Solutions / Launch & Expand
Tell us what you want to build. We’ll tell you where and how to build it.
For financial businesses entering regulated markets or moving into new ones: the regulatory model, the licences, the compliance program and the operating plan, in the right order.
Who it’s for
Built for firms at a threshold.
- A founder or executive team launching a payments, lending, brokerage, fund or digital-asset business and deciding where to be regulated.
- An established firm entering a second or third jurisdiction and needing to know the cost, the timeline and the operating model before committing.
- A business that has grown past its first licence and needs the compliance function rebuilt to match.
What you get
Build it right.
Launch is a sequence, and most delays come from doing it out of order. We run it in order.
Business and regulatory model design
What you are, in regulatory terms, and the cleanest structure that lets you do what you plan to do.
Regulatory perimeter analysis
Which activities need a licence, which do not, and where the line moves as the product grows.
Entity and jurisdiction strategy
Where to incorporate, where to be authorised, and how the entities relate.
Licensing strategy and application preparation
The route, the file, the business plan, the policies and the responses regulators expect.
Regulator interaction
Meetings, questions and follow-ups handled with people who have sat on both sides of the table.
Compliance program build
Policies, controls, monitoring, training and governance, sized to your risk rather than to a bank’s.
Technology and vendor selection
KYC, screening, monitoring and case management chosen for the model you actually run.
CCO / MLRO staffing
The people the regulator will want to meet, permanent or fractional.
Launch readiness
A final pass against what a regulator, a bank or an auditor is likely to ask on day one.
Options
Licensing routes we support.
Taft designs and prepares; it does not act as your law firm, and no adviser can guarantee an authorisation. Where local counsel is required, we work alongside it.
United States
- State money transmitter licences
- NYDFS BitLicense and virtual currency approvals
- Broker-dealer and FINRA membership
- SEC investment adviser registration
- NFA / CFTC registrations where applicable
United Kingdom and Europe
- UK FCA permissions
- EU MiCA / CASP authorisation
- EU investment-firm, payment and e-money licensing
Middle East and Asia
- UAE VARA, ADGM and DIFC regulatory pathways
- Singapore and Hong Kong pathways for payments and digital assets
- Other jurisdiction-specific routes on request
Expand / Where next?
Compare jurisdictions before you commit to one.
International expansion is a regulatory decision before it is a commercial one. We compare the markets you are considering on the things that decide the outcome.
Regulatory cost and licensing burden
Fees, capital requirements, timelines and the weight of ongoing reporting.
Staffing and substance
Who has to be where, in what role, and whether it can be outsourced.
Time to market
Realistic sequencing from application to first customer.
Tax and legal coordination
Handled with external specialists, so the regulatory plan and the corporate plan agree.
Operating model
The compliance infrastructure the chosen market will require, and how it connects to what you already run.
The Market Entry Matrix
One document that shows the choice.
The Expand engagement ends in the Taft Market Entry Matrix: a country comparison, a regulatory heat map, a licensing roadmap, a cost and complexity matrix, recommended sequencing and a target operating model. It is written to be put in front of a board.
Money transmission / United States
FinCEN registration and state licensing are separate steps.
A U.S. money transmitter answers to federal rules and to state law. Federal regulation requires a money services business to register with FinCEN whether or not a state has licensed it. Whether a state licence is needed, and on what terms, is set by each state’s own law, and that law varies from state to state.
Is the model money transmission?
