MSB does not always mean money transmission. This can be illustrated most simply by looking at the definitions provided in one state money transmitter law (California) and by FinCEN:
MSBs (as defined by FinCEN) are money service businesses, which include but are not limited to money transmission. MSBs include check cashers, issuers/sellers/redeemers of money orders and traveler’s checks, currency dealers, currency exchangers, and providers/sellers of prepaid access (includes prepaid cards). For more information, MSBs are defined at 31 CFR 1010.10
Money Transmission (as defined in California) includes selling or issuing payment instruments; selling or issuing stored value; or receiving money for transmission. For more information, the California Money Transmission Act starts at Cal. Fin. Code 2000
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