I apologize as I know I just read the same question not a few days ago, but I searched and searched and couldn't find it.


A customer (small gas station that cashes checks occasionally) is a registered MSB at another bank. Their account here takes their credit card deposits, then they transfer the deposits to the other bank. No MSB activity is conducted through their account here.

Do I get their registration information?

Well, to quote a couple of highlights from the examination manual"

FinCEN and the federal banking agencies issued interpretive guidance on April 26, 2005, to clarify the BSA requirements and supervisory expectations as applied to accounts opened or maintained for MSBs.

The following regulatory expectations apply to banks with MSB customers:

No where in any of the guidance will you find a caveat of them only conducting thier "MSB" activities in the accounts at your bank.