Skip to content
GeoDataVision
Thread Options
#1644372 - 12/29/11 08:10 PM Money Transmitters
jfredo Offline
Member
Joined: Dec 2011
Posts: 67
We have many customers who own convience stores that provide money transmission services to their clients. Do they need to have a license to engage in money transmitter activities?

Return to Top
BSA/AML/CIP/OFAC Forum
#1644380 - 12/29/11 08:22 PM Re: Money Transmitters jfredo
Banker Chick Offline
Junior Member
Joined: Jul 2006
Posts: 37
TN
Assuming they meet the definition of MSB as a money transmitter...
You need to know more about each customer. IE Convienve stores offering this service are more likely to acting as Agents for an MSB.

A person that is an MSB solely because that person serves as an agent of another MSB is not required to register. However, a person that is an MSB both because it engages in MSB activities on its own behalf and as an agent of another MSB must register.

31 CFR 1022.380(a)(2) (formerly 103.41(a)(2))
Go to this link for more info.
http://www.fincen.gov/financial_institutions/msb/
_________________________
Opinions expressed are my own and do not necessarily reflect those of my employer.

Return to Top
#1644382 - 12/29/11 08:25 PM Re: Money Transmitters jfredo
jfredo Offline
Member
Joined: Dec 2011
Posts: 67
They are selling money orders through Fidelity Express but they do engage in money service business activities as well.

Return to Top
#1644458 - 12/29/11 09:22 PM Re: Money Transmitters jfredo
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 4,198
New York City
Any amount of money transmission will cause the entity to be classified as an MSB. Agent status is only relevant for registration purposes. The MSB must still have an AML program and meet the other requirements specified by FinCEN.
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

Return to Top
#1644505 - 12/29/11 10:09 PM Re: Money Transmitters jfredo
devsfan Offline
Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
Plus your oversight, monitoring, etc responsibilities have now increased and you should be compensated appropriately.
Last edited by devsfan; 12/29/11 10:10 PM.
Return to Top

Moderator:  Andy_Z