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Exempting Agents from CTR reporting (MSB)

Question: 
We have a grocery store customer who is an agent for a large money transmitter. The customer offers no other MSB services and is otherwise not considered an MSB other than being an agent of one for this purpose. Is there any prohibition to exempting them from CTR reporting? Is it generally acceptable to exempt these agents from CTRs?
Answer: 

by Randy Carey:

It all depends on how their gross revenues are derived.

1020.315(e)(8) Ineligible businesses. A business engaged primarily in one or more of the following activities may not be treated as a non-listed business for purposes of this section: Serving as financial institutions or agents of financial institutions of any type; purchase or sale to customers of motor vehicles of any kind, vessels, aircraft, farm equipment or mobile homes; the practice of law, accountancy, or medicine; auctioning of goods; chartering or operation of ships, buses, or aircraft; gaming of any kind (other than licensed parimutuel betting at race tracks); investment advisory services or investment banking services; real estate brokerage; pawn brokerage; title insurance and real estate closing; trade union activities; and any other activities that may be specified by FinCEN. A business that engages in multiple business activities may be treated as a non-listed business so long as no more than 50% of its gross revenues are derived from one or more of the ineligible business activities listed in this paragraph (e)(8).

Answer: 

by Richard Insley:

You didn't mention whether your customer happens to be part of a large, publicly traded company--in which case the customer would be exempted automatically by Section 1020.315(b)(4).

First published on 12/03/2017

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