model (1–2 pages) reflecting the specifics of the activity

MSB registration with FinCEN

5-7 business days

Result: MSB status is assigned, and the company is included in the federal register.

  • Completion and submission of FinCEN Form 107

  • Submission of information about controlling persons, services, and locations

  • Receipt of official confirmation from FinCEN

  • Record keeping and preparation for periodic updates (once every 2 years)

Registration and interaction with FinCEN

2 weeks

Result: The company is registered, documents are prepared, the application to FinCEN is submitted, and internal processes to ensure compliance with regulations are initiated.

  • Legal registration of a company in the US (most often in the state of Montana)

  • Preparation of corporate documentation

  • Collection of extensive information about the client’s activities: nature of services, geography, target audience

  • Development and adaptation of AML/KYC policies to the cryptocurrency profile

  • Submission of FinCEN Form 107 and further support of the application

Opening a corporate account

4–6 weeks


Bank compliance can be the most time-consuming stage:

  • Analysis of suitable banks and EMI providers

  • Comparison of the bank’s and client’s risk profiles based on previously approved AML policies

  • Preparation of a package of documents for opening an account: source of funds, description of objectives, information about key partners, company website, utility bill, etc.

  • Supporting the client at all stages of communication with the bank until the account is successfully opened

info

All stages are implemented on a turnkey basis with professional support from the Gofaizen & Sherle team. We provide full support from company registration to the launch of MSB activities at the international level.

Regulation of cryptocurrencies in Montana

Montana has established itself as a unique jurisdiction for cryptocurrency companies, especially those focused on international markets. Its appeal lies in the combination of no mandatory Money Service Business License at the state level and consistent support for digital assets through progressive legislation.

Currently, the Montana Department of Banking and Financial Infrastructure officially confirms that it does not regulate money transmitters. This means that companies engaged in money transfers, currency exchange, and cryptocurrency transactions are not required to obtain a separate MSB license. Instead, they are subject to federal FinCEN requirements.
At the same time, Montana’s financial regulation is actively shaping a favorable regulatory environment for blockchain projects and crypto companies:

  • Law SB 178 (2023) recognized cryptocurrency as a form of personal property, exempted it from taxation when used in settlements, and ensured protection for mining from discrimination.

  • Law SB 265 (2025, “Financial Freedom and Innovation Act”) prohibited the use of CBDCs by state authorities, approved the right of businesses and individuals to use digital assets and self-hosted wallets, and introduced certification requirements for network token issuers.

All federal obligations remain in force. MSBs in Montana are required to:

  • register with FinCEN using FinCEN Form 107;

  • appoint a compliance officer;

  • develop and implement internal AML/CTF and KYC procedures;

  • file reports through the BSA E-Filing System.

This flexible approach makes Montana particularly attractive to crypto businesses, exchange services, DeFi platforms, and fintech startups seeking to scale internationally with minimal regulatory burden.


Who regulates MSBs at the federal level:

AuthorityWhat tasks does it perform
FinCENAccepts MSB registration via Form 107. Monitors compliance with AML/CTF requirements and the submission of SAR and CTR reports.
IRS (Internal Revenue Service)Assigns an EIN and tracks tax filings.
BSA E-Filing SystemPlatform for submitting mandatory reports on transactions.
State DepartmentMontana does not officially regulate money transfers. Other states may require a separate license.

Conclution

Montana is shaping its image as one of the most flexible and accessible states in the US for conducting cryptocurrency business. Thanks to the absence of a mandatory Montana Money Service Business License at the state level and a focus on compliance with federal regulations only, companies can launch projects faster and at a lower cost.

Modern Montana financial regulation focuses on encouraging innovation and technological development, especially in the field of digital assets. This simplifies entry into the US market, reduces the regulatory burden, and at the same time provides the necessary legal transparency.

Gofaizen & Sherle provides comprehensive support to cryptocurrency and fintech companies entering the US market through Montana. Our team of experts will help you register, build a compliance system, and take into account all federal regulatory requirements so that your business can scale confidently and legally in one of the most loyal jurisdictions in the US.



FAQ about Fintech Law Firm

  • What is an MSB license in Montana?

    At the state level, Montana does not require an MSB license (for money transmission and currency exchange). However, such companies are required to register with FinCEN at the federal level.

  • Who needs an MSB license in Montana?

    Companies that provide money transfer services, currency exchange, prepaid card sales, or cryptocurrency services are required to register with FinCEN as an MSB. This rule applies to any business that falls under the federal definition of a Money Services Business.

  • What are the federal FinCEN requirements for MSBs?

    Even without a separate license, companies in Montana that provide MSB services are required to register with FinCEN, designate a compliance officer, implement internal anti-money laundering procedures, and report regularly through BSA E-Filing.

  • How much does an MSB license cost in Montana?

    The cost of obtaining MSB status in the US with support varies from $4,900 to $15,900, depending on the package: basic registration, ready-made company, or full support with bank account registration. In Montana, no license is required, and the fee is related to federal registration and compliance.

  • How often do you need to update your FinCEN registration?

    FinCEN registration must be updated every two years. In addition, MSBs must notify the regulator of any significant changes in the company’s activities or structure.

Connect with our experts



TOP