I am new in this area and if this has been asked before I apologize. I am reviewing potential MSB's. If the customer has cashed checks for over $1,000.00 but only three or four times a month to different people, is this considered a MSB. Our bank has a couple of customers that have cashed checks to customers for over $1,000 but only 4 to 5 times over a three month period of time.

Is this considered a MSB and should I inform the customer of the rule.

I understand existing MSB have to re-register every two years. I understood in a meeting I was in that after they register the first time they re-register after one year and then two years after that. Is this true.

Thanks for any help you can give me.

I believe this business will qualify as a MSB. Recently, FinCEN issued an interpretation that basically said "if they promise not to do it again, they aren't necessarily a MSB." You can read FinCEN Ruling 2005-3 here.

Thanks for your help. I appreciate this information.