These frequently asked questions and answers are provided for general information only and should not be cited as any type of legal authority. They are designed to provide the user with information required to respond to general inquiries. Due to the uniqueness and complexities of Indian law and Federal tax law, it is imperative to ensure a full understanding of the specific question presented, and to perform the requisite research to ensure a correct response is provided.
Bank Secrecy Act and Money Services Businesses (MSB’s) are a type of non-bank financial institutions.
The following types of businesses are considered Money Services Businesses:
- Money transmitters
- Currency dealers or exchangers*
- Check cashers*
- Issuers of traveler’s checks, money orders, or stored value*
- Sellers or redeemers of traveler’s checks, money orders, or stored value*
- The U. S. Postal Service, except with respect to the sale of stamps and related items
For more complete information see, “Am I an MSB?”
* There are requirements before a currency dealer, check casher, or issuer, seller or redeemer of traveler’s checks, money orders, or stored value cards is considered a Money Services Business.
These requirements include engaging in one or more transactions on or after September 20, 1999 in an amount:
- Greater than $1,000
- In currency or monetary instruments
- For any person
- During any one day
Registration, Record Keeping, & Filing for Money Services Businesses
The FinCEN website Money Service Business Home contains information related to:
- Who must register
- Who is not required to register
- Agent relationships (filed with registration)
- Single or multiple location registration requirements
- Initial registration and required forms
- Renewal information and required forms
- Business changes and re-registration requirements
- Correcting prior reports
- BSA E-Filing System
- Record retention requirements
There is also contact information on how to get more information.
See MSB materials regarding reporting of Suspicious Activities and Money Laundering Prevention (including civil and criminal penalties and their applicability).
For questions on any tribal tax matter, please e-mail us. Be sure to include your name, your phone number and your email address so that we can respond to your question.