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Money remittance: licences and registrations for transfer businesses

A money transfer business is regulated in every country it serves, and the form of permission differs: an authorisation in the EU and UK, a registration with a financial intelligence unit in Canada and at federal level in the US, a licence in US states, Hong Kong and the UAE. We help you choose the regime, prepare the application and build the AML, finance and IT set-up that the regulator and partner banks will examine.

PSD2 · PSRs · MSBLicence or registration
The regime

What money remittance regulation covers

Money remittance is the business of receiving funds from a sender and making them available to a recipient, domestically or across borders, without the provider acting as a bank. In the EU and the UK it is one of the payment services and is authorised under payment services law with the lowest initial capital in that framework. In Canada and the US the same activity falls within the money services business (MSB) category, where federal registration is combined with provincial or state requirements.

Registration and licensing are not the same thing. FINTRAC (Canada's financial intelligence unit) and FinCEN (the US Financial Crimes Enforcement Network) register MSBs for anti-money laundering supervision, but registration is not an approval of the business. In the US, permission to transmit money is granted by each state separately; in Québec a provincial licence is needed in addition to federal registration.

For most remittance projects the critical issues are the same: correspondent and payout partners, safeguarding of client funds, agent networks and the strength of the AML/CFT (anti-money laundering and countering the financing of terrorism) framework. These determine both the regulator's decision and whether banks will open and keep accounts.

Who needs this

  • Cross-border remittance services for individuals, including migrant worker corridors
  • B2B payout platforms sending funds to suppliers, contractors or employees abroad
  • Mobile and online apps offering international transfers to their users
  • Cash-based transfer networks with agents and cash pick-up points
  • Exchange houses and currency exchange operators adding a transfer service
  • Groups building a corridor between Kazakhstan, the UAE, Europe or North America
  • Existing payment businesses entering a new market that requires a local permission
Scope

Scope of the permission

What it typically permits

  • Accepting funds from senders and paying them out to recipients domestically or abroad
  • Payouts to bank accounts, cards or wallets through licensed partners
  • Cash collection and cash pay-out where the regime and the network allow it
  • Currency conversion linked to the transfer, where covered by the permission
  • Operating through agents, subject to registration, checks and oversight rules
  • Serving clients online, subject to remote identification rules of the country

Restrictions

  • No deposit-taking or lending — these are banking activities
  • An EU or UK remittance-only authorisation does not cover payment accounts, card issuing or acquiring, which require a higher capital tier
  • UK small payment institution status is limited to an average monthly volume of €3 million and excludes payment initiation and account information services
  • Federal registration in Canada or the US does not replace provincial or state licences
  • Each country served usually needs its own permission or a lawful cross-border route
  • Client funds must be safeguarded and cannot be used as working capital
Jurisdictions

Regimes by jurisdiction

The table shows only requirements confirmed against official sources as of 15 October 2026. Other parameters are set by the regulator and confirmed at the assessment stage.

