We have about 4 MSBs that cash many, many payroll checks for undocumented workers (this is common knowledge in the local community). Does that fact alone make those 4 MSBs in the higher risk category per the Interagency guidance issued April 26, 2005?

What do you mean by "undocumented"? I know of a grocery store in a city in the valley that will cash illegal alien's paychecks. I would think that would be an MSB, but thankfully, they aren't our customer.

Are many of you finding alot of MSBs? I really don't think we have more than one or two. We are a small town with small businesses, and I don't see them having the ability to cash checks for over $1,000 per person per day, or issuing money orders that large.

I'm not sure, but I think "undocumented workers" is the politically correct term for illegal aliens. At any rate, we have have check cashers that cash payroll checks for these individuals. The checks are typically from drywall companies or roofers and the checks are noramlly in the $800-$1200 range. Where my concern is that will the examiners say "This is a high risk business" because you knew these individuals are illegal aliens. And you had a responsibility wo run these check cashers through a more high-risk analysis than you currently have been doing. Or they might say you should have reported them on an SAR because you had suspicions that these people were illegal aliens.
For our bank our MSBs are in the Latino areas of town. I'm concerned we should be doing more. I'm in the process of making sure they are all registered with FinCEN and the State. But I'm still struggling with whether or not they are low or high risk??????

My understanding is that NBFI/MSB's are all considered high risk regardless. They have the opportunity to launder money easier than others.

It would have fallen well short of "politically correct" for the Interagency Guidance to indicate that check cashers who routinely deal with illegal aliens are high risk.

Have you seen or heard about a regulatory presentation or an article where regulatory personel mention the Matricula Consular favorably as a form of identification, without noting that the vast majority of those who offer it as ID are in the U.S. illegally? (Not all regulatory personnel agree with that stance and not all of the agencies display the same amount of fervor.)

Regardless of what is PC, you are entitled, but not required, to reach the conclusion that MSBs dealing with significant numbers of illegal aliens are high risk. (The underlying premise of the Guidance is that it's your risk asssessment and there are no automatic answers anymore.) You might even get some support for your conclusion from field examiners...

A check casher in my local area is now in prison for selling false ids to illegal aliens. She even had Social Security employees involved.

Another asked if our bank would help them get "documentation" for their clients. We declined.