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#1772006 - 01/03/13 04:59 PM MSB?
Piano Man Offline
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Piano Man
Joined: Mar 2004
Posts: 442
Down South
If our customer issues money orders as an agent for another MSB, does our customer register with FinCEN?
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#1772041 - 01/03/13 05:42 PM Re: MSB? Piano Man
devsfan Offline
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Joined: Jun 2004
Posts: 1,927
NYC
No, the other MSB, such as Western Union, MoneyGram, etc is the one who must register with FinCEN. You should request a copy of the agreement between your customer and the other party, and might also be able to search the other party's Web site for their agents and find your customer. Your customer is still considered an MSB, however.

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#1772050 - 01/03/13 05:55 PM Re: MSB? Piano Man
Piano Man Offline
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Piano Man
Joined: Mar 2004
Posts: 442
Down South
They are considered an MSB, but don't register with FinCEN? Just want to make sure I understand.
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Love so amazing, so divine; Demands my soul, my life, my all.

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#1772087 - 01/03/13 06:21 PM Re: MSB? Piano Man
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
You understand. You would apply all of the April 2005 guidance given to banks that bank MSBs, e.g. you would do a risk assessment, but you would not verify federal registration because you established they are an agent for another already registered MSB.
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