JurisdictionRegulatorRegimeKey points
EU member statesNational competent authorityPayment institution authorisation (PSD2)Initial capital of €20,000 for money remittance only; ongoing own funds calculated by the method chosen by the regulator, with a reduced scaling factor for remittance; optional national small-institution exemption for up to €3 million in average monthly volume
United KingdomFCAAuthorised or small payment institution (PSRs 2017)€20,000 initial capital for an authorised institution offering money remittance; small payment institution registration for an average monthly volume of up to €3 million, with no fixed minimum capital; new safeguarding rules (CASS 15) since 7 May 2026 for authorised institutions
Canada (federal)FINTRACMSB registration — not a licenceRegistration required before starting operations, including for foreign MSBs serving clients in Canada; expires unless renewed every 2 years; compliance programme with an effectiveness review at least every 2 years; agent eligibility and criminal record checks since 1 October 2025
USA (federal)FinCENMSB registration (Form 107) — not a licenceFiled within 180 days of establishment; renewed every 2 years; re-registration on change of control; list of agents kept; AML programme
USA (states)State regulators, via NMLSMoney transmitter licenceLicensed state by state; the Money Transmission Modernization Act has been adopted in full or in part by 31 states; net worth and surety bond under state law
Hong KongCustoms and Excise DepartmentMoney Service Operator (MSO) licenceCovers remittance and money changing; fit-and-proper test including owners above 25%, competence assessment and interview; licence term 2 years; no minimum capital requirement
UAE (mainland)CBUAERetail payment services licence, Category I or IICross-border transfers are permitted in Categories I and II; initial capital AED 1.5m / 3m (Cat. I) or AED 1m / 2m (Cat. II), depending on whether average monthly volume is below or above AED 10m
UAE (mainland)CBUAEExchange house licence, Category A, B or CPaid-up capital AED 2m, 5m or 10m (AED 50m for an LLC); bank guarantee of at least the greater of 100% of minimum capital and 5% of average monthly transfers, capped at AED 75m
KazakhstanNational Bank of Kazakhstan (NBK)Registration of a payment organisationEntry in the NBK register via the e-government portal; services include accepting cash for payments without a bank account and processing client-initiated payments; operates under an agreement with a bank or a transfer organisation; capital confirmed at assessment
AIFC (Astana)AFSAAuthorisation: Providing Money ServicesCovers money transmission, currency exchange, payment instruments and stored value; separate from the Kazakhstan national regime; capital under AIFC prudential rules, confirmed with AFSA

How the regimes differ

  • Nature of the permission: the EU, UK, US states, Hong Kong and the UAE grant authorisations (the UK also registers small payment institutions); FINTRAC and FinCEN register businesses for AML supervision without approving them.
  • Capital: €20,000 for remittance-only institutions in the EU and UK; several million dirhams for UAE exchange houses; no fixed minimum for a Hong Kong MSO; net worth and bonding under state law in the US.
  • Agents: Canada requires eligibility and criminal record checks for agents since 1 October 2025 (agents engaged earlier must be checked by 1 October 2027); FinCEN requires a list of agents to be maintained.
  • Enforcement: Canada's Bill C-12, which received royal assent on 26 March 2026, raised maximum administrative penalties up to 40-fold and introduced compliance agreements and orders; operating without an MSO licence in Hong Kong is punishable by a fine of up to HK$1 million and 2 years' imprisonment.
  • UAE: the CBUAE regulates the mainland and non-financial free zones, while ADGM (FSRA, Providing Money Services) and DIFC (DFSA, Money Transmission) have their own regimes.
  • Kazakhstan: the NBK regime for payment organisations and the AIFC regime under AFSA are separate and are not interchangeable.
Requirements

Core requirements

Company and owners

  • Company incorporated in the licensing jurisdiction or with a lawful cross-border structure
  • Transparent ownership with disclosure of qualifying holders and beneficial owners
  • Fit-and-proper checks of owners and managers, including criminal record checks where required
  • Documented source of funds and source of wealth of the owners

Capital and finances

  • Initial capital where the regime sets one, held before authorisation
  • Ongoing own funds or net worth, and bank guarantees or surety bonds where required
  • Business plan and financial model for at least three years
  • Safeguarding arrangements for client funds

Management, team and local presence

  • Qualified management with relevant payments or financial services experience
  • Compliance officer or AML reporting officer appointed by the company
  • Local presence and substance as required by the regulator
  • Agent management and oversight procedures

Compliance and IT

  • AML/CFT programme: business risk assessment, customer due diligence, sanctions and PEP screening, transaction monitoring
  • Procedures for suspicious transaction reporting and record-keeping
  • Independent review of the compliance programme at the required frequency
  • Secure transfer platform with audit trail, reconciliation and reporting to the regulator

Regulatory capital is separate from state and application fees, operating costs and our fees. Our fees are agreed after the project assessment.

