As a community bank, we do not open accounts for MSBs due to the risk. However, we have several businesses that are agents of MSBs such as Sigue Corp, RIA Financial, Moneygram, and Western Union. Is the MSB responsible to see that these businesses are meeting reporting requirements, or are we to enhance our due diligence in overseeing these accounts?
We currently use armored carrier services for our MSB customers when ordering cash. For CTR reporting, we report on "delivery date" Vs "order date". Going forward, we are conducting research and looking to report our CTRs on "pick and pack", which is the date funds are actually removed from our vault, but not delivered to the customer. Would this change be acceptable to the IRS?