Regulatory Alerts2003-01-07
Added
Guidance on Definition of Check Casher and BSA Requirements
An entity providing money orders in exchange for checks exceeding $1,000 in value on any single day is classified as a check casher under 31 CFR 103.11(uu)(2) and must comply with Bank Secrecy Act registration, reporting, and anti-money laundering requirements. Conversely, providing wire transfers for checks over $1,000 does not trigger check casher status, though the entity may be regulated as a money transmitter. A Currency Transaction Report is not required when a check over $10,000 is cashed for less than $10,000 in physical currency, but such structuring may violate 31 U.S.C. § 5324 and necessitate a Suspicious Activity Report.