Guidance 

FIN-2006-G005 

Issued: March 31, 2006 

Subject: Frequently Asked Questions 

 Businesses Cashing Their Own Checks 

1. If a business only cashes its own employees’ payroll checks, is it a money 

services business? 

As a service to its employees, Business A cashes employee payroll checks issued to the 

employees by Business A. It does not cash any other checks. These checks may be 

cashed in amounts exceeding $1,000 per person per day in one or more transactions, 

which is the threshold for the Bank Secrecy Act definition of a check casher that qualifies 

as a money services business.1

 Is Business A a money services business if it offers this 

service? Does it matter if Business A charges a fee for this service? 

Answer: Business A does not meet the Bank Secrecy Act definition of a check casher if 

it only cashes its own employees’ payroll checks. If a business provides its employees 

with currency in exchange only for payroll checks issued by the business, we do not 

consider the business to be “engaged in the business of a check casher.” Consequently, to 

the extent that a business only cashes its own employees’ payroll checks it is not a money 

services business. Whether or not a business charges a fee for conducting these 

transactions is immaterial. 

However, if a business cashes checks other than its own business checks in an amount 

exceeding $1,000 for any person in one day in one or more transactions, the business 

would be defined as a check casher under the Bank Secrecy Act and be required to 

register as a money services business and be obligated to comply with all applicable Bank 

Secrecy Act programmatic, recordkeeping, and reporting requirements. 

 

1 See 31 C.F.R. § 103.11(uu)(2). 
 

2. If a business only cashes its own checks as payment for goods or services 

provided by a non-employee, is it a money services business? 

If Business B pays a non-employee by check for goods or services provided to Business 

B, and in response to the non-employee’s request, Business B cashes its own check to 

pay the non-employee in cash, is Business B a money services business if the payment 

exceeds $1,000 per person per day in one or more transactions?

Answer: Business B does not meet the Bank Secrecy Act definition of a check casher if 

it only cashes its own checks as payment for goods or services provided by a nonemployee, even if those payments exceed $1,000 per person per day in one or more 

transactions. A non-employee that provides goods or services may request payment from 

a business for those goods or services in cash rather than by check. If a business, for 

example, issues a check for payment to a non-employee for providing those goods or 

services as a means of creating an audit trail, and the non-employee desires payment in 

cash, we would not consider the cashing of its own business check to pay the nonemployee to be “engage[ing] in the business of a check casher.” The business would not 

be required to register as a money services business for solely engaging in this activity.

However, if the business cashed checks other than its own business checks in an amount 

exceeding $1,000 for any person in one day in one or more transactions, the business 

would be defined as a check casher under the Bank Secrecy Act and be required to 

register as a money services business and be obligated to comply with all applicable Bank 

Secrecy Act programmatic, recordkeeping, and reporting requirements. 

3. If a tax preparer business only cashes its own tax refund anticipation loan 

checks for taxpayers for whom it has prepared tax returns, is it a money 

services business? 

If Business C, an income tax preparer business, issues a tax refund anticipation loan 

check to a taxpayer for whom it has prepared a tax return, and only cashes that tax refund 

anticipation loan check for the taxpayer, is Business C a money services business if the 

payment exceeds $1,000 per person per day in one or more transactions? 

Answer: Business C does not meet the Bank Secrecy Act definition of a check casher if 

it only cashes its own tax refund anticipation loan checks for taxpayers for whom it has 

prepared tax returns. This activity is equivalent to disbursing loan proceeds with cash. In 

this instance, the check is used as further documentation of the loan transaction. Thus, 

we would not consider the business to be “engaged in the business of a check casher” 

solely for engaging in this activity. 

2
 

However, if the business cashed checks other than its own tax refund anticipation loan 

checks in an amount exceeding $1,000 for any person in one day in one or more 

transactions, the business would be defined as a check casher under the Bank Secrecy Act 

and be required to register as a money services business and be obligated to comply with 

all applicable Bank Secrecy Act programmatic, recordkeeping, and reporting 

requirements. 

 

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