Skip to content
BOL Conferences
Thread Options
#974664 - 06/13/08 01:59 PM MSB questions
AuditorK Offline
Platinum Poster
Joined: Feb 2003
Posts: 962
PA
I've had limited exposure to MSB issues in my career and I'm running into them now. I have two questions:

1. Does currency dealer/exchanger mean a person/entity that converts one form of currency for another (i.e. - Euros to US Dollars)?

2. Would a business that occasionally cashes a check for a customer or employee that is sometimes greater than $1,000 be considered an MSB and require registration, etc.?

Return to Top
BSA/AML/CIP/OFAC Forum
#974728 - 06/13/08 02:42 PM Re: MSB questions AuditorK
YosemiteSamIAm Offline
Power Poster
Joined: Jan 2004
Posts: 2,795
Guess
1. Not sure, but I think so.

2. Most definitely an MSB.
_________________________
Sorry, did I just use my outside voice?

Return to Top
#974741 - 06/13/08 02:52 PM Re: MSB questions YosemiteSamIAm
AuditorK Offline
Platinum Poster
Joined: Feb 2003
Posts: 962
PA
2. So if its a small business and they cash a payroll check for one of their employees in the amount of $1,100 - they are an MSB?

Return to Top
#974813 - 06/13/08 03:48 PM Re: MSB questions AuditorK
DebL Offline
Gold Star
Joined: Jan 2007
Posts: 314
CA
Businesses who only cash their own payroll checks for their employees aren't MSBs.

See this guidance:
http://www.fincen.gov/statutes_regs/guidance/html/msb_faqs_guidance_03312006.html
_________________________
Of all the things I've lost, I miss my mind the most.

Return to Top
#974868 - 06/13/08 04:28 PM Re: MSB questions DebL
AuditorK Offline
Platinum Poster
Joined: Feb 2003
Posts: 962
PA
Thank you.

Return to Top

Moderator:  Andy_Z