Synctera Is Now a Registered Money Services Business

Today, Synctera’s sharing a milestone that's been in the works since the start of the year: t-minus10 Finance LLC ("T-10"), Synctera's wholly owned subsidiary that performs Program Management and Money Services Business ("MSB") functions, has completed registration with FinCEN as a Money Services Business. 

Practically, that means Synctera (via T-10) is now a federally regulated "financial institution" under the Bank Secrecy Act, with direct, standalone obligations that previously sat solely with our bank sponsors - independent SAR and CTR filing, an AML program of our own, recordkeeping, and participation in FinCEN's 314(a) and 314(b) information-sharing programs. 

Registering with FinCEN is not a license, and it doesn't make Synctera a bank. Registering converts Synctera, for the programs where it applies, from an unaccountable intermediary into a directly regulated counterparty that FinCEN and IRS-MSB examiners can examine on their own authority.

Why should banks, FinTech customers, and investors care? 

Unfortunately his industry has been impacted by a well-documented history of failure, led by Synapse. The impact on consumers has been real and significant. Synctera has secured this registration specifically to avoid that and expand Synctera’s compliance responsibilities (not shrink them, as others have done). 

When Synapse collapsed, the core problem wasn't just poor bookkeeping - it was structural, and it was cultural. Synapse operated across multiple entities and banking relationships, eventually opening cash brokerage accounts for over 100 FinTech partners at four different banks, and by its own account, it deliberately segmented and distributed deposits across those banks specifically to keep each partner bank from knowing what share of the total deposit base it actually held. On top of that structural opacity, Synapse kept its own ledger of the FBO accounts held at its bank but appears to have never performed daily reconciliation between its ledger and the bank's ledger. Furthermore, it appears that Synapse failed to identify and report suspicious activity, effectively turning a blind eye to problems on its own platform rather than surfacing and fixing them. Once that reconciliation broke down, no one,  not the banks, not the FinTechs, not Synapse itself, could reconstruct who actually owned the money, and tens of millions of dollars in end-user funds has ended up unaccounted for.

Synctera's FBO model is built to make that scenario structurally impossible: every FinTech program sits in its own segregated FBO account (never commingled across programs), banks get direct ledger access and every transaction and balance change in real time, and a  daily reconciliation against the bank's own FBO account, backed by end-of-day sweeps and standardized FDIC custodial files. 

Synctera’s supports  that architecture with a Legal, Risk & Compliance team of lawyers and banking professionals — with prior careers at Citi, JPMorgan, Goldman Sachs, PayPal, Bank of America, Brex, Morgan Stanley, Santander, Citizens, and other financial institutions, who own the compliance function full-time, rather than treating it as an afterthought. MSB registration adds another layer on top of that architecture: independent SAR filing, recordkeeping, and direct examiner access, so that regulatory accountability doesn't depend on any single party's word.

Becoming an MSB alone doesn't change how money moves through Synctera’s bank partners' rails, and it doesn't change every program overnight. What an MSB registration changes is optionality: banks get a partner in Synctera that can now file SARs directly rather than routing every decision through them, cutting their operational burden while giving them more, not less, visibility into program activity. FinTech customers get a program manager with direct regulatory standing rather than a purely technical vendor; and it opens the door to use cases, including international money-movement programs, that require an MSB counterparty to begin with. 

None of Synctera’s increased contribution and participation in the safety of programs would mean much without the infrastructure to back it up, which is why we paired this registration with our acquisition of Cable in April. 

Cable's team, formerly led by Natasha Vernier, spent six years building the leading automated control-testing platform for banks and FinTechs, the kind of continuous, evidence-generating verification that turns "we have a compliance program" into "here's proof, in real time, that it's working." Bringing Cable in-house means banks don't just get Synctera’s compliance execution; they get an independent, continuously running test of whether that execution is actually holding up, on top of the ledger transparency and reconciliation discipline MSB registration formalizes.

Registering for and building out the capabilities to become an MSBdidn’t happen by accident, and it didn't happen quickly. Synctera’s team lead a cross company  team effort across the Legal, Risk and Compliance organization. 

• The LR&C team built and now runs the standalone AML program this registration required: CIP, CDD/EDD policy alignment, the MSB risk assessment, and the SAR/CTR governance framework, from the ground up. 
• Synctera’s Compliance Operations team, Ground Control, absorbed real volume growth while that build-out was underway. 
• And Synctera’s product and engineering teams shipped the underlying capabilities – automated Customer Risk Rating and Enhanced Due Diligence, live in production – that examiners expect to see operating, not just described in a policy binder. 
  

Managing Synctera’s compliance programs has been a collaboration between bank, FinTech and Synctera since day one. Synctera has been quietly proving out the Program Management model over the past year, and MSB registration is the next, deliberate step in that same trajectory.

BaaS as a category is maturing, not retreating – the market is on track to roughly double by 2030 (Research and Markets estimates the global BaaS market was $29.5B in 2024, growing to $74.8B by 2030 at a 16.8% CAGR). Providers who can prove compliance and give banks real controls and real-time observability, not just orchestration. will win.

Synctera becoming a registered MSB, backed by Cable's independent testing and a ledger architecture designed from the ground up to avoid Synapse's failure, is what that next segment of the market actually looks like. 

Happy to  share with any bank, FinTech, or investor who wants to understand exactly how this works.