Money Service Business Screening
MSB Background Checks for Money Transmitter Agents
Screen agents, owners, and control persons with one compliant report. We search federal and state criminal courts, OFAC and FinCEN lists, and the USDA food-stamp fraud file. Consequently, your BSA/AML program holds up when FinCEN or a state examiner asks how you vet agents.
No setup fees. USA-based analysts. Multiple Authentication Factor (MAF) on every user account.
PBSA member since 2010. FCRA-compliant consumer reporting agency.
We currently screen agents for some of the largest money transmitters in the United States. Therefore, references from national MSB compliance teams are available on request. Ask for MSB references.
Definition
What Is a Money Service Business?
A money service business (MSB) is a non-bank financial institution. It transmits money, cashes checks, exchanges currency, or issues and sells money orders and prepaid access. Some MSBs run physical storefronts. Others, however, operate entirely online as fintech or remittance platforms.
Most MSB principals must register with FinCEN and maintain a list of their agents. Additionally, each MSB must build a written anti-money laundering (AML) program under the Bank Secrecy Act (BSA). That program must be risk-based. Therefore, it should reflect your customers, your geographies, and the products you offer.
FinCEN expects MSB principals to “identify the owners of the MSB’s agents.” Principals must also weigh “whether the owners are known or suspected to be associated with criminal conduct or terrorism.”FinCEN Guidance FIN-2016-G001 on agent monitoring
In other words, agent screening is not optional paperwork. Instead, it is a core control in your AML program.
Compliance Drivers
Why MSBs Must Screen Agents and Control Persons
Regulators judge your agent network by how well you vet it. Consequently, a weak background check becomes a weak AML program.
FinCEN agent due diligence
FinCEN requires principals to identify agent owners and to monitor agents on an ongoing basis. Moreover, principals must reassess agent risk periodically and terminate non-compliant agents. A documented background check proves you did the work.
State money transmitter licensing
State regulators require background investigations for owners, directors, and control persons. New York DFS, for example, asks for fingerprints and a Background Investigation Report for each added officer. Similarly, most states now process these checks through NMLS.
Bank partner and examiner scrutiny
Banks de-risk MSB accounts when agent oversight looks thin. Likewise, IRS BSA examiners review your agent list and your due diligence files. Therefore, consistent screening protects both your license and your banking relationship.
The Hidden Risk
Three Gaps a State-Only Search Leaves Open
Many vendors search state courts only. However, federal crimes such as money laundering, wire fraud, and drug trafficking live in U.S. District Court records. We have found many agents with clean state records and open federal cases. Consequently, we strongly recommend the USDC federal search for every agent.
Additionally, food-stamp trafficking rarely reaches any criminal court. Retailers caught trafficking SNAP benefits appear only on the USDA/FNS suspension list. Our database searches that list automatically.
Finally, most convenience-store owners give you a TIN instead of a Social Security number. As a result, weak vendors search the wrong person or no person at all. We validate the TIN and resolve the true identity first.
Federal court cases
Money laundering, wire fraud, identity theft, structuring, and narcotics cases sit in USDC records, not state courts.
USDA/FNS disqualifications
SNAP trafficking sanctions are administrative. Therefore, only the USDA list reveals them. Regardless, they involve fraud.
TIN-only identities
We match TINs to real people before we search. Otherwise, the report proves nothing.
Service Offering
Our Custom MSB Agent Screening Package
Every component below runs from one order. Furthermore, a human quality-review analyst checks each record before you see it.
| Component | What it covers | Why it matters |
|---|---|---|
| SSN Trace Identity Verification | Confirms name, former names, aliases, date of birth, and past address history. Consequently, every later search targets the right person. | Identity |
| TIN Validation & TIN Matching | Validates a Taxpayer Identification Number to a true identity. When a TIN cannot resolve, we run TIN Matching to establish who the owner is. | Identity |
| Nationwide Criminal Records Database | Felonies and misdemeanors from state and local repositories nationwide. Additionally, includes the Nationwide Sex Offender Registry. | Criminal |
| USDC Federal District Criminal Search | Federal court cases for wire fraud, money laundering, structuring, currency transaction report (CTR) crimes, and drug trafficking. Strongly recommended for every agent and control person. | Criminal |
| USA Patriot Act & Sanctions Screening | Simultaneous search of the lists below.
| Sanctions |
| FinCEN Registration Status | Flags revoked or expired FinCEN MSB registrations for these activity types:
| Regulatory |
| UCC Liens | What other MSBs have filed UCC liens | Recommended |
| USA Asset & Liabilities Report | Comprehensive report listing address history, phone numbers, properties, vehicles, corporations, business entities, UCC liens, tax liens, judgments and bankruptcies. Normally used for risk-management or collections | Recommended |
Need county court searches, or a control-person package for a state license filing? Additionally, we tailor each package to your risk assessment. See standard pricing.
