We have non-customers attempting to cash on-us payroll checks. Many of the individuals cannot present proper ID to be able to cash these checks. They are endorsing the check back to the employer and the employer is coming in to cash the check for them. Would this make the employer a "check casher" for MSB purposes even though it's the bank actually cashing the check?
Thank you!

No, I recently called FinCEN about that and no they are not required to register as an MSB if they are cashing their own payroll checks even if they are over $1.000.00.

FIN 2006 - G005

While a one off transaction might not be a concern, employers who say they are "cashing" their employees' checks may be padding their payrolls, engaging in human trafficking, etc. Concern over MSB status may be minor in comparison.

Thank you both for your feedback!