Check Cashing Businesses

We have several business customers who are check cashing businesses. I have done some research concerning "Money Services Businesses," and it appears that these businesses are required to have a money laundering program and register with FINCen if they cash checks over $1000 per day per customer. What is our liability with BSA since the check casher is our customer? Must we be sure that the check casher who is our customer has an AML program and has registered with FINCen? I know these customers will impact our risk assessment procedures, I'm trying to determine how (or if we should even keep these businesses as customers).

We also have check-cashing businesses as customers, and we looked very carefully at both the up side and down side before deciding to keep the relationships. Honest check-cashing businesses do perform a service by assisting those who cannot, for whatever reason, open a bank account. They also contribute a huge amount in fee income to the bank's bottom line due to returned deposited items. You just need to be sure they are keeping compensating balances to cover their returned items, and monitor the activity more closely than you would other accounts. And yes, I do think that you should ask to see their FinCEN registration and their AML policy. In addition, check with your State department of licensing and resigtration to be sure they are licensed to do business in your state. I think that if you perform your due diligence, you should be fine.
BC