Just had to do a BIOS update with MSI's M-Flash BIOS utility and needed a fat32 formatted USB key. This is how to do it with diskpart
Commands in an Administrative Terminal
diskpart
list disk
select disk 2
rem (or whichever is your USB key)
rem Important don't get the select disk command wrong the next command wipes the entire drive
clean
create part primary
select part 1
format fs=fat32 quick
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