We now think the platform should have registered as an MSB months ago. Is late registration only an administrative fix, or can FinCEN penalties become serious?
The compliance team has finally accepted that our transaction flow likely falls inside money transmission, but no FinCEN registration was filed when the product launched. Some founders keep talking like this is just a paperwork step we can fix quietly with a late filing. I am less relaxed about it because regulatory failures around AML do not usually stay small once they become visible.
I want an honest answer about the seriousness of the registration gap. If FinCEN explicitly says civil money penalties and even criminal exposure can exist for registration failures, then the company needs to treat this as a real remediation matter instead of a harmless administrative oversight.
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