We have a customer that we have identified as a MSB based on their check cashing service. We determined they are not registered as a MSB, so we filed a SAR. We contacted the customer to inform them of their requirements to register, but they now say they no longer cash checks and refuse to register. In your opinion, should we file another SAR because they refuse to register although they say they no longer cash checks?

You need to review their activity to see if what they say = what they do. They can repent and not be an MSB any more if they jump through the hoops described in 2005-3 .

Thank you Ken.