MSBs Subject to the SAR Requirement - A person that is any one or more of the following types of MSB is subject to the suspicious activity reporting (SAR) requirement:
Money transmitter
Currency dealer or exchanger
Money order - issuer, seller and redeemer
Traveler’s check - issuer, seller and redeemer
U.S. Postal Service
The SAR requirement does not apply to the following types of MSB:
Check casher
Stored value - issuer, seller, and redeemer
A business that is two types of MSB. Any person that is both a type of MSB that is required to file SARs and a type of MSB that is not required to file SARs, is required to file SARs. The mandatory SAR requirement applies only to the type of transactions that make the business an MSB type subject to the SAR requirement. The MSB may voluntarily report suspicious activity occurring in transactions that are not subject to the SAR requirement, ie. check cashing and stored value.
Example: A convenience store company cashes checks for customers in amounts greater than $1,000 and conducts send and receive money transfer transactions for customers. Thus, the convenience store company is an MSB as a check casher and as a money transmitter. Since the company is both a type of MSB that is required to file SARs (a money transmitter) and type of MSB that is not required to file SARs (a check casher), the company is required to file SARs. The SAR obligation is limited to the money transfer transactions conducted by, at or through the MSB. The MSB may voluntarily report suspicious activity occurring in its check cashing transactions.
See 31 CFR 1022.320(a)(1) (formerly 31 CFR 103.20(a)(1))