Good morning. Trying to determine if a certain activity defines a customer as a money transmitter therefore requiring them to register as a MSB. Here's the scenario....the customer is a large shipping company. They have agents throughout port areas in the US. Some of these agents do not have banking relationships at these ports but still need to pay their employees. The agent will wire the money to shipping company for this payroll, the shipping company will then wire these funds to their bank in the port. A local shipping company employee will go to the bank and withdraw this amount in cash to take back to the agent who uses it to pay employees, expenses, etc. Apparently this is common practice in the shipping business.

So, what do you guys think? Another bank has told the shipping company that they need to register as a MSB. This bank is in California.

Are the wires conducted through a bank?

The original wire from the agent is conducted from the agents bank and the subsequent wire from the shipping company is conducted through a bank.

If the wires are conducted through banks, they are no more of a money transmitter than any other company that sends wires through your bank.

Thanks! That was my take on it.