Sending cross-border payments from the United States: the stack

By Polynopsis team · Last updated 28 October 2026

Collecting and sending cross-border payments from the United States takes FinCEN registration as a money services business plus state money transmitter licences; 31 states have enacted the Money Transmission Modernization Act in full or in part, which requires customer funds to be backed at all times by permissible investments at least equal to outstanding money transmission obligations. The usual stack pairs a sponsor bank that holds FBO accounts (such as Column, Cross River, Lead Bank or Coastal Community Bank) with ACH, FedNow and RTP collections through providers such as Stripe, Plaid or Dwolla, stablecoin ramps such as Circle Mint, Bridge or zerohash, FX from Convera or Corpay, and Fedwire wires on business days.

Currency	USD
Collection and funding rails	FedNow Service, FedNow network limit, RTP network, Fedwire Funds Service, FedACH and Same Day ACH, Same Day ACH limit
Holiday calendar	United States bank holidays 2026 and 2027

The United States market

The World Bank puts personal remittances paid from the United States at US$106,528 million in 2025, up from US$105,308 million in 2024 (World Development Indicators, updated 8 October 2026). source
The ACH Network carried 35.2 billion payments worth US$93 trillion in 2025; 1.4 billion of them were Same Day ACH payments worth US$3.9 trillion, up 16.7% in volume and 21.4% in value on 2024. source
In the third quarter of 2026 the ACH Network carried 9.3 billion payments worth US$25.6 trillion, 5.9% and 10.2% more than a year earlier; Same Day ACH accounted for 470.4 million of them, up 36.7%. source
The RTP network settled 447,207,091 payments worth US$1,454 billion in 2025, and 422,155,264 payments worth US$1,679 billion from January to September 2026. source
The RTP network processed 150 million transactions worth US$621 billion in the third quarter of 2026 and had more than 1,378 participants as of September 2026. source
The FedNow Service settled 6,376,467 payments worth US$370.9 billion in the third quarter of 2026, up 27.6% in volume on the second quarter, with an average payment of US$58,161; in 2025 it settled 8,413,402 payments worth US$853.4 billion. source
The FedNow Service had more than 1,800 participating financial institutions and over 50 certified service providers after adding 111 banks and credit unions in the second quarter of 2026. source

Licensing: who can send money from the United States

With few exceptions, each money services business must register with the US Treasury through FinCEN by filing FinCEN Form 107 within 180 days of being established, and must renew the registration every two years; a business that is an MSB only because it acts as agent of another MSB does not register. source
Money transmission is also licensed state by state. As of September 2026, 31 states have enacted the CSBS Money Transmission Modernization Act in full or in part, and money transmitters licensed in at least one adopting state account for 99% of reported money transmission activity. source
The Money Transmission Modernization Act sets a minimum tangible net worth of the greater of US$100,000 or 3% of total assets for the first US$100 million, 2% of assets from US$100 million to US$1 billion and 0.5% of assets above US$1 billion, and encourages states to run licensing, surety bonds and reporting through NMLS. source
The NMLS MSB Call Report is due within 45 days of each calendar quarter end; its company-wide destination country section, required for licensees engaged in foreign money transmission, is filed annually within 45 days after the fourth quarter. source
CFPB Regulation E Subpart B covers remittance transfer providers; a person that provided 500 or fewer remittance transfers in the previous calendar year and provides 500 or fewer in the current year falls under a safe harbour and is not a remittance transfer provider. source
Regulation E gives senders the right to cancel a remittance transfer for a refund when the request reaches the provider no later than 30 minutes after payment, subject to the conditions in 12 CFR 1005.34. source
The GENIUS Act, the federal framework for payment stablecoins, became Public Law 119-27 on 18 July 2025. source
The OCC issued its final rule implementing the GENIUS Act on 21 October 2026; the rule and the Act take effect on 18 January 2027. source

This page explains the rules in general terms and is not legal or regulatory advice. Check the primary source and take advice on how the rules apply to your firm.

Holding customer funds

Under the Money Transmission Modernization Act a licensee must hold, at all times, permissible investments with a market value (under US GAAP) of not less than the aggregate of all its outstanding money transmission obligations. source
Permissible investments under the Act include cash, including demand and savings deposits and funds held for the benefit of the licensee's customers in a federally insured depository institution, as well as ACH items and international wires in transit, AAA-rated money market funds and US government obligations. source
Under the Act, cash at foreign depository institutions counts only up to 10% of a licensee's total permissible investments, and only if conditions are met, and receivables from authorised delegates under seven days old count only up to 50%. source
Under the Act, permissible investments, even if commingled with the licensee's other assets, are held in trust for the purchasers and holders of outstanding money transmission obligations if the licensee becomes insolvent, enters bankruptcy, receivership or dissolution proceedings, or faces an action by a creditor who is not a beneficiary; investments impressed with that trust are not subject to attachment, levy of execution or sequestration by court order, except by a beneficiary, and are shared pro rata. source
The NMLS MSB Call Report includes a quarterly Permissible Investments Report, required for licensees engaged in money transmission, payment instruments, stored value and virtual currency. source
At Cross River, a pooled FBO account with FDIC pass-through insurance requires the partner to report balance and reconciliation to the bank every day; FBO accounts are not FDIC-insured per end user by default and need pass-through requirements such as user identification and record-keeping to be met. source

