You Move Money for Other Businesses. Someone Just Said Money Transmitter.

Your own licenses cost $250,000 and take up to two years. There is a second legal route: operate as an authorized delegate under licensed money transmitters, on a platform adapted to your flow of funds, with compliance running underneath. Live in weeks.

Who This Is For

Businesses that collect, hold or forward money for others, and discovered that this has a legal name.

Receivables & billing outsourcers

You invoice and collect on behalf of client businesses, hold the funds for a few days, and forward them net of your fee.

Payout & disbursement platforms

You pay contractors, vendors, sellers or claimants on a client's behalf from funds the client sends you first.

Vertical software that added payments

Rent, tuition, dues, bookings or marketplace sales flow through your platform before they reach the business that earned them.

Stablecoin payment companies

You move value for third parties across borders and settle on stablecoins. The rail does not change the licensing answer.

Payroll, escrow and holdback services

Funds sit with you between the payer and the person entitled to them, which is the definition regulators use.

Accounting practices that run collections

Bookkeeping and AR firms that moved from reconciling client money to actually receiving and remitting it.

Why the Question Came Up

The definition is broader than most founders expect, and the exemptions are narrower.

Under the Bank Secrecy Act, a money transmitter is any person that accepts currency, funds or value from one person and transmits it to another. It does not matter that both parties are businesses, that you charge a flat fee, that the funds only sit with you for three days, or that they move by ACH rather than across a border.

Most states offer an exemption for an agent of the payee: a business that collects on a payee's behalf under a written agreement, so that payment to the agent counts as payment to the payee. It is a real exemption and many models fit inside it. Many do not. Taking assignment of a receivable, collecting into an entity you own, netting your own fee from the funds, or holding money for your own account are the usual ways a model steps outside it, and the moment a bank's compliance team or a state examiner notices, the question becomes a letter.

The answer in that letter is binary: get licensed, or operate under someone who is. Federal law anticipates the second path. Under 31 CFR § 1022.380(a)(3), a business that is a money services business solely because it acts as the agent of another money services business is not required to register separately. That is the authorized delegate model, and it is the structure most money movement in the United States already runs on.

Operating as an unlicensed money transmitting business is a federal offence under 18 U.S.C. § 1960 and a state offence almost everywhere. If you are already moving funds for others, the exposure is current, not future. This page is general information, not legal advice; the right answer for your model comes from a review of your actual flow of funds.

Your Own Licenses vs. Operating Under Ours

Same business, same customers, same brand. A different route to being allowed to run it.

FeatureYour own MTLsAuthorized delegate on Platly
Upfront licensing cost$250,000+None
Time before you can operate compliantly12-24 monthsWeeks
Surety bonds and net worth minimums
Write and audit your own AML program
State examinations and reporting
KYB, KYC and sanctions screening toolingBuild or buyIncluded
ACH, card and wire collectionBuild or buyIncluded
Stablecoin settlement where it fitsSeparate stackIncluded
Platform adapted to your flow of fundsYour engineeringOurs, with you
Your brand, your pricing, your customers

How It Works

Four steps from the first call to operating compliantly.

Step 1

Scope the flow

A 30-minute call to map who pays, who is paid, where funds rest, for how long, and in which states. Most flows are clear within the hour.

Step 2

Compliance review

Our compliance team and the licensing principal confirm whether your flow fits under the licenses and what the controls look like for your model.

Step 3

Adapt the platform

Collection methods, payout rails, settlement timing, FBO structure, reporting. We configure the platform around your flow rather than asking you to fit ours.

Step 4

Go live as an authorized delegate

You operate under the licenses with the compliance program running underneath. Weeks from the first call, not years.

What Runs Underneath

The licensing is the visible part. This is what makes a flow of funds operable.

FinCEN MSB registration and state money transmitter licenses
Written AML program, independent audit, examinations
KYB and KYC verification of the businesses and people you serve
Real-time sanctions screening, including on-chain addresses
ACH, card and wire collection with return and chargeback handling
Domestic and cross-border payouts, stablecoin settlement where it fits
For-benefit-of account structure and segregated client funds
Transaction monitoring, SAR filing and record retention

The compliance program is described on our compliance page. If your model is consumer remittance at a counter rather than business payments, start with the money transmitter license page instead.

Questions Founders Ask

We just collect payments for our clients. Is that really money transmission?
Often, yes. Federal law defines a money transmitter as a person that accepts funds from one party and transmits them to another. Many states exempt an 'agent of the payee' that collects on the payee's behalf under a written agreement, but that exemption is narrow: structures where you take assignment of the receivable, collect into your own entity, or hold funds for your own account tend to fall outside it. If a bank, a regulator or counsel has raised the question, the honest answer is that it needs a proper review, and that is where we start.
What does operating as an authorized delegate mean?
Under 31 CFR 1022.380(a)(3), a business that is a money services business solely because it acts as the agent of another money services business does not have to register with FinCEN separately. The licensing principal holds the money transmitter licenses and the regulatory relationships; you operate your business under them, following the compliance program they provide. It is how most storefront money transfer in the United States already works, and the same structure applies to business-to-business flows.
Can any flow of funds be covered?
No, and nobody should tell you otherwise before reviewing it. Coverage depends on who the parties are, where funds rest, what you do with them, and which states are involved. We scope the flow first and give you a straight answer. If it does not fit, we say so and point you at the right licensing counsel.
We settle on stablecoins. Does that change anything?
Not the licensing answer. Transmitting value on behalf of others is money transmission regardless of the rail, and since the GENIUS Act of 2025 the stablecoins themselves are a regulated instrument. What changes is the compliance tooling: on-chain address screening alongside the usual sanctions checks. The platform supports stablecoin settlement where it fits the flow, with the customer experience staying fiat to fiat if you want it to.
What stays our responsibility?
Your customers, your pricing, your product and the day-to-day operation of your business. You follow the AML program, verify the businesses you serve and escalate anything unusual. The principal and our compliance team hold the licenses, run the program, file the reports and face the examinations.
We already applied for our own licenses. Is this still relevant?
Frequently it is the bridge. Applications take 12 to 24 months and you usually cannot operate in the meantime. Operating as an authorized delegate lets you serve customers compliantly while your own licenses are pending, and some businesses find they never need to finish the applications.

Scope Your Flow of Funds

A 30-minute call: who pays, who is paid, where the money rests, and whether the authorized delegate route fits your model. A straight answer either way.