Documents

Main application documents

  • Application form and corporate documents
  • Ownership structure chart and beneficial ownership disclosures
  • Fit-and-proper questionnaires, CVs and criminal record certificates
  • Business plan with corridor, client and volume description
  • Financial projections and evidence of capital
  • Safeguarding policy and agreements with safeguarding banks
  • AML/CFT policy, business-wide risk assessment and KYC procedures
  • Sanctions screening and transaction monitoring procedures
  • Agent management policy and agent list where agents are used
  • Governance, internal control and complaints handling policies
  • IT and information security description, outsourcing arrangements
  • Agreements or term sheets with payout and correspondent partners
Process

How the project runs

  1. 01

    Model and perimeter analysis

    We map flows of funds, corridors, client types and partners, and determine which permissions each country requires.

  2. 02

    Jurisdiction and structure

    We compare regimes, capital, timelines and banking access, and propose the corporate structure.

  3. 03

    Company and team

    We register or restructure the company and help recruit or document key persons, including the compliance officer.

  4. 04

    Application package

    We prepare the business plan, financial model, policies, AML framework and IT description and file the application or registration.

  5. 05

    Regulator dialogue

    We answer questions, revise documents and support interviews until a decision is made.

  6. 06

    Launch and support

    We help open safeguarding and operating accounts, configure the platform and support ongoing reporting and inspections.

Timing

Timing

Only some regimes set binding deadlines. FinCEN requires registration within 180 days of establishment; FINTRAC registration must be in place before services start; a Hong Kong MSO licence is valid for 2 years and its renewal must be filed at least 45 days before expiry. Real timelines depend on the regulator's workload, the quality of the application and how quickly the company fulfils any conditions.

  • Number of countries and US states involved
  • Completeness of the ownership and source-of-funds evidence
  • Readiness of the AML programme and of the compliance officer
  • Availability of safeguarding and correspondent banks
  • Use of agents and the scope of agent checks
  • Volume of regulator questions and document revisions
Our work

What our team does

Lawyers

  • Analyse the business model and the regulatory perimeter in each target country
  • Recommend the jurisdiction and the type of permission
  • Register the company and prepare the corporate structure
  • Draft client terms, agent agreements and partner agreements
  • Prepare the application and lead the dialogue with the regulator
  • Coordinate foreign-law opinions with local counsel where required

Finance specialists

  • Build the business plan and the financial model
  • Calculate capital, own funds, guarantees and operating funding needs
  • Design safeguarding and reconciliation processes
  • Prepare financial information for the regulator and banks

AML/compliance specialists

  • Prepare the business-wide risk assessment and the AML/CFT policy
  • Design KYC/KYB, sanctions and PEP screening and transaction monitoring
  • Set up suspicious activity handling, agent oversight and training
  • Help prepare and support the person appointed by the company as compliance officer
  • Prepare the company for inspections and effectiveness reviews

Engineers

  • Design or adapt the transfer platform to regulatory requirements
  • Integrate payout partners, banks and screening providers
  • Build audit trail, reporting and reconciliation functions
  • Document IT and information security for the application
After authorisation

After the permission is granted

  • Renew registrations and licences on time, for example every 2 years for FINTRAC and FinCEN registrations and a Hong Kong MSO licence
  • Notify the regulator or re-register on changes in control, ownership or agents
  • Maintain capital, guarantees and safeguarding at the required level
  • File regulatory and AML reports, including suspicious transaction reports
  • Run periodic effectiveness reviews or audits of the compliance programme
  • Check and oversee agents, including periodic criminal record checks where required
  • Update policies when rules change, for example under EU payment law reform
FAQ

Frequently asked questions

Describe your project in a few sentences. We will give you a substantive reply: which questions need answering and where to start.

Discuss your project
Is FINTRAC or FinCEN registration a licence?

No. Both are registrations for anti-money laundering supervision and do not mean that the regulator has approved the business. In the US a money transmitter also needs state licences, and in Québec a provincial licence is required in addition to FINTRAC registration.

What capital is needed for money remittance in the EU or the UK?

