Answer:
Few small business owners would be in a position to affirmatively say they are not an MSB because they probably do not know what an MSB is. Banks generally elicit facts from their new customers by asking due diligence questions such as:
Do you cash checks, sell checks, sell stored value cards (prepaid access devices), do currency exchanges, send wire transfers or provide any financial services for your customers?
If they say, "Yes," then enhanced due diligence questions focus on the specific type of activity and the amounts involved. Your bank, not the customer, will decide if the customer is an MSB.
First published on BankersOnline.com 3/19/12
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