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#945968 - 04/18/08 08:41 PM MSB and bank's requirements
Beckster Offline
Joined: Aug 2005
Posts: 64
The bank has two customers that are registered with FINcen as a MSB. I am in the process of doing the BSA risk assessment of the high risk customers, so I am reviewing the activity on these customers.

My question is that one of the customers (a customer for 4 years) is a registered WU agent and cashes an average of 4 WU drafts that exceed $1,000 and the remaining deposits are cash, what is the bank's responsibility?

Does the bank have to have a copy of their BSA program on file? If they are a registered MSB, can they cash those drafts without a problem?

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#946431 - 04/21/08 02:41 PM Re: MSB and bank's requirements Beckster
devsfan Offline
Diamond Poster
Joined: Jun 2004
Posts: 1,927
You state that they are a registered MSB, but as an agent of WU they do not need to register with FinCEN. So, if they are also registered I would assume that it is because they do other things that require registration.

On this issue of cashing the WU drafts, there have been previous threads on this issue and I have also contacted WU directly. The only way that a recipient of a WU money transfer can get his funds is to go into any WU agent. The WU agent uses the WU system and prints a draft, called, I believe, a 'Money Transfer Receive'. The draft shows the name of the WU agent and the date. This is then cashed by the agent. As long as the draft shows your customer as the agent who printed the draft with the current or recent date, this act does not make the agent a check casher subject to FinCEN registration.

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