Skip to content
BOL Conferences
Forums · Active Threads · Forum Rules · Mark All Read · Log In
BankersOnline.com Forums Banker Forums BSA/AML/CIP/OFAC Forum Considered an MSB?
Thread Options
#1944017 - 07/22/14 02:26 PM Considered an MSB?
kabocca Offline
New Poster
Joined: Jul 2014
Posts: 4
A real estate LLC (LLC) owns a property that an MSB operates out of. MSB and LLC are same owners. Should LLC be considered an MSB for BSA purposes? Thank you!

Return to Top
BSA/AML/CIP/OFAC Forum
#1944024 - 07/22/14 02:36 PM Re: Considered an MSB? kabocca
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
You're mixing apples and oranges. It doesn't make any difference who owns the real estate where the business is located.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
#1944040 - 07/22/14 02:57 PM Re: Considered an MSB? kabocca
kabocca Offline
New Poster
Joined: Jul 2014
Posts: 4
Thanks, Ken. Just so I understand your response, the LLC should not be considered an MSB?

Return to Top
#1944066 - 07/22/14 03:23 PM Re: Considered an MSB? kabocca
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Does the LLC operate the business that cashes checks, sells checks, does currency exchanges, etc.? Does their FinCEN registration indicate that they are an LLC?
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
#1944081 - 07/22/14 03:39 PM Re: Considered an MSB? kabocca
kabocca Offline
New Poster
Joined: Jul 2014
Posts: 4
No it does not cash checks, etc. The MSB is the only entity that is registered with FinCEN. Thanks again!

Return to Top

Moderator:  Andy_Z