Does Depositing Third Party Checks Trigger BSA?

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Question:

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?

Answer:

If you mean a business or an individual is depositing checks payable to other individuals which have been endorsed over to your depositor, then you need to determine if the customer is acting as a check casher. If so, you determine if they are in compliance with state laws regarding licensure. Then, you determine if the items they are cashing exceed $1,000 per person per day in order to establish if they are required to register as an MSB.

First published on BankersOnline.com 6/20/05