Is the owner/operator of a privately owned ATM considered an MSB?
Can an individual be considered an MSB? For example: we have a customer who cashes checks for his friends, some in amounts greater than $1,000.00, but this person does not operate a business.
If there is a customer that does less than 1,000 dollars of check cashing per day per customer, but transfers money out of the country using an outsourced wire transfer company, how would the bank need to hand this? Would it be an MSB? Does the bank have any risk associated with the wire transfers that it does not perform?
One of my business customers owns a furniture store. In order for them to collect payments from many of their customers, they cash payroll checks. As the BSA Officer, I find this to be check cashing and asked them to register as a MSB. My reasoning is that more than likely the majority of their tax return checks or payroll checks are not going to the payment, but to the payees pocket. Do you agree with this?