Multi-currency and FX account for money services businesses with a US LLC

First, we map your currency needs: where you are paying from, where you are sending to, and the monthly volumes for each corridor. We use this to identify the right type of institution, whether a US-based provider or an EEA-licensed EMI that can support your specific corridors.

Next, we build the compliance file. For a US MSB, this means packaging the state and FinCEN registrations, the full AML programme, and a clear narrative explaining your customer onboarding, transaction monitoring, and the commercial purpose of your payments. This file demonstrates a compliant operation to underwriters, pre-empting their questions and setting the stage for a smooth review.

Underwriters and compliance teams focus entirely on anti-money laundering (AML) risk. They will verify your MSB registration with FinCEN and any state-level licences. The core of their review is your flow of funds and exposure to high-risk jurisdictions or sanctioned entities. Be prepared to provide lists of currency corridors, major counterparties, and expected monthly volumes for each.

They will scrutinise your UBO and director nationalities and residency, looking for nexus to sanctioned countries. Finally, they will expect to see commercial contracts or a coherent business plan that justifies the need for the currency corridors you operate, ensuring the activity is legitimate trade or remittance and not speculative FX trading.

Using a US LLC provides a strong base for USD-denominated activities. However, for currencies like EUR and GBP, access is typically via UK or EU-based EMIs, which require a comprehensive compliance file for an American MSB. While a US office is not strictly required, providing evidence of a US operating address and substance greatly helps underwriting.

The key US authorities involved are the state registry where the LLC is formed, FinCEN for your MSB registration, and the IRS for tax reporting. For foreign-owned single-member LLCs, this includes filing Form 5472. This clear regulatory structure is an advantage compared to using entities from jurisdictions with less formal MSB oversight.

Accounts for MSBs are commonly declined for three reasons: an incomplete licence, unclear source of funds, or a high-risk profile that is poorly explained. Many applicants fail to provide their full AML programme or cannot produce a satisfactory third-party AML audit. This is an immediate red flag for any regulated institution.

Another major failure is an inability to explain the flow of funds, particularly for remittance businesses with agent networks or cash intake. Our process prevents this by documenting the entire payment chain from end to end, supported by a clear diagram and narrative. We ensure the file demonstrates robust controls that match the risks of the business, presenting you as a professional, compliance-aware operator from the outset.

For a well-prepared US MSB, the timeline to get a multi-currency account live is typically between one and five weeks. The initial stage involves our team working with you to assemble the complete KYB package, including all licences, the AML programme, and the flow-of-funds diagram. This takes about a week.

Once submitted to the financial institution, their review process can take anywhere from a few days to four weeks, depending on their complexity and appetite for the MSB sector. To ensure you stay live, we advise on best practices for transaction monitoring and communicating with your provider. We can also help scope a backup provider to ensure business continuity.