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#384371 - 07/12/05 04:00 PM Servimex
Maya Offline
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Joined: Jan 2005
Posts: 154
South Carolina
One of our banks has a restaurant customer (Spanish) that will collect currency from its customers and deposit to their bank account. They will then draw a check to a service, Servimex, that will wire the money to their families in Mexico. Our bank is completing a CTR when needed. This company seems to be a well established company that is somewhat similar to Western Union. If our customer is an agent of Servimex, I understand that they would not be considered an MSB. Is this correct and does anyone else have any experience with a customer using this Servimex company?

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#384372 - 07/12/05 04:36 PM Re: Servimex
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Let's first get rid of the notion that your customer won't be an MSB. They appear to be arranging money transfers. That means they fit the MSB definition, regarless of the dollar amounts. However, if that is their only money services business, and they do it only as an agent of Servimex, and if Servimex is registered as an MSB with FinCEN, then the restaurant won't be required to register as an MSB with FinCEN on its own. It may, of course, have licensing/registration requirements with the state.

As an MSB, the restaurant needs to considered a relatively greater risk for money laundering than your average customer (restaurants themselves present a higher risk profile).
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#384373 - 07/12/05 04:46 PM Re: Servimex
BankerMama Offline
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BankerMama
Joined: Jun 2001
Posts: 1,543
I agree that this customer is an MSB but unless they add another service like cashing checks over $1,000 they do not have to register.

We have a couple of business customers who are agents for Servimex.

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