Is it a requirement that the bank must make an annual visit to an MSB? What about all High Risk Customers? I read something about this in an MSB Registration Fact Sheet

You should state in your policy what actions you will take for each risk group.
For MSBs I would do quarterly visits.
For cash intensive customers, - if they are your local Burger King etc., I would do an annual visit.
Hope that helps you.

We require site visits only for our high risk customers. A customer providing MSB services may, or may not, be high risk depending on the nature and volume of MSB services provided.

BrendaC, what would "the visit" look like? are you observing customer activity, check cashing activities?
Thanks.

Exactly. We are looking at the business to make sure that what we see is what we expect. Sometimes you find surprises in the most unlikely places. We have found restaurants that are now in the funds transfer business in the back office (no signage in place as required, we visited because of ACH activity noted in the account that we suspected was related to funds transfer services). We have found convenience stores that sell money orders when they clearly told us that they did not and we have identified small grocers that seemed to have inordinate amounts of cash for the number of customers we observed during our visits (timed for what would normally be peak hours-I like Thursdays at about 4:00 pm). So look for signage supporting services offered by the customer, activity volume and velocity commensurate with nature of business, and check cashing practices (are personnel trained to ID customers and adhere to any limits that may have been communicated to you by the owner).

I also cold call businesses, especially convenience stores, that indicate they do not offer any money services. It only takes a moment to call and inquire whether they sell money orders.

Thanks BrendaC. This is very helpful.