Your LLC is
the hard part
the easy part.
Everything after it isn't.
Any $500 platform can form your U.S. company. But money transmitter licensing, FinCEN, AML, and a bank that says yes — that's where LatAm founders get stuck, fined, or rejected. That's what Cogent Law fintech attorneys handle on your behalf, and in your language! That's the green light.
Formation platforms are great.
At exactly one thing.
Stripe Atlas, doola, Firstbase — genuinely good at forming a company. But if your product moves money, the company is maybe 10% of your U.S. problem. Here's the other 90%:
The filing you've never heard of
Foreign-owned U.S. LLCs and 25%+ foreign-owned C-corps must file Form 5472 every year there's a reportable transaction — even pre-revenue, even at $0 income. Miss it, file it late, or file it incomplete, and the penalty starts at $25,000. We handle it for you.
No U.S. SSN? You still need an EIN
The IRS has made it harder for founders without a Social Security Number to apply online. It's a paper Form SS-4, mailed or faxed to a specific IRS unit — get it wrong and you're waiting weeks or months. We file it right the first time and follow up with the IRS by phone and email until it's approved.
One federal license. 50+ state licenses.
There's no single U.S. "money license." There's a federal license, then state-by-state licenses — a maze that costs six figures. Most founders don't need all of it on day one; knowing which licenses you actually need can save you hundreds of thousands.
Map your flow of funds — before you build
Whether you need a license (and where) depends on who controls the money, who has custody, and who moves it — not what you call your product. Get that analysis wrong and you find out you can't launch after the product's already built. We map it out first.
The MSB registration isn't the finish line
Registering as a Money Services Business with FinCEN is the easy part. The real lift is state-by-state Money Transmitter Licensing — separate applications, separate bonds, separate net-worth requirements, per state. We run both tracks at once.
What the bank will say
Without a real AML program and clean ownership documentation, U.S. banks and BaaS providers reject foreign founders by default. Your product doesn't exist until a bank says yes — we prepare the docs and make the bank introductions.
The program examiners want to see
A generic AML/KYC template doesn't survive an exam or a banking partner's due diligence. You need a written program — risk assessment, CDD, transaction monitoring, SAR procedures — built around what your product actually does. We draft it, and the paper trail behind it.
One memo, not six figures of guesswork
A regulatory roadmap memo maps your actual flow of funds against every state's MTL statute before you file a single application — what's licensable, what's exempt, what can wait. Founders who skip this step often license everywhere "to be safe" and spend money they didn't need to. We write the memo that tells you where to spend it instead.
Pick your model. See your checklist.
Different products trigger different U.S. requirements. This is the simplified map — your free assessment turns it into a precise plan.
▸ Simplified for orientation only — not legal advice. The real answer depends on your flows, custody, and states. That's what the assessment is for.
$500 entity formation platform vs. Cogent Law Fintech Team.
Not a knock on the platforms — use one, they're fine at formation. The question is who owns all the work after the certificate arrives.
| What you need | Formation platform | Cogent Law |
|---|---|---|
| Company formation + EIN | ✓ genuinely good — though some can't register EINs for foreign owners | ✓ structured for tax + investors |
| Form 5472 foreign-owner filing | ~ paid add-on, easy to miss | ✓ handled, every year |
| Draft regulatory roadmap | ✗ | ✓ flow of funds mapped against every state's law |
| FinCEN MSB registration | ✗ | ✓ filed right, obligations mapped |
| BSA/AML compliance program | ✗ | ✓ built by a former CCO |
| State licensing strategy | ✗ | ✓ incl. partner-bank paths that defer costs |
| Bank-ready documentation | ✗ template docs get rejected | ✓ what banks accept — plus the introductions |
| Attorney-client privilege | ✗ not a law firm | ✓ a real U.S. law firm |
| Defense if a regulator calls | ✗ | ✓ audits, inquiries, response |
| Speaks your language | ✗ English-only support | ✓ EN · ES · PT, on the ground in LatAm |
▸ platforms referenced generically; capabilities per their public offerings. use both: platform for paper, a legal team for the green light.
One path. Six checkpoints.
Zero guessing.
Transparent, packaged scope — you know what's happening and what's next. No open-ended hourly meter.
Launch assessment
Free call, your language. We map your flows and tell you exactly what you need — and what you don't.
Entity + EIN, done right
The structure that fits your tax picture and future investors, with the foreign-owner EIN route handled.
FinCEN + AML build
MSB registration filed correctly, and the written AML program banks and regulators expect — built by a team with a former CCO on it.
Draft regulatory roadmap + licensing strategy
A written memo maps your flow of funds against every state's MTL law — which states, when, and whether a partner-bank model can defer six-figure costs while you grow.
Banking readiness
Ownership, control, and compliance docs packaged the way U.S. banks and BaaS partners want to see them — and we make the bank introductions.
Ongoing counsel
New states, new products, audits, questions — a long-term legal partner, not a one-time vendor.
A practice built for both sides of the border.
Cogent Law's fintech practice combines U.S. regulatory depth with real Latin American presence — licensing strategy, compliance operations, and counsel in your language.
The reviews we're collecting.
"He explained in ten minutes what three U.S. lawyers couldn't explain in a month."
"We almost paid for licenses we didn't need yet. He mapped a partner-bank path instead."
"Finally one person who understands both sides of the border. The bank said yes."
Is this you?
GO Book the assessment if…
- → You run a fintech, payments, or crypto company in LatAm
- → Your product moves money — payments, remittances, stablecoins, and crypto
- → You need U.S. banking, licensing, or investors to grow
- → You'd rather do it once, correctly, than patch it later
WAIT Grab the free guide if…
- ○ You're still validating and not ready to talk
- ○ You want to understand the U.S. rules first
- ○ You're pre-company, mapping options
- ○ You'll get there — just not this quarter
Founder questions.
No — the formation is probably fine. What's missing is the regulated layer: FinCEN registration, AML, licensing strategy, bank-ready docs, and the Form 5472 filing platforms often leave to you. We start from what you have and complete it.
Maybe… or maybe not! It all depends on your flow of funds, the services you offer, and the states you plan to operate in — or where your customers are located. There are legitimate structures (like partner-bank models) that defer six-figure licensing costs while you grow, along with state-level exemptions for certain types of activity. Getting that answer right, early, is worth more than any single filing. That's the point of our assessment.
Sim / sí. The team works in English and Spanish and supports Portuguese-speaking founders directly — your assessment happens in the language you think in.
Consultancies file paperwork. A law firm gives you privilege (your conversations are protected), formal legal opinions banks rely on, and someone who can defend you if a regulator calls. With a former Chief Compliance Officer on the team, you get the operator's playbook with the lawyer's protection.
Depends on what you actually need — which is exactly what the free assessment scopes. Engagements are packaged and transparent: you approve the scope and price before anything starts. No open-ended hourly meter.
Formation and EIN move quickly; FinCEN, AML, and banking take longer; state licensing is the long pole — if you even need it now. The assessment gives you a realistic sequence for your case, ordered to get you operating as fast as safely possible.
Stop guessing.
Get the green light.
A free 30-minute launch assessment with Cogent's fintech legal team. You leave with a clear map — whether or not we work together.