An institution providing only money remittance needs initial capital of €20,000. On top of that it must maintain own funds calculated by the method the regulator applies. In the UK a small payment institution with up to €3 million average monthly volume has no fixed minimum capital.

Can one licence cover several countries?

Only within specific frameworks such as passporting inside the EU. Canada, the US, the UAE, Hong Kong and Kazakhstan each require their own permission, and in the US licences are issued state by state.

Do we need our own compliance officer?

Yes. All the regimes on this page require the company to appoint a person responsible for AML compliance. We help prepare and support that person; outsourced support models can be discussed where the law allows, case by case.

Can you guarantee the licence and a bank account?

No. The decision belongs to the regulator, and the decision to open an account belongs to the bank. We prepare the project so that it meets the requirements and can withstand the review.

How is a remittance licence different from a currency exchange licence?

Remittance moves money between a sender and a recipient; currency exchange converts one currency into another for the same client. Some regimes cover both, such as the Hong Kong MSO or UAE exchange houses; others treat them separately.

Sources checked on 15 October 2026
  • Directive (EU) 2015/2366 (PSD2), Art. 7, 9, 32 — https://www.legislation.gov.uk/eudr/2015/2366/article/7/data.html (checked 15 Oct 2026)
  • UK Payment Services Regulations 2017, Schedule 3 and Regulation 14 — https://www.legislation.gov.uk/uksi/2017/752/schedule/3 (checked 15 Oct 2026)
  • FCA PS25/12 and CASS 15 (safeguarding, in force 7 May 2026) — https://www.fca.org.uk/publications/policy-statements/ps25-12-changes-safeguarding-regime-payments-and-e-money-firms (checked 15 Oct 2026)
  • FINTRAC — MSB registration — https://fintrac-canafe.canada.ca/msb-esm/reg-eng and https://fintrac-canafe.canada.ca/msb-esm/intro-eng11 (checked 15 Oct 2026)
  • FINTRAC — administrative monetary penalties (Bill C-12) — https://fintrac-canafe.canada.ca/pen/3-eng (checked 15 Oct 2026)
  • Revenu Québec — money-services business licence application — https://www.revenuquebec.ca/en/businesses/sector-specific-measures/money-services-businesses-msbs/money-services-business-licence-application/ (checked 15 Oct 2026)
  • FinCEN — MSB registration — https://www.fincen.gov/index.php/money-services-business-msb-registration (checked 15 Oct 2026)
  • CSBS — Money Transmission Modernization Act adoption — https://www.csbs.org/node/231461 (checked 15 Oct 2026)
  • Hong Kong Customs and Excise — MSO Licensing Guide (May 2026) — https://eServices.customs.gov.hk/MSOS/download/guideline/Licensing_Guide_en.pdf (checked 15 Oct 2026)
  • CBUAE — Retail Payment Services and Card Schemes Regulation (C 15/2021) — https://rulebook.centralbank.ae/node/1580 (checked 15 Oct 2026)
  • CBUAE — Exchange Business Standards (official rulebook copy) — https://cbuae.thomsonreuters.com/en/entiresection/3531 (checked 15 Oct 2026)
  • ADGM FSRA — Providing Money Services framework — https://adgm.com/media/announcements/fsra-introduces-enhancements-to-the-regulatory-framework-for-providing-money-services (checked 15 Oct 2026)
  • National Bank of Kazakhstan — registration of payment organisations — https://nationalbank.kz/ru/news/uchetnaya-registraciya-platezhnoy-organizacii (checked 15 Oct 2026)
  • AFSA — regulated activities (Providing Money Services) — https://afsa.aifc.kz (checked 15 Oct 2026)

Discuss your transfer business

Describe your corridors, clients and partners. We will outline the permissions required, the main risks and the next steps; our fees are agreed after this assessment.

Discuss your project
Contact

Tell us about your project

We will review the description and give you a substantive reply: which regime may apply and where to start.

Prefer e-mail? Write to us directly.info@paralex.kz

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