There is a minority opinion on the check-cashing agent scenario, and apparently FinCEN is in that minority. Based, I believe, on the now ancient FinCEN "shrimpboat" ruling (
Ruling No. 2000-1), FinCEN has said (but not in a published ruling, to my knowledge) that unless one of the check payees will receive more than $10,000 from the check cashing transactions, the payees don't need to be in Section A entries. Instead, I believe, the company gets listed because the transactions are being done on its behalf (it is providing a check-cashing service to its employees and the company can't do it without the bank cashing the checks).
And, of course, the courier/agent of the company is identified in Section B.
At this year's BOL Top Gun Conference, we were told that FinCEN is trying to juggle its resources so that it can pull some of its old rulings off the shelf, dust them off and either revise them to accommodate current processing realities, rescind them if they are no longer relevant, or issue new rulings to address some of the most frequently asked questions.
If the multiple payroll check, one courier scenario hasn't raised the same question hundreds of times, nothing has.
The problem, I think, is that the "shrimpboat" ruling doesn't seem germane to the payroll check-cashing scenario on its face. So the sooner FinCEN can address the check-cashing question head-on with a ruling, the better. Then we can reconcile ourselves to whatever the ruling says, stop the gnashing of teeth on the issue, and move on to the next big BSA/AML issue.