What is the difference between an Authorized Delegate and an Authorized Agent?

In the context of USA Money Services Businesses (MSBs) and associated licensing, “authorized delegate” and “authorized agent” are related terms, but they are not necessarily the same thing. These terms are often used in the context of businesses like money transmitters, check cashers, and currency dealers, which are considered MSBs and are subject to federal and state regulations.

Authorized Delegate:

  • An authorized delegate is a term commonly used in the context of money transmitters. When a money transmitter (like a Western Union or MoneyGram agent) wants to extend its services to other locations or entities, it may appoint authorized delegates. These authorized delegates are essentially third-party agents or partners that are authorized to conduct money transmission activities on behalf of the licensed money transmitter.
  • Authorized delegates typically have to go through a vetting and approval process by the licensed money transmitter and regulatory authorities to ensure they meet compliance and security standards.
  • Authorized delegates operate under the authority and supervision of the licensed money transmitter and are required to comply with anti-money laundering (AML) and know-your-customer (KYC) regulations.

Authorized Agent:

  • The term “authorized agent” can have a broader application and is not limited to money transmitters. It can be used in various contexts, including financial services and other industries.
  • An authorized agent is an entity or individual authorized by another entity to act on its behalf or represent it in certain business activities or transactions.
  • In the context of MSBs, an authorized agent could refer to a business or individual that acts on behalf of an MSB for specific functions, such as conducting customer verifications or performing other related tasks. The specific roles and responsibilities of authorized agents can vary depending on the arrangement between the MSB and the agent.
  • Authorized agents, like authorized delegates, may also be subject to regulatory oversight and compliance requirements depending on the nature of their activities.

In summary, while both “authorized delegate” and “authorized agent” involve one entity acting on behalf of another in the context of MSBs, “authorized delegate” is a more specific term often associated with money transmitters appointing third-party agents to provide money transmission services. “Authorized agent” is a broader term that can apply to various business relationships in the financial services industry and beyond. The specific legal and regulatory implications may vary depending on the specific roles and responsibilities of these entities. It’s important for businesses involved in such arrangements to understand the regulatory requirements and compliance obligations associated with these roles.

This page was last updated on October 14, 2023.

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