Collection and funding rails

Rail	Operator	What matters	Source
FedNow Service	Federal Reserve Banks	Instant payments between participating financial institutions in real time, around the clock, every day of the year, with recipients getting full access to funds immediately.	source
FedNow network limit	Federal Reserve Banks	Since 12 November 2025 the network transaction limit is US$10 million for customer credit transfers and payment returns (up from US$1 million) and US$10 million for liquidity management transfers (up from US$2.5 million).	source
RTP network	The Clearing House	Instant payments up to US$10 million per transaction, 24/7/365, with final settlement at any time and ISO 20022 messaging; more than 1,378 participants as of September 2026.	source
Fedwire Funds Service	Federal Reserve Banks	Each funds-transfer business day opens at 9:00 p.m. ET on the preceding calendar day and closes at 7:00 p.m. ET, with a 6:45 p.m. ET cut-off for customer transfers. Saturdays, Sundays and Federal Reserve holidays are not business days.	source
FedACH and Same Day ACH	Federal Reserve Banks (operator) under Nacha rules	Same Day ACH files are due by 10:30 a.m., 2:45 p.m. and 4:45 p.m. ET and settle at 1:00, 5:00 and 6:00 p.m. ET; items not eligible for same day settle at 8:30 a.m. ET on the next banking day.	source
Same Day ACH limit	Nacha	The Same Day ACH per-payment limit, US$1 million since March 2022, rises to US$10 million on 17 September 2027.	source

The send-side stack, layer by layer

A starting shortlist for each layer, described from each provider's own documentation. Confirm terms, coverage and licences with each provider.

Sponsor banks and safeguarding accounts

Provider	What it does	Source
Column	Payment Origination setup that holds client funds in a Column account for the benefit (FBO) of the client's customers, with Column's ledger as system of record, a Third-Party-Sender agreement, and direct access to wires, ACH and book transfers.	source
Cross River	Recommends FBO accounts on the payment company's tax ID for making and receiving payments on behalf of its customers, with subledgers that each carry a unique account number for reconciliation, and FDIC pass-through insurance when pass-through requirements are met.	source
Lead Bank	Offers FDIC-insured FBO accounts with a dedicated account number per end user, ACH and wires, international USD wires and card issuing under one charter, with stablecoins available as a payment rail.	source
Coastal Community Bank (CCBX)	Banking-as-a-service division offering demand deposit accounts, FBO and sub-accounts, dynamic account numbers, and money movement over ACH, wires, RTP and FedNow with a direct Federal Reserve connection.	source

Collections and pay-ins

Provider	What it does	Source
Stripe (ACH Direct Debit)	Accepts debits from US bank accounts with standard settlement four business days after payment creation (21:00 ET cut-off) or two business days (14:00 ET cut-off) for eligible US businesses.	source
Plaid Transfer	US multi-rail bank payment platform for ACH, RTP, request for payment, wire and FedNow transactions through one API, with routing between RTP and FedNow, fallback to Same Day ACH, and a reconciliation report.	source
Dwolla	Payments platform built on the ACH Network that adds instant payments over RTP and FedNow (credit push only, funds available within seconds) and reports which network each transfer used.	source

Stablecoin ramps

Provider	What it does	Source
Circle Mint	Lets institutional customers mint and redeem USDC 1:1 for US dollars directly with Circle, funded by wire from a linked bank account, through a web console or API; Circle Internet Financial, LLC is licensed as a money transmitter by the New York State Department of Financial Services.	source
Bridge	Single API to on-ramp and off-ramp USD and other currencies and move USDC, USDT and issuer stablecoins across 10+ blockchains; US services are provided by Bridge Building Inc. (NMLS ID 2450917).	source
zerohash	Crypto and stablecoin infrastructure for on and off-ramps, cross-border payments and remittance; zerohash llc is a FinCEN-registered MSB and regulated money transmitter, and it and its affiliate zerohash liquidity services llc hold New York virtual currency licences.	source
Lead Bank (on and off-ramps)	Converts between USD and stablecoins for a bank's own treasury or on behalf of third parties, with funds starting and settling as USD in Lead deposit or FBO accounts.	source

