MSB Registration

FinCEN has published a revised form 107 for registration of Money Service Businesses ("MSBs") with FinCEN. The form is dated 12/31/04 and should be used by any MSB registering with FinCEN. Some examiners have asked banks for proof that their MSB customers are registered with FinCEN and some have even suggested that the bank is responsible for the registration. This is not correct. The MSB is responsible for the registration. The bank, in its due diligence program, should verify that the MSB is registered. The bank should also maintain careful monitoring of the MSB as a high risk customer.

Copyright © 2005 Compliance Action. Originally appeared in Compliance Action, Vol. 10, No. 1, 1/05