Regulatory Alerts2003-10-24
Added
Definition of Check Casher
FinCEN determined that one party meets the definition of a check casher under 31 CFR 103.11(uu)(2) and must register with FinCEN, comply with BSA reporting and recordkeeping requirements, and implement an anti-money laundering program. This determination is based on the party's retention of check title and risk of loss, operation of customer service, and allowance of check cashing transactions exceeding $1,000 per person per day. The other party is not considered a check casher or agent of a check casher for BSA purposes, though it may be an MSB or agent of an MSB regarding other financial services offered through the terminals.