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Just an Ice Cream Parlor or an MSB?
Answer by David Dickinson, BOL Guru (Guru BIOS )
Question: The Bank Secrecy Act includes a check casher as a form of an MSB. A check casher is defined as a person engaged in the business of a check casher. What is meant by "engaged in the business of a check casher"? An ice cream store, which derives more than 50% of its revenue from the sale of ice cream, cashes checks for some ot its patrons, some of which are in excess of $1,000, and may or may not charge a fee. Is the store a check casher for purposes of the BSA? In looking at the purpose, spirit, intent, etc. of the BSA, I would say that the store qualifies as an MSB, should register with FinCEN, have AML policy and procedure, etc. But since they are not "engaged in the business of a check casher" but engaged in the business of selling ice cream, are they an MSB?
Answer: If a business cashes checks in excess of $1,000, they are a MSB. Whether they charge a fee, or how much of their revenue is derived from check cashing is irrelevant.
First published on BankersOnline.com 4/4/05
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