FX and liquidity

Provider	What it does	Source
Federal Reserve H.10 rates	Weekly release of daily noon buying rates in New York for cable transfers in major currencies, certified by the Federal Reserve Bank of New York for customs purposes.	source
Convera	B2B cross-border payments in over 140 currencies to 200+ countries and territories over SWIFT, SEPA, ACH, BACS and FPS, with multi-currency holding balances in more than 60 currencies and an API suite; US services are provided by Convera USA, LLC (NMLS ID 907333).	source
Corpay Cross-Border	Trading and payments platform connected to more than 100 correspondent banks and counterparties, with balances in nearly 40 currencies, forward contracts, limit orders, mass payments and API integration for partners and financial institutions.	source
Cross River International Payments	Outbound international payments over SWIFT and in-country rails through a correspondent network, with 24/5 executable FX quotes and routing by corridor, size and currency.	source

KYC and KYB providers

Provider	What it does	Source
Middesk	Business verification (KYB), fraud, registration and monitoring built on 400+ government and authoritative sources, verifying 7 million businesses a year.	source
Persona	Identity platform with government ID, selfie, database and document checks and workflows for KYC, KYB and AML compliance.	source
Alloy	Identity and fraud orchestration for KYC, KYB, AML and fraud checks, connecting 300+ partner data solutions; used by more than 900 financial institutions and fintechs.	source
Socure	Identity verification for consumers and businesses, with global watchlist screening, deceased checks and eCBSV name, date of birth and SSN matching with the Social Security Administration.	source

Bank data and open banking

Provider	What it does	Source
Plaid (Balance)	Real-time balance retrieval; /accounts/balance/get returns current and available balance for treasury and other uses, while /signal/evaluate checks balance against ACH return risk.	source
MX	Consumer-permissioned OAuth data access with instant account details, ownership and balance information.	source
Mastercard Open Finance (Finicity)	APIs that reach 95% of US deposit accounts for permissioned account details, ownership, balances and transaction history.	source
Akoya	Fully API-based, consumer-permissioned data sharing network that connects fintechs and aggregators to data from financial institutions through one integration.	source

When money can leave the United States

Fedwire does not run on Saturdays, Sundays or Federal Reserve holidays; the Monday business day opens at 9:00 p.m. ET on Sunday and every business day closes at 7:00 p.m. ET, with customer transfers cut off at 6:45 p.m. ET. source
Federal Reserve holidays in the rest of 2026 are Veterans Day (11 November), Thanksgiving (26 November) and Christmas (Friday 25 December); in 2027, Juneteenth (19 June) and Christmas (25 December) fall on Saturdays, so the Reserve Banks open on the Friday before. source
Over Christmas 2026 FedACH processing ends at 11:30 p.m. ET on 24 December and resumes at 5:30 p.m. ET on 27 December. source
FedNow and RTP run 24/7/365 but are domestic US rails: Dwolla's documentation describes both as exclusively for US domestic transfers and credit push only. source
ACH debit collections take days to confirm: Stripe's ACH Direct Debit can take up to 4 business days to confirm success or failure, with standard settlement four business days after payment creation, or two business days for eligible US businesses. source

Corridors from here

Frequently asked questions

What licences does a company need to send money abroad from the United States?

Federal registration with FinCEN as a money services business (Form 107, filed within 180 days and renewed every two years) and state money transmitter licences. As of September 2026, 31 states have enacted the Money Transmission Modernization Act in full or in part.

How must a US money transmitter hold customer funds?

In states that have enacted the Money Transmission Modernization Act, it must hold permissible investments at all times worth at least its outstanding money transmission obligations. Cash in accounts held for the benefit of customers at a federally insured bank counts, while cash at foreign banks counts only up to 10%. Licensees report permissible investments quarterly in the NMLS MSB Call Report.

Can I wire USD to a foreign partner at the weekend?

Not over Fedwire, which closes on Saturdays, Sundays and Federal Reserve holidays; each business day runs from 9:00 p.m. ET the evening before to 7:00 p.m. ET, with a 6:45 p.m. ET customer cut-off. FedNow and RTP run 24/7/365 but only between US institutions.

What are the FedNow and RTP transaction limits?

US$10 million per transaction on both. FedNow raised its network limit from US$1 million to US$10 million on 12 November 2025.

When does the GENIUS Act stablecoin framework take effect?

On 18 January 2027. The Act was approved on 18 July 2025 and the OCC issued its implementing final rule on 21 October 2026.

What is the Same Day ACH limit?

US$1 million per payment today, rising to US$10 million on 17 September 2027. Same Day ACH files are due by 10:30 a.m., 2:45 p.m. and 4:45 p.m. ET for settlement at 1:00, 5:00 and 6:00 p.m. ET.

Sources

Know where all your money is.

Polynopsis gives cross-border payment teams one live position across every bank, payout partner, exchange and wallet, including money in flight, and warns before a corridor runs dry.

Book a demo →Learn more →