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#693986 - 02/27/07 05:40 PM Newly Registered MSB
Neytiri Offline
Platinum Poster
Neytiri
Joined: Jul 2002
Posts: 645
Pandora
We have an grocery store that finally registered as an MSB. Now what??

Do we have to keep monitoring them as closely as we were or can we ease off a little? Can we go to quarterly monitoring or even less? Will we just be monitoring to see if their business mix stays the same, cash deposits are the same, etc? I know we need to make sure their registration is renewed properly.

Any regulatory guidance or any BOL prior posts on this? Our focus has been on getting the business to register and now we are kind of at a loss as to what we should do next.

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#694188 - 02/27/07 10:09 PM Re: Newly Registered MSB Neytiri
Dip Offline
Power Poster
Dip
Joined: Mar 2005
Posts: 6,298
San Diego, CA
get a copy of the fincen acknowledgement of registration (sent the the customer once the registration is received and processed). continue to monitor the customer as you were before they were registered (registration is just a piece of paper and doesnt mean any less risk). if during your reviews, you conclude the customer is nto too risky, you could probably get away with reducing the frequency of reviews, but i would always keep an eye on any msb you have transaction accounts for.
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Dabbling in banking, law, accounting...the life of a trustee.

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#694190 - 02/27/07 10:13 PM Re: Newly Registered MSB Neytiri
nk78 Offline
Member
Joined: Aug 2006
Posts: 67
Illinois
You may want to review this guidance issued by FinCEN back in 2005:

GUIDANCE TO MONEY SERVICES BUSINESSES ON OBTAINING AND MAINTAINING BANKING SERVICES

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#695090 - 03/01/07 04:43 PM Re: Newly Registered MSB Neytiri
AnonRegulator Offline
Gold Star
AnonRegulator
Joined: Mar 2002
Posts: 451
Everywhere, USA
I think the joint statement and guidance and advisory issued by FinCEN and the regulators in 2005 will be good guidance for you.

Answering your question about the level and frequency of monitoring will be based on the risks you see in the account. For example, if the MSB cashes only local checks, that's probably less risky than one that cashes checks from far away. I think the guidance will help you get to where you need to be. AR.

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