Money Service Businesses have to bank somewhere. If that somewhere is your bank, you should be aware of the MSB requirements for registering with FinCEN. While the registration and other forms of compliance, such as reporting, is the primary responsibility of the MSB, the existence of an MSB as a deposit customer of a bank brings a high level of risk to the bank. Thus, regulatory agencies expect banks to recognize and manage this risk. OCC's AL 2004-7 outlines steps banks should take to manage the risk associated with MSBs as deposit customers.
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