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#486689 - 01/20/06 05:18 PM High Risk MSB
Dottie Offline
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Joined: Oct 2004
Posts: 113
If a money service business (located in a high intensity drug trafficking area)does state wide check cashing which includes third party checks and commercial accounts, would it be considered high risk? They also redeem traveler's checks and money orders. They are an established business with an operating history. They are already registered as a MSB.

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BSA/AML/CIP/OFAC Forum
#486690 - 01/20/06 05:20 PM Re: High Risk MSB
Hrothgar Geiger Offline
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Hrothgar Geiger
Joined: Jun 2005
Posts: 10,395
Jersey Shore
What do you think of the AML program that they have in place? What do you think of other controls and procedures they've implemented?

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#486691 - 01/20/06 05:42 PM Re: High Risk MSB
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
They would be high risk, - and how high depends on the dollar amounts they are cashing - and I would look at the corporate checks to ensure that they are from industries that "have a need" to be cashing checks - such as those that pay day workers, i.e. construction industry.
I have refused to take corporate checks from medical companies - unless of course it is a normal payroll check.

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#486692 - 01/20/06 05:55 PM Re: High Risk MSB
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
The Interagency Guidance lists a number of potentially high and low risk factors you should consider. I suggest you do a comprehensive review using those lists.
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