We have a chain store that is wanting to open an account with us. We asked about MSB activity and they indicated they do have a contract with Western Union, but only through the App. So the customer does their transaction through the app, the store doesn't have any information on where the money is going or where it is coming from. They only facilitate the cash in or out on occasion, according to the QR Code that is shown on their app. The store's account with us, would not have any ACH transactions ran through their account with us. All money will be swept out of the account daily to their "master" account at another institution. Basically, the account would be for the local store to deposit their funds into and then the funds would go out to their master account somewhere out of our area. Would we consider this to be an MSB since the transactions are not ran through their account with us? We would receive cash deposits from them if their customer brought in cash to wire funds through their app on their phone, and I'm assuming they may obtain cash from us from time-to-time for their store.

Sounds to me like they might be an agent of Western Union which would not require that they separately register. How you treat an MSB that is not required to be separately registered is a business decision.

While they appear (as Randy stated) to be an agent of WU. The question should be how are you going to monitor the transactions if you do not see them? and is your fee schedule appropriate to cover the cost (and risk).