Process
How MSB Agent Screening Works
Most MSB reports return the same business day. Federal court searches may add a day in some districts.
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Open your account
Sign up online in minutes. Every user login includes Multiple Authentication Factor (MAF) protection.
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Submit agents
Enter one agent or upload a batch. Provide a name with an SSN or TIN. We resolve the identity first.
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Human quality review
Our USA-based analysts verify each hit against identifiers such as DOB and address. Therefore, you receive fewer false positives.
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Adjudicate and document
Download the report, record your decision, and keep it in your agent file. Additionally, we support FCRA adverse-action steps when they apply.
Who We Serve
Money Transmitters, Check Cashers, and Fintech Companies
We built this package for principal MSBs that onboard hundreds of retail agents. However, the same searches fit fintech background checks for payment apps, remittance platforms, and crypto exchanges registered as MSBs.
- Money transmitters vetting new and existing agent locations
- Check cashers and money order issuers or sellers
- Currency exchangers and prepaid access providers
- Fintech, payments, and crypto companies screening owners, officers, and employees
- Compliance officers preparing state money transmitter license filings
Why USAbackground
Built From Years of MSB Screening
We have screened agents for some of the largest MSBs for many years. Specifically, we improved their turnaround time, cost, and data accuracy compared with their prior vendor. References are available on request.
- Both federal and state criminal searches on every package
- USA-based human review; no offshoring of personal data
- Multiple Authentication Factor (MAF) on all user accounts
- Batch uploads for large agent networks
- Mobile Self-Screening: Send an invite link to agent from within your account. Customize your disclosure and consent forms for e-signature
Know the Rules
Legal Restrictions on MSB Background Checks
Background reports carry legal duties. Therefore, we explain the main restrictions in plain language below. This summary is not legal advice. Consult your counsel for your specific program.
Permissible purpose under the FCRA
You may order a consumer report only for a permitted reason. Agent onboarding usually qualifies as a business transaction the agent initiates. Employment screening, however, requires a separate written disclosure and authorization.
Adverse action steps
If you decline an agent or employee because of the report, you must follow adverse action rules. Specifically, you must provide a copy of the report and a summary of rights. We supply the required notices.
Reporting limits and accuracy
Federal law limits how long certain non-conviction records may appear. Some states add further limits. Additionally, sanctions hits are often name matches only. Our analysts therefore verify identifiers before a record reaches your report.
For a deeper look, read our guide to background screening laws.
Get Started
Stronger Agent Due Diligence Starts Today
Open an account now, or request a customized proposal with a free trial. Either way, you will see the federal records other vendors miss.
Questions? Call (800) 661-0278 or email MSB@usabackground.com.
FAQ
MSB Background Check Questions
What is an MSB background check?
An MSB background check screens an agent, owner, or control person of a money service business. It combines identity verification, federal and state criminal searches, and sanctions screening. Consequently, it supports the agent due diligence FinCEN expects in your AML program.
Does FinCEN require background checks on money transmitter agents?
FinCEN does not prescribe one specific check. However, its guidance requires principals to identify agent owners and to consider whether they are associated with criminal conduct. A documented background check is the practical way to meet that expectation.
Why do you search U.S. District Courts as well as state courts?
Federal prosecutors handle money laundering, wire fraud, and drug trafficking cases. Those cases never appear in state court records. Therefore, a state-only search can clear an agent with an active federal case.
Can you screen an agent who only provides a TIN?
Yes. We validate the TIN and resolve the owner’s true identity first. When a TIN cannot resolve, we run TIN Matching. As a result, every search targets the correct individual.
What is the USDA/FNS suspension list, and why does it matter for MSBs?
The USDA Food and Nutrition Service disqualifies retailers that traffic SNAP benefits. Those sanctions are administrative, so they never reach a criminal court. Our database therefore includes the USDA/FNS suspension list for store-owner agents.
Do you support state money transmitter license background checks?
Yes. We screen owners, officers, and control persons for license applications and change-of-control filings. Additionally, we can add county court searches when a state requires them.
How fast are MSB agent screening results?
Most reports return the same business day. Federal district searches may take an extra day in some jurisdictions. Batch uploads follow the same timeline.
What is Multiple Authentication Factor (MAF)?
MAF requires a second verification step at login, beyond the password. We enable it on every user account. Consequently, agent data stays protected even if a password leaks.
How do I start, and is there a free trial?
Open an account online, or contact us for a customized proposal. Furthermore, we offer a free trial so you can compare our results with your current vendor.