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A person that is an MSB solely because that person serves as an agent of another MSB is not required to register. However, a person that is an MSB both because it engages in MSB activities on its own behalf and as an agent of another MSB must register.

An agent is a separate business entity from the principal that the principal authorizes, through a written agreement or otherwise, to sell its instruments or, in the case of funds transmission, to sell its send and receive transfer services.

Create and Implement KYC Policies KYC regulations stipulate that MSBs must collect information to identify individuals and businesses, such as their full name, date of birth, address, and official documents, such as passports or driver's licenses.

These businesses are (1) currency dealers or exchangers, (2) check cashers, (3) issuers of traveler's checks or money orders, (4) sellers or redeemers of traveler's checks or money orders, and (5) money transmitters. MSBs must register with the Department of the Treasury and renew their registration every two years.

The term "money services business" includes any person doing business, whether or not on a regular basis or as an organized business concern, in one or more of the following capacities: (1) Currency dealer or exchanger. (2) Check casher. (3) Issuer of traveler's checks, money orders or stored value.

FinCEN's regulations define the term "money transmitter" as a person that provides money transmission services, or any other person engaged in the transfer of funds.

The term "money services business" includes any person doing business, whether or not on a regular basis or as an organized business concern, in one or more of the following capacities: (1) Currency dealer or exchanger. (2) Check casher. (3) Issuer of traveler's checks, money orders or stored value.

Generally, MSBs that know, suspect or have reason to suspect that the transaction or pattern of transactions is suspicious and involves $2,000 or more, must electronically file a FinCEN Form 111, Suspicious Activity Report on the activity.