Skip to content
BOL Conferences
Thread Options
#2197058 - 11/01/18 03:56 PM PrestoCash
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 2,211
The West
We are being approached by a mini-mart that uses PrestoCash to cash checks for locals. Does anyone have any experience with this company?

They are based in Mexico and their website is in Spanish. My understanding is that they cater to check cashing businesses who are not required to register as an MSB with FinCEN. Batches of checks are submitted to them and the check casher receives an ACH credit to their account.
_________________________
TryingToComply
CRCM

Return to Top
BSA/AML/CIP/OFAC Forum
#2197089 - 11/01/18 06:33 PM Re: PrestoCash TryingtoComply
HappyGilmore Online
10K Club
Joined: Jun 2004
Posts: 19,855
Pulling people out of the ditc...
don't know the first thing about them, but my gut says if you are asking these questions it leaves a bad feeling in your gut as well...if this were posed to me i would tell them no thank you.
_________________________
Providing alternative truths since the invention of time

Return to Top
#2197128 - 11/01/18 08:40 PM Re: PrestoCash TryingtoComply
edAudit Offline
Power Poster
edAudit
Joined: Jul 2008
Posts: 4,796
You are here
cashing businesses who are not required to register as an MSB with FinCEN

Seems like they would need to register anyway

https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/definition-check-casher

Because [ ] determines which checks to cash, clears the checks through its own bank account, bears the risk of loss if a check does not clear, pays for the cash that is provided to customers, maintains a customer service relationship with customers wishing to cash checks, and cashes checks for over $1,000 per person, per day, FinCEN has determined that [ ] meets the MSB definition of check casher found at 31 CFR 103.11 (uu)(2). As a check casher, [ ] is required to register with FinCEN pursuant to 31 CFR 103.41, and to comply with applicable BSA reporting and recordkeeping requirements, and the requirement to implement an anti-money laundering program.
_________________________
Opinions can be considered as coming from anywhere but my employer.

CAMS


Return to Top
#2197165 - 11/02/18 01:17 PM Re: PrestoCash TryingtoComply
thomasj Offline
Power Poster
Joined: Mar 2001
Posts: 5,063
Pennsylvania
It would be very difficult to determine if they actually are required to register since you will never see the amounts of the checks to determine if they are cashing items over $1,000, you will just see the ACH settlement for the batch. I suspect that what you would essentially be seeing is a large volume of cash withdrawals to facilitate the cashing of checks and incoming ACH credits for settlement to the account with very little documentation or verification of what is actually going on. I think this would be more risky and difficult to manage that an traditional FinCen registered MSB.
_________________________
Knowledge is knowing what to say. Wisdom is knowing when to say it.

Return to Top
#2197174 - 11/02/18 02:22 PM Re: PrestoCash TryingtoComply
praBSA Offline
Gold Star
Joined: Aug 2018
Posts: 348
Agreed. This seems equivalent to what would be an agent for MoneyGram but in the check world. The customer is the one taking on the risk cashing the checks with PrestoCash. If you cant see the actual transactions there is no way for you to tell. IF, hypothetically, I was to keep that customer, I would want to see their agency agreement with PrestoCash, who is responsible for BSA/AML monitoring, etc etc.

Return to Top

Moderator:  Andy_Z