We have a local grocery store that transmits money through Western Union. Would they be considered an agent of Western Union, and if so, should we expect an AML program including a policy, officer, training and independant review from them? Would WU provide this to their agents?

Yes, they are considered an MSB. No, they don't have to register unless they are doing "other" activity that would make them an MSB.

Yes, Western Union proviedes training to their agents.
No you don't need Western Unions AML Program

the above is in my opinion only

How about if the grocery store cashes checks and sells money orders? I just received a copy of my customer's MSB registration with FINCEN and there is no mention of them being a money transmitter, but they offer Western Union services. The only activity on the registration form is the check cashing and money order sales.

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