U.S. Bank Account Wanted for a Florida Money Transmitter License Applicant: Segregated Client Funds, ACH, Fedwire and SWIFT

Summary

A Florida company that has applied for a Florida Money Transmitter License is looking for a U.S. bank account in its own legal name. The account must expressly permit MSB and money transmitter activity and keep client funds separate from the company's own funds, so that it can support the pending application with the Florida Office of Financial Regulation.

Forecast fiat volume is about US$3 million a month with an average transaction of about US$30,000, in USD, over ACH, Fedwire and SWIFT. A fiat-only solution is the first priority. Crypto support is optional and can be quoted separately.

Description

A Florida LLC that has applied for a Florida Money Transmitter License is looking for a banking provider. The account is needed to meet the banking requirements of the Florida Office of Financial Regulation (OFR) for the pending application.

A fiat-only solution is acceptable and is the first priority. Crypto support is optional.

The applicant

• A Florida LLC formed in 2025, with operations in Latin America
• Services: collections, supplier payments, domestic and international money transfers, commercial cross-border payments and remittances
• Customers: importers and exporters, small and mid-sized businesses with overseas suppliers, freelancers and independent professionals
• Markets under consideration: the United States, Canada, the European Union and Latin America, subject to regulatory, sanctions and risk review
• Principal currency: USD

What is needed

• A customer-funds (clearing) account in the applicant's own legal name, with clear segregation, permitted customer receipts and onward payments, and an auditable customer ledger
• A separate operating account for the company's own funds and expenses, or a documented separate arrangement
• Inbound and outbound ACH, Fedwire and international SWIFT
• Simple account access. An API or other integration is welcome but not required
• A clearly identified deposit bank and the deposit protection that applies. FDIC-insured banking is preferred

An FBO arrangement can be considered where it fits. No particular account product is assumed: the provider should explain how its structure meets this use and supports the OFR review.

Forecast volumes

• Monthly fiat volume: about US$3 million
• Average fiat transaction: about US$30,000
• Rails: ACH, Fedwire and SWIFT
• Funds handled: customer funds, held separately from company funds

These are forecasts, not historical volumes. The monthly volume is money passing through, not the balance expected to stay on deposit. Maximum payment sizes, daily peaks and balances are confirmed during underwriting.

How the money moves

1. Onboarding: the company identifies the customer, completes KYC or KYB and beneficial-owner checks, sets a risk profile and obtains compliance approval.
2. Instruction and funding: the customer requests a collection or payment. Funds arrive in the approved account and are recorded against that customer in the segregated arrangement.
3. Checks: AML/BSA, OFAC, counterparty and transaction-monitoring controls are applied. The link between customer, payer and beneficiary is documented, especially where names differ.
4. Execution: the company sends the permitted transfer or settlement through approved banking channels by ACH, Fedwire or SWIFT.
5. Reconciliation: the instruction, receipt, payment and customer entitlement are documented and reconciled.

The applicant is not asking for nesting, correspondent banking or account access for other financial institutions.

Licensing and compliance position

• The Florida Money Transmitter License application is in process. The applicant states it will not begin regulated Florida money transmission until the required licenses, registrations and authorizations are in place
• A written AML program dated October 2026 covers customer identification, KYC and KYB, beneficial-owner review, risk-based and enhanced due diligence, sanctions screening, automated transaction monitoring, escalation, regulatory reporting, staff training, independent review and record keeping
• A full-time compliance officer is reported
• These are the applicant's own statements and written policies. They have not been independently verified and are open to the provider's due diligence
• Whether any cash service is in scope is to be confirmed in underwriting. Providers should not assume cash activity

Providers are asked to treat opening the account and switching on regulated flows as two separate steps. If an account can be opened before the license is granted, please say what restrictions and conditions apply. Opening an account is not regulatory approval, and OFR's acceptance of any structure is the regulator's own decision.

Optional: crypto

Crypto is not needed for the core fiat solution. It can be quoted as an extra capability or handled by a separate provider.

• Assets: BTC, ETH, USDT and USDC only
• Activity: customer-initiated receiving, sending, conversion, purchases and sales
• Forecast: about US$1 million a month, average transaction about US$5,000
• Controls described in the AML program: wallet screening, ownership checks on self-hosted wallets, Travel Rule controls and daily wallet reconciliation
• Not in scope: an exchange, trading, investment or DeFi platform, kiosks, stored-value or wallet products, lending, staking or yield

A fiat-only provider should say whether any crypto-related fiat receipts or payouts are allowed on the account.

What to include in a proposal

1. Whether the applicant is eligible, given its ownership, operating footprint and pending license
2. The proposed account title, deposit bank, segregation or FBO structure, and the documents available for OFR review
3. Permitted customer-funds activity, rails, currencies, countries and third-party payment rules
4. Onboarding documents required, licensing conditions and any limits before activation
5. Transaction, balance and exposure limits, minimum balances, reserves, holds and settlement timing
6. Setup, monthly, payment, correspondent and FX fees, and the expected review and opening timeline
7. A separate answer on crypto: what is supported and on what terms, or a statement that the proposal is fiat-only

Who should respond

• U.S. banks that bank MSBs and money transmitters
• Banking-as-a-service and FBO account providers working with an identified U.S. deposit bank
• Other regulated account providers that can offer segregated customer-funds accounts in the applicant's own name

Confidentiality

The applicant's name, owners, addresses and supporting documents are withheld in this listing. They are shared with providers that can show a suitable solution. This listing is managed by DealHarbor on the applicant's behalf.