In consideration of 31 CFR 103 concerning MSBs, does "money transmitters" include online companies that offer international wire transfer services to businesses? They do not deal in actually physical currencies. Also, why would online bill payment services not meet the criteria for money transmitters given the regulatory definition? It is not backed by actual currency, but would be classified as "any other person engaged as a business in the transfer of funds." Also, since payments can be made to just about anyone, it is not verifiable that the payment is the execution and settlement of a transaction other than the funds transmission itself.
We recently completed a MSB risk assessment on deposit customers. However, we are now wondering if we should have included business customers who only have a loan relationship with the bank. Should we have included these customers as well?
If an MSB closes an account at a bank and opens a new account with another bank do they need to re-apply with FinCEN by completing another 107 form?
Third Party Checks. Does depositing third party checks trigger any part of BSA since we do not know the original party that the check is payable to?