We are not situated in an area where money exchangers, etc. are operating. We had one person cashing checks and the person stopped this rather than register as an MSB.We have an existing food market that wants to offer the Western Union wire transfer services. I remember something about the fact that Western Union was the MSB, however, I believe that my customer would be one also if he routinely accepts money and handles wires through Western Union. Am I correct?

If he is an agent of Western Union he does not have to register as an MSB.

While he does not have to register with FinCEN he is an MSB and you should risk-rate him accordingly. I also suggest that you require a copy of the WU agreement, periodically review the activity in the account, charge an MSB fee, etc.

In addition to all other suggestions, you may want to review your state MSB license requirements. In MA, Western Union is required to obtain a separate license for each of their money transmitter agents.

Welcome to BOL, fellow Cape Codder!

Good points. We sent the customer back to review the whole package with Western Union and also to understand the MSB issue. We'll see if they still want to do this....