We have a customer that has a home equity line of credit. They run a check cashing business with it by bringing in the checks and applying them as a payment, then doing a large advance from the loan to take back to the store to use in cashing checks. I regularly file CTRs on them, but do I still need to treat them as a MSB even though they do not have a business deposit account? Do I need to have them fill out questionnaires just like I would do on a deposit account?
Must a bank be registered as an MSB since most of the MSB criteria are met by banks?
For risk assessment purposes in determining if the business is a MSB, why would the question of do they sell lottery tickets or have an ATM onsite be questionable?
I know that a business that engages in check cashing over the $1000 limit must register with FINCEN, but what about an individual customer that during a one or two month period cashes tax refund checks for approximately 20 people and about 1/2 are over $1000. Should they register? Can an individual register as a MSB? If they don’t should we file a SAR?
Money Service Businesses. What are they? How do they work? What documentation should the owner of a MSB provide?
For the purposes of CTR reporting, does aggregation of multiple transactions include multiple entities? A couple of examples: we have an individual who owns three MSB entities, separate tax IDs, different names, and operates in three different towns. Should their cash transactions be aggregated? If so, who goes on Part A of the CTR: the owner and/or all three entities? Another scenario: a customer has a joint account, a corporate account, and is a signer on their child’s account. If cash is deposited into all three accounts by one of the joint account holders, an employee of the corporation, and the child into each respective account. Which accounts would be included on a CTR and reported under who's name? The other scenario: if it makes a difference, is you do not know who made each of those three deposits, should they be aggregated? Bottom line: how far does aggregation go?