Federal regulation defines money transmission services as accepting currency, funds or other value that substitutes for currency from one person and transmitting it to another location or person by any means. Whether a person is a money transmitter is a matter of facts and circumstances, and the rule lists limitations. Each state applies its own law to the same facts. Source: 31 CFR 1010.100(ff)(5) (federal regulation, eCFR current text read November 8, 2026), https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1010/subpart-A/section-1010.100
FinCEN registration
With limited exceptions, such as a business that is a money services business only because it acts as an agent of another, each money services business must register with FinCEN, whether or not any state has licensed it. The initial registration is due by the end of the 180-day period beginning the day after the business is established. Any person who owns or controls the business is responsible for registering it. Source: 31 CFR 1022.380(a), (b)(3) and (c) (federal regulation, eCFR current text read November 8, 2026), https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022/subpart-C/section-1022.380
The registration form
FinCEN’s guidance names the form as FinCEN Form 107, completed and signed by the owner or controlling person. FinCEN says this guidance does not replace or supersede the regulations. Source: FinCEN, Money Services Business (MSB) Registration (read November 8, 2026), https://www.fincen.gov/money-services-business-msb-registration
State licences
Each state decides under its own law whether a licence is needed and what an application must contain. Requirements, process and any financial conditions differ by state, and this page does not summarise them. In participating jurisdictions, the Nationwide Multistate Licensing System (NMLS) is the official system for applying for, amending, renewing and surrendering the licence authorities it manages. Source: Conference of State Bank Supervisors, Nationwide Multistate Licensing System (read November 8, 2026), https://www.csbs.org/nationwide-multistate-licensing-system-nmls
Before the first application
What a money transmitter needs in hand before it applies.
A working list of inputs, not any state’s form. The federal items come from the regulations cited. Each target state’s application asks for its own items on top.
Perimeter analysis
The activity set against the federal definition and against the law of each target state. Where a legal conclusion is needed, it comes from your counsel.
Business plan and flow of funds
What the business does, for whom, and how money moves: who receives it, who holds it and when it leaves.
Ownership and control
Who owns and who controls the business. Under federal regulation, any person who owns or controls a money services business is responsible for registering it. Source: 31 CFR 1022.380(c) (federal regulation, eCFR current text read November 8, 2026), https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022/subpart-C/section-1022.380
Written AML program
Federal regulation requires a money services business to have an effective anti-money laundering program, in writing and commensurate with its risks, with policies, procedures and internal controls, a designated compliance person, training and independent review. For a business established now, the program is due by the end of the 90-day period beginning the day after the business is established. Source: 31 CFR 1022.210 (federal regulation, eCFR current text read November 8, 2026), https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022/subpart-B/section-1022.210
Agents
A business that will use agents prepares its first list of agents by the due date of its initial registration. Source: 31 CFR 1022.380(d)(1) (federal regulation, eCFR current text read November 8, 2026), https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022/subpart-C/section-1022.380
State-specific items
Each target state sets its own application contents and any financial requirements, under its own law. This page quotes none of them.
Who does what
The applicant applies. Taft prepares. Counsel advises on the law.
Each application belongs to the applicant. Taft is not a law firm and does not provide legal advice.
The applicant
Signs and files its own applications and registrations. Every statement in them is the applicant’s.
Taft
Designs and prepares: the route, the file, the business plan, the policies and the responses regulators expect. Taft does not act as your law firm.
Counsel
Where legal advice is required, your counsel gives it, or we introduce specialists. Where local counsel is required, we work alongside it.
The regulator
Each state decides on its own licence. No adviser can guarantee a licence or an authorisation.
After registration and licensing
The federal duties that continue.
These federal duties apply to money services businesses under the regulations cited. Each state sets its own ongoing duties on top, and they differ by state.
