Regulatory · FinCEN
The first track: money-services-business registration.
FinCEN registration under 31 CFR 1010 establishes Wavestar as a regulated money-services business — the legal predicate for custodial handling of member settlement funds in dollar and stablecoin form. Registration is paired with state-by-state money-transmitter licensing and a full Bank Secrecy Act compliance programme.
- Filing
- FinCEN Form 107
- Status
- Pre-filing preparation
- Next deadline
- Initial registration · Mo. 3
- Public docket
- fincen.gov / MSB Registrant
What this authorises
Custodial settlement. Dollar and stablecoin. At scale.
MSB registration enables Wavestar to hold, transmit and settle member funds across the clearing programme. Each capability is separately licensed and separately audited.
- 01
Custodial settlement accounts
Member cash collateral — initial margin, variation margin, default-fund contributions — held in segregated for-benefit-of accounts at qualifying US depository institutions. Daily reconciliation; bankruptcy-remote structure. - 02
Stablecoin on- and off-ramp
Fiat-to-USDC and USDC-to-fiat conversions offered to members via contracted banking partners. Tokens never commingled with corporate treasury; every transfer signed and anchored. - 03
Inter-member settlement transmission
Instructed transfers between member accounts on T+0 atomic rails. MSB status permits payment-initiation on behalf of members without taking principal risk. - 04
State money-transmission coverage
49 state MTLs plus the District of Columbia, sequenced to achieve national coverage within 18 months of initial FinCEN registration. Multi-state Money Services Businesses programme (MSB MOU) where available. - 05
BSA-regulated cross-border flows
Authorisation to transmit funds to and from non-US operator counterparties, with OFAC screening, Travel Rule compliance, and suspicious-activity reporting built into the flow. - 06
Recordkeeping and audit trail
Seven-year retention of every transmission record. Every entry is signed, canonicalised and anchored — subpoena-ready export in hours, not weeks.
Filing timeline
A nine-month arc from formation to national coverage.
- Month 0Complete
Corporate formation complete
Wyoming parent, US operating subsidiary, and trust-company structure stood up. Board seated; risk, compliance and internal-audit functions reporting. - Month 3Planned
FinCEN Form 107 filed
Initial MSB registration electronically filed through the FinCEN BSA E-Filing System. Full activity disclosure, principal identification, and designated compliance officer on record. - Month 4Planned
BSA programme activated
Written AML policy, customer-identification programme, OFAC screening, internal controls, designated compliance officer and independent review scoped. First transaction-monitoring cycle begins. - Months 4 – 12Planned
State money-transmitter licensing in motion
State applications filed through the Nationwide Multistate Licensing System (NMLS). Waves prioritised by volume and favourable safe-harbour: NY BitLicense, Texas, California, Florida, Illinois first. - Month 9Planned
Independent BSA review completed
First annual independent review by external counsel and auditors. Findings filed with the board risk committee and available to regulators on request. - Month 12Planned
National coverage — Wave 1
25-state licensing footprint live, covering ~90% of US clearing-member counterparties by expected cleared notional. - Month 18Planned
National coverage — Wave 2
49 states plus DC. Remaining holdout jurisdictions either live or operating under an express exemption letter.
Ongoing obligations
Registration is the beginning. Not the end.
Each obligation below is owned by a named officer and audited at least annually. We treat the FinCEN programme as continuous, not episodic.
Public documents
What we file, we publish.
The archive below mirrors every publicly-available filing tied to the FinCEN programme. Private sections of filings are redacted and the redaction itself is signed.
FinCEN filings register
- Form 107 — Initial registration
Target filing window: month 3. Updated on each biennial renewal and on material changes.
- BSA Program Manual
Redacted sections: transaction-monitoring rule thresholds, PII-handling runbooks. Redactions are hashed and signed.
- Independent Review — Summary
Published 60 days after each review completion.
- State MTL register
Updated as each state approval lands; shows effective date, license number, and scope.
- Custodial-account attestation
SSAE 18 / SOC 1 Type II attestation on member-fund segregation and reconciliation controls.
Next tracks
From FinCEN to the derivatives clearing organisation.
MSB registration is the cash-side predicate. The next track — SEC ATS-N — introduces the securities-side venue. After that, CFTC DCO registration completes the central-counterparty arc.