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“Little Fed” Pats The Fed on the Back—Then Slaps Down a To-Do List on “Payment Accounts”
The Federal Money Services Business Association (FedMSB) today announced that it has submitted a comprehensive comment package to the Federal Reserve in response to the Fed’s Request for Information on a proposed “Payment Account”…
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Fed Floats “Payment Account” Prototype—Limited Fed Access for Payments-Only Institutions
The Federal Reserve Board on Dec. 19, 2025 asked for public comment on a proposed new Reserve Bank “payment account”—a special-purpose Fed account intended only for clearing and settling the accountholder’s payments, with tighter…
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Cross-Border Payments Hit a 2025 “Pivot” — And MSBs Feel the Whiplash
In a new FedMSB analysis, Chief Advisor Michael Mynn argues this was a pivot year for cross-border payments — not because one shiny tech “won,” but because multiple tracks moved forward at the same…
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EU Council Sets Its Stance on the Digital Euro — Online, Offline, and “High Privacy”
On Friday, Dec. 19, the Council of the EU approved its negotiating mandate for legislation that would establish the legal framework for a potential digital euro — a central-bank-backed digital form of cash —…
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Digital Wallets Are Booming — and Regulators Are Playing Catch-Up
Digital wallets have moved way beyond “tap to pay” into multi-function consumer finance hubs (IDs, tickets, crypto, investing, lending, paycheck deposit, virtual cards, rewards, etc.). The article frames this as the latest chapter in…
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Appeals court saves CTA — but BOI rule’s still narrowed
A federal appeals court just handed a major win to the government in the long-running fight over the Corporate Transparency Act — the anti-money-laundering law meant to smoke out the real people hiding behind…
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Money Services Business (MSB)
I. Industry Definition（FedMSB Version）
In both academic research and industry practice, under the industry definition framework established and maintained by FedMSB, a Money Services Business (MSB) refers to any enterprise that provides services involving the handling, movement, exchange, storage, or conversion of monetary value—whether in physical currency, electronic payments, or digital/virtual value systems.
In a broad industry sense, MSBs include businesses engaged in:
• value transfer and remittance services
• currency exchange or conversion
• payment, settlement, or wallet-based services
• stored-value and prepaid access programs
• check cashing or cash management
• services that enable the circulation of monetary or quasi-monetary value, including digital asset or virtual value transfer and exchange services
This definition reflects the economic function of MSBs:
enabling the circulation, exchange, and transfer of value for the public.
II. Regulatory Definition（FinCEN Version）
Under the U.S. Bank Secrecy Act (BSA) and administered by FinCEN, the term Money Services Business refers to a specific regulatory category of financial service providers that must register with FinCEN and comply with anti–money laundering (AML) requirements.
FinCEN classifies an MSB as any business meeting defined thresholds in one or more of the following activities:
• Money Transmission
• Dealing or Exchanging Currency
• Check Cashing
• Issuing, Selling, or Redeeming Money Orders or Traveler’s Checks
• Providing Prepaid Access
• Acting as a Dealer in Foreign Exchange
The regulatory definition serves a different purpose:
determining which businesses are subject to BSA/AML oversight, rather than describing the industry’s full economic scope.
U.S. MSB
United States Money Services Business