Bank Customer Sells Money Orders

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Question:

Our bank has a business customer who printed checks with different remitters. The checks are clearing through one account. Should we close the account? What potential liability could we have?

Answer:

Check the laws of your state for licensure requirements that may be applicable to sellers of money orders. Review the activity to see if there is evidence that your customer is selling checks of $1,000 or more or multiple checks to the same person that may aggregate $1,000 or more. If so, your customer may be required to register as an MSB.

I don't quite understand: "...who printed checks with different remitters." Regardless, notify your BSA officer. Your customer needs to come in for a sit down.

First published on BankersOnline.com 8/30/10