My bank is considering a product that will sign on a good number of new commercial business clients. They will have DDA and/or time deposit accounts with us but not their primary business accounts.
My question is: Do we need to verify if they operate as an MSB and complete our MSB due diligence on each entity, even though their MSB activity will not be transacted through our institution?
Any thoughts or insights will be helpful. I know my personal thoughts on this, but wanted to get the consensus of the banking community.
Thanks!
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It is actually possible for you and I to have different opinions and yet still live peaceably upon this planet.