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#1151676 - 03/26/09 01:03 PM Money Remitter - MSB Registration?
Sheldon Hendrix Offline
Diamond Poster
Sheldon Hendrix
Joined: Jun 2006
Posts: 1,194
South
If we come across a customer who is running a money remittance business, but it appears that they are simply just an agent of a large company that facilitates those services, do we need to get the customer to register with FinCEN as an MSB, or do we simply need to confirm their agent status?

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#1151756 - 03/26/09 01:46 PM Re: Money Remitter - MSB Registration? Sheldon Hendrix
Midwest Banker Offline
Gold Star
Joined: Nov 2004
Posts: 349
Cheeseland
If for example you are referring to a business which is processing transactions for Western Union, the (small) business itself does not need to register independently as they are under the Western Union umbrella.

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#1151795 - 03/26/09 02:12 PM Re: Money Remitter - MSB Registration? Midwest Banker
smash Offline
Gold Star
Joined: May 2004
Posts: 331
Texas
Confirm their agent status, i.e. ask for a copy of their agent agreement.

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