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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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8