If a customer is an agent for Western Union and cashes the Western Union check that the issue and some of the checks are over $l,000. or they considered an MSB or just an agent for Western Union?

My understanding is that they are definitly an MSB with the only difference between them and any other MSB being that they do not need to register with FinCEN, since WU is registered with them. You need to consider them high risk with all of the associated EDD, monitoring, etc.

We do have them on our High Risk Listing. Thanks

We have a similar situation with WU agent that we are requiring MSB registration since the company cashes checks in excess of $1,000- separate from the WU transaction. I have a question to add to the WU agent question- CDD on WU agent shows large number of money orders payable to business, all slightly less than $1,000 each and may total 3,000 to 4,000 in a single deposit. when added to the transaction currency exceeds $10,000. WU agent and owner of business same individual. my suspicous mind thinks they may be converting cash to MO to avoid CTR?

Exactly.