I would meet with the customer, hand them the MSB guide (from msb.gov, you can print one or order the actual booklets) and strongly encourage them to read it carefully. I would then inquire as to whether they planned to offer check cashing services over $1,000 to any one person on any one business day. If so, I would set a deadline for them to furnish proof of info needed (MSB registration letter of acknowledgement, AML program, etc.). If they indicated that it was not their intention to function as a money service business, I would ask them to document that to me in writing and let them know that everything is great. I would also explain that we'll be performing periodic reviews of the account, as required by our federal regulators. If they change their mind down the road, it's important to let us know.
If the customer indicates that they are not going to offer check cashing services like this any longer, but you find they are still offering the service, I would file a SAR. If they indicate they plan to continue the activity, but not register, I would file a SAR. And in either case, I would close the account.
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