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FinCENLicensingApril 30, 2026

FinCEN Seeks Comments on MSB Registration Form 107 Renewal

FinCEN is inviting public comments on renewing — without change — the BSA requirement for money services businesses to register using FinCEN Form 107, renew that registration every two years, and maintain an agent list where applicable. While no rule changes are proposed, this is a timely reminder for MSBs (including many crypto firms that qualify as MSBs) to confirm their registration is current and their agent list is accurate, as lapses can trigger BSA violations.

What to do

  • Verify that your FinCEN MSB registration is active, confirm your two-year renewal date, and ensure your agent list is up to date before the comment period closes.

Who this affects

Money Services BusinessCrypto ExchangeWallet ProviderPayments Company

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Source

Read the official publication

This radar entry is educational and does not constitute legal advice. Summaries are AI-assisted and grounded in the linked official source; always verify against the primary source and consult qualified legal counsel for jurisdiction-specific guidance.

Related developments

FinCEN

FinCEN GTO: Southwest Border MSBs Must Report Cash Transactions $1K–$10K

FinCEN has issued a Geographic Targeting Order (GTO) requiring certain money services businesses operating along the U.S. southwest border to report and retain records of cash transactions between $1,000 and $10,000 — well below the standard $10,000 CTR threshold — and to verify the identity of customers presenting such transactions. This is a significant AML/BSA escalation for covered MSBs in the targeted geography, effectively lowering the transaction monitoring and KYC trigger point for cash dealings. Non-compliance with a GTO carries the same penalties as violations of the Bank Secrecy Act.

FinCEN

FinCEN Proposes Cutting Off UAE Branches of Banque Misr Over Money Laundering Risk

FinCEN is proposing to designate the UAE-based branches of Banque Misr as a primary money laundering concern under Section 311 of the USA PATRIOT Act. If finalized, U.S. financial institutions would be prohibited from opening or maintaining correspondent accounts for Banque Misr UAE, required to take reasonable steps to block transactions involving Banque Misr UAE flowing through foreign correspondent accounts, and required to apply enhanced due diligence to foreign correspondent accounts to prevent their use for such transactions. Any firm that maintains foreign correspondent banking relationships — including crypto exchanges and fintechs with banking partners — must ensure Banque Misr UAE exposure is identified and addressed.

SEC

SEC Proposes New Crypto Asset Offering Exemptions and Security Safe Harbor

The SEC is proposing 'Regulation Crypto Assets,' which would create two new exemptions from securities registration — one for offerings up to $5 million over four years and another for offerings up to $75 million per year — with principles-based disclosure requirements for issuers. Critically, the proposal also includes a conditional safe harbor that could allow certain crypto assets to be deemed not to involve an investment contract, potentially removing them from the definition of 'security.' Crypto exchanges, token issuers, broker-dealers, and legal/compliance teams need to evaluate how these exemptions and the safe harbor conditions interact with their current token listing and offering practices.

CFTC

CFTC Proposes Lighter Registration Rules for RIAs Managing Crypto/Commodity Pools

The CFTC is proposing to exempt certain SEC-registered investment advisers from CPO registration when managing commodity pools for sophisticated investors, add a related CTA exemption, and raise the Small Pool Exemption threshold to account for inflation. Broker-dealers, RIAs, and fund managers that touch crypto or commodity-linked products should assess whether they currently rely on no-action relief that this proposal would supersede. This could reduce duplicative compliance burdens for firms already registered with the SEC.

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