We still maintain a log on these items. Individual comes in to purchase item on behalf of business. We log the information on the individual, but check show business as purchaser. Is this ok?

I don't see a problem with it, but I find it very suspicious that a business would give anyone over $3,000 in cash to go and purchase a monetary intrument on behalf of the business. I would want to know why they are doing this before I agreed to the transaction. Sounds like a good way to launder money or evade taxes.

I'm in the process, of confirming, but it appears the individual involved is a sales person for food distribution company and the business that she is purchasing the cashiers check for, has given bad checks for payment in the past.

I read 103.29 quite literally and it seems to me that the information being requested is that of the individual making the purchase, not the entity owned by or the employer of the individual. One reason for taking this approach - how do you know the individual is always acting on behalf of the business?

I had a similar question that I posted on November 14, 2002 so you might want to look there also. (I don't know how to connect with this message.) Be careful about the cash deposit suggestion, however, FinCEN came out shortly thereafter and said depositing cash and then w/d it to purchase a negotiable instrument would not eliminate the information gathering requirement.

The log should be completed on the individual making the purchase of the Monetary Instrument.