When must a Money Services Business (MSB) renew its FinCEN registration?
MSBs that were initially required to be registered on or before December 31, 2001, were required to renew their registration for the first time by December 31, 2003. Thereafter, their renewal is required every 2 years. MSBs that came into existence after December 31, 2001, are initially required to be registered within 180 days beginning on the day after the business is established as an MSB. Their renewal deadline is the end of the 2-calendar year period beginning in the year they initially were required to be registered. For example, if an MSB is required to be registered on October 15, 2007, it must renew by December 31, 2008. Thereafter, renewal is required every 24 months (on or before December 31, 2010, December 31, 2012, etc.). It is also important to understand there are events that would cause an MSB to re-register with FinCEN.
