Compliance and licensing

Compliance before activity

No regulated activity opens before the matching authorisations are in hand. In the United States, international money transmission falls under Florida’s Money Transmitter licence, and a money transmitter is generally an MSB subject to FinCEN and BSA rules.

Federal frameworkMSB — FinCEN / BSA rules
RegistrationFinCEN Form 107
State licenceMoney Transmitter — Florida
Currency exchangeSeparate regulated activity

Four pillars of the programme

01IdentificationKYC at onboarding, beneficiary identification, record keeping and file updates.
02MonitoringTransaction monitoring, alert handling, sanctions screening and reporting procedures.
03Agent networkAgent selection, training, control and supervision. For an MSB subject to registration, FinCEN requires an agent list carrying the required information.
04AuditStanding internal audit, external audit where required, and regulatory reporting on the applicable schedule.

What the compliance programme covers

  • KYC
  • AML
  • transaction monitoring
  • beneficiary identification
  • sanctions screening
  • fraud prevention
  • record keeping
  • agent control
  • regulatory reporting
  • alert handling
  • reporting procedures
  • internal audit
  • external audit where required

Authorisation steps in the United States

  1. 01
    Company formationIncorporation in Florida and final corporate documents.
  2. 02
    EIN and own bank accountFederal tax identifier, then an account in the company’s name, separate from group accounts.
  3. 03
    MSB status and FinCEN registrationStatus assessment, then registration — Form 107 is generally used, with renewal on the regulatory schedule.
  4. 04
    Florida Money Transmitter licenceThe licence authorises certain transmissions of currency, monetary value or payment instruments, including by electronic transfer or internet, to or from locations outside the United States.
  5. 05
    Operational BSA/AML complianceWritten programme, appointed AML/BSA officer, training, controls and audit trails.
  6. 06
    Banking and partner requirementsBank and payment-operator due diligence before corridors open.
Legal reserveWhat this is not

Zantray Transfert’s institutional design is not a Money Transmitter licence, a FinCEN registration, a banking licence, or an authorisation to operate in a foreign country.

Each regulated activity — money transfer, payments, currency exchange — opens only once the applicable authorisations are obtained, and every country is assessed on its own legal analysis.

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Source: Zantray Transfert founding act and governance documents.
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