There would still have to be an entanglement step. The photons need to be coupled. This is currently accomplished by a laser across long distances. I suppose that in this sense there is a latency at the speed of light to add new particles. But once the photons have been entangled they can communicate instantaneously.
Edit: See http://en.m.wikipedia.org/wiki/Quantum_teleportation for more.
Edit 2: If you say that the particles themselve are 'communicating' ftl, then you are perfeclty correct, yes. Unfortunatly one cannot use this behaviour to transmit arbitrary data.
This is also why it's interesting cryptographically, unless you have information on the movements of both particles you can't pull a signal from the movements.