Am I an MSB?

The current rules amended in 1999 by the Financial Crimes Enforcement Network revised the regulatory definitions of certain non-bank financial institutions for purposes of the Bank Secrecy Act (BSA) and grouped the definitions into a separate category of financial institution called "money services businesses" or "MSBs." A business that meets one or more of the definitions of a type of MSB (as currently defined) is an MSB and must comply with BSA requirements applicable to it as an MSB, as a financial institution and as a specific type of MSB.

The capacities in which a business might be acting that could bring it within the definition of an MSB are:

Product or Service Capacity(Type of MSB)
Money Orders Issuer of money orders
Seller of money orders
Redeemer of money orders
Traveler's Checks Issuer of traveler's checks
Seller of traveler's checks
Redeemer of traveler's checks
Money Transmission Money transmitter
Check Cashing Check casher
Currency Exchange Dealer in foreign exchange
Currency Dealing Dealer in foreign exchange
Prepaid Access Provider of Prepaid Access
Seller of Prepaid Access

To review the complete regulatory definition of "money services business", click here.

If your business is an MSB, the business must comply with the BSA requirements applicable to financial institutions as well as to each of the specific requirements applicable to MSBs. The following MSB requirements may apply to your business:

Registration

Agent List

Suspicious Activity Reporting

The www.fincen.gov website contains other information that you may find useful. We suggest that you visit each of the sections of www.fincen.gov to gain a better understanding of the BSA and how it may affect you and your business.