If a convenience store has a Western Union kiosk on their premises, does it mean they are an agent of Western Union, and therefore, an MSB? We have one that is telling us they have nothing to do with the handling of the kiosk. But we feel they must be an agent in order to have the kiosk on their premises. In this case, what documents would you obtain from them? Agent agreement, etc.

If the kiosk is on their premises, but they are not involved in its operation, there should be a lease for the space. Ask for a copy to prove their point.

In addition to Ken's suggestion, are you seeing any ACH transactions, most likely debits, in the account from Western Union? You should if the customer is an WU agent.

Thanks for your suggestions. I am not seeing any activity from Western Union in the account, so will ask for a lease agreement.