We have a convenience store that takes third party checks (US Treasury Checks for SSI, Payroll Checks, etc.) as payment for gas, tires, food, etc. and gives their customer cash back. While monitoring it was noted that there was one customer in particular that brings in 2 SSI checks each month for a total of $1,326 and has done this practice for atleast the last 14 months. The business owner says this particular customer pays her charge account at the store each month and gets the rest in cash but it's never $1,000 or more. I really lean towards not believing this, but this store is in a very rural area and maybe the lady does have a $327+ charge account every month. But, do I simply take the business owner's word for it? What other due diligence do I need to do? Also, am I correct in thinking that MSB registration is only required when there's at least $1,000 in CASH? Since this involves 3rd party checks, that's not the same, correct?
Thank you!

$327 doesn't go very far, especially at a C-store. I think the response is credible. More so, even, given that you haven't come across anyone else who appears to be running checks more than $1,000 through the store.

Unless there's a state licensing requirement involved, I think you're fine. Registration is required for a check casher if it "accepts checks (as defined in the Uniform Commercial Code), or monetary instruments (as defined at § 1010.100(dd)(1)(ii), (iii), (iv), and (v)) in return for currency or a combination of currency and other monetary instruments or other instruments, in an amount greater than $1,000 for any person on any day in one or more transactions."

In other words, if the C-store pays her back $1000 or less in any one day, it's not an MSB.

Thanks John! My first thought was that this lady who draws SSI shouldn't use much gas and should buy her groceries at the grocery store. I guess I really didn't take the time to think about it and realize that $327 would be a legitimate amount for gas and any food she does get from there.