Will agents of MSBs be registered with FinCEN or just with the MSB? For example we have several customers who are agents of Enramex, Sigue, etc, but when I went to look on the FinCEN website for the list of registered MSBs none of our customers were on the list for our state.

If they are only required to be a licensed agent through the MSB then what documentation would I need to verify that and would I need a copy?

An agent of a MSB is not required to register with FinCEN unless they engage in other MSB activity in addition to being an agent. (ie. check cashing)

We obtain a copy of the agent agreement from our customers who are agents.

An agent of an MSB may not be required do register with FinCEN as an MSB because their agent is regstered and has the right to appoint agents. However, they are still considered an MSB. Since they are still an MSB you will need to follow all of your due diligence and enhanced due diligence procedures.

In our institution if we have an agent that is not required to register as an MSB we require agent agreements, BSA policies and copies of independent reviews if they are considered high risk.

Don't forget state law requirements in addition to federal requirements. They can differ.