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| Guidance
Dear [ ]:
I am responding to your letter of January 24, 2008 to the Financial Crimes Enforcement Network, requesting a ruling as to whether your company [ ] is a money services business. Specifically, you have asked us to determine whether your company is a currency dealer or exchanger or a money…
| Guidance
Dear [ ]:
I am responding to your letter of September 2, 2005 to [the Financial Crimes Enforcement Network]. You seek a determination as to whether your client, [ ] (the "Company") is a money services business, specifically a currency dealer or exchanger or a money transmitter, as those terms are…
| Guidance
Dear [ ]:
I am responding to your letter of June 29, 2007 to [the Financial Crimes Enforcement Network]. You have requested a ruling as to whether your client, [Forex Company], is a money services business, specifically a currency dealer or exchanger or a money transmitter, as those terms are…
| Guidance
This letter is in response to a request from [Service Company], a subsidiary of [Parent], dated June 6, 2007, to the Financial Crimes Enforcement Network (FinCEN) for an administrative ruling concerning the treatment under the Bank Secrecy Act (BSA) provisions applicable to money services…
| Guidance
The Financial Crimes Enforcement Network ("FinCEN") is issuing this guidance clarifying the risk assessment required to be performed under the Interim Final Rule requiring anti-money laundering programs for dealers in precious metals, precious stones, or jewels ("Interim Final Rule").1 Specifically…
| Speech
Good morning ladies and gentlemen. It is a real pleasure for me to be with you here at this Jewelers Vigilance Committee AML seminar. This is a great opportunity for us to engage in a fruitful dialogue about still relatively new anti-money laundering responsibilities for the dealer industry.
I…
| Speech
Good morning. I am delighted to be here this morning to help kick-off SIFMA's Anti-Money Laundering Compliance Conference for 2008. I would like to thank Alan Sorcher of SIFMA, who has been a leader on AML issues for broker-dealers since we commenced with the USA PATRIOT Act rulemakings. I am…
| Guidance
In the securities brokerage industry, certain broker-dealers ("introducing firms") enter into clearing agreements with other broker-dealers ("clearing firms") according to the provisions of the rules of a broker-dealer self-regulatory organization, which permit the introducing firm and clearing…
| Speech
Good morning. I would like to thank Clemente Vazquez-Bello for his kind introduction. I’d also like to thank Pat Roth for her leadership within the Florida International Bankers Association and for inviting me to speak with all of you today at the 8th Annual Florida International Bankers…
| Speech
Good morning. I would like to thank Clemente Vazquez-Bello for his kind introduction. I’d also like to thank Pat Roth for her leadership within the Florida International Bankers Association and for inviting me to speak with all of you today at the 8th Annual Florida International Bankers…