AML program, maintained
The program is implemented and maintained, not written once. The designated compliance person makes sure it is updated as necessary to reflect current requirements and related Treasury guidance. Independent review is matched in scope and frequency to the risk, and the reviewer cannot be the designated compliance person. Source: 31 CFR 1022.210(a), (d)(2) and (d)(4) (federal regulation, eCFR current text read November 8, 2026), https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022/subpart-B/section-1022.210
Renewal
Registration runs in two-calendar-year periods. The renewal form is due on or before the last day of the calendar year before each renewal period. Source: 31 CFR 1022.380(b)(2) and (b)(3) (federal regulation, eCFR current text read November 8, 2026), https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022/subpart-C/section-1022.380
Re-registration
A business re-registers within 180 days after a change in ownership or control that requires re-registration under state law, a transfer of more than 10 percent of its voting power or equity interests (unless the transfer must be reported to the SEC), or a more than 50 percent increase in its number of agents during a registration period. Source: 31 CFR 1022.380(b)(4) (federal regulation, eCFR current text read November 8, 2026), https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022/subpart-C/section-1022.380
Agent list
A business with agents revises its list each January 1 for the preceding 12 months and keeps it at the U.S. location reported on its registration form. Source: 31 CFR 1022.380(d)(1) (federal regulation, eCFR current text read November 8, 2026), https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022/subpart-C/section-1022.380
Records
A copy of each registration form and any registration number is kept at a location in the United States for five years. Source: 31 CFR 1022.380(b)(1)(iii) and 1010.430(d) (federal regulation, eCFR current text read November 8, 2026), https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1010/subpart-D/section-1010.430
State duties
Each state sets its own ongoing duties for its licensees. Licence authorities managed through NMLS are amended and renewed there. Source: Conference of State Bank Supervisors, Nationwide Multistate Licensing System (read November 8, 2026), https://www.csbs.org/nationwide-multistate-licensing-system-nmls
Digital assets
The U.S. opportunity is changing. Is your regulatory strategy changing with it?
Stablecoins, tokenisation, custody, payments and exchange models each sit differently against U.S. federal and state rules, and the rules are moving. We build U.S. digital-asset strategy the same way: perimeter first, then licensing, banking relationships and the compliance program.
Regulatory perimeter and licensing
Which parts of the model are money transmission, securities, commodities or none of the above, and what that means state by state.
AML, sanctions and banking relationships
The program a bank will accept and a regulator will examine.
Market-entry strategy
Sequencing U.S. entry against the other markets you operate in.
How it runs
How an engagement runs.
Map
A working session on your model, products, customers and target markets. You leave with the regulatory perimeter drawn.
Decide
Jurisdiction and licensing options compared on cost, time, substance and risk. One recommendation, with the reasoning.
Build
Applications, program, people and technology, run as one plan with one owner.
Launch
Regulator interaction through to authorisation, and a readiness review before the first customer.
Questions
Asked before, answered plainly.
- Do we need FinCEN registration or a state money transmitter licence?
- They are separate questions. With limited exceptions, a money services business must register with FinCEN whether or not any state has licensed it. Whether a state licence is needed depends on that state’s law and on the facts of the model, and state law varies. Source: 31 CFR 1022.380(a)(1) (federal regulation, eCFR current text read November 8, 2026), https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022/subpart-C/section-1022.380
- Who files and signs the applications?
- The applicant. Its applications and registrations are its own statements. Taft designs and prepares the route, the file, the business plan, the policies and the responses regulators expect. Taft is not a law firm and does not provide legal advice; where legal advice is required, your counsel gives it.
- How long does a licence take, and what will it cost?
- This page does not quote approval times, capital or bond figures, or fees. Each state sets its own requirements and process under its own law, and no adviser can guarantee a licence. The fixed federal date is a filing deadline: the initial FinCEN registration is due by the end of the 180-day period beginning the day after the business is established. Source: 31 CFR 1022.380(b)(3) (federal regulation, eCFR current text read November 8, 2026), https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022/subpart-C/section-1022.380
- Does the AML program have to be in place before launch?
- Federal regulation requires a money services business to have a written anti-money laundering program. For a business established now, it is due by the end of the 90-day period beginning the day after the business is established. Source: 31 CFR 1022.210(c) and (e) (federal regulation, eCFR current text read November 8, 2026), https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022/subpart-B/section-1022.210
- Does FinCEN registration end once a state licence is granted?
- No. Registration is required whether or not a state has licensed the business, and it is renewed for each two-calendar-year period. Source: 31 CFR 1022.380(a)(1) and (b)(2) (federal regulation, eCFR current text read November 8, 2026), https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022/subpart-C/section-1022.380
Taft provides regulatory strategy and compliance services. It is not a law firm and does not provide legal advice; where legal advice is required we work with your counsel or introduce specialists. No adviser can guarantee a licence or an authorisation.