In general, a money transmitter is:
- – Any person, whether or not licensed or required to be licensed, who engages as a business in accepting currency, or funds denominated in currency, and transmits the currency or funds, or the value of the currency or funds, by any means through a financial agency or institution, a Federal Reserve Bank or other facility of one or more Federal Reserve Banks, the Board of Governors of the Federal Reserve System, or both, or an electronic funds transfer network; or
- – Any other person engaged as a business in the transfer of funds.
A money transmitter is an MSB regardless of the dollar amount transmitted.
In addition to federal requirements, such businesses must also comply with state laws requiring registration, licensing, documentation and record retention requirements, bonding, requirements and restrictions on investment of funds pending disbursement, et cetera.