Entities can conduct any of the following activities to be considered an "MSB"
Last edited by ETX L Complaince; 01/16/13 06:05 PM.
- Check cashing
- Purchase / Sale of Money Orders
- Currency Exchange
- Traveler's Checks
- Money Transmission
- Stored Value *(Gift Cards) *The definition of an issuer, seller or redeemer of stored value is further limited in our regulations to only those persons that issue, sell or redeem more than $1,000 in stored value per person per day in one or more transactions. For example, one customerís simultaneous purchase of three stored value cards, each with a face amount of $500, would reach this threshold. (From FinCen)
Now... if the customer is a registered agent acting on behalf of Western Union or something similar, they're not required to be considered an MSB nor registered as an MSB. High risk customer? Probably. But they don't have the necessary requirements set forth by FinCen.
I hope this helps you a little. You've got a lot of definitions that need to be defined before you can really say, what's the difference between this and that... etc.
Can't is not an option.