Author: Lawyer Shao Jiadian
Introduction
In the past two years, almost all project teams looking to engage in crypto payments, stablecoin transactions, U-cards, PayFi, and cross-border settlements cannot avoid one term: U.S. MSB.
Many people still understand MSB as "cheap, fast, and easy to obtain," but to be honest—
What truly matters is not "easy to obtain," but "easy to use."
If you are new to crypto payments or are establishing a compliance framework for your project, the U.S. MSB is essentially the first piece of the puzzle that cannot be overlooked.
Let’s state the conclusion: Why is MSB often the first choice for crypto payments?
In a nutshell: MSB is not about the "regulatory halo," but about "business feasibility."
From a practical perspective, the U.S. MSB has three decisive advantages:
1. Covers the core actions of "crypto payments"
2. Can serve as the starting point for a global compliance structure
3. Is "implicitly recognized" by banks, channels, and partners
These three points determine its position in crypto payments.
What can MSB actually do?
The U.S. MSB (Money Services Business) is a financial entity registered with FinCEN. Essentially, it is a framework for anti-money laundering regulation, not a "financial license." However, precisely because of this, it is very "usable" in crypto payments.
Under compliance conditions, MSB typically covers:
Receiving and sending payments in stablecoins/cryptocurrencies
Crypto payment services for enterprise clients, including bulk disbursements
Payment channel integration for fiat ↔ stablecoin
Providing services as a payment platform/API layer
Offering compliance identity for U-cards, PayFi, and cross-border settlements
You will notice a reality:
Many crypto payment platforms that "do not appear to be U.S. companies" definitely have an underlying U.S. MSB.
Why is there a world of difference between "having MSB" and "not having MSB" in crypto payments?
From a lawyer's perspective, here is a very straightforward practical judgment: Without MSB, you don’t even have a ticket to the compliance discussion.
This is reflected in three aspects.
(1) The "minimum compliance threshold" for banks and channels
U.S. or non-U.S. banks
Stablecoin issuers
Custodians
Fiat channels/PSPs
Their first question is usually not about "how innovative your model is," but: Do you have an MSB?
(2) Are you providing "payments" or "illegal fund channels"?
When helping clients receive USDT:
With MSB + AML/KYC: compliant payment service
Without MSB: high-risk illegal fund intermediary
The legal classification is completely different.
(3) Is there a subsequent upgrade path?
MSB is stackable, expandable, and upgradable:
MSB → Hong Kong MSO
MSB → Singapore MPI
MSB → EU CASP
MSB → U-card, stablecoin, PayFi combination structure
The true positioning of MSB: not an "endpoint," but a "starting point."
Here’s a truth that many intermediaries may not want to hear: MSB itself is not sufficient, but without MSB, it is even less likely to be usable.
Let me directly clarify a few common misconceptions:
MSB ≠ can be casually directed at U.S. retail investors
MSB ≠ does not need to consider state laws in the U.S.
MSB ≠ stablecoin issuance license
MSB ≠ guaranteed bank account opening
But it is the compliance anchor point for all your subsequent actions.
Which crypto payment projects are "very suitable" to start with MSB?
Based on the projects we have actually served, the following types highly match MSB:
1. Stablecoin payments/merchant acquiring
2. Enterprise crypto payment services, salary, and commission disbursement
3. U-cards, crypto cards, PayFi underlying structures
4. Cross-border settlements, OTC, fiat entry
5. B2B crypto payment API/SDK
In one sentence:
As long as you are involved in "the flow of money," MSB is the first brick in your compliance structure.
So where are the "pits" of MSB?
As a lawyer, I must clarify the risks:
MSB ≠ universally accepted across the U.S. (state MTL remains a red line)
Bank account opening ≠ automatic success (materials and models determine everything)
Annual compliance maintenance ≠ just going through the motions (real AML)
Passive registration ≠ compliant operation (enforcement has clearly intensified)
MSB is not about buying a certificate; it is a continuous compliance project.
Finally, let me say one more truth
If you ask me now: "When doing crypto payments, how should I choose the first license?"
My answer remains: First solidify the U.S. MSB, then discuss others.
Not because it is perfect, but because—
It is the most balanced card in the real world in terms of cost, speed, and usability.
If you are building a compliance structure for crypto payments, stablecoins, U-cards, or PayFi,
How to register for MSB is just the simplest question; the key is: how to use it, how to avoid pitfalls, and how to pave the way for the future.
For these types of questions, Mankun has been on the front line. If needed, feel free to reach out.
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