We conduct an annual review of the "parent" MSB's our customers are agents of to ensure they're current with FinCEN registration requirements. We did this today, and discovered that the registration for Western Union is no longer listed. It was there this time last year (was renewed in June, 2010, so would have been due to expire last year). According to the FinCEN website approx 7,600 MSB's were removed from the list in Feburary due to non-renewal. Any thoughts on how to proceed?

Just plug in Western Union in the legal name search field - it came up for me. They are not registered in every State - only in their home office State.

Hi, Randy. The only Western Union registrations currently appearing on the FinCEN Website are for specific agents, none of which are related to my MSB customers). Western Union MSB registrations have historically included a "generic" one for their headquarters in Colorado (i.e. not specific to any specific agent), which listed all their MSB activities. That particular registration is no longer on the FinCEN website. Have a call into FinCEN; will let you know what they advise.