MLR3C10100 - Business sector specific Guidance: Money Service Businesses: What would I expect to see at a Cheque Cashers

Cheque cashing can be a main or secondary business activity. You will find that generally cheque cashers fall into the following two categories.

• Independent. These businesses will operate using their own bank account. The cheque cashing is usually ancillary to the main business activity (for example a jeweller or general store). The business has full autonomy over the types of cheques being cashed and therefore can present a higher risk of money laundering. Where there is dual business trading activity there will be a separate account for the cheque cashing side of the business.
• Franchise. Generally the business will follow the franchisor’s procedures and may offer additional services (such as the retail of second hand goods, pawn broking, other financial products and currency exchange).

Where a business undertakes mixed trading activities such as cheque cashing and providing loans (for example pawn broking, pay day loans or debit card advances) these loan products are types of consumer credit and come under the terms of the Consumer Credit Act. The Office of Fair Trading (OFT) is responsible for the supervision of businesses offering Consumer Credit and that supervision extends to compliance with MLR. However, to avoid the need for the dual supervision of these businesses it has been agreed that HMRC will supervise all products and services offered by these businesses for MLR purposes. Supervision by HMRC applies in relation to all businesses where there is mixed MSB and consumer credit trading activity even where the consumer credit business is the greater part of the trade.