Is this operation an MSB?
Q. My customer is an entity recently acquired by a company listed on the New York Stock Exchange. The company tells me the new entity is an operating subsidiary. According to the information provided, the subsidiary performs various medical services. Further, the only service that the new entity
A. The term "money services business" (MSB) is broadly defined and includes specific activities. You can find help on this at www.msb.gov/msb/index.html, and subsequent links. To meet the definition of an MSB, a person selling money orders must conduct more than $1,000 in business with one person in one or more transactions (in one category of activity listed on the web page) on any one day.
If that threshold is exceeded, the company is not exempt by virtue of being a Fortune 500 company traded on the NYSE. The parent company may be confusing the Phase I publicly listed company exemption for filing Currency Transaction Reports with their obligations in connection with running an MSB. Use the following website resources to educate them: www.msb.gov for information about MSBs and the revised Federal Financial Institutions Examination Council BSA/AML Examination Manual. You can find the manual at: www.ffiec.gov/pdf/bsa_aml_examination_monual2007.pdf. The relevant material begins on page 226.
As far as SAR filing is concerned, if the subsidiary company is an unregistered MSB, (and possibly unlicensed in your state) you are actually required to file.
Leslie Callaway, CRCM, contributing editor, works with ABA experts to answer member questions. Submit questions to lcallawa@aba.com
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