I'm preparing for a "chat" with one of our customers that appears to meet the definition of an MSB, so that he is aware of the regulation and his reponsibilities.
I'm bringing a copy of FinCEN Form 107 (MSB Registration), as well as the definition of an MSB (and exceptions).
His only apparent MSB activity is the cashing of checks for locals and 'occasionally' exceeding the $1,000 per person per day limit.
Any thoughts as to how the tone should go (e.g., you can't keep your account with us if you keep up this activity, stay under $1,000 per person per day and you don't have to register, etc., etc.)? I want to balance the discussion, but also want to be cautious about appearing to advise him in any way. Or is it best just to explain the situation and let him ask any questions he has about transaction activity?
I hear and I forget. I see and I remember. I do and I understand.--Confucius