Money Services Businesses (MSBs) have evolved into a critical backbone of the U.S. financial ecosystem, facilitating domestic and international payments, credit issuance, digital asset management, and more. Traditionally, MSBs included money transmitters, currency exchangers, and check cashers. In recent years, however, their scope has expanded significantly to encompass fintech platforms, digital wallets, crypto exchanges, and card issuing programs. In 2025, launching a multistate MSB is more practical and scalable than ever due to sweeping regulatory changes brought about by the Money Transmission Modernization Act (MTMA).
MSB licenses are a foundational element in powering e-commerce acquiring and merchant services platforms. By holding an MSB license, companies can legally process payments, handle settlement flows, and offer stored value accounts for online merchants. This structure enables integration with card networks, payment gateways, and digital wallets while maintaining full regulatory compliance. For platforms offering embedded checkout, digital invoicing, or international payouts, an MSB provides the legal and operational backbone to support growth in the e-commerce and digital marketplace space.
Likewise, MSB licenses serve as the regulatory foundation for many fintech platforms, including neobanks, payment processors, and digital wallet providers. These businesses rely on MSB structures to manage customer balances, facilitate domestic and international payments, and connect to essential financial infrastructure such as ACH, wire, and card networks. With the harmonization of licensing standards under the MTMA, fintech operators can now scale across multiple states using a unified compliance framework, significantly reducing onboarding time, audit costs, and legal risk.
For crypto exchanges and blockchain-based platforms, an MSB license is often the first step toward operating legally in the U.S. market. While not sufficient on its own for every virtual asset activity, an MSB enables the legal transmission of fiat and digital value, allows for partnerships with custodians and banks, and positions the company for future regulatory registrations (such as with FinCEN or state regulators). Combined with strong AML controls and clear use cases, an MSB license provides credibility and structure to crypto firms entering or expanding in the regulated financial ecosystem.
Historically, the fragmented state-by-state licensing model presented a major barrier to entry. Each state maintained its own licensing, bonding, and compliance requirements, leading to inconsistent costs, redundant audits, and operational delays. The MTMA is transforming that reality. As of 2025, 31 states—including key financial hubs like California, New York, Texas, and Florida—have adopted or partially adopted MTMA standards. These standards unify capital requirements, licensing documentation, and regulatory oversight, making it easier for businesses to scale nationwide.
A multistate MSB strategy offers significant advantages over pursuing a single-state license. Not only does it create operational and compliance efficiencies, but it also allows companies to launch and manage embedded finance, ACH payment processing, credit issuance, and even crypto services under one harmonized framework. With shared examinations and consistent thresholds for surety bonds and net worth, multistate licensing has become a cost-effective and strategic move for any serious fintech, international bank, or card issuer.
Our firm specializes in structuring and launching multistate MSB operations under this new regulatory environment. We do not recommend pursuing isolated, one-off licenses. Instead, we help clients build a foundation that leverages the MTMA’s harmonized structure for true scalability. Whether you are a startup or an established international financial entity, we provide the full suite of licensing, compliance, and integration services needed to operate in multiple U.S. states with confidence and agility.
For international banks licensed in Puerto Rico under Act 273, adding a U.S. MSB license introduces valuable synergies. This hybrid model opens access to domestic payment rails (ACH, Fedwire, SWIFT), facilitates card issuing via BIN sponsorship, and enables legal structuring of digital lending products such as merchant cash advances and receivables financing. Through the MSB-IFE combination, clients can extend their reach while maintaining full regulatory compliance both in Puerto Rico and on the U.S. mainland.
For non-U.S. banks—including IFEs licensed in Puerto Rico or international institutions abroad—a U.S. MSB license offers a strategic gateway to the American financial system. By establishing a multistate MSB, your institution can access critical payment infrastructure such as ACH, Fedwire, and SWIFT; legally issue USD credit cards through BIN sponsorship; and support cross-border lending products like merchant cash advances and receivables financing. An MSB also enables you to open correspondent accounts with domestic banks, facilitating the settlement of client transactions within a regulated framework. This structure creates operational flexibility, enhances credibility with U.S. counterparties, and aligns your services with the compliance standards expected in the world’s largest financial market.
In summary, 2025 represents a transformative moment for MSB licensing in the United States. With MTMA adoption accelerating and the tools for coordinated compliance in place, there has never been a better time to launch or expand a multistate MSB. Our team is here to help you navigate every step of the process—from strategic planning and license filings to compliance implementation and audit readiness.
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