Skip to content
BOL Conferences
Thread Options
#1643658 - 12/28/11 02:58 PM Money Service Business
cbrewster Offline
100 Club
Joined: Apr 2010
Posts: 170
Trying to decide if a grocery store across the street is considered a money service business or not. Here are the details.

Small locally owned grocery store
They sell Money Orders
Provide Western Union
Do not cash checks over $1,000 (if they do anything it is give cash back from the purchase of goods)
Sell gift cards for their store only
I do not believe that they are but want to clarify. I have done a lot of reading but come up with a clear definition. As far as the money orders, they act an agent as well as for western union. I looked on FINCENs website and they are not registered as a money service business. I know that you do not have to be registered but under certain circumstances but that you can still be a money service business. For BSA purposes, I am just not 100% sure. Can you guys help?

Return to Top
BSA/AML/CIP/OFAC Forum
#1643662 - 12/28/11 03:08 PM Re: Money Service Business cbrewster
edAudit Offline
Power Poster
edAudit
Joined: Jul 2008
Posts: 4,796
You are here
_________________________
Opinions can be considered as coming from anywhere but my employer.

CAMS


Return to Top
#1643667 - 12/28/11 03:18 PM Re: Money Service Business cbrewster
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 4,344
New York City
Originally Posted By: cbrewster
Provide Western Union


In almost all cases I have seen, Western Union means the entity is a money transmitter. Any amount of money transmission hits the MSB category. Acting as an agent of another MSB is only relevant for registration purposes. An MSB would still need an AML program, etc.
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

Return to Top

Moderator:  Andy_Z