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Dear [ ]: This letter responds to your letter dated July 8, 2003, requesting an administrative ruling with respect to whether your client, [ ], is required to register with FinCEN as a Money Services Business in accordance with 31 CFR 103.41. FinCEN had previously declined to provide [ ] with such…

Dear [ ]: This letter responds to your July 14, 2003 letter on behalf of [ ] and [ ], requesting an administrative ruling with respect to whether either party, [ ] or [ ], is a Money Services Business (“MSB”) as defined in 31 CFR 103.11(uu), and therefore subject to the MSB registration requirement…

Dear [ ]: This letter responds to your October 6, 2003 letter requesting an administrative ruling with respect to whether you are required to obtain a license or to register because you transport your own currency from Colombia into the United States. Based on the representations contained in your…

Q. Broker-dealers engage in transactions through omnibus accounts and sub-accounts established by financial intermediaries. In these situations, (1) the omnibus account or relationship is established by or on behalf of a financial intermediary for the purpose of executing transactions that will…

Dear [ ]: This is in response to your letter of May 19, 2003 to the Financial Crimes Enforcement Network ("FinCEN") requesting guidance as to whether your client, who provides funds for business operating capital to customers, may file Currency Transaction Reports (“CTRs”) on behalf of the client’s…

Dear [ ]: This letter responds to your letter dated November 21, 2002, requesting a determination with respect to whether [ ], a subsidiary of [ ], is a Money Services Business (“MSB”) for purposes of regulations implementing the Bank Secrecy Act (“BSA”) found at 31 CFR Part 103. [ ] is licensed…