A store has transactions on their business account that suggest the owners make loans to other convenience stores. There are checks for "loans" up to 20K and there are deposited items for "loan payments" at 5K. The owners have multiple stores, and they are in, what the account officer calls, a "close community." He states it is not uncommon for them to help each other out. What do I do with this account that appears to be making loans to other store owners? Do the requirements change for this MSB? I assume these loans are much like a relative loaning money. There are multiple stores that I can see they have loaned money to. One is a second store and INC that they are signers on. The others they are not related to on paper that I can tell. I believe with the way the payments appear there is no interest on these loans- just even amounts paid back in large even amounts. All are done by check - it doesn't appear they are hiding the activity. Any guidance is appreciated.

Depending on the timing and frequency of the repayment as well as where the repayment checks are drawn, I would look closely to ensure that it is not an elaborate check kiting scheme. I have seen this with closely related convenience stores in the past.

That is a good point. Thank you.