Question:  One of our deposit customers is a liquor store.  We just realized that it is cashing checks for customers.  Does that make it a Money Service Business?  
 
Answer:  First, Texas doesn't license check cashers.  So there is no state licensing requirement at this time.  However, check cashers MAY be an MSB under the USA PATRIOT Act.  But notice that the regs (31 CFR 103.11) exclude a person who does not cash checks in an amount greater than $1,000 in currency or monetary or other instruments for any person on any day in one or more transactions.  In other words, if the store is only cashing small checks, it does not have to register as an MSB with Treasury.
 
Still, this makes the customer higher on your risk scale and worth extra monitoring.